ML20137X042
| ML20137X042 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee, Prairie Island  |
| Issue date: | 11/27/1985 |
| From: | Musolf D NORTHERN STATES POWER CO. |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8512100402 | |
| Download: ML20137X042 (9) | |
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Northem States Power Company 414 Nicollet Mall Minneapohs, Minnesota 55401 Telephone (612) 330-5500 i
November 27, 1985 Director Office of Nuclear Reactor Regulation U S Nuclear Regulatory Commission Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 Docket Nos. 5,0-305 License Nos. DPR-60 Request for Extensfon of Time for Completing NUREG-0737 Supplement No. 1 Requirements On June 14, 1984 the NRC issued an order confirming Northern States Power Company commitments to meeting the requirements of NUREG-0737 Supplement 1.
This order was revised on March 11, 1985. A review of our progress in completing the work required by the revised order indicates that, largely due to circumstances beyond our control, we will have difficulty in meeting portions of the specified schedule.
The purpose of this letter is to request an extension of time from the Director, Division of Licensing, for completing these items. The June 14, 1984 order permits such extensions if good cause is shown.
The following is a description of the NUREG-0737 Supplement 1 items covered by the June 14, 1984 order for which schedule relief is requested and the reasons why such relief should be granted:
Item 3b, Regulatory Guide 1.97 - Application to Emergency Response Facilities The June 14, 1984 order currently requires implementation of the requirements of Regulatory Guide 1.97, Revision 2, be completed in Unit No. I three months after return to power following the 1986 refueling (approximately July 23, 1986) and in Unit No. 2 three months after return to power following the 1985 refueling outage (February 2, 1986).
On September 15, 1983 we submitted a report describing how we would implement the requirerents of Regulatory Guide 1.97.
In a letter dated December 4, 1984 we were prvvided with the results of a review completed by EG&G Idaho, Incorporated under contract to the NRC.
In responding to this review on January 18, 1985 and June 6, 1985 we agreed to increase the scope of our planned r0 modifications in several areas.
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8512100402 851127 PDR ADOCK 05000282 PDR g
Dir, NRR November 27, 1985 Page 2 Northem States Power Company The time required for engineering, procurement, and construction during planned refueling outages of the expanded list of modifica-tions will require going beyond the original schedule.
Therefore, we are requesting that the date for completion of all Regulatory Guide 1.97 activities be extended to June 30, 1987 for both units.
This revised schedule will provide one additional refueling outage of each unit to complete the expanded Regulatory Guide 1.97 upgrade program.
In a separate, but related, matter we also seek NRC Staff concur-rence with a deviation to a modification previously agreed to and described in the NRC Safety Evaluation Report (SER) dated October 18, 1985 related to Regulatory Guide 1.97, Revision 2, conformance.
As described in Sections 3.3.19 and 3.3.20 of the SER, we originally planned to install new RHR heat exchanger inlet temperature instru-mentation to assist in monitoring the operation of the containment spray system and in monitoring containment sump water temperature.
A preliminary evaluation has found, however, that this modification would be very difficult to accomplish except during the next ten-year outage of each unit when the core is removed and RHR system operation is not required. We would be required to tap the RHR piping in order to install an RTD well. As an alternative, we now plan to install an environmentally qualified temperature detector on the lower containment wall directly above the RER recirculation sump. We believe that this will satisfy the Regulatory Guide and not change the substance of the Staff's findings in items 3.3.19 and 3.3.20 of the SER.
Item ib, Safety Parameter Display System The June 14, 1984 order currently requires the Safety Parameter Display System (SPDS) be completed in Unit No. I three months after return to power following the 1986 refueling (approximately July 23, 1986) and in Unit No. 2 three months after return to power following the 1985 refueling outage (February 2, 1986).
The computer software vendor selected to supply the computer system to Prairie Island has experienced significant delays in the development of a generic software package necessary to scan, process, and display the SPDS inputs.
This software package is essential to the operation of the new plant datt acquisition and computer system which supports the SPDS system for the Emergency Response Facilities (ERF).
Delays in development of this software has delayed the implementa-tion of the entire computer upgrade project for the plant resulting in delays in implementation of the SPDS function. provides details and a sequence of events of the steps and measures Northern States Power has taken to monitor and expedite the prcject to ensure SPDS implementation delays are minimized. As presented by the attachment the major problem J
Dir, NRR November 27, 1985 Page 3-Northem States Power Company experienced by the original software vendor was the lack of pro-gress.on the basic software package needed to support the applica-tions programs of which the SPDS function is a major portion.
Shortly after signing of the contract the vendor made an internal decision to develop a standard generic product to support scan logging and alarming for all of its projects instead of doing custom packages for each of its projects. The vendor underesti-mated the effort and complexity involved in implementing this decision.
By May of 1984 the vendor was unable to-produce this generic package. Their. management reorganized and restaffed the respon-sible department and the effort was restarted.
Restarting the project has resulted in a delay of the generic sof tware available to support the required NSP Computer Upgrade Project and imple-mentation of SPDS. Also due to uncertain estimating tools the schedules produced by the vendor for the generic software project were not realistic.
