ML12366A264
| ML12366A264 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 12/31/2012 |
| From: | Nease R NRC/RGN-II/DRS/EB1 |
| To: | Gillespie T Duke Energy Corp |
| Linda K. Gruhler 404-997-4633 | |
| References | |
| IR-12-013 | |
| Download: ML12366A264 (21) | |
See also: IR 05000287/2012013
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
December 31, 2012
Mr. T. Preston Gillespie, Jr.
Site Vice President
Duke Energy Corporation
Oconee Nuclear Station
7800 Rochester Highway
Seneca, SC 29672-0752
SUBJECT: OCONEE NUCLEAR STATION UNIT 3 - REACTOR PROTECTIVE
SYSTEM/ENGINEERED SAFEGUARDS PROTECTIVE SYSTEM (RPS/ESPS)
DIGITAL MODIFICATION - U.S. NUCLEAR REGULATORY COMMISSION
INSPECTION REPORT 05000287/2012013
Dear Mr. Gillespie, Jr.:
On October 9, 2012, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection
at your Oconee Nuclear Station, Unit 3 reactor facility. The enclosed inspection report
documents the inspection results, that were discussed with you and other members of your
staff.
The inspection was performed in accordance with Inspection Procedure 52003, Digital
Instrumentation and Control Modification Inspection, and also focused on the list of
recommended Site Inspection Follow-Up Items outlined in the RPS/ESPS Safety Evaluation
dated January 28, 2010, (ADAMS Accession Number ML100220016). The inspection
examined activities conducted under your license as they relate to safety, compliance with the
Commissions rules and regulations, and with the conditions of your license. The team
reviewed selected procedures and records, observed activities, and interviewed personnel. No
findings were identified during this inspection.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its
Enclosures, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room, or from the Publicly Available Records (PARS) component of the
T. P. Gillespie, Jr.
2
NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Sincerely,
/RA by Eric J. Stamm Acting For/
Rebecca L. Nease, Chief
Engineering Branch 1
Division of Reactor Safety
Docket No. 50-287
License No. DPR-55
Enclosure:
Inspection Report 05000287/2012013,
w/Attachment: Supplemental Information
cc: (See page 3 and 4)
T. P. Gillespie, Jr.
2
NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Sincerely,
/RA by Eric J. Stamm Acting For/
Rebecca L. Nease, Chief
Engineering Branch 1
Division of Reactor Safety
Docket No. 50-287
License No. DPR-55
Enclosure:
Inspection Report 05000287/2012013,
W/Attachment: Supplemental Information
cc: (See page 3 and 4)
Distribution:
J. Bartley, RII, DRP
C. Rapp, RII, DRP
G. Ottenberg, RII, SRI
E. Elli, RII, SI
M. Endress, RII, RI
C. Evans, RII, EICS
L. Douglas, RII, EICS
RIDSNRRDIRS
PUBLIC
RidsNrrPMOconee Resource
X PUBLICLY AVAILABLE
G NON-PUBLICLY AVAILABLE G SENSITIVE X NON-SENSITIVE
ADAMS: X Yes
ACCESSION NUMBER: ML12366A264 X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED
OFFICE
RII:DRS
RII:DRS
RII:DRS
RII:CCI
RII:CCI
SIGNATURE
EJS2 for SAW4
EJS2 for RLN1
SXD7 via e-mail
SAW4 for CRS2 via e-mail
LSD2 via e-mail
NAME
S. WALKER
R. NEASE
S. DARBALI
S. SMITH-STANDBERRY
L. DUMONT
DATE
12/ 19 /2012
12/ 31 /2012
12/ 19 /2012
12/ 20/ 2012
12/ 20 /2012
E-MAIL COPY
YES
NO
YES
NO
YES
NO
YES
NO
YES
NO
OFFICIAL
RECORD
COPY DOCUMENT
NAME:
S:\\DRS\\DIGITAL
IC\\OCONEE
MODIFICATION\\OCONEE RPS-ESPS_2012013.DOCX
T. P. Gillespie, Jr.
3
cc:
Thomas D. Ray
Plant Manager
Oconee Nuclear Station
Duke Energy Corporation
Electronic Mail Distribution
James A. Kammer
Design Engineering Manager
Oconee Nuclear Station
Duke Energy Corporation
Electronic Mail Distribution
Robert H. Guy
Organizational Effectiveness Manager
Oconee Nuclear Station
Duke Energy Corporation
Electronic Mail Distribution
Terry L. Patterson
Safety Assurance Manager
Duke Energy Corporation
Electronic Mail Distribution
Kent Alter
Regulatory Compliance Manager
Oconee Nuclear Station
Duke Energy Corporation
Electronic Mail Distribution
Judy E. Smith
Licensing Administrator
Oconee Nuclear Station
Duke Energy Corporation
Electronic Mail Distribution
Joseph Michael Frisco, Jr.
