ML060190539
| ML060190539 | |
| Person / Time | |
|---|---|
| Site: | Oconee  (DPR-038, DPR-047, DPR-055) |
| Issue date: | 01/12/2006 |
| From: | Brandi Hamilton Duke Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML060190539 (12) | |
Text
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BRUCE H HAMILTON Duuke Vice President I-OPowere Oconee Nuclear Station Duke Power ONO1 VP / 7800 Rocherster Highway Seneca, SC 29672 864 885 3487 864 885 4208 fax January 12, 2006 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Document Control Desk
Subject:
Oconee Nuclear Station Docket Numbers 50-269, 270, and 287 Response to Request for Additional Information Pertaining to the License Amendment Request (LAR) for RPS/ESPS Digital Upgrade Technical Specification Change (TSC) Number 2004-09, Supplement 5 In a submittal dated February 14, 2005, Duke Energy Corporation (Duke) proposed to amend Appendix A, Technical Specifications, for Renewed Facility Operating Licenses DPR-38, DPR-47 and DPR-55 for Oconee Nuclear Station, Units 1, 2, and 3. The License Amendment Request (LAR) requests Nuclear Regulatory Commission (NRC) to approve the Reactor Protective System (RPS)/Engineered Safeguards Protective System (ESPS) modification and associated Technical Specification (TS) change.
By letter dated October 6, 2005, Duke provided responses to many of the NRC questions in a Request for Additional Information (RAI) dated September 6, 2005.
Since many of the responses are tied to design deliverables in the RPS/ESPS modification schedule, Duke committed to provide the remaining responses on or before November 3, 2005, December 1, 2005, and January 12, 2006.
Duke provided additional responses on November 3, 2005, and November 30, 2005. provides Duke's responses to RAIs 1.K, 1.0, 1.Q, l.T, 4.B, and 18. provides an updated list of NRC commitments associated with this LAR.
A,--l www. dukepower. corn
U. S. Nuclear Regulatory Commission January 12, 2006 Page 2 If there are any questions regarding this submittal, please contact Boyd Shingleton at (864) 885-4716.
Very truly yours, B. H. Hamilton, Vice President Oconee Nuclear Site
U. S. Nuclear Regulatory Commission January 12, 2006 Page 3 cc:
Mr. L. N. Olshan, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-14 H25 Washington, D. C.
20555 Dr. W. D. Travers, Regional Administrator U. S. Nuclear Regulatory Commission -
Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. M. C. Shannon Senior Resident Inspector Oconee Nuclear Station Mr. Henry Porter, Director Division of Radioactive Waste Management Bureau of Land and Waste Management Department of Health & Environmental Control 2600 Bull Street Columbia, SC 29201
U. S. Nuclear Regulatory Commission January 12, 2006 Page 4 B. H. Hamilton, being duly sworn, states that he is Vice President, Oconee Nuclear Site, Duke Energy Corporation, that he is authorized on the part of said Company to sign and file with the U. S. Nuclear Regulatory Commission this revision to the Renewed Facility Operating License Nos.
DPR-38, DPR-47, DPR-55; and that all the statements and matters set forth herein are true and correct to the best of his knowledge.
B. H. Hamilton, Vice President Oconee Nuclear Site scribed and sworn to before me this /la m-) day of 2006 Nbtary Public A
MY..Crnim3ssaion Expires:
=,
ZY Duke Response to Request for Additional Information (RAI)
Oconee Nuclear Station License Amendment Request for RPS/ESPS Digital Upgrade RAI 1.K Please provide the following documentation:
The Oconee system and software training plan (BTP-14, Section 3.1.g).
Please include User Instruction Manual and an explanation of what training will be provided to control room operators, I&C maintenance personnel and plant engineering, as described in specification item 12.
Duke Response to RAI 1.K Duke/ Framatome-ANP (FANP) discussed the User Instruction Manual (Maintenance and User Manual) with NRC reviewers during an on-site visit to FANP offices in Alpharetta, Georgia on November 14, 2005 through November 18, 2005. The section manual that was needed at this stage of the review was Volume 4, Vendor Manuals, which was provided to the reviewers prior to the November 18, 2005, exit. This material is for reviewer reference and will not be docketed. Volumes 1, 2 and 3 will be provided for reviewer reference only when the initial approved revision is completed. Copies of Volumes 1, 2 and 3 will be provided as soon as they are available but no later than 3 weeks prior to the beginning of the Factory Acceptance Test (FAT), which is currently scheduled to begin on March 7, 2006.
