LR-N13-0197, Intent to Submit License Amendment Request to Install Power Range Neutron Monitor (Prnm) in Accordance with Interim Staff Guidance, Digital I&C-ISG-06
| ML13240A293 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 08/27/2013 |
| From: | Duke P Public Service Enterprise Group |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| LR-N13-0197 | |
| Download: ML13240A293 (46) | |
Text
Enclosure 4 Contains Proprietary Information.
Withhold from Public Disclosure Under 10 CFR 2.390 (a)(4).
PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 AUG 2 7.2013 LR-N13-0197 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354 PSEG NucleaT LLC 10 CFR 2.390 10 CFR 50.90
Subject:
Intent to Submit License Amendment Request to Install Power Range Neutron Monitor (PRNM) in accordance with Interim Staff Guidance, Digital I&C-ISG-06 In accordance with Interim Staff Guidance, "Digitaii&C-ISG-06", PSEG Nuclear LLC (PSEG) is submitting a letter of intent to support the PRNM Pre-Application (ISG-06 Phase 0) meeting on September 11, 2013 (ADAMS ML13233A113). provides the presentation material for the open (public) portion of the meeting. provides a non-proprietary redacted version of the presentation material for the closed portion of the meeting. provides an affidavit related to the proprietary material in Enclosure 4. provides the proprietary presentation material for the closed portion of the meeting. contains proprietary information as defined by 10 CFR 2.390. General Electric Hitachi (GEH), as the owner of the proprietary information, has executed the Enclosure 3 affidavit identifying that the proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure.
GEH requests that the proprietary information in Enclosure 4 be withheld from public disclosure, in accordance with the requirements of 10 CFR 2.390 (a)(4), "Public inspections, exemptions, requests for withholding." Contains Proprietary Information.
Withhold from Public Disclosure Under 10 CFR 2.390 (a)(4).
AUG 27 2013 Page 2 LR-N13-0197 10 CFR 2.390 10 CFR 50.90 There are no regulatory commitments contained in this letter. If you have any questions or require additional information, please contact Mr. Brian Thomas at (856) 339-2022.
Sincerely, ge.
Manager - Licensing
Enclosures:
(4) cc:
W. Dean, Regional Administrator - NRC Region I J. Hughey, Project Manager - USNRC NRC Senior Resident Inspector - Hope Creek P. Mulligan, Manager IV, NJBNE Hope Creek Commitment Tracking Coordinator PSEG Corporate Commitment Tracking Coordinator Contains Proprietary Information.
Withhold from Public Disclosure Under 10 CFR 2.390 (a)(4).
LR-N13-0197 Presentation material for the open (public) portion of the September 11, 2013 PSEG PRNM Pre Submittal (Phase 0) Meeting Non-proprietary
Phase 0 Meeting_!fp()se 2
- 1. Communicate PRNM license amendment need, approach and design concept
- 2. Discuss project preparation and specific aspects of PRNM upgrade
- 3. Describe evaluation appr-oach of key topics related to digital systems
- 4. Address conformance with current NRC guidance
- 5. Gain alignment on ISG-06 requirements
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Meeting Purpose and lntrodlicHons PRNM LAR Need, Approach and Design Concept Project Preparation I Specific Aspects of PRNM Upgrade Evaluation Approach of Key Digital System Topics Conformance with current NRC guidance ISG-06 Alignment Summary Questions, Discussion and Feedback (Public Presentation)
Conclusion (Public Presentation)
GEH Development Program (Proprietary Information Presentation)
Questions, Discussion and Feedback (Proprietary Information Presentation)
- Summary-Conclusion (F:Wprfetary Information Presentation)
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Introductions
4 PSEG I GEH Team Kenneth Knaide-PSEG Director of Engineering - Hope Creek Robert Gallaher-PSEG PRNM Project Manager Chuck Lukacsy-PSEG Operations Keith Swing - PSEG System Engineer Ron Veideman-PSEG Lead Engineer Dave Heinig - PSEG Design Engineer Brian Thomas-PSEG Principal Licensing Engineer Robert Hoffman - PSEG Licensing _gineer Kahlim Miller-GEH Project Manager Larry Chi - GEH Chief Engineer Frank Novak-GEH PRNM Technical Lead Sara Rudy-GEH Licensing Engineer Hope Creek G!Nf..FtAtiNG STA.nOJ!f
PRNM Project Og!!!!ion s
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PRNM LAR Need,. Approach and Design Concept 6
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- Need....