Vice President, Nuclear Design Engineering
General Office
Duke Energy Corporation
Electronic Mail Distribution
M. Christopher Nolan
Director - Regulatory Affairs
General Office
Duke Energy Corporation
Electronic Mail Distribution
David A. Cummings (acting)
Fleet Regulatory Compliance & Licensing
Manager
General Office
Duke Energy Corporation
Electronic Mail Distribution
Alicia Richardson
Licensing Administrative Assistant
General Office
Duke Energy Corporation
Electronic Mail Distribution
Lara S. Nichols
Deputy General Counsel
Duke Energy Corporation
Electronic Mail Distribution
David A. Cummings
Associate General Counsel
General Office
Duke Energy Corporation
Electronic Mail Distribution
Division of Radiological Health
TN Dept. of Environment & Conservation
401 Church Street
Nashville, TN 37243-1532
Sandra Threatt, Manager
Nuclear Response and Emergency
Environmental Surveillance
Bureau of Land and Waste Management
Department of Health and Environmental
Control
Electronic Mail Distribution
Senior Resident Inspector
U.S. Nuclear Regulatory Commission
Oconee Nuclear Station
7812B Rochester Hwy
Seneca, SC 29672
Charles Brinkman
Director
Washington Operations
Westinghouse Electric Company
Electronic Mail Distribution
cc: (continued on page 4)
T. P. Gillespie, Jr.
4
cc: (continued from page 3)
County Supervisor of Oconee County
415 S. Pine Street
Walhalla, SC 29691-2145
W. Lee Cox, III
Section Chief
Radiation Protection Section
N.C. Department of Environmental
Commerce & Natural Resources
Electronic Mail Distribution
Enclosure
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No:
50-287
License No:
Report No:
Licensee:
Duke Energy Company
Facility:
Oconee Nuclear Station, Unit 3
Location:
7821 Rochester Highway
Seneca, SC 29672
Dates:
May 7, 2012 - October 9, 2012
Inspectors:
S. Walker, Senior Reactor Inspector, RII DRS (Lead)
S. Darbali, Technical Reviewer, NRR
L. Dumont, Construction Inspector, RII CCI
C. Smith-Standberry, Construction Inspector, RII CCI
Approved by:
Rebecca L. Nease, Chief
Engineering Branch 1
Division of Reactor Safety
SUMMARY OF FINDINGS
IR 05000287/2012013; 5/7/2012 - 10/9/2012; Oconee Nuclear Station, Unit 3; Digital
Instrumentation and Control Modification Inspection.
This inspection was conducted by a team of three NRC inspectors from the Region II office, and
one technical reviewer from the Office of Nuclear Reactor Regulation. No findings were
identified. The NRC's program for overseeing the safe operation of commercial nuclear power
reactors is described in NUREG-1649, Reactor Oversight Process, (ROP) Revision 4, dated
December 2006.
REPORT DETAILS
Background Information
On January 31, 2008, Duke Energy Carolinas submitted a first-of-a-kind license amendment
request to upgrade the Oconee Nuclear Station to a digital Reactor Protective System (RPS)
and Engineered Safeguards Protective System (ESPS). The proposed amendment would allow
replacement of the existing Bailey Meter Company analog, solid-state design, RPS/ESPS with a
digital computer based TELEPERM XS (TXS) platform at Oconee Units 1, 2 and 3. The digital
RPS/ESPS would provide signal processing, signal validation, and protection logic function for
these systems.
NRR approved the LAR and issued a safety evaluation report (SER) dated January 28, 2010
(ML100220016). NRR conducted an evaluation of the license amendment as part of the normal
review process. This included a review of the design and capabilities of the modification.
Regional inspectors were tasked with performing documentation and functionality reviews after
the system left the vendor in accordance with Inspection Procedure 52003.
In addition, the SER discussed inspection activities (Section 3.14., Regional Activities) for the
digital RPS/ESPS that would be addressed by the NRC regional office during site acceptance
testing, installation, startup testing, and operation of the system. The activities, referred to as
inspection follow-up items, were intended to verify licensee activities that were not part of the
licensing process, but were related to the safe operation of the digital RPS/ESPS system. The
bases for the inspection activities were derived from Chapter 7 of the Standard Review Plan
(SRP), and explained in detail throughout the SER.
Region II developed a site-specific inspection plan to select and review the activities associated
with the major phases of the digital I&C modification. Region II observed portions of testing,
installation, and operation of the RPS/ESPS modification on Unit 1 in 2011. This included a
sample of inspection requirements involving four major areas of effort: (1) developing an
understanding of the modification design; (2) documentation verification; (3) review of testing,
operations, and training; and (4) a review of plans for maintenance and repair efforts. The
results of the inspection were documented in Inspection Report 05000269/2011011
(ML 12069A088).
