ML22038A099

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Summary of January 11, 2022, Public Meeting with Exelon Generation Company, LLC Regarding Planned Digital Modernization License Amendment Request
ML22038A099
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 02/23/2022
From: Ballard B
Plant Licensing Branch 1
To:
Exelon Nuclear, Exelon Generation Co
Ballard B, NRR/DORL/LPL1, 415-0680
References
EPID L-2020-LRM-0041
Download: ML22038A099 (6)


Text

February 23, 2022 LICENSEE:

Exelon Generation Company, LLC1 FACILITY:

Limerick Generating Station, Units 1 and 2

SUBJECT:

SUMMARY

OF JANUARY 11, 2022, PUBLIC MEETING WITH EXELON GENERATION COMPANY, LLC REGARDING PLANNED DIGITAL MODERNIZATION LICENSE AMENDMENT REQUEST FOR LIMERICK GENERATING STATION, UNITS 1 AND 2 (EPID L-2020-LRM-0041)

On January 11, 2022, a public meeting via webinar was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Exelon Generation Company, LLC (Exelon, the licensee). The purpose of the meeting was to discuss technical specification (TS) changes that the licensee plans to submit as part of a planned license amendment request (LAR) involving the modernization of instrument and control (I&C) systems at Limerick Generating Station (Limerick), Units 1 and 2. This meeting was a continuation of a public meeting on the same topic held on December 7, 2021. The meeting notice and agenda, dated November 30, 2021, are available in the Agencywide Documents Access and Management System (ADAMS) Accession No. ML22010A205. The presentation material used by the licensee during the meeting is available in ADAMS Accession No. ML22010A069. A list of attendees is enclosed.

During the meeting, the licensee presented information in response to NRC staff feedback from the public meeting held on December 7, 2021, regarding proposed changes to the TS for Limerick that are intended to reflect the digital design and improve consistency with the standard technical specifications. A copy of the NRC staff feedback from the December 7, 2021, meeting is available in ADAMS Accession No. ML22005A181. The meeting summary from the December 7, 2021, meeting is available in ADAMS Accession No. ML22021B294.

The licensee addressed the following topics in its presentation in response to NRC staff feedback from the December 7, 2021, public meeting (additional details available in the staff feedback document and licensee presentation):

How Limericks proposed protection system meets design requirements.

How Limericks proposed protection system provides lowest functional capability of the system.

Reestablishing the basis for continued elimination of previously removed response times from the TS.

1 On February 1, 2022 (ADAMS Accession No. ML22032A333), Exelon Generation Company, LLC was renamed Constellation Energy Generation, LLC.

Potential impacts on limiting conditions for operation and surveillance requirements (SR) for engineered safety features actuation system and emergency core cooling system (ECCS).

Potential impacts associated with the SR for the manual initiation functions at the system level for each subsystem of ECCS and the nuclear steam supply shutoff system.

Additionally, the licensee presented a change from the December 7, 2021, meeting regarding the proposed TS changes. The licensee previously stated the proposed TS change would include TS 3.3.3, Reactor Trip Units, which would provide requirements on the trip system from the division reactor trip matrix through the scram valves. The licensee suggested existing requirements in TS 3.1.3.1, Control Rod Operability, and a SR in TS 3.3.2, Plant Protection System Divisions, will provide end-to-end verification of the operability of the reactor trip system.

The NRC staff informed the licensee that the following should be described in more detail at a future public meeting and in the planned LAR:

A description of the limiting condition for operation and associated action statements entered for each reduction in the number of channels available in the Plant Protection System.

In order to better understand how the proposed system complies with the criteria of IEEE 603, the NRC staff requested a description using a staged approach to loss of channels and associated example action statements in the information request following the December 7, 2021, public meeting. That information was not able to be made available at the January 11, 2022, meeting.

A description of how channels out of service will impact operability of the actuated systems.

The NRC staff pointed out that operability of the Plant Protection System would impact actuated equipment. The licensee stated the proposed TS will have actions that recognize impact of inoperable divisions on actuated equipment and the LAR will describe and justify that the TS have appropriate mitigating actions for the specific degradation. The staff suggested additional discussion on those actions prior to submittal of the LAR may be helpful in preparing for the review.

Another pre-submittal meeting will be held in March 2022.

No regulatory decisions were made during the meeting. Members of the public were in attendance. No comments or questions from the public were received during the meeting.

Public Meeting Feedback forms were not received.

Please direct any inquiries regarding this meeting summary to me at 301-415-0680 or Brent.Ballard@nrc.gov, or Michael Marshall at 301-415-2871 or Michael.Marshall@nrc.gov.

/RA/

Brent Ballard, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No(s). 50-352 and 50-353

Enclosures:

List of Attendees cc: Listserv

Enclosure LIST OF ATTENDEES JANUARY 11, 2022, PUBLIC MEETING WITH EXELON GENERATION COMPANY, LLC LIMERICK GENERATING STATION, UNITS 1 AND 2 PROPOSED LICENSE AMENDMENT REQUEST INVOLVING DIGITAL MODERNIZATION Name Organization Rossnyev Alvarado U.S. Nuclear Regulatory Commission (NRC)

Brent Ballard NRC Robert Beaton NRC Eric Benner NRC Victor Cusumano NRC Samir Darbali NRC Bhagwat Jain NRC Jeanne Johnston NRC Michael Marshall NRC Philip McKenna NRC David Rahn NRC Neil Sheehan NRC Richard Stattel NRC Tarico Sweat NRC Shilp Vasavada NRC Shakur Walker NRC Michael Waters NRC Khadijah West NRC Jack Zhao NRC George Bonanni Exelon Generation Company, LLC (Exelon)

George Budock Exelon John Connelly Exelon Joe Drahus Exelon Michael Foote Exelon David Helker Exelon Steven Hesse Exelon Paul Krueger Exelon Francis Mascitelli Exelon David Molteni Exelon Darani Reddick Exelon Mark Samselski Exelon Scott Schumacher Exelon Gerald Segner Exelon Pareez Golub Sargent & Lundy Brian Mann Excel Services Warren Odess-Gillett Westinghouse Calvin Tang Westinghouse Terrence Tuite Westinghouse Name Organization Alison Hahn Department of Energy (DOE)

William Walsh DOE Alan Campbell Nuclear Energy Institute Steven Dolley S&P Global Platts, Inside NRC Stephen Kimura

ML22038A099 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NAME BBallard MMarshall KEntz DATE 2/4/2022 2/4/2022 2/9/2022 OFFICE NRR/DEX/EICB/BC NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME MWaters JDanna BBallard DATE 2/14/2022 2/16/2022 2/23/2022