ML071920349

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Information for 7/10/07 Conference Call - Oconee Digital LAR Licensing Plan - Update
ML071920349
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 07/10/2007
From:
Duke Energy Corp
To:
Office of Nuclear Reactor Regulation
References
Download: ML071920349 (21)
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Text

kDuke WEnergy Oconee Digital LAR Licensing Plan - Update

9 Duke nergy Aed-fr Introduction Digital LAR Finding Digital LAR Regulatory Requirements Digital LAR Regulatory Guidance Digital LAR Format and Content Cyber Security Licensing Document Availability Document Review Options Acceptance Review Checklist Proposed Digital LAR Review Plan Key Dates Licensing Actions 2

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_n tro duct nto 4:* The purpose of the Digital LAR Licensing Plan Update is to establish a regulatory framework that reduces the risk and uncertainty of licensing a digital LAR S:* We are now approximately 5 months prior to planned submittal date - need to freeze all guidance documents and requirements S:* Changes in guidance documents that occur after this date will be considered to extent practical (we can't hit a moving target)

  • o We'd like the staff to document its position with respect to this licensing plan 3

kDuke

!Energy Dig.italI L-AR,-

Regulao jindin/g NOOSE

  • 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 (RG 1.206, C.1.7, page C.1.7-1) 4

Durke

, Jr.

Duke Digital LAR ReFqurenents En rgy itr e f

10 CFR 50.55a (h) - "Codes and Standards" 10 CFR 50.62 -"Requirements for reduction of risk from anticipated transients without scram (ATWS) events for light-water-cooled nuclear power plants" 10 CFR 50, Appendix A- "General Design Criteria for Nuclear Power Plants" 10 CFR 50, Appendix B- "Quality Assurance Criteria" 5

a Duke Digital LAR Regua tory SJEnergy Guidance EPRI Topical Report (TR)-1 02348, Revision 1 - "Guideline on Licensing Digital Upgrades" as endorsed by RIS 2002-22 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 o:o 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 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" 6

kDuke WEnergy Digital LAR ReguI1a try Gu dance RG 1.168 - "Verification, Validation, reviews, and Audits for Digital Computer in Safety Systems of Nuclear Power Plants," Revision 1, February 2004 RG 1. 169- "Configuration Management Plans for Digital Computer Software Systems of Nuclear Power Plants," Revision 0, September 1997 Software Used Used in Safety 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 RG 1.206-Combined Licenses for Nuclear Power Plants (LWR edition)," June 2007; specifically, C.1.7, "Instrumentation and Controls."

RG 1.209- "Guidelines for Environmental Qualification of Safety-Related Computer-Based Instrumentation and Control Systems in Nuclear Power Plants," March 2007 7

WPuke W'nergy Use of' RegujIa tory Guidance-kwý

    • Note - in many instances the existing regulatory guidance documents endorsed IEEE Standards that have been recently revised
    • 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 8

Duke

.nergy Digital LAR Format and Con tent Guidance S:.

NEI 06-02 provides guidance for the basic format and content S:.

RG 1.206 provides guidance for the technical portion of the LAR 71 BTP 7-14 will be used to address Software QA

    • Comparison of RG to SRP identified differences 71 RG does not require auxiliary features or multi-unit stations to be addressed/SRP does

_Concerns in IEEE standard and.Regulatory Guidance do not apply to the Oconee RPS/ES modification

_Human factors considerations are to be addressed in Chapter 18 -

Oconee will address in LAR itself using the existing Oconee human factors process 9

Duke Cyber Security nWenergy Licensing May 1, 2007, meeting discussed cyber security Duke plans to submit two letters (AREVA & Duke) addressing cyber security requirements (labeled withhold from public disclosure pursuant to 2.390)

Submittal will be prior to RPS/ES LAR submittal and incorporated by reference as permitted by 10 CFR 50.32 S:.

Duke may request a separate SE that would permit use on not only the Oconee RPS/ES LAR submittals but also future Duke digital LAR submittals 10

Duke Energy Documir ent A vailability Existing regulatory guidance assumes that all design documents will be available at time of LAR submittal

!Puke

.nergy Documennt A vaiIbittty Post-Submittal Document Availability Factory Acceptance Test Procedures Site Acceptance Test Plan Factory Acceptance Test Results Requirements Traceability Matrix (post FAT version)

SAT Procedures SAT Results Power-Imbalance Safety Limits and Setpoints Removal and Restoration Procedures Training documents Operating documents Maintenance documents January 2008 1st quarter 2008 December 2008 June 2009 July 2009 October 2009 12