This report documents the inspection results for the RPS/ESPS modification on Unit 3. For the
Unit 3 review, the site-specific inspection plan included an emphasis on: 1) review of corrective
action program (CAP) documents to ensure lessons learned and operating experience had
been properly captured and implemented; and 2) additional emphasis was considered for those
licensee activities that included new or different management controls, or were being
managed/controlled in a different manner, or implemented with new techniques.
Because the SER was applicable to all three units, many of the inspection follow-up items that
were previously reviewed during the Unit 1 inspection effort were not reviewed again.
4
4.
OTHER ACTIVITIES
4OA5 Other Activities - Digital Instrumentation and Control Modification Inspection (52003)
.1
Design Review
.1.1
Full Scope Modification
a. Inspection Scope
The team reviewed all the documentation required to gain a working knowledge of the
digital instrumentation and control (I&C) modification including, but not limited to: the
staffs SER; any licensing commitment documents; manufacturers literature on the
hardware and software being installed; and applicable drawings and schematics. In
addition, the team reviewed design specification attributes including design architecture,
input consolidations, isolation and interface devices, affected indicators, and the credited
function of the system to verify proper system requirements were met and/or maintained
during installation.
The team discussed several changes the licensee made during the Unit 1 installation to
verify that they were appropriately captured in the Unit 3 scope. The team also reviewed
the Unit 3 modification project plan to determine if any changes following installation on
Unit 1 had been appropriately evaluated.
b. Observations and Findings
No findings were identified. The team determined that given the complexity and large
scale of the modification, the licensee adequately implemented the full scale design.
The team reviewed Problem Investigation Program (PIP) O-11-8106 documenting the
licensees lessons learned from Unit 1, and observed that the Integrated Test performed
on Unit 1 was not being performed on Unit 3, or following installation on Unit 2 in 2014.
The PIP stated that the Unit 3 modification test plan should outline the purpose for the
integrated test performed on Unit 1, and the necessary justification to support not
performing the test on Unit 3. When the team reviewed the Unit 3 mod test plan, it was
noted there had been no justification for not performing the test. The team questioned
whether there were components or features that would not be tested due to removal of
the integrated testing. Following discussions, the licensee revised the modification test
plan to document that the integrated test performed on Unit 1 was to be a final
demonstration of what was considered to be the worst cases for the network loading and
power supply loading with all ES channels tripped and six of 10 RPS trips generated.
This test scope was not required by the SER, or by the post-modification testing
requirements. Software integration and loading of the TXS cabinet power supplies
was demonstrated by Factory Acceptance Testing, Site Acceptance Testing, and
post-modification verification and functional tests. The team found the justification
acceptable.
5
.1.2
Modification Schedule
a. Inspection Scope
The team reviewed the licensees proposed schedule for implementation to verify the
licensee properly evaluated any associated shutdown risk due to modification
implementation and emergent changes to the schedule. The team reviewed the
licensees modification plan to verify whether the implementation would be done in
conjunction with shutdown risk activities, such as a complete core offload or mid-loop
operations. The team reviewed and assessed the emergent issues to evaluate the
potential impact on the overall implementation and testing schedule.
b. Observations and Findings
No findings were identified. The team determined the licensee adequately scheduled
installation, maintenance, and testing appropriate to the circumstances. As emergent
issues arose, the licensee would prioritize issues utilizing safety and risk insights. The
team determined the licensee incorporated lessons learned from the Unit 1 installation
which provided for more effective scheduling.
.2
Documentation Review
.2.2
Procedure Review
a. Inspection Scope
The team performed, on a sampling basis, a review of the licensee procedures affected
by the modification of the RPS/ESPS system. PIPs were reviewed to verify issues that
arose during installation that may affect procedural guidance were appropriately entered
into the CAP and resolved.
The inspection consisted of the review of surveillance, abnormal operating, emergency
operating, annunciator response, maintenance, and testing procedures that were
updated for Unit 3. These procedures were reviewed in order to assure that they
accurately reflected Unit 1 implementation; any new systems attributes; and were in
accordance with the design commitments and technical specifications. The team was
provided a list of changes made to Unit 3 RPS/ESPS versus Unit 1 installation, which
included the approved scope of the Unit 3 engineering changes and the associated
PIPs. There were several PIPs reviewed from this list to confirm adequate changes
were made to the Unit 3 and associated procedures. The team also reviewed the
engineering change (EC) documents for the RPS and ESPS project (EC 77069 and
EC 77070).
b. Observations and Findings
No findings were identified.
6
Procedures:
The team determined that the RPS/ESPS Maintenance, Testing, and Operation
procedures reviewed for Unit 3 were adequate and consistent with Unit 1, the design
capability, and plant specifications. Any modifications that were made on Unit 3 and
differed from Unit 1 were reflected in the Unit 3 procedures.
