ML031750226
| ML031750226 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/24/2003 |
| From: | Donohew J NRC/NRR/DLPM/LPD4 |
| To: | |
| Donohew J N, NRR/DLPM,415-1307 | |
| References | |
| TAC MB6726, TAC MB6727, TAC MB6728 | |
| Download: ML031750226 (16) | |
Text
June 24, 2003 LICENSEE:
Arizona Public Service Company (APS)
FACILITIES:
Palo Verde Nuclear Generating Station
SUBJECT:
MEETING WITH REPRESENTATIVES OF ARIZONA PUBLIC SERVICE COMPANY FOR PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 (TAC NOS. MB6726, MB6727, AND MB6728)
A meeting was held on Wednesday, May 14, 2003, between the Nuclear Regulatory Commission (NRC) staff and the licensee for Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Palo Verde or PVNGS). The meeting was held at the request of NRC. Notices for the meeting were issued on May 5 and 7, 2003. The notices stated there would be meetings on May 14 and 15, 2003; however, a meeting only had to be conducted on May 14th. The second notice showed that the meetings were scheduled to be conducted until 5 p.m. each day and that there may be discussions on proprietary information submitted by the licensee. is the list of attendees. Enclosure 2 is the slides handed out by the NRC staff.
There was no handout from the licensee. Enclosure 3 is the request for additional information sent by the NRC staff to the licensee and Enclosure 4 is the draft information in response to the questions. Enclosure 4 was provided by the licensee in preparation for the meeting and none of the information is proprietary. Enclosure 5 is a list of acronyms used in this meeting summary and in Enclosures 2 through 4.
BACKGROUND The licensee submitted an application dated November 7, 2002, to change the Technical Specifications. The changes are needed to support an upgrade to the core protection calculator (CPC) system to replace the current system due to parts obsolescence. The licensee stated that all CPC and control element assembly calculator (CEAC) systems are to be replaced with a functionally equivalent, digital Common Qualified (or Common-Q) CPC System provided by Westinghouse. The basic Common-Q CPC System design concept was approved by NRC in its Safety Evaluation, Acceptance for Referencing of Topical Report CENPD-396-P, Revision 01, "Common Qualified Platform" and Appendices 1, 2, 3, and 4, Revision 01, dated August 11, 2000.
The licensee requested that NRC approve the license amendment request (LAR) by July 1, 2003, with 90 days allowed for the implementation of the amendment. The licensee is planning to install the first CPC upgrade first at Unit 2 during the fall 2003 refueling outage, because this outage will be an extended outage, because of the steam generator replacement also planned for this outage. The installations for Units 1 and 3 would be done in later refueling outages for these units, but with the experience gained from the installation at Unit 2. The licensees request for the amendment to be issued by July 1, 2003, was to allow time to complete the planning and scheduling to install the CPC upgrade in the Unit 2 fall refueling outage which begins late September 2003.
With the application for the amendment submitted November 7, 2002, the NRC staff expected to complete its review of the LAR in May 2003; however, because of the retirement of the lead reviewer in March 2003, the NRC staff has had to reconsider the schedule requested by the licensee. It is the NRC staffs belief that installing the CPC upgrade in the Unit 2 fall outage is worthwhile in terms of safety, because the extended outage will allow the licensee more time to install, test, and work with the upgrade. Therefore, the NRC staff decided to expedite its review of the LAR to try to complete its review in time so that the upgrade can be installed in the Unit 2 fall outage if the LAR is acceptable.
This meeting was requested by the NRC staff to assist in identifying additional information needed from the licensee. The meeting was scheduled such that the NRC staff would have time to review Enclosure 4 prior to the meeting.
The agenda for the meeting was for the NRC staff to (1) discuss with the licensee the current status of the following three reviews that comprise the NRC staff evaluation of the CPC upgrade LAR and (2) identify what additional information may be needed from the licensee for the NRC staff to complete the reviews:
Instrumentation and Control Systems (ICS) Review Human Factors (HF) Review Reactor Systems (RS) Review Documenting Information Provided by the Licensee The discussion in these three review areas is addressed below:
ICS Review Results The expectations and additional information needed by the NRC staff based on the ICS review to date are in Enclosure 3. This was discussed with the licensee. The slides provide the history of the interaction between the NRC staff and the licensee in the ICS review area. Some of ICS documents reviewed by the NRC staff were reviewed in the Westinghouse Rockville, Maryland office. The NRC staff identified additional information needed for this review area. For example, in terms of the responses to NRC staff questions in Enclosure 4:
For Question 1, an explanation of how nonsafety system channels may affect safety systems is needed.