Duke Document Review PVEnergy Options Option 1 - Onsite Reviews at Oconee (1 or more) 71 Availability of Duke/AREVA personnel to answer questions 71 Unit 1 equipment available for observations 71 Document in trip report 71 Staff travel may be a concern

  • .Option 2 - Reading Room at AREVA Offices in Bethesda 71 Reading room open for a set period of time 71 Duke/AREVA personnel could meet with staff periodically to answer questions 71 Document review in trip reports 71 Minimizes staff travel impact
  • - Option 3-Meetings in NRC Offices (Open or Closed) 71 Pre-send documents for staff review 71 Meetings to answer questions 71 Document in meeting summaries 13

Duke Energy Ac ceptance Re view Checklist

.** See draft proposed Acceptance Review Checklist 14

Duke Fro posed Duigita LAR L -E'nergy Re view Pn

<- LAR Submittal

+ + 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

Duke Key Dates 4VEn e rgv..

S:* Estimated date of submittal by 11/30/07

  • . Factory Acceptance Test: 2/18/08 - 10/1/08 o:. Safety Evaluation requested by 3/31/09
  • - Site Acceptance Test: 1/5/09 - 5/11/09
  • - Unit 1 Installation - Fall 2009 16

kDuke Wnergy trure: V j f j f-)p)i S:- Quality Process

Setpoint Methodology
    • Level of detail in selected sections of the LAR 17

Duke

.Energy Reque s ted Actions

  • Confirm 71 Finding 71 Regulatory Requirements 71 Regulatory Guidance 71 Format and Content of LAR 71 Document Availability & Review Options 71 Acceptance Review Checklist A1 Digital LAR Review Plan
    • Future Meetings 18

Acceptance Review Checklist Technical Portion of a Digital LAR Submittal Regulatory Guide 1.206 Section C.1.7 - Instrumentation and Controls Appendix C.I.7-A, Digital Instrumentation and Control Systems Application Guidance The application addresses the following topics:

(1) The design criteria to be applied to the proposed system.

(2) The I & C design as applicable to the final safety analysis report.

(3) Defense in depth and diversity (4) Functional requirements and commitments (5) Life-cycle process planning (refers to BTP 7-14)

(6) Life-cycle process requirements (refers to BTP 7-14)*K (7) Software life-cycle process design outputs (refers to, BTP 7-14)

Yes No Appendix C.I.7-B, Conformance with IEEE Std 603; C.l.7.B-1 Safety System Design Basis The application addresses the following topics:

(1) Single-Failure Criterion (2) Completion of Protective Action (3) Quality (refers to BTP' 714 which is software quality even though this section is4rt hardware'quality)

(4) Equipment Qualification (5) System Integrity.

(6) Independence (7) Cap ability for Test and Calibration,.

(8) Information Displays (9) Control of Access (10) Repair (11) Identification (12) Human Factors Considerations (13) Reliability El E3, El El El El El El El El nl r_1 El-El El El El El El El El El El I~

Acceptance Review Checklist Technical Portion of a Digital LAR Submittal Regulatory Guide 1.206 Yes No Section C.1.7 - Instrumentation and Controls Appendix C.I.7-B, Conformance with IEEE Std 603; C.1.7.B-2 Functional and Design Requirements The application addresses the following topics:

(1) Automatic Control m

(2) Manual Control 11 El (3) Interaction between the Sense and Command Features and E,

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Other Systems (4) Derivation of System Inputs (5) Capability for Testing and Calibration of System Inputs El El (6) Operating Bypasses El (7) Maintenance Bypass (8) Setpoints (documents available for NRC audit)

E.

r-Appendix C.1.7-C, Conformance with IEEE Std 7-4.3.2; C.I.7.C-1 Computer-Based Safety System Design Basis The application addresses the following topics: 4d, (1) Single-Failure CriterionEl1 (2) Completion of Protective Action El (3) Quality (refers to BTP 7-14)

.l El (4) Equipment Qualification 0,

El, (4)(a) Computer System Testing El.El (4)(b) Qualification of Existing Commercial Computers El El (5) Systelrn Itegrity

.l El (6) Independence El El (7) Capability for0iTest and Calibration El El (8) Information Displays (documentation to be available for staff audit)

(9) Control of Access El El (10) Repair El El (11) Identification El El (12) Human Factors Considerations El El (13) Reliability El Rl 2

Acceptance Review Checklist Technical Portion of a Digital LAR Submittal Regulatory Guide 1.206 Yes No Section C.1.7 - Instrumentation and Controls C.I.7.C-2 Cyber Security Requirements The digital safety system development process should address El potential security vulnerabilities in each phase of the digital safety system life cycle.(Refers to regulatory positions 2.1 through 2.9 of RG 1.152) Not clear what should be provided in the LAR itself.

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