The team requested several operational procedures from the licensee in order to verify
that the test machine, which is a portable unit that can be used to perform calibration
checks and logic tests on TXS systems, was correctly identified in the procedures. The
licensee staff stated that the test machine was not incorporated in their operation
procedures because they have no plan to use the unit in the future. The team also
determined that the implementation of the Technical Specifications (TS), applicable
licensee standards, and vendor recommendations were appropriately integrated in the
sampled calibration procedures.
The team reviewed several PIPs (listed in the Documents Reviewed section of this
report) that were listed on a requested lessons learned list of Unit 1 issues. These PIPs
were written as a result of various issues discovered during Unit 1 installation of the
RPS/ESPS system, and some required hardware modifications or procedure changes,
as resolution. Affected procedures that were listed in the PIP were reviewed by the
team to verify described changes were actually implemented in the procedure, and were
similar to those changes of Unit 1 procedures.
The team identified some differences in the Unit 3 procedures; however, interviews with
the licensee staff revealed that these differences were either new modifications planned
for Unit 3, which will be implemented on Unit 1 at a later date; or they were minor
changes that would only be specific to Unit 3. The changes that were relevant to the
human factors of the Graphical Service Monitors (GSM) were verified by inspectors,
because according to the written PIPs, the GSM for Unit 1 required several modifications
that have not yet been implemented on Unit 1. According to the licensee, the required
changes for Unit 1 have been captured and will be reflected in the continuous use
procedures for Unit 3 by use of notes to point users to differences for Unit 3. The work
to implement the changes on Unit 1 is scheduled for the next outage date. The
inspectors interviewed training personnel to verify that maintenance personnel were
trained in the differences between the systems on each unit. According to the licensee,
the training did not have to be repeated because the same user skill set required for Unit
1 is used for Unit 3. For other changes implemented, the users are able to refer to
procedures, as well as the Users Manual and training was not required.
Configuration Management:
On Unit 1, the licensee failed to perform adequate post modification testing to evaluate
the adequacy of a design modification to the RPS/ESPS, and allowed an improper wiring
configuration of the nuclear instrumentation (NI) Power Range detector cables affecting
all four RPS channels (LER 05000269/2011-05-01). The team determined the licensee
took appropriate corrective actions to prevent this from happening on the Unit 3
RPS/ESPS modification.
The team conducted interviews and was provided with the corrected drawings and
procedures for Unit 3. The design drawings used for the connection of the NI cables
7
were modified to show in more detail the connection points for each cable. Procedure
TN/3/A/77070/001, Reactor Protective System Replacement Modification, was
modified to show proper labels for the cable terminations, and new signature blocks for
implementation management and engineering oversight were added. A new continuity
test sequence for Power Range NIs was added to procedure TN/3/A/77070/001. A new
section was also added to procedure TN/3/A/77070/002, Functional Checkout of Unit 3
RPS Replacement Modification, to include the Power Range NI, and hot leg cable
testing.
The team inspected the RPS Channel A cabinet 1 (3PPSCA0001) to verify that the
Power Range connection for 3NI-5 was performed according to drawing O-2781, Rev.
16E. The team concluded that the connection of triaxial cables JC and JA was
performed according to the drawing.
Bend Radius:
During the Unit 1 installation and inspection, the team noted that the four channels of the
RPS system had wires (e.g., Okonite model 3BA-12U) that had appeared to have
exceeded the allowable bend radius. The inspectors determined that the training radius
for the wire, as specified by the manufacturer, was four times the outer diameter (4xOD)
of the wire. The licensee documented this issue in the CAP as PIP O-11-6850. The
licensee concluded that guidance for recommended target minimum bending radius for
individual insulated conductors within enclosures would be added to the procedures for
making cable terminations, as well as included in the pre-job briefings for such work.
Just prior to the inspection teams arrival onsite for the Unit 3 inspection, the licensee
discovered the procedures had not been properly updated. As a result, the licensee
issued PIP O-12-5512 and conducted a walkdown to determine if there were any wires
that exceeded their bend radius. The results of the inspections identified five examples
of wires that were bent more than needed; however, the licensee noted none of the
examples were reported as being less than the 4xOD limit. A follow-up walkdown was
performed by the inspection team. The team inspected ES cabinets 3PPSCA0017,
3PPSCA0018, and 3PPSCA0010; and RPS cabinets 3PPSCA0001 and 3PPSCA0002,
for potential bend radius issues on cables and conductors. The team observed several
examples of inadequate bend radius (most notable in RPS cabinet 3PPSCA0001) that
were less than 4xOD.
The team identified that the licensee did not adequately incorporate acceptance criteria
for bend radii of low voltage cables as a result of an NRC issue identified during Unit 1
RPS Installation. Specifically, the NRC identified that the governing procedures for
conductor installation (DPS-1390.01-00-003 and IP/0/A/3009/017,Wire Terminal
Installation, Labeling, and Termination 600V or Less, Rev. 35), did not have specific
guidance to verify bend radii for single conductor cables that could cause degradation.