The October 6, 2005, submittal (Supplement 1), stated that an additional explanation of Duke training would be provided by January 12, 2006. As indicated in that submittal, training for control room operators, I&C maintenance personnel and plant engineering is being developed as part of the modification process.
The Oconee administrative procedure that addresses the digital upgrade process provides guidance on the type of training and the type of personnel requiring training.
Oconee personnel will be provided comprehensive formal training on the operation, maintenance, and servicing of the system as installed at Oconee. This training will provide Oconee personnel with an in-depth understanding of all operational features and aspects of the system, including a review of maintenance procedures related to software and hardware. The following formal training classes will be provided to plant personnel:
Maintenance Procedure Writer Training Two training sessions will be provided that are designed to satisfy the needs of procedure writers. Session 1 will be a one-day introduction/overview that introduces the Teleperm XS product to the end user. Session 2 will be a five-day course that will build upon the knowledge obtained in Session 1. The course will be based on Maintenance and Engineering course materials and specifically designed to fulfill the needs of procedure writers.
January 12, 2006 Page 2
- Users' Overview Training for System Engineers, I&C Technicians and Operators This training will be an introduction to all operational features and aspects of the system.
Hardware Maintenance Training for System Engineers and l&C Technicians This training will be on routine maintenance and troubleshooting techniques and will be divided into sections according to major divisions of the hardware that allow select personnel to attend part or the entire course. Instruction on the operation of all hardware diagnostic programs will be provided. The course will include operation and troubleshooting on the actual system hardware.
Software Engineering Training This training will focus on system software modifications including configuration control and testing. The software course will foster a familiarity with off-line procedures of the generation of new programs, operation of peripherals, use of the documentation, use of the console, start-up and shutdown procedures, and the use of off-line de-bugging techniques. This training will also include reviews of code listings for all the major software subsystems.
Operations training.
FANP will provide the Operations Training Organization Lesson Plans for the RPS and ES systems. These lesson plans will be in the format required by the Operations Training Organization and will be available to Operations in March 2006. Operations will take these lesson plans and develop Operations training materials as required. The formal Operations Training sessions will be completed prior to U1 EOC23.
RAI 1.0 Please provide the following documentation:
The Failure Modes and Effects Analysis (FMEA), including not only significant failure modes but all failure modes (specification item 2.1.cc, 2.3.u, 6.12, and 11.11).
Duke Response to RAI 1.0 Duke provided a copy of the FMEA in electronic format to the NRC Staff via electronic mail on December 15, 2005. Duke requests that this document be withheld from public disclosure pursuant to 10 CFR 2.390.
January 12, 2006 Page 3 RAI 1.0 Please provide the following documentation:
The RPS/ESPS System Instrument Setpoint Calculations and Instrument Accuracy Uncertainty Calculations. If the ONS setpoint methodology is derived from ISA 67.4, please state which methodology is used. Has the setpoint methodology been reviewed and approved by NRC? If so, please provide the appropriate reference documents. The intent is to demonstrate:
- 1) That in accordance with plant specific action item 10 contained in the April 13, 2000, SER on the TXS topical report, that overly conservative setpoints that may occur due to elimination of analog system drift are not retained, as this would increase the possibility that the TXS equipment may be performing outside the vendor specifications, and 2) to show that the approach that is used to develop the proposed limits provides adequate assurance that the plant will operate in accordance with safety analyses, and that operability is ensured in the Technical Specifications.
Duke Response to RAI 1.0 In the October 6, 2005, RAI Response, Duke committed to provide a summary of the results of the revised calculations when issued. These calculations are currently in final review and are expected to be issued within one week. Duke will provide a summary by January 31, 2006. Duke will add steps to the calibration procedures to ensure that reduced uncertainty does not increase the possibility that the TXS equipment may be performing outside vendor specifications. As previously stated in Duke's October 6, 2005, submittal, Oconee's setpoint methodology has been reviewed and approved by the NRC. The setpoint methodology and the associated NRC approval documents were provided on a compact disk (CD) sent to NRC on June 23, 2005.
