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COL Docs - Updated PMS SR LAR Pre-Submittal Presentation for October 4th Technical Exchange Meeting - Public Version
	ML18276A287
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1 Vogtle PEmails From:

Hoellman, Jordan Sent:

Wednesday, October 3, 2018 2:03 PM To:

Vogtle PEmails

Subject:

Updated PMS SR LAR Pre-Submittal Presentation for October 4th Technical Exchange Meeting - PUBLIC VERSION Attachments:

Pages from ND-18-1266_Public File_Updated.pdf For use during the public meeting on Thursday, October 4, 2018, please see the attached updated pre-submittal presentation for PMS SR LAR.

Jordan Hoellman Project Manager NRO / DLSE / LB4 U.S. Nuclear Regulatory Commission office: OWFN 08-C18 phone: (301) 415-5481 email: Jordan.Hoellman2@nrc.gov From: Sparkman, Wesley A. [1]

Sent: Wednesday, October 03, 2018 1:59 PM To: Patel, Chandu <Chandu.Patel@nrc.gov>; Hoellman, Jordan <Jordan.Hoellman2@nrc.gov>; Tjader, Theodore

<Theodore.Tjader@nrc.gov>; Zhao, Jack <Jack.Zhao@nrc.gov>; Agee, Stephanie Y. <SYAGEE@southernco.com>; Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Subject:

[External_Sender] Updated Draft PMS SR LAR Technical Exchange Meeting Presentation for October 4th Technical Exchange Meeting - PUBLIC VERSION Chandu / Jordan, In reviewing the slides that I sent earlier, we identified that a slide was included that no longer reflects our intent for the LAR. Please use this file for the public meeting instead. Here is the updated public version of the presentation for Thursday.

Thanks, Wes.

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Updated PMS SR LAR Pre-Submittal Presentation for October 4th Technical Exchange Meeting - PUBLIC VERSION Sent Date:

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PMS TS Surveillance LAR Technical Exchange Meeting October 4, 2018 APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 2

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

SVP_SV0_005298 September 27, 2018 Page 2 of 48 ND-18-1266

Meeting Purpose Discuss the proposed changes to the VEGP 3&4 PMS TS surveillance requirements (SRs)

Discuss the regulatory impact Discuss the Westinghouse methodology evaluating each SR type Discuss preliminary analysis results of application of methodology Receive and address Staff feedback APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 3

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Agenda

Background

LAR Purpose Statement Current and proposed licensing basis Regulatory discussion Technical discussion Summary APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 4

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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=

Background===

VEGP Units 3 & 4 instrumentation Technical Specifications (TS) based on Standard TS for analog protection systems PMS uses the Westinghouse Common Q platform which is a digital platform Westinghouse Common Q NRC-generically approved WCAP-16097-P-A SER describes the Common Q diagnostic features a,c APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 5

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Background (contd)

Fully leveraging the continuous, self-diagnostic testing features of the PMS digital protection system to reduce the scope/frequency of manual TS surveillance testing would:

Increase safety by lowering operational risk associated with human performance errors Reduce the duration of how long the PMS is at less than full redundancy Reduce resources necessary to perform surveillances, and Save substantial operational costs and still meet regulation APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 6

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Background (contd)

VEGP 3&4 intends to submit a LAR to revise/eliminate select PMS TS SR manual testing by crediting digital platform self-diagnostic features Westinghouse performing analysis to evaluate whether the PMS self-diagnostics can replace the current surveillance tests In all cases, the self-diagnostics provide continuous coverage APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 7

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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LAR Purpose Statement Current PMS TS SRs were not designed for a digital protection system Self-diagnostic capabilities of a digital protection system provide sufficient testing to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met This allows for elimination and/or reduction of select manual VEGP TS PMS SRs APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 8

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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CURRENT LICENSING BASIS APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 9

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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a,c APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 10

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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a,c APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 11

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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PROPOSED LICENSING BASIS APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 12

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Credit PMS Self-diagnosis Crediting continuous self-diagnostic features allow elimination of most of the PMS manual surveillance testing required for TS compliance:

Elimination of Channel Check Elimination of Channel Operational Tests (COTs)

Elimination of Actuation Logic Test (ALT)

Elimination of scope of Response Time Test for PMS Cabinets APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 13

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Regulatory Discussion Regulations, regulatory guidance, and industry standards related to periodic surveillance testing:

10 CFR 50.36(c)(3) 10 CFR 50.55a(h)

IEEE 603 / IEEE 7-4.3.2 IEEE 338 BTP 7-17 APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 15

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Regulatory Discussion (contd) 10 CFR 50.36(c)(3)

Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

Continuous self-diagnostic features provide 10 CFR 50.36(c)(3) assurance This allows elimination of select manual surveillance testing required for technical specification compliance APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 16

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Regulatory Discussion (contd)

10 CFR 50.55a(h) - requires meeting the requirements of IEEE 603-1991

IEEE 603-1991, IEEE Standard Criteria for Safety Systems for Nuclear Power Generating Stations, Clause 5.7, Capability for Test and Calibration Capability for testing and calibration of safety system equipment shall be provided while retaining the capability of the safety systems to accomplish their safety functions. The capability for testing and calibration of safety system equipment shall be provided during power operation and shall duplicate, as closely as practicable, performance of the safety function. Testing of Class 1E systems shall be in accordance with the requirements of IEEE Std 338-1987 [3]. Exceptions to testing and calibration during power operation are allowed where this capability cannot be provided without adversely affecting the safety or operability of the generating station. In this case:

(1) appropriate justification shall be provided (for example, demonstration that no practical design exists),

(2) acceptable reliability of equipment operation shall be otherwise demonstrated, and (3) the capability shall be provided while the generating station is shut down.