The licensee conducted a subsequent follow-up inspection and provided an update to
PIP O-12-5512; where they listed the conductors, (approximately 54, excluding spares
and shields), that were identified to have a small bend radius, (between 1xOD and
2xOD), and were subsequently corrected (to 4xOD or greater) per work orders. The
licensee stated that they had no plans to correct any spare or shield cables that may
8
have inadequate bend radii. The inspectors noted that spare cables should be tested
prior to being used to ensure no damage has occurred due to an inadequate bend
radius.
Based on the information collected and evaluations performed, the licensee determined
the minimum bend radius to be 2xOD for individual conductors 10AWG and smaller,
serving low voltage, low current instrumentation and controls circuits. The licensee
stated conductors for power feeder cables shall follow vendor recommended bend
radius values; and conductors for lw voltage, low current I&C cables should be not less
than 2xOD minimum bend radius; unless restricted by vendor qualification reports.
Following several discussions and review of the evaluations performed by the licensee,
the team found the licensees position on bend radius acceptable. Because the system
had not returned to service at the time of discovery, the as-found cables were not
considered degraded, and the licensee took immediate corrective actions, the team
considered this issue appropriately resolved.
Panel Wiring:
The inspection team performed spot checks to verify cable terminations on the RPS and
ESPS cabinets were being performed according to the drawings. The team inspected
the following cabinets, terminals, and drawings:
For RPS cabinet 3PPSCA0001, the team looked at terminal blocks X011 and
X111 and compared them with drawing O-2781, Rev. 16E (Interconnection
Diagram Nuclear Instrumentation and Reactor Protection System Cabinet
3PPSCA0001)
For RPS cabinet 3PPSCA0002, the team looked at terminal blocks X023, X026,
and X122 and compared them with drawing O-2781-02, Rev. C (Interconnection
Diagram Nuclear Instrumentation and Reactor Protection System Cabinet
3PPSCA0002); and terminal block X016 and compared it to drawing O-2781-03,
Rev. D (Interconnection Diagram Nuclear Instrumentation and Reactor
Protection System Cabinet 3PPSCA0002)
For ESPS cabinet 3PPSCA0017, the team looked at terminals 53 and 56
on terminal block 121 and compared it with drawing O-2757-G, Rev. 18C
(Connection Diagram Engineering Safeguards Cabinet 3PPSCA0017); and
terminal blocks X112, TB-5, and TB-6 and compared them to drawing
O-2757-G-001, Rev. D (Connection Diagram Engineering Safeguards Cabinet
3PPSCA0017)
For the terminals checked, the inspectors concluded that the wiring for those terminals
was correct. The team conducted interviews and went through the work order that was
used to perform the terminations for RPS cabinet 3PPSCA0001. The team noted that
compared to the RPS/ESPS cabinets on Unit 1, the cabinets on Unit 3 were wired in a
much more organized manner. The licensee attributes this to giving 'ownership' of each
cabinet to a group of electricians, and having only them work on those cabinets. The
licensee incorporated this format based on lessons learned from Unit 1.
9
.2.3
Design Bases Document Review
a. Inspection Scope
The team conducted sample reviews of the Updated Final Safety Analysis Report
(UFSAR), design basis documents, TSs, and plant drawings to verify that design basis
documents were adequately updated to reflect the replacement RPS/ESPS system.
b. Observations and Findings
No findings were identified. The team noted that the design basis documents were
adequately updated to reflect the new system and associated design changes. The
team also reviewed the UFSAR change summary package and observed the
subsequent UFSAR revision included the appropriate updates to reflect the design
changes to Unit 3. Because this modification is being installed on each one of the units
in phases, the UFSAR revision did not specifically denote which unit was modified;
rather it generically addressed units as either a unit with the RPS installed or not
installed.
During the Unit 1 installation, the team observed the ES changes and the UFSAR
change packages referenced IEEE 279, Criteria for Protection Systems for Nuclear
Power Generating Stations, however, the new RPS/ESPS is licensed to IEEE 603,
IEEE Standard for Safety Systems for Nuclear Power Generating Stations. The
licensee captured this issue in the CAP as PIP-O-11-6663. The team reviewed the
status of this PIP and found the licensee took appropriate corrective actions to update
the UFSAR.
.3
Testing, Operations, and Training
.3.1
Software Testing Plan
a. Inspection Scope
The team reviewed the installation and startup test procedures for the RPS/ESPS
systems to assess whether the procedures ensured that the as-installed modifications
were consistent with the SER, the design drawings, and the licensees commitments.