PRNMS-provides scram function above IRM range; provides a rod block signal Upgrade existing analog system to provide increased reliability, enhanced operation and improved maintenance capability
- Benefit.... The GEH NUMAC PRNM Implementation at Hope Creek will provide:
Enhanced APRM features to improve system operation -use of ODA on front panels Automated system surveillance testing -built-in auto-calibration and self-test functions
-%scram reduction; managing risk, eliminate use of extender card and INOP inhibit button Highly reliable and accurate system functions Familiarity w/ NUMAC chassis (operation & troubleshooting-leak detection, MSL rad monitors)
Hope Creek
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GE,H NUMAC Configur(ltion 7
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2-out-of-4 Logic Chassis Average Power Range Monitor (APRM) Chassis with Option Ill and DSS-CD Stability functions Rod Block Monitor (RBM) Chassis Control Room Operator Display Assemblies (ODAs)
NUMAC Interface Computer (NIC)
Quad Low Voltage Power Supplies (QLVPS)
Similar to NUMAC PRNM Systems
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Nine Mile Unit 2 Susquehanna Units 1 and 2 Peach Bottom Unit 1 and 2 Limerick Unit 1 and 2 Brown's Ferry Unit 1, 2, 3 Monticello Grand Gulf Columbia (LAR submitted for approval)
Etc... (more than 30 installed systems)
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Main Display lPRM Display
Existing S}{stem !!f!lparison a
Subsystem Safety Function LPRM Flow APRM OPRM RBM Hope Creek
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Existir1gi?Rl\\fMSystern Upscale Flux Trip Simulated Thermal Power Trip Setdown Flux Trip OPRM trip provided by ABB OPRM system
- 43 LPRM strings, 172 LPRM detedor Signas Four Flow channels, 8 Flow Transmitters Flow channels A&C provide input to APRM A, C, E Each APRM selects the low input Flow channels B&D provide input to APRM 8, D, F Each APRM selects the low input 6 APRM Channels 21 or 22 LPRM inputs signals to eachAPRM channel LPRM.Groups A & B are not used l1y APRMs Eight outputs to RPS APRM A-RPS Channel A1 APRM B-RPS Channel Bi APRM C-RPS Channel A2 APRM D-RPS Channel 82 APRM E-RPS Channel A 1, A2 APRM F-RPS Channet81, 82 Two bypass switches ABB BWROG Option Ill stability solution 2 RBMs, Flow-biased setpoints NUMAC PRNM System Upscale Flux Trip Simulated Thermal Power Trip Setdo:wn Flux Trip OPRMtrip No Change Four Flow channels, 8 Flow Transmitters Each flow channel provides input to 1 APRM channel 4 APRM Channels 4 LPRM NUMACs coupled with assodated APRM channel to process all LPRM input signals 43 LPRM inputs signals to each APRM channel All LPRM detectors used by the APRMs
- Eight outputs to RPS Voter A 1 - RPS Channel At Voter Bt - RPS Channel 81 Voter A2 - RPS Channel A2 Voter 82-RPS Channel 82 One bypass switch GE BWROG Option Ill and GEH DSS-CD stability solutions 2 RBMs, Power-biased setpoints (Full ARTS implementation)
PRNM & lnterface_,!ms g
Reactor Manual Control System 172 LPRM Detectors Recirculation Loop Flow Transmitters Reactor Mode Switch
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Discrete Contacts Rod Select Serial Word Discrete Contacts Analog 0-3mA Analog 4-20mA GEHPropr.
Fiber GEHPropr.
Fiber Denotes fiber-optic cable TCPIIP Plant Computer Analog 0-lV
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Fiber GEHPropr.