For Question 5, copies of related implementing procedures are needed.
For Question 10, licensee needs to expand on the draft response.
For Question 16, licensee needs to expand its response to Plant Specific Action Item (PSAI) 6.11, which is on pages 24 to 26 of the second enclosure to the application dated November 7, 2002.
The 10 questions shown on page 7 of Attachment 2 were discussed with the licensee in the meeting.
As stated on page 8 of Attachment 2, further additional information may be identified by the NRC staff since it has not completed its review in this area. Also, visits to Westinghouse and the licensee to conduct a software audit and review licensee activities with respect to the CPC upgrade are shown.
The licensee gave the NRC staff the following three drawings: "Reed Switch Assy,"
CEDM-E-R1000, Rev. 08; "CPC/PMS Data Link Fiber Optic Cable," C-14273-416-410, Rev. 02; and "Control Wiring Diagram Plant Computer System," 02-E-RJF-001, Rev. 13, Sheet 7.
HF Review Results The NRC staff conducted a conference call with the licensee on March 6, 2003. The licensee explained that some work remained to be done in the human factors area for the CPC upgrade.
The licensee submitted a discussion of this work in the letter dated April 25, 2003 (ADAMS Accession No. ML031270090), which included proprietary and non-proprietary versions of the Westinghouse topical report WCAP-16076-P, "Requirements Phase Human Factors Review for the Common Q Phase 3 Core Protection Calculator System Project," dated March 2003.
A conference call was conducted in the meeting with the author of the above topical report.
The NRC staff discussed the information in the topical report and in the licensees letter dated April 25, 2003, and concluded that no additional information was needed beyond what the licensee had submitted.
RS Review Results A conference call was held with the licensee on May 15, 2003, that discussed the draft information in the RS review area in Enclosure 4. The licensee stated that it would expand on some of the responses in the second part (15 pages) of Enclosure 4, including the evaluation of accuracy in the response to NRC Question 2 that is stated to be described later. The NRC staff concluded that it did not need any to add any new questions on the CPC upgrade beyond those given in Enclosure 3.
Documenting Information Provided by the Licensee The draft information provided by the licensee in Enclosure 4, and the additional information requested by the NRC staff in (1) the discussions held in the above three areas of review and (2) any future request for information, will be submitted by the licensee in a letter or letters to the NRC. These letters will be placed on the Palo Verde dockets for the three units. The final evaluation of the CPC upgrade LAR by the NRC staff will not be based on the draft information in Enclosure 4, but on the information to be submitted by the licensee in letters to the NRC and which will have gone through the licensees quality assurance/quality control review.
The NRC staff completed its presentations and the meeting was closed.