Any changes or deviations from Unit 1 were noted and discussed with the licensee to
understand the purpose of any changes and to ensure the design and licensing bases
were maintained. The team performed field reviews of the modification of the digital
RPS/ESPS system, which was in the process of being installed and tested on Unit 3.
The team observed portions of the installation testing, including component checks,
functional testing, and start-up testing to verify the testing plan was adequate in
identifying proper design implementation. The team assessed whether the procedures
were clear and sufficiently detailed enough to allow site personnel to perform the tests.
The team observed portions of the Unit 3 ES Voter Actuation Testing on the Even Voter.
The licensee used procedure TN/3/A/77069/002, ES Post-Modification Functional
Verification, and inspectors observed Subsection 4.4.13.42 through 4.4.13.66 to verify
the testing was adequately performed and the test procedure was properly followed.
The Unit 3 ES Test modification plan (770609) was also reviewed in order to verify that
the performed testing procedure used was included in the plan.
10
The team reviewed several PIPs (listed in the Documents Reviewed section of this
report) associated with user document reviews of the RPS/ESPS system given that user
documentation evaluations were considered by the NRC staff to be necessary
components of acceptable methods for meeting the requirements of Appendices A and
B to 10 CFR Part 50 and were not available at the time of the SER.
The team reviewed Duke Energys Nuclear System Directive 106, Configuration
Management, to ensure that software installation and test procedures were developed
by the licensee, in accordance with this directive which assures systems, structures, and
components are operated, maintained and modified within their design basis. The team
reviewed procedure IP/3/A/0315/026, TXS (Teleperm XS) Service Unit Software
Loading, to verify that limitations were put in place to prevent the development of new or
modified operational software on the service unit since such actions were not approved
in the SER. The inspection team discussed software limitation mechanisms with the
licensee to further understand what level of privilege that is required, and who from the
staff has such privilege to load the system or application software.
The team reviewed a number of licensee site-specific documents that described the
Software Life Cycle process associated with the TXS from the Digital System
Specification (ODSS-0806-PPS.0003) document. The Digital System Specification
described the recommended requirements as well as the responsibilities to ensure that
RPS/ESPS provides intended results. The team assessed the Digital System
Specification document to verify that it met the requirements of Branch Technical
Position 7-14 (BTP 7-14).
b. Observations and Findings
No findings were identified. The team observed installation testing, functional testing,
and system start-up testing. The team found that the test plans assured adequate
controls to implement the modification. The team found that the licensee addressed any
potential issue according to its safety and risk significance. The team observed the
RPS/ESPS system start-up test and that it had functioned properly. It was noted that
some inputs could not be simulated during the testing stages, and would only be verified
during actual plant startup. These inputs were assessed and determined to be not
safety significant, and would cause no increase to public health and safety if not tested
prior to startup. The team determined the licensee adequately performed testing which
was in accordance with the Unit 3 ES testing procedures and that the testing procedures
were detailed and clear.
The team observed that the licensee employed a two-phase process to assess their end
user documentation associated with the RPS/ESPS system. First, a document review
phase was performed in 2008 in preparation for the Unit 1 project. Then, Verification &
Validation (V&V) document evaluation activities in accordance with procedure, Nuclear
System Directive 705, were accomplished to demonstrate proper translation of the TXS
User Manuals into their end user procedures. The team reviewed PIPs that outlined the
different types of issues identified, and the action taken to resolve them, during the
document review phase and the V&V document evaluation phase.
During the inspection, the team determined that the Software Operations Plan of the
Digital System Specification ODSS-806.0003 Attachment F-1, did not clearly define how
the licensee would restrict unauthorized changes to the hardware. In addition, the team
11
could not find any provisions on how the licensee would respond to security problems.
In accordance with BTP7-14, these measures are to be defined in the licenses Software
Operations Plan. The inspector could not assess the software Installation Process
which describes the installation process, the goals of that process, and a general
description of the environment, (such as temperature, humidity, vibration, and rack
space), within which the computer system and software system is qualified to operate.
The licensee demonstrated that this specific information was captured appropriately in
other documents. The licensee captured this issue in the CAP as PIP O-12-6592.
3.4
Personnel Training
a. Inspection Scope
The team reviewed training documents and interviewed personnel to verify that
operators, technicians, and system engineers had been adequately trained and have
an understanding of the system commensurate with their responsibilities.
b. Observations and Findings
No findings were identified. Following review of relevant documents, the team
determined the licensee underwent appropriate training in preparation for
implementation of the RPS/ESPS modification. The team reviewed the ongoing training
requirements and documents, specifically on Go/NoGo Testing and GSM Functional
Testing. The licensee stated training procedures for Unit 1 and Unit 3 were taken from
the GSM User Manual. There was no required retraining for Unit 3 maintenance
personnel because the User Manual and Operating procedures had been updated with
any major differences.
