ML091330029
| 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
Ocon Ocon Lic Lic May May nee RPS/ESPS Digital nee RPS/ESPS Digital Upgrade Upgrade censing Experience censing Experience 6, 2009 6, 2009
Digital Upgrade 3/4 Replaces Analog Reactor Protection S System 3/4 18 cabinets 3/4 Uses existing reactor trip and accident 3/4 Adds diverse LPI and HPI Actuation S 3/4 Adds diverse LPI and HPI Actuation S
Licensing Activities 3/4 Duke License Amendment Request al January 2008 3/4 Two Rounds of RAIs for each submitta 3/4 16 LAR Supplements, 3 Cyber Securit 3/4 142 Documents submitted to NRC 3/4 4 NRC audits (Oconee Site, AREVA A RPS/ESPS Digital RPS/ESPS Digital Upgrade Overview Upgrade Overview System and Engineered Safeguards Protection t mitigation sensor inputs Systems 2
Systems ong with separate Cyber Security Submittal -
al ty Supplements Alpharetta Office, and Erlangen Germany Test Field)
Lice Lice RPS/ESPS LAR Submittal NRC LAR Acceptance Review 1st Set of LAR RAIs 1st Set of Cyber Security RAIs Response to 1st Set of LAR RAIs Response to 1st Set of Cyber Security R 2nd Set of LAR & Cyber Security RAIs Response to 2nd Set of RAIs Draft SE to DORL SE Issuance ensing Review Timeline ensing Review Timeline January 31, 2008 April 24, 2008 August 20, 2008 September 26, 2008 3
September 30, 2008 RAIs November 6, 2008 March 9, 2009 April 3, 2009 July 2009 Fall 2009
Numerous pre-application meetings to addr 3/4 NEI 06-02 for basic format and content 3/4 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 3/4 Chapter 1 provides summary description 3/4 Chapter 2 describes proposed design cha 9 Provides information consistent wit LA LA Provides information consistent wit 3/4 Chapter 3 9 Provides information consistent wit 9 Addresses compliance with IEEE 6 9 Testing performed or planned 9 Summary of FMEA 9 Operation, maintenance and suppo 3/4 Chapter 4 - Regulatory Evaluation 3/4 Chapter 5 - Environmental Consideration
LAR Enclosure 2 provides evaluation of pro
LAR Enclosure 3 provides list of regulatory
LAR Enclosure 6 provides documents need ress format and content al portion e proposed change ange h RG 1.206, C.I.7.2, C.I.7.3, & C.I.7.8 AR Format and Content AR Format and Content h RG 1.206, C.I.7.2, C.I.7.3, & C.I.7.8 h RG 1.206 C.I.7 603-1998 and IEEE 7-4.3.2-2003 by clause ort aspects of new system ns oposed Technical Specification change commitments ded for acceptance review 4
May 1, 2007 Meeting Duke and information should be provided Regulatory Guide 1.152, Revisi NRC Staff for complying with cy 3/4 Di tl li bl t
d C
3/4 Directly applicable to new de 3/4 Requires correlation to previo Submittal addresses cyber secu concepts phase through the ret d NRC Staff agreed security sensitive separately on 2 describes method acceptable by yber security regulations i
Cyber Security Submittal Cyber Security Submittal esigns ously approved designs urity aspects of the system from the irement phase 5
F Oconee RPS/ESPS LAR is the replacement reviewed by NRC NRC ISGs for Digital I&C Revi development - most were issu TELEPERM XS Platform used 3/4 Long time interval between 3/4 NRC concerns with changes changes 3/4 Lack of detail in Topical Rep facets of platform design First First --of of-a Kind Licensing a Kind Licensing Challenges Challenges e first complete RPS/ES C
iews did not exist during submittal ed just prior to submittal 6
by Oconee approved May 2000 approval & Oconee Project Review s since platform approval and control of port SER caused re-review of many
NRC Review Guidance out of date or d
Interim Staff Guidance (ISG) develope process for both new and existing plan
ISGs issued during LAR development Oconee application 3/4 As a result, significant effort required Chan Chan g
q 3/4 ISG-02 on Diversity and Defense in 9 Impact of 30 minute operator r actions credited for existing sa 3/4 ISG-04 on Communication Independ 9 Interchannel communication 9 Permanent connection of Serv 3/4 ISG-01 on Cyber Security 9 Mapped nuclear safety activiti process focus 9 One-way hardware device use 3/4 Draft ISG-06 on licensing process did not exist during Oconee LAR development ed to provide predictable, and timely licensing nts or after LAR submittal were applied to the d to correlate old guidance to new guidance nging Regulatory Guidance nging Regulatory Guidance g
g Depth esponse time assumption (re-review of manual fety analyses not affected by digital upgrade) dence ice Unit to MSI es to cyber security topics to meet NRC lifecycle ed in gateway subject to extensive review 7
Affect o Affect o Duke advised during acceptanc tool (SIVAT) was an issue pres completing LAR review NRC position is that use of simu approval prior to use for validat Changed Oconee V&V Plan for Software Integration Testing to Acceptance Testing for all 3 Un AREVA to submit TELEPERM X review and approval of NRC Position on Tools of NRC Position on Tools ce review that use of simulation test enting a significant challenge to ulation test tool requires review and ion testing 8
r Software Integration Testing be performed during Factory nits XS SIVAT Topical Report to NRC for
Test Performed for Oconee R 3/4 Software - RPS, ESFAS, 3/4 Hardware - RPS and ESF DHPIAS, and DLPIAS 3/4 System - One Pump Coas F
3/4 System One Pump Coas Test Duration - 7 weeks NRC audited primarily the so RPS/ESPS System GSM, GW, & Cyber Security F Response Time, HW Failures, stdown SBLOCA Startup/Shutdown Factory Acceptance Testing Factory Acceptance Testing stdown, SBLOCA, Startup/Shutdown oftware aspects of FAT 9
RAIs Addressed NRC Preparing Safety Evalu Weekly Telecons Being Used while writing SE while writing SE Favorable Outcome Expecte Feedback First installation plan on Unit ation Report d to Address NRC Staff questions Current Licensing Status Current Licensing Status d Based on Preliminary NRC 1 in Spring 2011 Outage 10
Closing Remarks Closing Remarks 11