ML070590252
| ML070590252 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 02/27/2007 |
| From: | Duke Energy Corp |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML070590252 (28) | |
Text
Duke Energy Proposed Technical Specifications for Oconee Digital RPS/ES Oconee Nuclear Station February 27, 2007
luke w.nergy Agenda
- Opening o:o RPS/ES Remarks Digital Design o:o Proposed Tech Spec Changes o:o Discussion of Proposed Tech Spec Changes
- o Closing Remarks 2
kDuke
!Energy Opening Remarks
- . Introductions
- .# Purpose of Meeting &Expected Outcome
" Meeting Purpose
> Provide NRC with an understanding of proposed Oconee Tech Specs and the reason for retaining separate Tech Specs for RPS and ES
" Expected Outcome C
Common understanding of Oconee design and proposed Tech Specs
> Agreement on structure of proposed Tech Specs for RPS and ES 3
Duke Energy Oconee RPS/ES Digital Design o;- The digital RPS will be functionally equivalent to the analog system it replaces o:. The digital ESPS will be functionally equivalent to the analog system it replaces o:. The modification adds a redundant set of ESPS A, B and C channels that share processors with RPS channels A, B and C 4
ESPS Inputs Channel ESPS Inputs Channel Oconee RP/ES ESPS Inputs Digital Design RPS Inputs Channel D
REACTOR TRIP BREAKERS l
A T
I ESPS Outputs Odd Channels ESPS Fiber Optic Link Outputs Even Channels 5
Processor Distribution RPS/ESPS A 2
RPS/ESPS B 2
RPS/ESPS C 2
RPS D J'1 Cabinet 3 Cabinet 4 m 1 A
Odd Voters Even Voters ESPS A 1
ESPS B 1
Cabinet 10 mm ESPS C 1
(.........................
NI/ MSI U
Cabinet 14 Cabinet 15
'mm amm Cabinet 16 mm' ESPS Status Cabinet 17 Cabinet 18 Total CPUs = 32 6
Duke Energy Affected Technical Specifica ion Changes I
RPS Tech TS TS TS Specs 3.3.1, RPS Instrumentation 3.3.2, RPS Manual Reactor Trip - No changes 3.3.3, RPS - Reactor Trip Module ESPS Tech Specs TS 3.3.5, ESPS Input Instrumentation TS 3.3.6, ESPS Manual Initiation - No changes TS 3.3.7, ESPS Output Instrumentation Note: Oconee has one set of Technical Specifications that apply to all three units and operators are licensed on all three units 7
kDuke Wnergy Proposed Technical Specification Changes Extend Required Action (RA) Completion Time (CT) for placing inoperable channel in trip from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> o:o Eliminate 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> channel checks o:o Extend channel functional test frequency to 18 months
- o Other potential changes are under consideration 8
kDuke Energy Discussion of Proposed Tech-Spec Changes o:o The digital RPS and ESPS are functionally equivalent to the analog systems they replace o:o There are two redundant sets of ESPS channels, only one of which is required to be operable One set of ESPS channels (A, B, and C) shares processors with RPS channels A, B, and C
- Changes to Tech Specs are minor - extending CTs and surveillance intervals 9
SDuke Discussion of Proposed 01 4WEnergy Tech Spec Changes (continued) o:o Retaining separate RPS and ESPS Tech Specs reduces operator burden associated with implementation o:o An inoperable RPS/ESPS processor will require entry into RA for RPS Tech Spec
- o An inoperable RPS/ESPS processor would only require entry into RA for the ESPS Tech Spec if the other redundant set is inoperable o:o An inoperable RPS or ESPS sensor on an RPS and ESPS channel sharing a processor would require entry into the Tech Spec associated with the inoperable sensor o:o An inoperable processor on the standalone ESPS set of channels would only require entry into the ESPS Tech Spec if the other redundant set is inoperable o:o TSAIL used for tracking inoperable Tech Spec components 10
Duke Energy Closing Remarks 11
puke Fnergy Oconee Digital LAR Licensing Plan Oconee Nuclear Station February 27, 2007
R Duke Energy Agenda S:.
Purpose
- . Digital LAR Finding Digital LAR Regulatory Requirements Digital LAR Cyber Security Requirements
.Digital LAR Regulatory Guidance Digital LAR Format and Content DG-1145 Comments Document Availability Acceptance Review Checklist Proposed Digital LAR Review Plan Future Licensing Actions 2
Duke Energy Opening Remarks o:o The purpose of the Digital LAR Licensing Plan is to establish a regulatory framework that reduces the risk and uncertainty of licensing a digital LAR 3
~Duke eurgy Digital LAR Finding
- . The facility and equipment, the operating procedures, the processes to be performed, and other technical requirements provide reasonable assurance that the licensee will comply with the regulations of 10 CFR Chapter I, and that public health and safety will be protected (DG-1145, C.1.7, page C.1.7-1) 4
kDuke
!Energy Digital LAR Requirements o:.