/RA/
Jack Donohew, Senior Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-528, 50-529, and 50-530
Enclosures:
- 1. List of Meeting Attendees
- 2. NRC Staff Meeting Handout
- 3. Request for Additional Information Sent to Licensee
- 4. Draft Information Provided by Licensee
- 5. List of Acronyms cc w/encls: See next page
ML031750226 NRC-001 OFFICE PDIV-2/PM PDIV-1/LA SRXB EEIB IEHB PDIV-2/SC NAME JDonohew MMcAllister MKowal CGraham REckenrode RGramm for SDembek DATE 6/17/03 6/10/03 6/18/03 6/23/03 6/24/03 6/24/03 DOCUMENT NAME: G:PDIV-2\\PaloVerde\\Summary05-14-03MTG.pvngs.wpd
LIST OF ATTENDEES AT MEETING OF MAY 14, 2003 EXPECTATIONS OF AND INFORMATION NEEDED BY NRC STAFF CPC UPGRADE LICENSE AMENDMENT REQUEST REVIEW NAME AFFILIATION J. Donohew NRC/NRR/PDIV-2 S. Dembek NRC/NRR/PDIV-2 E. Marinos NRC/NRR/EEIB C. Graham NRC/NRR/EEIB M. Waterman NRC/NRR/EEIB P. Loeser NRC/NRR/EEIB V. Hall NRC/NRR/EEIB D. Tifft NRC/NRR/EEIB C. Doutt NRC/NRR/SPSB J. Cai NRC/NRR/IEHB M. Chiramal NRC/NRR/EEIB R. Eckenrode NRC/NCR/IEHB M. Kowal NRC/NCR/SRXB#
T. Weber APS D. Gregoire APS**
A. Tasufiq APS F. Swirbul APS**
M. Stofko Westinghouse W. Odess-Gillett Westinghouse W. Gardner Westinghouse R. Fuld Westinghouse##
Where:
= Arizona Public Service Company NRC
= Nuclear Regulatory Commission NRR
= Office of Nuclear Reactor Regulation PDIV-2
= Project Directorate IV-2 EEIB
= Electrical and Instrumentation and Controls Branch IEHB
= Equipment and Human Performance Branch SPSB
= Probabilistic Safety Assessment Branch SRXB
= Reactor Systems Branch DE
= Division of Engineering Also attended at NRC headquarters the conference call on the reactor systems review area on May 15, 2003.
Only attended the conference call on May 15, 2003.
Participated by conference phone.
ENCLOSURE 1
NRC STAFF HANDOUT FOR MAY 14, 2003, MEETING ADAMS ACCESSION NO. ML031490635 ENCLOSURE 2
- 1 -
REQUEST FOR ADDITIONAL INFORMATION SENT TO LICENSEE Requests for additional information were sent to the licensee by emails for the Electrical and Instrumentation and Controls Branch and the Reactor Systems Branch. The emails and the questions sent to the licensee are given below.
Electrical and Instrumentation and Controls Branch:
From: Jack Donohew Sent: Thursday, March 20, 2003 11:40 AM To: Weber, Thomas N(Z00499)
Cc: Paul Loeser
Subject:
Electrical Branch RAI for CPC Upgrade LAR Send me a reply that you have received this RAI.
Review the questions quickly to see if you have any immediate questions on the RAI questions because I am in the office this afternoon, but will be out of the office tomorrow. Otherwise we will talk at the next weekly call about any questions your staff has.
<JND>
REQUEST FOR ADDITIONAL INFORMATION CPC UPGRADE LICENSE AMENDMENT REQUEST PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 Arizona Public Service Company (APS, the licensee) submitted its core protection calculator (CPC) upgrade license amendment request in its application dated November 7, 2002 (102-04864). The NRC staff has reviewed the application and the following additional information is needed for the staff to complete its review. If it is appropriate to reference Westinghouse topical reports (TRs) or NRC safety evaluations (SEs) as part of the response to a question, the TR or SE title, revision number, issuance date, section, and page number needs to be included.
1.
Provide the following documentation:
- b. procurement document that APS is using to procure the CPC.
- d. copy of any plant procedures which will change as a result of this upgrade.
- e. copy of the human/machine interface (HMI) review. (see page 23 of the attachment to the application, PSAI 6.7)
ENCLOSURE 3
- 2 -
2.
Discuss the operation of the CPC using a more detailed diagram than provided in the application (i.e., Figure 2-2). As an example of what detail to include in the response, consider the following (not a complete list):
Diagram of the RPSTs (resistor ladder ?)
Connectivity from all sensors to the RPS other connectivity (plant computer, other)
Communication protocols used Sensor input type (analog 4-20 ma, digital, smart sensor) connectivity between 4 proposed channels of the CPC Note that the staff would prefer an engineering level drawing.
3.
Provide an assembly drawing for one channel of CPC to allow the staff to understand the front level view of the system.
4.
Provide the schematic capture drawings written in the application specific software that will allow the staff to trace the flow path from field inputs to the reactor protection system (RPS). Include the calculation algorithms in diagram form to allow the staff to view where and how the system meets the SRS and SysRS.
5.
