ML091330029

Meeting Slides, Oconee Rps/Esps Digital Upgrde Licensing Experience

ML091330029
Person / Time
Site:	Oconee
Issue date:	05/06/2009
From:	Duke Energy Carolinas
To:	Office of Nuclear Reactor Regulation
Stewart Bailey, NRR/DIG I&C, 415-1321
References
Download: ML091330029 (11)

Text

Oconnee RPS/ESPS Digital Upgrade Lic censing Experience May 6, 2009

RPS/ESPS Digital Upgrade Overview Digital Upgrade 3/4 Replaces Analog Reactor Protection System S and Engineered Safeguards Protection System 3/4 18 cabinets 3/4 Uses existing reactor trip and accidentt mitigation sensor inputs 3/4 Adds diverse LPI and HPI Actuation S Systems Licensing Activities 3/4 Duke License Amendment Request along with separate Cyber Security Submittal -

January 2008 3/4 Two Rounds of RAIs for each submitta al 3/4 16 LAR Supplements, 3 Cyber Securitty Supplements 3/4 142 Documents submitted to NRC 3/4 4 NRC audits (Oconee Site, AREVA Alpharetta A Office, and Erlangen Germany Test Field) 2

Lice ensing Review Timeline RPS/ESPS LAR Submittal January 31, 2008 NRC LAR Acceptance Review April 24, 2008 1st Set of LAR RAIs August 20, 2008 1st Set of Cyber Security RAIs September 26, 2008 Response to 1st Set of LAR RAIs September 30, 2008 Response to 1st Set of Cyber Security RAIs R November 6, 2008 2nd Set of LAR & Cyber Security RAIs March 9, 2009 Response to 2nd Set of RAIs April 3, 2009 Draft SE to DORL July 2009 SE Issuance Fall 2009 3

LA AR Format and Content Numerous pre-application meetings to addrress format and content 3/4 NEI 06-02 for basic format and content 3/4 al portion Regulatory Guide 1.206 C.I.7 for technica 3/4 SRP BTP 7-14 for software QA LAR Enclosure 1 provides evaluation of the e proposed change 3/4 Chapter 1 provides summary description 3/4 Chapter 2 describes proposed design cha ange 9 Provides information consistent with RG 1.206, C.I.7.2, C.I.7.3, & C.I.7.8 3/4 Chapter 3 9 Provides information consistent with RG 1.206 C.I.7 9 Addresses compliance with IEEE 603-1998 6 and IEEE 7-4.3.2-2003 by clause 9 Testing performed or planned 9 Summary of FMEA 9 Operation, maintenance and suppo ort aspects of new system 3/4 Chapter 4 - Regulatory Evaluation 3/4 Chapter 5 - Environmental Consideration ns LAR Enclosure 2 provides evaluation of pro oposed Technical Specification change LAR Enclosure 3 provides list of regulatory commitments LAR Enclosure 6 provides documents need ded for acceptance review 4

C Cyber Security Submittal May 1, 2007 Meeting Duke and d NRC Staff agreed security sensitive information should be provided separately Regulatory Guide 1.152, Revision 2 describes method acceptable by NRC Staff for complying with cy yber security regulations 3/4 Directly Di tl applicable li bl tto new d de esigns i

3/4 Requires correlation to previo ously approved designs Submittal addresses cyber secu urity aspects of the system from the concepts phase through the retirement phase 5

F First -of of--a Kind Licensing Challenges Oconee RPS/ESPS LAR is the e first complete RPS/ES replacement reviewed by NRC C NRC ISGs for Digital I&C Reviiews did not exist during submittal development - most were issued just prior to submittal TELEPERM XS Platform used by Oconee approved May 2000 3/4 Long time interval between approval & Oconee Project Review 3/4 NRC concerns with changess since platform approval and control of changes port SER caused re-review of many 3/4 Lack of detail in Topical Rep facets of platform design 6

Chan nging Regulatory Guidance NRC Review Guidance out of date or did d not exist during Oconee LAR development Interim Staff Guidance (ISG) develope ed to provide predictable, and timely licensing process for both new and existing plan nts ISGs issued during LAR development or after LAR submittal were applied to the Oconee application 3/4 As a result,, significant g effort required q d to correlate old g guidance to new g guidance 3/4 ISG-02 on Diversity and Defense in Depth 9 Impact of 30 minute operator response time assumption (re-review of manual actions credited for existing safety analyses not affected by digital upgrade) 3/4 ISG-04 on Communication Independ dence 9 Interchannel communication 9 Permanent connection of Service Unit to MSI 3/4 ISG-01 on Cyber Security 9 Mapped nuclear safety activities to cyber security topics to meet NRC lifecycle process focus 9 One-way hardware device use ed in gateway subject to extensive review 3/4 Draft ISG-06 on licensing process 7

Affect of o NRC Position on Tools Duke advised during acceptanc ce review that use of simulation test tool (SIVAT) was an issue presenting a significant challenge to completing LAR review NRC position is that use of simu ulation test tool requires review and approval prior to use for validation testing Changed Oconee V&V Plan forr Software Integration Testing Software Integration Testing to be performed during Factory Acceptance Testing for all 3 Un nits AREVA to submit TELEPERM XS X SIVAT Topical Report to NRC for review and approval 8

F Factory Acceptance Testing Test Performed for Oconee RPS/ESPS R System 3/4 Software - RPS, ESFAS, GSM, GW, & Cyber Security 3/4 Hardware - RPS and ESF F Response Time, HW Failures, DHPIAS, and DLPIAS 3/4 System - One Pump Coas stdown SBLOCA stdown, SBLOCA, Startup/Shutdown Test Duration - 7 weeks NRC audited primarily the so oftware aspects of FAT 9

Current Licensing Status RAIs Addressed NRC Preparing Safety Evaluation Report Weekly Telecons Being Used d to Address NRC Staff questions while writing SE Favorable Outcome Expected Based on Preliminary NRC Feedback First installation plan on Unit 1 in Spring 2011 Outage 10

Closing Remarks 11