Fiber A1 RPS Discrete Contacts Operator Display I
Assemblies 82 A2 A2 A1 RRCS
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PRNM Pre
- aration and Issue lden,tification 1 o
- Industry Lessons-Learned applied
- Critical Digital Review completed
- HCGS Digital Program assessment completed
- TS Amendment removing APRM OPCON 5 operability requirement impleme¬!ed.----
- Procedure Development Plan To support FAT To enhance Digital Program/Processes
- Potential future projects assessed for PRNM upgrade implications To identify I mitigate I resolve issues early Hope Creek Gf.Nf'R!iflf'-/G STATION- -
Specific Aspects trgNM Upgrade 11
- Full ARTS implementation
- Flow-biased to power-biased RBM
- OPRM: Change from ABB OPRM with BWROG Option Ill stability to GE OPRM with BWROG Option Ill and DSS-CD stability
- Mode Switch configuration (Susquehanna LER 387-06004)
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TSTF-493 12
- Performed evaluation of current HCGS setpoint methodology against TSTF elements Current method based on GEH method Seven TSTF concepts already addressed in HC program Includes equivalent AFT I AL T Nonfunctioning I Out of tolerance findings evaluated Other conservative elements provide high level of confidence
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Ke Di ital Sy.ei!!.Jp!Cs 13
- DI&C-ISG-04 Highly Integrated Control Rooms - Communication Issues
- RG 1.152 Criteria for Use of Computers in Safety Systems of Nuclear Power Plants Secure Development & Operational Environment Cyber security
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ISG-04 Highly Integrated Cointrol Rooms - Communications l.ssues 14 Interdivisional Communications PRNM includes channel-to-channel communications Supports the safety function of the system (voting)
PRNM includes NSR-to-SR communications Analysis will evaluate PRNM vs. 20 points in ISG-04 Command Prioritization Not applicable-the priority module (RPS) is not digital No diverse actuation signals are combined in PRNM
- Multidivisional Control & Display Stations ODAs are NSR, and utilize_oneway communication from APRM/RBM NUMACs No control functions
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BTP 7-19 Divers.itl!l'\\_c:l Defense ir1 Depth 15
- 03 Analysis will be submitted with Phase 1 LAR
- Only minor Chapter 15 deltas were identified
- Will address all 9 criteria in BTP 7-19 Rev 6
- Will rely on built-in divers_ity_ with other plant systems No requirement for a diverse actuation system is anticipated
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BTP 7-21 Digital Computer Real-Time Performance 16
- Analysis will demonstrate that response time is within TS requirements
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- PRNM is qualified to RG 1.180 limits
- PRNM is located in a radio exclusion zone
- Qualification Summary Report is delivered with Phase 2 documentation
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RG 1 *. 152 Criteria *tor Use of Computers in Safety Systems of Nuclear Power Plants 18
- GEH SDOE report is expected t9 be very similar to CGS report Report details GEH SDOE program from Concept through Test phases
- Subsequent phases after turnover of system to PSEG removed from RG 1.152 and are now covered under RG 5.71 HCGS is compliant with NRC approved cyber security plan License Amendments No. 189 and 192
- Cyber Security Levels PRNM will be at Level 4 CRIDS and 30M remain at level 3 -Application Firewall between Levels 3 & 4 Data Diodes installed between Level 3 and 2 -eliminating outside attacks from impacting Level 3 & 4 systems.
GAF uploads performed through the Application Firewall
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Conformance to Current NRC Guid:ance 19
- PRNM upgrade I LAR will conform to current regulatory guidance - ISG-06
- Life-Cycle Processes (PSEG and GEH) will incorporate latest regulatory guidance Revisions to RGs 1.168, 1.169, 1.170, 1.171, 1.172, and 1.173
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ISG-06 Alignment 20 Tier 2 submittal roadmap submitted with Phase 1 & 2 Similar to Columbia PRNM upgrade; incorporating RAis and NRC feedback Review of Columbia SE as precedent Phase 2 Setpoint Calculations I Phase 1 TS markup PSEG Digital Lifecycle Program GEH Digital Lifecycle Process
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GEH Develome!=ram 21
- Purpose Describe the new GEH Program and its application to the Hope Creek PRNM project GEH Digitaii&C System Life Cycle Program:
Comply BTP 7-14 criteria and IEEE Std. 1012 Incorporates RG 1.168 definition o f Independent V& V Enables full life cycle requirements traceability Compliance with al! applicable regulatory guidance (RG 1.152, RGs 1.168 thru 1.173, RG 5.71}
Life cycle artifacts conducive to DI&C-ISG-:06 licensing Leverages legacy documents Produces project specific documentation as required One scalable process for SW I Applies the existing procedures I Programmable Logic Focuses on project deliverables Applies IEEE 1012 to safety related systems Applies CP-03-04 "Technical Design Review" rigor to non-safety related systems Terminology that is consistent with NRC guidance documents BTP 7-14 and Regulatory Guides // Dl&C-lSG-06 Maximize use of standardized templates Planning documents (based on NUREG/CR-61 01 and IEEE standards)
Artifact content and verification scope
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GEH Services Digitai i&C System - Life Cycle Development Phases 22
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Standards Hope Creek
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System Requirements Requirements Validation Requirements Validation Sub-System Requirements
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I&C 1 earrt j Component Requirements V ISG-06 Licensing Submittals Requirements V:lidation
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I&C Implementation I PLD Design Spec V' ;
& T esling I SWDesign Ú J
Opportunities for Process Efficiency Improvements 23
- ISG-06 Experience and Lessons Learned to Date NRR presentation to INPO May 2013 Lessons Learned Need to re-submit generic Enclosure B documents?