Discuss the organizational structure that exists at APS that ensures the software system life-cycle activities are carried out. The response should be detailed enough to allow the staff to view the software quality assurance (SQA) process APS personnel use for the CPC. If APS does not have a Configuration Control Board, how will the configuration be controlled, and who will be responsible.
6.
What differences exist between the system to be delivered to PVNGS and the system approved by NRC staff? As part of answering this question please consider new software versions, hardware design changes, corrections or modifications as a result of testing.
7.
Please discuss CPC and operations personnel responses to the following scenarios:
A disparity between redundant RPSTs Multiple failed reed switches Channel penal factor disparity Recovery of channel form loss of power 8.
Please provide a hardware listing of one channel of the CPC. This listing can be at the card and rack level. For example analog input card, digital output card, PC node box, FPDS, etc.
9.
How does the close out generic open items, as addressed in the staff safety evaluation issued February 24, 2003, for TR CENPD-396-P, Revision 1, affect the application.
- 3 -
10.
For justification to remove technical specification (TS) Condition E in the application, CPC cabinet high temperature, the application mentions "extensive online diagnostics."
Please provide a justification that the diagnostics mentioned in Section 2.2, page 3, of the application meet the intent of the original TSs which requires a channel functional test (i.e. how do you ensure that the diagnostics provide sufficient coverage to perform the functional test as originally intended).
11.
For Condition F, the TS discussion on page 4 of the application, discuss the corrective actions intended for the following: during a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period, the maintenance staff performs a restart of a channel three or more times.
12.
The application regarding TS 3.3.1 proposes changes that would remove all limiting conditions for operation (LCO) requirements associated with the CPC. Please justify why no LCO conditions exist in the proposed TSs for the CPC upgrade. When considering your response, you should provide more than just a qualitative answer regarding the existence of diagnostics.
13.
In the discussion of Factory Acceptance Test (FAT), the application states in part,"
inputs calculated to exercise branches in C code."
What C code is the application referring to?
How many lines of code are there?
Please rank the code complexity considering and providing: number of branches, recursion, function calls variable and similar items to help the staff understand how testing will "stress the system."
Please provide any fault injection methods used at the unit or module level.
What calculations are performed to determine appropriate exercising of branches and conditional statements.
14.
Provide the FAT and site acceptance test (SAT) for the proposed CPC upgrade.
15.
For PSAI 6.1 in the attachment to the application, the APS response discusses the input/output (I/O) subsystem and meeting of the SysRS. Discuss if APS is using S600 I/O modules and if, so address the PSAI 6.1 assessment of S600 I/O modules.
16.
Provide the plant specific failure modes and effects analysis (FMEA) mentioned in the APS responses to PSAIs 6.3 and 6.10. Include a diagram of sufficient detail that will allow the staff to follow the FMEA to confirm its adequacy and completeness.
17.
Provide the timing requirements of the CPC. What is the response time required by the Palo Verde Updated Final Safety Analysis Report.
- 4 -
Reactor Systems Branch:
> From:
Jack Donohew
> Sent:Friday, February 14, 2003 10:23 AM
> To:
Weber, Thomas N(Z00499)
Subject:
Fwd: Palo Verde CPC Upgrade
> > <<Palo Verde CPC Upgrade>>
REQUEST FOR ADDITIONAL INFORMATION CPC UPGRADE LICENSE AMENDMENT REQUEST PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3
REFERENCE:
Letter from D. Mauldin, Palo Verde Nuclear Generating Station (PVNGS), to US NRC, "Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2 and 3, Docket Nos. STN 50-528/529/530, Request for Amendment to Technical Specifications: 3.2.4, Departure From Nucleate Boiling Ratio (DNBR), 3.3.1, Reactor Protective System (RPS) Instrumentation -
Operating, 3.3.3, Control Element Assembly Calculators (CEACs)," dated November 7, 2002.
In the above referenced letter, APS submitted a License Amendment Request proposing to make changes to PVNGS Technical Specifications (TS) associated with an upgrade of the Core Protection Calculator System (CPCS). SRXB is reviewing the proposed change to TS 3.2.4 regarding DNBR and has the following Draft RAI questions:
DRAFT QUESTIONS 1.
