ML15035A006
| ML15035A006 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/04/2015 |
| From: | Schrader K Pacific Gas & Electric Co |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML15035A006 (16) | |
Text
DIABLO CANYON POWER PLANT PROCESS PROTECTION SYSTEM REPLACEMENT LESSONS LEARNED USING ISG 6 NRC Meeting on Digital I&C February 4 2015 February 4, 2015 Ken Schrader, MS Senior Advisory Engineer PG&E Vice Chairman, PWROG kjse@pge.com 805-545-4328 11
Agenda ISG 6 (Licensing Process for Digital I&C System Modifications) Pilot Application and Status PG&E ISG 6 Positive Experiences PG&E ISG 6 Lessons Learned 2
ISG 6 Pilot Application Diablo Canyon is pilot plant for use of ISG 6 Diablo Canyon is pilot plant for use of ISG 6 PG&E participated in ISG 6 working group PG&E submitted pilot application 10/26/11 PG&E submitted pilot application 10/26/11 (ML11307A331)
Process Protection System replacement Process Protection System replacement Invensys Tricon V10 (PLC b d)
(PLC based)
Westinghouse Advanced Logic System (ALS) (FPGA based) 3
- (ALS) (FPGA based)
ISG 6 Pilot Application Current Status Invensys - Factory Acceptance Testing (FAT) completed and equipment delivered W
ti h
Fi l d i
i IV&V i
FAT Westinghouse - Final design in IV&V review, FAT scheduled to be completed in May Initial ACRS meetings completed with no requested Initial ACRS meetings completed with no requested changes Completing final documentation and will need to p
g respond to final set of RAIs NRC approval expected late 2015 4
ISG 6 Pilot Application NRC support of application has been excellent Resources Use of sharepoint site for documentation Efficient resolution of open items Efficient resolution of open items Identifying lessons learned from Oconee project ACRS presentations/meetings ACRS presentations/meetings 5
ISG-06 Positive Experiences ISG 6 Pre-submittal (Phase 0) Meetings ISG 6 Pre submittal (Phase 0) Meetings NRC feedback critical to completing initial design that did not require any subsequent significant q
y q
g changes PG&E decided to not use cross channel communications, two-way safety communications, or signal voting in the design Very beneficial to reduce licensing and financial Very beneficial to reduce licensing and financial risk 6
ISG-06 Positive Experiences ISG 6 Process for use of Approved Vendor ISG 6 Process for use of Approved Vendor Topical Reports (Tier 1, fast-track)
Significantly simplifies LAR (5-10 times smaller)
Significantly simplifies LAR (5 10 times smaller)
Can largely reference topical report for compliance with ISG-4, IEEE-603, IEEE 7-4.3.2 Eliminate need for large project team (utility and vendor) 7
ISG-06 Positive Experiences ISG 6 Allowance for Open Items List and ISG 6 Allowance for Open Items List and Public Phone Calls Allowed efficient resolution of questions Allowed efficient resolution of questions Limited Requests for Additional Information that required docket responses to be minimized Use of internet sharepoint website for documents Allowed documents to be viewed by NRC staff Facilitated efficient response to questions 8
ISG-06 Lessons Learned PG&E original design used single non-safety PG&E original design used single non safety maintenance workstation for both Tricon and ALS subsystems in each of four divisions Testing and software requirements following software changes were not considered, became NRC issue PG&E h d d i
t t
i t PG&E changed design to use separate maintenance computer for each subsystem in each division Simplifies factory acceptance testing requirements and Simplifies factory acceptance testing requirements and eliminates potential software interaction issues 9
ISG-06 Lessons Learned PG&E issued single Functional Requirements PG&E issued single Functional Requirements Specification for project (applied to both vendors)
All functional requirements were not applicable to each d
vendor Resulted in unnecessary difficulty for vendor design, vendor documentation, and NRC review Contributed to vendors not meeting all applicable requirements during detailed design Vendor verification personnel and NRC identified issues Vendor verification personnel and NRC identified issues during vendor audits Required redesign, extended vendor schedules, complicated NRC i
10 NRC review
ISG-06 Lessons Learned PG&E did not incorporate I&C maintenance personnel PG&E did not incorporate I&C maintenance personnel expectations to support troubleshooting and maintenance into initial Functional Requirements S
ifi ti Specifications Required revision to Functional Requirements Specification to include maintenance personnel needs Specification to include maintenance personnel needs Caused vendors to have to redesign to meet a few new functional requirements 11
ISG-06 Lessons Learned Vendors did not fully understand meaning of some Vendors did not fully understand meaning of some functional requirements Nuclear requirements and terminology are unique Some vendor design personnel did not have prior nuclear project experience (most PLC and FPGA business is non-nuclear)
Clarifying questions on requirements from vendors occurred late in detailed design, required some redesign Utilities need to proactively ensure vendor design and IV&V Utilities need to proactively ensure vendor design and IV&V personnel have correct understanding of all requirements 12
ISG-06 Lessons Learned Vendors underestimated effort for detailed design Vendors underestimated effort for detailed design First-of-Its-Kind large scope application of each vendor platform to US nuclear plant protection system N
l i
t d
l Nuclear requirements and processes are more complex Vendor document revisions required to address ISG 6 requirements Two year delay occurred in LAR review schedule to address combined aspects of functional requirements specification changes redesign and First of its Kind specification changes, redesign, and First-of-its-Kind engineering 13
Summary ISG 6 ISG 6 Roadmap to success to develop acceptable License Amendment Request (LAR) q
(
)
ISG 6 process will reduce licensing uncertainty and effort for future licensees/vendors Utilities should strongly consider designs with approved Vendor Topical Reports LAR f ll i
ISG 6 d i ti l
LARs following ISG 6 and incorporating lesson learned from initial plant applications can be approved in timely manner 14 14 approved in timely manner
ISG 6 Pilot Application Project Scope Project Scope 15 15
ISG 6 Pilot Application Process Protection System Replacement A
hit t
Architecture 16 16