3.5
Hardware and Software Failures
a. Inspection Scope
The team reviewed test incident reports and PIPs to verify the licensee was
appropriately capturing hardware and software failures that occurred, and that the issues
were properly resolved.
b. Observations and Findings
No findings were identified. The team determined the licensee utilized an appropriate
threshold for entering issues into the CAP. The team followed up on several PIPs
identified during the Unit 1 installation and found them to have had adequate resolution
(the issue with inadequate bend radius was an exception). The team noted that the
licensee documented several new issues related to the implementation of the system,
categorized each issue based on its significance, proposed appropriate corrective
actions, and documented the resolution(s). The issues were appropriately entered into
the CAP as PIPs (during the SAT, issues discovered were documented as test incident
reports), and subsequently tracked separately in accessible tables. The licensee also
reviewed the issues to determine mode applicability to ensure design basis limits and
commitments (i.e., TS LCO) were maintained.
12
3.8
Indication and Annunciation
a. Inspection Scope
The team reviewed procedures, performed walkdowns, and observed control room
operations and testing; to verify proper indication and annunciation for system failures,
and system bypass were functional, and met the licensing basis as stated in the SER.
b. Observations and Findings
No findings were identified.
4OA6 Meetings, Including Exit Meeting
Exit Meeting Summary
The inspection team presented the inspection results to the staff during an exit with
members of licensee management on October 9, 2012. The inspectors asked the
licensee if any of the material examined during the inspection should be considered
proprietary and no proprietary information was identified.
ATTACHMENT: SUPPLEMENTAL INFORMATION
Attachment
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
M. Bailey, I&C Systems Manager
J. Bryan, OMP RPS/ES Engineering Supervisor
J. Ledbetter, RPS/ES Maintenance Training Supervisor
B. Loftis, RPS/ES Subject Matter Expert
W. MacIntyre, Operations Tech Support Supervisor
B. Shingleton, Regulatory Compliance
B. Thomas, RPS/ES Outage Coordinator
NRC
A. Sabisch, Senior Resident Inspector
R. Stattel, Senior Technical Reviewer, NRR
2
Documents Reviewed
Procedures
NSD 106, Configuration Management, Rev. 6
NSD 705, Instructions for the Verification and Validation of Technical Procedures Rev. 7
PT/0/B/0115/009, Key Verification, Rev. 069
PT/0/A/0600/001 A, Loss of Computer, Rev. 030
TN/1/A/90423/002, Functional Checkout of Unit 1 ES Replacement Modification, Rev. 001
AM/1/A/0315/017, TXS RPS Channels A, B, C, and D Parameter Changes for Abnormal/Normal
Operating Conditions, Rev. 0
TN/3/A/77069/002, Functional Checkout of Unit 3 ES Replacement Modification, Rev. 2
TT/3/A/77069/001, Unit 3 ESPS Startup Functional Test, Rev. 0
PT/3/A/0202/012, Component Test of ES Channels 1 & 2, Rev. 23
OP/3/A/1102/001, Controlling Procedure for Unit Startup, Rev. 253
PT/0/A/0711/001, Zero Power Physics Testing, Rev. 63
PT/0/A/1103/020, Power Maneuvering Predictions, Rev. 21
IP/3/A/0315/001G, TXS Plant Protective System Cabinet ON3PPSCA0011 Power Up, Rev. 0
IP/3/A/0315/001J, TXS Plant Protective System Cabinet ON3PPSCA0016 Power Up, Rev. 0
IP/3/A/0315/011 B, TXS RPS 3NI-6 Power Range Instrument Calibration, Rev. 1
IP/3/A/0315/011 C, TXS RPS 3NI-7 Power Range Instrument Calibration, Rev. 1
IP/3/A/0315/011 D, TXS RPS 3NI-8 Power Range Instrument Calibration, Rev. 1
IP/3/A/0315/026, TXS Service Unit Software Loading, Rev.0
Calculations and Miscellaneous Documents
EC 77070, U3 RPS Engineering Change and Modification Test Plan, Rev. 3
EC 77069, U3 ESFAS Engineering Change and Modification Test Plan, Rev. 2
EC 90423, U1 ESFAS Engineering Change and Modification Test Plan, Rev. 2
EC 90482, U1 RPS Engineering Change and Modification Test Plan, Rev. 2
ODSS-0866.PPS.0001, Digital System Specification, Rev. 0
OSC-3348, RPS/ES Failure Modes and Effects Analysis Summary Calculations, Rev. 6
OM 201.N-0024.005, Oconee Nuclear Station, Unit 1 RPS/ESFAS Controls Upgrade Software
Design Description, Rev. 012