The licensees post-installation test program includes using a Core Protection Calculator (CPC) simulation program after startup that calculates local power density (LPD) and departure from nucleate boiling ratio (DNBR) based on actual plant parameters and compares to CPC LPD and DNBR values.
a.
At what power level(s) will this testing be performed? Include a discussion of the consequences should an anticipated operational occurrence which relies on these trips occur during power ascension and prior to the testing being completed and verified.
b.
Please provide the acceptance criteria values which will be used to determine that the CPC calculated LPD and DNBR values are acceptable. Also provide the basis for these acceptance criteria.
c.
Please discuss any benchmarking or validation process used to ensure the accuracy of the CPC simulation program.
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2.
The licensee states that the PVNGS UFSAR Chapter 15 analyses are not impacted by the upgraded CPCS. Please provide quantitative results which demonstrate that the UFSAR Chapter 15 assumptions for CPC performance, response time and accuracy will continue to be satisfied with the upgraded CPCS.
3.
The licensee states that the upgraded CPCS will utilize safety-related algorithms which are functionally identical to the existing CPCS. Please define exactly what is meant by "functionally identical" (e.g., calculation method, frequency of calculation,...) and discuss any verification and validation processes performed to ensure identical functionality.
4.
Please discuss any impacts of the upgraded CPCS on the relationship and compatibility with the Core Operating Limit Supervisory System (COLSS).
5.
The Control Element Assembly Calculators (CEAC) calculate CEA position related penalty factors for use in the CPCs. Is the CEAC calculation of the penalty factors in the upgraded CPCS identical to the method used in the current system? Please provide a discussion and justification for any differences.
6.
Please discuss any impacts of the upgraded CPCS on the CPC Addressable Constants.
DRAFT INFORMATION PROVIDED BY LICENSEE ADAMS PACKAGE ACCESSION NO. ML031490460 1.
Draft Responses to Electrical and Instrumentation and Control (E&IC) Branch, 34 pages, ADAMS Accession Number ML031490455.
2.
Draft responses to Reactor Systems Branch, 15 pages, ADAMS Accession Number ML031490458.
ENCLOSURE 4
LIST OF ACRONYMS APS Arizona Public Service Company CEA Control element assembly CEAC Control element assembly calculators COLSS Core operating limit supervisory system CPC Core protection calculator CPCS Core protection calculator system DNBR Departure from nucleate boiling ratio Docs Documents FAT Factory acceptance test FMEA Failure modes and effects analysis HDD Hardware design description HMI Human/machine interface HF Human factors ICS Instrumentation and control systems LAR License amendment request LPD Local power density PVNGS Palo Verde Nuclear Generating Station PSAI Plant specific action item RS Reactor systems SDD system design description SE Safety evaluation SQA Software quality assurance SRS Software requirements specification SysRS System requirements specification TR Topical report UFSAR PVNGS Updated Final Safety Analysis Report ENCLOSURE 5
Palo Verde Generating Station, Units 1, 2, and 3 cc:
Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007 Douglas Kent Porter Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O. Box 800 Rosemead, CA 91770 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 40 Buckeye, AZ 85326 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Chairman Maricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, AZ 85003 Mr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, AZ 85040 Mr. Craig K. Seaman, Director Regulatory Affairs/Nuclear Assurance Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072-2034 Mr. Hector R. Puente Vice President, Power Generation El Paso Electric Company 2702 N. Third Street, Suite 3040 Phoenix, AZ 85004 Mr. John Taylor Public Service Company of New Mexico 2401 Aztec NE, MS Z110 Albuquerque, NM 87107-4224 Mr. Jarlath Curran Southern California Edison Company 5000 Pacific Coast Highway Building DIN San Clemente, CA 92672 Mr. Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, AZ 85251 Terry Bassham, Esq.
General Counsel El Paso Electric Company 123 W. Mills El Paso, TX 79901 Mr. John Schumann Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100 Brian Almon Public Utility Commission William B. Travis Building P. O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326 Mr. Gregg R. Overbeck Senior Vice President, Nuclear Arizona Public Service Company P. O. Box 52034 Phoenix, AZ 85072-2034