10 CFR 50.55a (h) - "Codes and Standards" o:o 10 CFR 50.62 -"Requirements for reduction of risk from anticipated transients without scram (ATWS) events for light-water-cooled nuclear power plants" o:o 10 CFR 50, Appendix A-Nuclear Power Plants" "General Design Criteria for 5
k Duke FEnergy Cyber Security
.Requirements F_
o:o NEI 04 "Cyber Security Program for Power Reactors,"
o:o 10 CFR 73.55(m) Rulemaking -"Requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage" 6
Eh Duke Digital LAR Regulatory
' Energy Guidance EPRI Topical Report (TR)-102348, Revision 1 - "Guideline on Licensing Digital Upgrades" SECY 93-087 - "Policy, Technical, and Licensing Issues Pertaining to Evolutionary and Advanced Light-Water Reactor (ALWR) Designs"
- - Branch Technical Position HICB "Guidance for Evaluation of Defense-in-Depth and Diversity in Digital Computer-Based Instrumentation and Control Systems"
- +
Regulatory Guide (RG) 1.47 -"Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety Systems," Revision 0, May 1973
- +
RG 1.53 - "Application of the Single-Failure Criterion to Nuclear Power Plant Protection Systems," Revision 2, November 2003 RG 1.62 -"Manual Initiation of Protective Actions," Revision 0, October 1973
RG 1.75 - "Physical Independence of Electric Systems," Revision 3, February 2005 RG 1.118 -"Periodic Testing of Electric Power and Protection Systems,"
Revision 3, April 1995 7
DUke Digital LAR Regulatory eEEnorgy Guidance
- e RG 1.152 - "Criteria for Use of Computers in Safety Systems of Nuclear Power Plants" RG 1.153 - "Criteria for Safety Systems" and IEEE 603-1991 - "IEEE Standard Criteria for Safety Systems for Nuclear Power Generating Stations" RG 1.168 - "Verification, Validation, reviews, and Audits for Digital Computer Software Used in Safety Systems of Nuclear Power Plants," Revision 1, February 2004 RG 1.169 -"Configuration Management Plans for Digital Computer Software Used in Safety Systems of Nuclear Power Plants," Revision 0, September 1997 RG 1.170 -"Software Test Documentation for Digital Computer Software Used in Safety Systems of Nuclear Power Plants," Revision 0, September 1997 RG 1.171 -"Software Unit Testing for Digital Computer Software in Safety Systems of Nuclear Power Plants," Revision 0, September 1997 RG 1.172- "Software Requirements Specifications for Digital Computer Software Used in Safety Systems of Nuclear Power Plants," Revision 0, September 1997 RG 1.173 -"Developing Software Life Cycle Processes for Digital Computer Software Used in Safety Systems of Nuclear Power Plants," Revision 0, September 1997 RG 1.180 -"Guidelines for Evaluating Electromagnetic and Radio-Frequency Interference in Safety Related Instrumentation and Control Systems," Revision 1, October 2003 8
puke Fn ergy Use of Regulatory Guidance o:.
Note - in many instances the existing regulatory guidance documents endorsed IEEE Standards that have been recently revised o;. The policy of Oconee will be to state explicitly within the LAR the IEEE Standard to which the Digital RPS/ES Systems has been designed 9
kDuke FEnergy Digital LAR Format and Content Guidance S:.
NEI 06-02 provides guidance for the basic format and content 71 General Information S:.
DG-1 145 (RG 1.206) provides guidance for the technical portion of the LAR 10
Dnuke DG-1145 Comments WE~ne rgy Oconee will review the final regulatory guide for format and content following its issuance - currently expected in March 2007
- . The current draft contains some guidance that is vague as to what specifically is expected to be submitted Some sections contain no guidance as to what should be in an application 11
PDluke Duker Document Availability Energy Existing regulatory guidance assumes that all design documents will be available at time of LAR submittal All documents listed in NRC letter dated January 11, 2006 will be available at time of submittal with a few exceptions Estimated time of submittal is by November 30, 2007 12
Duke Document Availability 4Energy Documents Available Post-SE Issuance 71 Requirements Traceability Matrix (post FAT version) 71 Factory Acceptance Test Procedures and Results 71 Site Acceptance Test Plan, Procedures, and Results 71 Power-Imbalance Safety Limits and Setpoints 71 Removal and Restoration Procedures 71 Training documents 71 Operating documents 71 Maintenance documents 13
Duke Acceptance Review U Energy Checklist° Operating Experience from previous submittal indicates need for Acceptance Review Checklist Proposal:
SUse NEI 06-02 for overall completeness o
General Information, Summary Descriptions, Regulatory Evaluation, Environmental Considerations, Technical Specification mark-ups SUse digital-specific regulatory guidance for completeness of Technical Information portion o
DG-1145, C.1.7, Instrumentation and Controls Appendices A, B, C Duke could provide a draft Acceptance Review Checklist for discussion purposes 14
Duke Proposed Digital LAR SWEn e rgy Review Plan LAR Submittal S:.
+ 1 Month - Acceptance Review Complete
+ 4 months - All RAIs sent by NRC to Duke
+ 6 months - All RAI responses submitted by Duke
+ 8 months - Staff conducts on-site audit
+ 9 months - Management Meeting to identify any areas of concern not resolved
+11 months - Technical Review complete
+12 months - NRC issues Safety Evaluation 15
Puke Future Licensing Actions r.lnergy o:o Finalize Format of LAR
- o Establish Acceptance Review Checklist (completeness)
- o Confirm Staff Review Plan 16