ML19282A390
| ML19282A390 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/16/2019 |
| From: | Masters A NRC/NRR/DIRS/IRAB |
| To: | Victor Hall NRC/NRR/VPOB |
| Keefe-Forsyth M, NRR/DIRS, 301-415-5717 | |
| References | |
| Download: ML19282A390 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 16, 2019 MEMORANDUM TO:
Victor E. Hall, Chief Vogtle Project Office Office of Nuclear Reactor Regulation FROM:
Anthony D. Masters, Chief /RA/
ROP Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
SAFETY EVALUATION INPUT REGARDING VOGTLE UNITS 3 AND 4, PROTECTION AND SAFETY MONITORING SYSTEM SURVEILLANCE REQUIREMENT REDUCTION TECHNICAL SPECIFICATION REVIEW By letter dated March 25, 2019, the Nuclear Regulatory Commission (NRC) Agencywide Documents Access and Management System (ADAMS) Accession number: ML19084A310 Southern Nuclear Operating Company, the utility for Vogtle Electric Generating Plant Units 3 and 4, requested the NRC approval of their application to remove technical specifications surveillance requirements requiring manual channel checks, channel operational tests, actuation logic tests and actuation logic output tests to be performed on a Protection and Safety Monitoring (PMS) systems components.
Based on the staffs review of the licensees March 25, 2019, submittal, the IRAB staff has enclosed its draft safety evaluation input.
Docket No.: 52-025 and 52-026
Enclosure:
Human Factors Safety Evaluation CONTACT: Molly Keefe-Forsyth, NRR/DRO 301-415-5717
ML19282A390 Office NRR/DIRS/IRAB NRR/DIRS/IRAB Name MKeefe-Forsyth AMasters Date 10/9/19 10/15/19 Enclosure SAFETY EVALUATION INPUT FOR LAR-19-001, PROTECTION AND SAFETY MONITORING SYSTEM SURVEILLANCE REQUIREMENT REDUCTION TECHNICAL SPECIFICATION REVISION
1.0 BACKGROUND
By letter dated March 25, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML19084A309), Southern Nuclear Operating Company (SNC, the licensee) requested an amendment to combined licenses (COLs) numbered NPF-91 and NPF-92, for Vogtle Electric Generating Plant (VEGP) Units 3 and 4, respectively.
In this license amendment request (LAR)19-001, the licensee proposes: 1) to credit the continuous self-diagnostic testing features of the digital components of the Protection and Safety Monitoring System (PMS), which implements the instrumentation and actuation logic functions of the reactor trip system (RTS) and the engineered safety feature actuation system (ESFAS), as part of the Technical Specification (TS) Surveillance Requirements (SRs). If the LAR is approved, it would eliminate several of the manual surveillance tests currently required per the TSs since the automated self-diagnostic tests would serve as their replacements; 2) that trip setpoints be automatically verified by self-diagnostic testing features in lieu of TS SRs, which requires a manual Channel Operational Test to verify trip setpoints; and 3) to change the approach for satisfying the surveillance requirements for the RTS and ESFAS response time tests.
Therefore, the licensee proposes corresponding changes to the plant-specific Tier 2 information in UFSAR Appendix 1A, Appendix 7A.5, Appendix 7A.8, and UFSAR Sections 7.3.2.2.6 and 15.0.6. The licensee does not propose any change to the PMS software and hardware in the LAR. The licensee also proposes associated changes to COL Appendix A, which consists of the plant-specific TS. Specifically, the licensee proposes to change plant-specific TS Sections 1.0, 3.1, 3.2, 3.3, 3.9, and 5.5 by removing plant-specific TS SRs for manually performing Channel Checks, Channel Operational Tests (COTs), Actuation Logic Tests (ALTs) and Actuation Logic Output Tests (ALOTs) of the digital components of the RTS and ESFAS functions of the PMS.
2.0 REGULATORY EVALUATION
The regulatory requirements and guidance which the Nuclear Regulatory Commission (NRC) staff considered in its review of the LAR are as follows:
2.1 Appendix A to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, General Design Criteria (GDC), Criterion 19 - Control room. A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents Equipment at appropriate locations outside the control room shall be provided (1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) with a potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures.
2 2.2 10 CFR 50.120, Training and qualification of nuclear power plant personnel; 2.3 NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition:
- Chapter 13 addresses Conduct of Operation, specific sub-chapters considered in this review were Chapters 13.2.1, Reactor Operator Requalification Program; Reactor Operator Training, Rev. 3, and 13.5.2.1, Operating and Emergency Operating Procedures Rev. 2.
- Chapter 18, Rev.2, provides review guidance for Human Factors Engineering.
2.4 NUREG-1764,"Guidance for the Review of Changes to Human Actions;"
Revision 1; 2.5 GL 82-33, "Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capability";
2.6 NUREG-0700, Human-System Interface Design Review Guidelines Revision 2; 2.7 NUREG-0711, "Human Factors Engineering Program Review Model," Revision 2;
2.8 IN 97-78, "Crediting Operator Actions in Place of Automatic Actions and Modifications of Operator Actions, Including Response Times";
3.0 TECHNICAL EVALUATION
Procedure Design and Operator Training The elimination of manual surveillances reduces overall operator tasks and workload during normal operations, plant startup, shutdown, and outages. There are minor impacts on plant operating procedures that will require future revision (after approval of the license amendment request) due to this change.
The operator response to self-diagnostics alarms does not change operator workload because there is no proposed change to any alarms or Human System Interfaces (HSI). No new alarms are proposed. The existing validated operating procedures and training include the response to the PMS fault alarms.
The impacts to the operating procedures, training, and previously completed human factors engineering (HFE) verification and validation (V&V) activities (i.e., Design Verification, Task Analysis, Integrated System Validation, and Human Engineering Discrepancy Resolution) will be evaluated per Combined Operating License (COL) Appendix C ITAAC No. 3.2.00.01e.
This Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) requires an evaluation of the implementation of the plant HFE/HSI (as designed at the time of plant startup) to be performed in accordance with APP-OCS-GEH-520, Plant Startup Human Factors Engineering Design Verification Plan, which is a Tier 2* document that is incorporated by reference into the plant-specific Design Control Document (DCD).
3 IRAB reviewed alarm response procedures and has determined that there is reasonable assurance the operators will respond appropriately to any alarms through the written procedures and the associated training. In addition, the impacts of the operating procedures, training, and previously completed HFE V&V activities will be evaluated per ITAAC 3.200.01e.
The Staff concluded that the operators are able to detect a critical system failure of the automatic PMS system and respond with appropriate manual actions.