ML15035A006

Meeting Presentation, Diablo Canyon Power Plant Process Protection System Replacement Lessons Learned Using ISG 6 NRC Meeting on Digital I&C.

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 4, 2015 Ken Schrader, MS Senior Advisory Engineer PG&E Vice Chairman, PWROG kjse@pge.com 805-545-4328 1

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 PG&E participated in ISG 6 working group PG&E submitted pilot application 10/26/11 (ML11307A331)

Process Protection System replacement Invensys Tricon V10 (PLC bbased) d)

Westinghouse Advanced Logic System

- (ALS) (FPGA based) 3

ISG 6 Pilot Application Current Status Invensys - Factory Acceptance Testing (FAT) completed and equipment delivered W ti h Westinghouse - Final Fi l design d i in i IV&V review, i FAT scheduled to be completed in May Initial ACRS meetings completed with no requested changes Completing p g final documentation and will need to 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 Identifying lessons learned from Oconee project ACRS presentations/meetings 5

ISG-06 Positive Experiences ISG 6 Pre Pre-submittal submittal (Phase 0) Meetings NRC feedback critical to completing initial design that did not require q any y subsequent q significant 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 risk 6

ISG-06 Positive Experiences ISG 6 Process for use of Approved Vendor Topical Reports (Tier 1, fast-track)

Significantly simplifies LAR (5-10 (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 Public Phone Calls 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 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 changed h dddesign i tto use separate t maintenance i t computer for each subsystem in each division Simplifies factory acceptance testing requirements and eliminates potential software interaction issues 9

ISG-06 Lessons Learned PG&E issued single Functional Requirements Specification for project (applied to both vendors)

All functional requirements were not applicable to each vendor d

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 during vendor audits Required redesign, extended vendor schedules, complicated NRC reviewi 10

ISG-06 Lessons Learned PG&E did not incorporate I&C maintenance personnel expectations to support troubleshooting and maintenance into initial Functional Requirements S

Specifications ifi ti Required revision to Functional Requirements 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 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 personnel have correct understanding of all requirements 12

ISG-06 Lessons Learned 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 Nuclear requirements i t andd processes are more complex l 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 changes, redesign redesign, and First First-of-its-Kind of its Kind engineering 13

Summary ISG 6 Roadmap to success to develop acceptable License Amendment Request q ((LAR))

ISG 6 process will reduce licensing uncertainty and effort for future licensees/vendors Utilities should strongly consider designs with approved Vendor Topical Reports LAR ffollowing LARs ll i ISG 6 and d iincorporating ti llesson learned from initial plant applications can be approved in timely manner 14

ISG 6 Pilot Application Project Scope 15

ISG 6 Pilot Application Process Protection System Replacement A hit t Architecture 16