RAI 1.T Please provide the following documentation:
The Software Installation Plan (BTP-14, Section 3.1.e).
Duke Response to RAI 1.T Duke provided a copy of the Software Installation Plan in electronic format via electronic mail on December 20, 2005. Duke requests that this document be withheld from public disclosure pursuant to 10 CFR 2.390.
January 12, 2006 Page 4
RAI 4
The submittal identified several differences between the TXS system approved by the NRC and the system proposed for installation at ONS, principally the SVE CPU module and the communications modules. Please provide the following information:
B.
The environmental test data which verified the new equipment qualifications, including temperature, humidity, radiation, seismic, and electromagnetic qualifications.
Duke Response to RAI 4.B In the November 30, 2005, submittal, Duke committed to provide a qualification summary report addressing Oconee specific equipment such as relays, breakers, transmitters, etc., when issued. Duke provided a copy of this document in electronic format via electronic mail on January 4, 2006. Duke requests that this document be withheld from public disclosure pursuant to 10 CFR 2.390.
RAI 18
Please discuss the response time requirements for the RPS/ESPS functions. What is the expected worst case response time for the TXS systems as it will be installed at Oconee, and how will that response time be tested at ONC (sic)? This should include a discussion of the microprocessor cycle times, sampling rates, and testing procedures. In addition, please provide the system response time reports as discussed in specification item 6.14.
Duke Response to RAI 18 The minimum response time requirements listed in specification item 6.14 is the "worst case" response time allowed by the system. FANP is required to provide the System Response Time test reports to Duke for approval and acceptance prior to beginning the SAT. FANP will perform response time testing during the FAT. Duke will provide the system response time reports coincident with the FAT report (expected to be issued by May 4, 2006).
Updated List of NRC Commitments (from Duke Letters dated October 6, 2005, November 3, 2005, November 30, 2005, submittals)
RAI Commitment Status 1).D The final approved SDQA document is in preparation, review and Provided approval and is expected to be issued by December 1, 2005. Duke will Rev. 0 provide the final approved plan when issued. [Note: In the context 11/30/05 used "final approved" means Revision 0 to the approved plan.]
1.F The Software Safety Analysis Plan is in preparation, review, and Provided approval and is expected to be issued by October 31, 2005. Duke will 11/2/05 provide a copy of the plan when issued.
1.H These documents are in preparation, review, and approval and are Integration expected to be issued by the dates indicated below:
and Test Plans iv.
Implementation Specification January 28, 2006 provided
- v.
Integration Plan November 30, 2005 11/30/05 vi.
Test Plan November 30, 2005 In progress Duke will provide these documents when they are issued.
1.1 Software Design Reviews and Source Code Reviews are performed in Design later Software Life-cycle phases and are expected to be issued by phase V&V October 31, 2005, and December 16, 2005, respectively. Duke will report provide these documents when they are issued. The Verification and provided Validation Report is being provided in phases and are in preparation, 11/30/05 review, and approval and are expected to be issued by:
- 1) design phase-November 15,2005 In progress
- 2) implementation - January 30, 2006
- 3) testing phase - May 4, 2006 Duke will provide these reports when they are issued.
1.J The FAT Plan, FAT Procedure, and FAT Report are expected to be FAT Plan issued by the dates indicated below:
provided 11/30/05 FAT Plan November 30, 2005 FAT Procedure February 28, 2006 In progress FAT Report May 4, 2006 Duke will provide the FAT Plan, Procedure, and Report when issued.
January 12, 2006 Page 2 Updated List of NRC Commitments (from Duke Letters dated October 6, 2005, November 3, 2005, November 30, 2005, submittals)
RAI Commitment Status 1.J The Site Acceptance Test (SAT) Plan, SAT Procedure, and SAT Report In progress are expected to be issued by the dates indicated below:
SAT Plan February 28, 2006 SAT Procedure March 28,2006 SAT Report June 30, 2006 Duke will provide the SAT Plan, Procedure, and Report when they are issued.
1.K The Oconee User Instruction Manual is in preparation, review, and Provided approval and is expected to be issued by December 15, 2005. Duke 11/18/05 will provide this document when it is issued.
1.K Copies of Volumes 1, 2 and 3 (Users Instruction Manual) will be In progress provided as soon as they are available but no later than 3 weeks prior to the beginning of the Factory Acceptance Test (FAT), which is currently scheduled to begin on March 7,2006.