The proposed TS revisions will continue to meet Clause 5.7 APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 17

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Regulatory Discussion (contd)

IEEE 7-4.3.2-2016, IEEE Standard Criteria for Programmable Digital Devices in Safety Systems of Nuclear Power Generating Stations, Clause 5.7, Capability for Test and Calibration The measurement and test equipment (M&TE) used for safety systems shall not adversely affect the safety system functionality. Safety system functionality includes the entire safety system functionality and is not limited to the channel or division under test.

Self-diagnostic features operation do not adversely affect safety system functionality Note: IEEE 7-4.3.2-2003 does not have any additional criteria from 603 on Capability for test and calibration APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 18

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Regulatory Discussion (contd)

RG 1.118 Rev. 3 endorses IEEE 338-1987, IEEE Standard Criteria for Safety Systems for Nuclear Power Generating Stations. IEEE 338-1987 addresses periodic surveillance testing:

Surveillance testing definition, Periodic testing to verify that safety systems continue to function or are in a state of readiness to perform their safety function.

IEEE 338 Section 6.3 specifies the following types of surveillance tests: 1) channel checks, 2) functional tests, 3) channel calibration tests, 4) response time verification tests, and 5) logic system functional tests.

The proposed TS revisions will continue to meet RG 1.118 APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 19

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Regulatory Discussion (contd)

IEEE 338-1987, IEEE Standard Criteria for Safety Systems for Nuclear Power Generating Stations, addresses response time testing:

Response time testing of all safety-related equipment is not required if, in lieu of response time testing, the response time of safety system equipment is verified by functional testing calibration checks or other tests, or both. This is acceptable if it can be demonstrated that changes in response time beyond acceptable limits are accompanied by changes in performance characteristics that are detectable during routine periodic tests.

The proposed TS revisions will continue to meet IEEE 338-1987 APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 20

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Regulatory Discussion (contd)

BTP 7-17, Guidance on Self-Test and Surveillance Test Provisions, states:

1. Introduction Surveillance testing taken together with automatic self-testing should provide a mechanism for detecting all detectable failures.

and

3. Acceptance Criteria Self-test functions should be verified during periodic functional tests.

If automatic test features are credited with performing surveillance test functions, provisions should be made to confirm the execution of the automatic tests during plant operation. The capability to periodically test and calibrate the automatic test equipment should also be provided. The balance of surveillance and test functions that are not performed by the automatic test feature should be performed manually to meet the intent of Regulatory Guide 1.118.

APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 21

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Regulatory Discussion (BTP 7-17 contd) a,c APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 22

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Regulatory Conclusion Proposed TS surveillance test revisions continue to meet regulatory requirements and industry standards.

APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 23

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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TECHNICAL DISCUSSION APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 24

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Proposed PMS SR Testing PMS equipment functionality maintained by:

Remaining manual TS surveillance testing Continuously running, hardware and software self-diagnostic features APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 25

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Westinghouse Analyses Activities a,c APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 26

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Westinghouse Analyses Activities (contd) a,c APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 27

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Self-Diagnostic Overview There are two types of self-diagnostics:

Platform - which are the built-in error detection functions and self-diagnostics of the equipment as provided by the equipment manufacturer Application - which are the error detection functions provided by the application programs APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 28

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Channel Operational Test (COT) Analysis In Progress APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 29

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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COT Evaluation Approach COTs that are covered by self-diagnostics will be eliminated from TS.

Same approach is applicable to Actuation Logic Tests.

a,c APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 30

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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COT Equipment Scope a,c APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 31

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APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 32

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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PM646A Self-Diagnostic Table (example)

Excerpt of Table 1 provides a partial listing of the platform diagnostics for the PM646A The results are preliminary only to demonstrate Westinghouse evaluation methodology APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 33

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Westinghouse Proprietary A1-1 Processor Module PM646A Processing Section (PS) Diagnostic Table Table A-1 APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 34

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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FMEDA Evaluation of the PMS COT Scope (example)

Excerpt of table provides a partial Failure Modes, Effects, and Diagnostic Analysis (FMEDA)

The results are preliminary only to demonstrate Westinghouse evaluation methodology APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 35

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Westinghouse Proprietary C1-1 Table C-1 PM646A FMEDA APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 36

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Response Time Testing (RTT) Analysis In Progress APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 37

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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RTT Evaluation Approach Westinghouse evaluating WCAPs to determine applicability to AP1000

- WCAP-14036-P-A R1 Elimination of Periodic Protection Channel Response Time Tests

- NRC Approved RTT Elimination for Legacy PWRs APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 38

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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RTT Evaluation Approach (contd) a,c APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 39

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RTT Equipment Scope RTT equipment to be evaluated includes all equipment in actuation path from PMS input to PMS output (PMS Cabinets).

APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 40

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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a,c APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 41

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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a,c APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 42

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Preliminary Evaluation of the RTT Scope a,c APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 43

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Channel Check Analysis In Progress APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 44

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Channel Check Evaluation Approach a,c APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 45

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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a,c APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 46

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Conclusion Proposed VEGP 3&4 TS surveillance testing changes meet regulatory requirements and assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 47

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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Questions & Discussion APP-GW-GLY-163, Revision 0 Westinghouse Non-Proprietary Class 3 Page 48

- - This record was final approved on 9/27/2018 11:48:25 AM. (This statement was added by the PRIME system upon its validation)

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