Electronic Reading Room?
Add!tional document mapping/depiction to support Acceptance Rev1ew?
Columbia precedent citing?
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PRNM Project Scc:!1.de I Milestones 24
- Phase 0 Meeting
- Phase 1 Submittal
- Phase 2 Submittal
- Amendment I SE
- Phase 3 I Install
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September 2013 1st Qtr 2015 1st Qtr 2016 Fall 2016 Fall 2017 Spring 2018
Project Milestones/Timeline 25 3:
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Phase 2 Submittal 1 Amenment
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5/14/2018 Installation (Install)
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Summar 26 What we discussed today*
- 1. PRNM license amendment need, approach and design concept
- 2. Project Preparation and specific aspects of PRNM upgrade
- 3. Evaluation approach of key topics related to digital systems
- 4. Conformance with current NRC guidance
- 5. Alignment on ISG-06 requirements CHopeCreek
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Acronym list 29 30M-3DMONICORE' (core monitoring system)
ABB - ASEA Brown Boveri AFT -As Found Tolerance ALT -As Left Tolerance APRM -Average Power Range Monitor BTP-Branch Technical Position CAP -Corrective Action Program CCF - Common Cause Failure CGS -Columbia Generating Station CRIDS -Control Room Integrated Display System (Hope Creek Process Plant Computer System)
DSS-CD - Detect and Suppress Solution -Confirmation Density 03 - Diversity, Defense in Depth ESFAS - Engineered Safety Feature Actuation System FAT - Factory Acceptance Testing GAF-Gain Adjustment Factor GEH-General Electric Hitachi Nuclear Energy HW-Hardware INPO-Institute of Nuclear Power Operations IRM - Intermediate Range Monitor ISG - Interim Staff Guidance LAR - License Amendment Request LPRM-Local Power Range Monitor LTR-Licensing Topical Report NIC-NUMAC Interface Computer NRC-U.S. Nuclear Regulatory Commission NUMAC-Nuclear Measurement Analysis and Control
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'r NSR-Non Safety Related ODAs - Operator Display Assemblies OPRM -Oscillation Power Range Monitor PRNM - Power Range Neutron Monitor PSEG -Public Service Electric and Gas QLVPS - Quad Low Voltage Power Supplies RAI - Request for Additional Information RBM - Rod Block Monitor RG - Regulatory Guide RMCS - Reactor Manual Control System RPS - Reactor Protection System RRCS - Redundant Reactivity Control System RTS - Reactor Trip System Rx-Reactor SE - Safety Evaluation SDOE -Secure Development and Operational Environmental SRM - Source Range Monitor SW -Software TSTF -Technical Specification Task Force LR-N13-0197 This is a non-proprietary version of Enclosure 4 (Attachment 1 of GEH letter GEH-KT0-182455-018) of this letter which has the proprietary information removed. Portions of the document that have been removed are indicated by an open and closed bracket as shown here ((
)).