1.K Duke will submit an explanation of what training has been provided by Provided FANP to Duke by November 3, 2005.
11/3/05 1.K Training for control room operators, l&C maintenance personnel and Provided plant engineering is being developed as part of the modification 1/12/06 process. Duke will provide additional explanation of this training by January 12, 2006.
1.L The requirements matrix is a living document, and is updated at the end In progress of each V&V phase. Duke expects to issue the next updates by February 14, 2006, and May 4, 2006. Duke will provide these updates when they are issued.
1.0 The FMEA is in preparation, review, and approval and is expected to be Provided issued by December 15, 2005. Duke will provide a copy of the FMEA 12/15/05 when it is issued.
January 12, 2006 Page 3 Updated List of NRC Commitments (from Duke Letters dated October 6, 2005, November 3, 2005, November 30, 2005, submittals)
RAI Commitment Status 1.Q These calculations (Setpoint) require revision as a result of the In progress RPS/ESPS digital modification. The revised calculations will address any margin gains or losses. The required revisions are in preparation, review, and approval and are expected to be issued by December 31, 2005. Duke will provide a summary of the results of the revised calculations when issued. As of January 12, 2006, these calculations are currently in final review and are expected to be issued within one week. Duke will provide a summary by January 31, 2006.
1.R Additional information related to the qualification of the SIVAT Provided simulation tool is in preparation and will be submitted as a revision to 11/3/05 this RAI response by December 1, 2005.
1.T The Software Installation Plan is in preparation, review, and approval Provided and is expected to be issued by December 31, 2005.
12/20/05 1.U The Software Safety Plan is in preparation, review, and approval and is Provided expected to be issued by November 30, 2005.
11/2/05 1.V Duke will provide a date when Software Operations Plan can be Provided provided by November 3, 2005.
11/3/05 4.A &
The response to RAI 4.A and 4.C will be included in Duke's response to Provided 4.C RAI 30. The response to RAI 4.B is in preparation and will be 11/3/05 submitted by November 3, 2005.
4.B Test Report # 968/K 110.00/02 is currently being translated from Provided German to English. Duke will provide this document to the NRC staff 11/30/05 when it is available.
4.B A qualification summary report addressing Oconee specific equipment Provided such as relays, breakers, transmitters, etc., is in preparation, review 1/4/06 and approval and is expected to be issued by December 22, 2005.
Duke will provide this document when it is issued.
6 Duke will respond to the question related to channel independence in Provided our response to RAI-27. [Note - this question was addressed in 11/3/05 response to RAI 6.]
6 Duke's response to the question related to communications and data Provided exchange is in preparation and will be submitted by November 3, 2005.
11/3/05 7c Duke will submit more information regarding the hardware solution by Provided November 3, 2005.
11/3/05 January 12, 2006 Page 4 Updated List of NRC Commitments (from Duke Letters dated October 6, 2005, November 3, 2005, November 30, 2005, submittals)
RAI Commitment Status 10 Duke provided a preliminary response to this question on June 30, Provided 2005. After discussions with the staff on August 17, 2005, Duke agreed 11/3/05 to revise this response. The response to this RAI is in preparation and will be submitted by November 3, 2005.
15 The response to this RAI is in preparation and will be submitted by Provided December 1, 2005.
11/3/05 18 The response to this RAI is in preparation and will be submitted by Provided January 12, 2006. Duke will provide the system response time reports 1/12/06 to NRC (expected to be submitted by May 4, 2006).
18 FANP will perform response time testing during the FAT. Duke will In progress provide the system response time reports coincident with the FAT report (expected to be issued May 4, 2006) 21,22 Duke discussed the preliminary response provided to the draft RAI in Provided the August 17, 2005, Duke/NRC RAI meeting and agreed to revise this 11/3/05 response. This response is in preparation and will be submitted by November 3, 2005.
27 The response to this RAI is in preparation and will be submitted by Provided December 1, 2005.
12/1/05 29 The response to this RAI is in preparation and will be submitted by Provided December 1, 2005.
11/3/05 30 The response to this RAI is in preparation and will be submitted by Provided December 1, 2005.
11/3/05 31 The response to this RAI is in preparation and will be submitted by Provided December 1, 2005.
11/3/05