ML15181A063
| ML15181A063 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/01/2015 |
| From: | Schrader K Pacific Gas & Electric Co |
| To: | Joseph Holonich Research and Test Reactors Branch B |
| Holonich J, NRR/DPR, 301-415-7297 | |
| References | |
| Download: ML15181A063 (18) | |
Text
DIABLO CANYON POWER PLANT PROCESS PROTECTION SYSTEM REPLACEMENT LESSONS LEARNED USING ISG 6 NRC Digital I&C Workshop Meeting July 1 2015 July 1, 2015 Ken Schrader, MS Principal 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 t i l d
d
)
(PLC based, triple redundancy)
Westinghouse Advanced Logic System (FPGA based redundancy and diversity) 3
- (FPGA based, redundancy and diversity)
ISG 6 Pilot Application Current Status Invensys - Factory Acceptance Testing (FAT) completed and equipment delivered W
ti h
F t
A t
T ti (FAT)
Westinghouse - Factory Acceptance Testing (FAT) in progress Initial ACRS meetings completed with no requested Initial ACRS meetings completed with no requested changes, additional ACRS presentations expected Completing final documentation to be submitted and p
g will need to respond to final set of RAIs NRC approval expected early 2016 4
ISG 6 Pilot Application NRC support of application has been excellent Resources Knowledgeable personnel Use of sharepoint site to view documentation Use of sharepoint site to view documentation Efficient resolution of open items Identifying lessons learned from Oconee project Identifying lessons learned from Oconee project 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 Meetings very beneficial to confirm understanding Meetings very beneficial to confirm understanding of requirements, reduce licensing and financial risk 6
ISG-06 Positive Experiences Phase 0 Meetings Topics PG&E Meetings Phase 0 Meetings Topics, PG&E Meetings Design redundancy and diversity Diversity and Defense-in-Depth (D3) assessment Diversity and Defense in Depth (D3) assessment Communications Software development requirements Software development requirements System connections to non-safety systems, maintenance and plant computer, control systems Cyber security controls LAR contents (figures, level of detail, documents) 7
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)
NRC will have prior experience with platform 8
ISG-06 Positive Experiences ISG 6 Allowance for Open Items List and ISG 6 Allowance for Open Items List and Public Phone Calls NRC Open Items emailed, public calls held to NRC Open Items emailed, public calls held to discuss items, Open Items contained in NRC teleconference summary letter Allowed efficient resolution of questions Use of Open Items list Li it R t f Additi l I f ti th t i
Limits Requests for Additional Information that require docket responses Allows NRC feedback on responses during calls 9
ISG-06 Positive Experiences Use of Internet Sharepoint Website for Use of Internet Sharepoint Website for Documents Allowed documents to be viewed by NRC staff Allowed documents to be viewed by NRC staff Facilitated efficient response to questions Limited the number of documents and information that needed to be submitted 10 10
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 11
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
12 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 13
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 14
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 15
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 16 16 approved in timely manner
ISG 6 Pilot Application Project Scope Project Scope 17 17
ISG 6 Pilot Application Process Protection System Replacement A
hit t
Architecture 18 18