Non-proprietary
GE Hitachi Nuclear Energy Non-ProprietarylnfoFmation-Ciass I (Public)
GEH Development Program Hope Creek Power Range Neutron Monitor NUMAC Digital Upgrade Pre-Submittal (Phase 0} Meetin Date: 09/11/20lr--------
HITACHI
Non-Proprietary lnfqrmation-Ciass I (Public)
Agenda-Proprietary Information
- NUMAC Process-history
- Summary of the GEH Digitaii&C System Life Cycle Development Program
- Corporate procedures
- Independent V&V
- New process & refinement
- HITACHI 2
Non-Proprietary Information-Class I (Public)
History of NUMAC SMP o
First established in 1990 o
Approved with PRNM LTR o
Applied to all PRNM since Hatch o
NRC raised issues with ISG-06 for Grand Gulf and Columbia o
Grand Gulf PRNM approved with compensatory actions o
Columbia PRNM resubmitted in accordance with ISG06 requirements-included compensatory actions o
New DI&C Life Cycle Process roll out in 1/2012 in the form of CP-23-300- includes "compensatory actions" baked into process o
Process improvement -and simplification in 3/2013
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Digitaii&C Life C}/cle Simplification 2012 Digital I&C Process 2013 Digital I&C Process
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- HITACHI 8
Non-Proprietary Information-Class I (Public)
GEH Development Program Summary GEH Services Digital I&C System Life Cycle Development Program:
- Comply with BTP 7-14 criteria and IEEE Std. 1012
- life cycle artifacts conducive to DI&C-ISG-06 licensing submittal
- One scalable process for SW I HW I Programmable Logic
- Terminology that is consistent with NRC guidance documents
- Maximize use of standardized templates
- Process simplified to resolve implementation difficulties
(. HITACHI 9
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LR-N13-0197 Affidavit for Enclosure 4
GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Linda C. Dolan, state as follows:
(1) I am the Manager of Regulatory Compliance, Regulatory Affairs, of GE-Hitachi Nuclear Energy Americas LLC ("GEH"), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in Attachment 1 of GEH letter, GEH KT0-182455-018, Kahlim Miller (GEH) to Robert Gallaher (PSEG) "Hope Creek Generating Station PRNM Phase 0 Meeting Slides," dated August 22, 2013. The GEH proprietary information in Attachment 1, which is entitled "GEH Development Program Slides for HCGS PRNM Phase 0 Meeting," is identified by double square brackets. ((This sentence is an example. {3))) In each case, the superscript notation {3) refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.
(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Iriformation Act ("FOIA"), 5 U.S. C. Sec. 552(b)(4), and the Trade Secrets Act, 18 U.S. C.
Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought also qualifies under the narrower definition of trade secret, within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy
- Project v. Nuclear Regulatory Commission, 975 F.2d 871 (D.C. Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F.2d 1280 (D.C. Cir. 1983).
1 I
( 4) lrhe information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that fit into the definition of proprietary information are:
- a.
Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's competitors without license from GEH constitutes a competitive economic advantage over other companies;
- b.
Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;
- c.
Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;
- d.
Information that discloses trade secret or potentially patentable subject matter, or both, for which it may be desirable to obtain patent protection.
(5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GEH, Affidavit for GEH-KT0-182455-018 Page 1 of3
and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GEH, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions, or to proprietary or confidentiality agreements that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in the following paragraphs (6) and (7).
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH. Access to such documents within GEH is limited to a "need to know" basis.
(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist, or other equivalent authority for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary or confidentiality agreements, or both.
(8) The information identified in paragraph (2), above, is classified as proprietary because it contains the detailed setpoint methodology and design information for the instrumentation and control equipment thút is used in the design and analysis of the power range neutron monitoring system for the GEH Boiling Water Reactor (BWR). These methods, techniques, and data along with their application to the design, modification, and analyses associated with the power range neutron monitoring system was achieved at a significant cost to GEH.
The development of the GEH digital instrumentation and control system life cycle development program was derived from extensive experience and at great expense that constitutes a major asset of GEH or its licensor.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit making opportunities. The information is part of GEH's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.
The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial. GEH's competitive advantage will be lost if its Affidavit for GEH-KT0-182455-018 Page 2 of3
competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.
I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.
Executed on this 22nd day of August 2013.
Affidavit for GEH-KT0-182455-018 Linda C. Dolan Manager, Regulatory Compliance Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Rd.
Wilmington, NC 28401 Page 3 of3