ODSS-0806.PPS.0001, Unit 1 TXS Reactor Protection System and Engineered Safeguards
Software (RPS/ES)
ODSS-0806.PPS.0003, Digital System Specification (dated 11/14/2011), Rev. 0
Unit 3 RPS/ES Equipment Management Plan (EMP), Rev. 0
Maintenance and Test Facility (MTF) Control/Access Agreement for Unit 3 RPS/ES, Rev. 0
Drawings
O-2781, Interconnection Diagram Nuclear Instrumentation and Reactor Protection System
Cabinet 3PPSCA0001, Rev. 16E
O-2781-02, Interconnection Diagram Nuclear Instrumentation and Reactor Protection System
Cabinet 3PPSCA0002, Rev. C
O-2781-03, Interconnection Diagram Nuclear Instrumentation and Reactor Protection System
Cabinet 3PPSCA0002, Rev. D
O-2757-G, Connection Diagram Engineering Safeguards Cabinet 3PPSCA0017, Rev. 18C
O-2757-G-001, Connection Diagram Engineering Safeguards Cabinet 3PPSCA0017, Rev. D
3
Codes & Standards
IEEE Std. 603-1998, Standard for Safety Systems for Nuclear Power Generating Stations
IEEE Std. 7-4.3.2-2003, Standard Criteria for Digital Computers in Safety Systems of Nuclear
Power Generating Stations
RG 1.152, Criteria for Digital Computers in Safety Systems of Nuclear Power Plants
PIPs Reviewed
O-08-06242, Maintenance Manual Volume 1
O-08-06243, Maintenance Manual Volume 3
O-08-06245, Maintenance Manual Volume 2
O-08-00789, Maintenance Manual Volume 4
O-09-06059, Bitable Removal
O-09-05857, Maintenance Manual Volume 3
O-09-06746, Maintenance Manual Volume 4
O-10-07591, Bitable Removal O-10-08224, Software Loading
O-10-04983, No requirements for how OAC determines health of data from RPS/ES TXS
cabinets
O-10-10037, Problem discovered in validation of IP/1/A/0315/080 Go Test
O-11-07081, Rolled leads for Upper and Lower core flux detectors
O-11-05900, Procedure issues during ES Even Voter Alarm Test
O-11-05756, RPS/ES Ne Optics Port Tap Dip Switch settings
O-11-05635, Diverse HPI/LPI Bypass position but no stat alarms
O-11-04487, TXS cabinets 17 & 18 are to be electrically isolated from Bailey ACS cabinets
O-11-05512, Procedure error identified during power up of ES Cabinet 16
O-11-05593, Unexpected stat alarms received that clear at power up
O-11-10361, GSM Screens do not provide consistent results
O-11-00946, Additional work needed to meet Tech Spec Surveillance requirements
O-11-00279, Inadequate reflash capability exists in hardware design of ES Voter
O-11-04841, Loss of Manual Bypass Statalarm on loss of SVE2 software
O-11-06889, IC1 and IC2 ES Trouble Alarms locked in
O-11-06872, Unit 1 control room receiving RPS Trouble statalarms
O-11-06062, IEC26 RPS/ES Testing Issue
O-11-04902, U1 RPS/ES Fire break material cannot be installed as designed
O-11-04259, Rework of Fire Penetration 1CF-56/54
O-11-05827, ES 1A WR Pressure out of cal
O-11-05554, Testing delays due to unexpected statalarm actuations and incorrect statalarm
indications
O-11-05866, ES-6 Trip Alarm not received as expected during testing
O-11-05916, Polarity is reversed for RPS Channel E RC Flow transmitters
O-11-06097, During the design phase of the RPS/ES project for Unit 1, the rewiring of events
recorder was not designed per the wiring convention used at ONS
O-11-06663, Revise UFSAR change package for RPS/ES to refer to IEEE 603
O-11-07865, Received 1C RPS Trouble and OAC Alarm 1C RPS Hot Leg Temperature
O-11-08016, Documentation of 1EOC26 RPS/ES Lessons Learned
O-12-04855, Prompt Investigation Response Team Report for PIP O-12-4580
O-12-04852, Unit 3 ES/RPS Unexpected voltage found on 3UB2
O-12-04143, Unit 3 ES/RPS Voltage found in 3B2 RCPPM cabinet during zero energy checks
O-12-03846, This PIP documents the actions being taken to address the need to replace the
499 ohm resistors for the Units 1, 2 and 3 RPS and ES, based on SVT approval of the
requested change
O-12-06591, Unit 3 NI-2 SR Level signal for Refueling and ZPPT areas reading negative value
4
O-12-03442, An additional problem identified with 499 ohm 0.1% precision resistors in U1
O-12-06526, Discussion on QA condition of PSW pressurizer heater cables - separation issue
O-12-05512, Inadequate bend radius in ES and RPS cabinets
O-12-06439, Oconee RPS/ES system cyber security issue
PIPs Generated Due to Inspection:
O-12-04609, New labels for RPS Cabinets 5 & 6 are incorrect
O-12-06592, Enhancements needed to RPS/ES Software Operations Plan