The following steps were initiated by NSP to monitor the performance of the vendor and provide support for published schedules:
An. increasing physical presence in the vendors facility to.
o review schedule progress and actual work progress.-
Intense discussions with vendors key management to empha-o size the importance of project progress.
Extensive technical support of the vendor to help define o
' project technical requirements and relaxation of the original technical specifications to accommodate the capability of the
-vendor.
o Use of an independent software consultant to review the technical progress of the vendor and validity of the published schedule.
Reduction in the initial scope of the Prairie Island Computer o
Upgrade Project to support only SPDS and Reg. Guide 1.97 requirements.
Late in 1984 and in June of 1985 NSP informed the NRC that the published schedule for SPDS may not be met (Reference 4 and 5 of ).
Due to continued schedule slippage and the missing of key milestones it became obvious in mid 1985 that the schedules in the NRC Order (Reference'3 and 6) would not be met for SPDS.
In order to gain control of the implementation schedule the capabilities of alternate vendors were explored. Vendors that have cprovided scan log alarm software on operational systems similar to the hardware NSP has purchased have been found. Due to continued schedule problems with the original vendor and the belief that viable alternate' vendors are available a decision was made to terminate the contract with the original vendor and begin detailed discussions with alternate vendors.
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Dir, NRR November 27, 1985 Pcge 3 p
experienced by the original software vendor was the lack of pro-gress on the basic softnare package needed to support the applica-1 tions programs of which the SPDS function is a major portion.
Shortly after signing of the contract the vendor made an internal decision to develop a standard generic product to support scan logging and alarming for all of its projects instead of doing custom packages for each of its projects. 11e vendor underesti-mated the effort and complexity involved in implementing this decision.
By May of 1984 the vendor was unable to produce this generic package. Their management reorganized and restaffed the respon-sible department and the effort was restarted. Restarting the project has resulted in a delay of the generic software available to support the required NSP Computer Upgrade Project and imple-mentation of SPDS. Also due to uncertain estimating tools the schedules produced by the vendor for the generic software project were not realistic.
j The following steps were initiated by NSP to monitor the performance of the vendor and provide support for published schedules:
An increasing physical presence in the vendors facility to o
review schedule progress and actual work progress.
Intense discussions with vendors key management to empha-4 o
size the importance of project progress.
Extensive technical support of the vendor to help define L-o project technical requirements and relaxation of the original technical specifications to accommodate the capability of the vendor.
o Use of an independent software consultant to review the technical progress of the vendor and validity of the published schedule.
' Reduction in the initial scope of the Prairie Island Computer o
i Upgrade Project to support only SPDS and Reg. Guide 1.97 requirements.
Late in 1984 and-in June of 1985 NSP informed the NRC that the published schedule for SPDS may not be met (Reference 4 and 5 of
' Attachment 2).
Due to continued schedule slippage and the missing of key milestones it became obvious in mid 1985 that the schedules in the NRC Order (Reference 3 and 6) would not be met for SPDS.
In order to gain control of the implementation schedule the capabilities of alternate vendors care explored. Vendors that have provided scan log alarm software on operational systems similar to the hardware NSP has purchased hcve been found. Due to continued schedule problems with the original vendor and the belief that viable alternate vendors are available a decision was made to terminate the contract with the original vendor and begin detailed discussions with alternate vendors.
Dir, NRR November 27, 1985 Page 4 Northem States Power Company From preliminary discussions with alternate vendors we believe implementation of the SPDS requirement can be achieved by the end of 1986.
Therefore, we are requesting that our confirmatory date for completion of the SPDS requirement (Item lb of Reference 3 and
- 6) be extended to December 31, 1986 for both units.
To support the request for extension a brief review of the ERF technical information status is provided.
Emergency exercises have proven that the facilities are well equipped for presentation of technical information. Delays in implementation of the SPDS function will not result in any significant exposure to reduced information availability for control room personnel or emergency response personnel.
o CONTROL ROOM The control room has available a terminal from the Radiation Dose Assessment Computer. This terminal displays parameters involved with radiation releases and meteorological data. Also the Control Room Design Review project has completed their detailed review of the Control Room.
Recommended changes to the reactor control por-tions of the control board which will enhance the presentation of primary system information to the operators have been implemented on both units.
' Westinghouse Owners Group Emergency Procedure Guidelines have been fully implemented at Prairie Island since April, 1984.
The new procedures contain the Critical Function Status Trees in the same format as will be presented in the SPDS primary display.
The Shift i
Technical Advisors have been trained in the use of the status trees 1
and all of the informational needs required for performance of the
/
trees is currently available in the control room. These human engi-neered and technical expanded procedures provide the control room operators and support personnel with enhanced capabilities for identi-fying and responding to off normal events.
I o TECHNICAL SUPPORT CENTER The TSC has available a terminal from the Radiation Dose Assess-ment Computer.
For performance of TSC functions, plant data (both hist.orical and real time), is available via a B&W Recall data acquisition display system and the present plant computer engi-neer's console.
o EMERGENCY OPERATIONS FACILITY The EOF has available a terminal from the Radiation Dose Assess-ment Computer. Also, data essential for performance of EOF functions is available via telephone communications with the TSC and displayed manually on a status board.
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Dir, NRR November 27, 1985 Page 5 Northem States Power Company The Safety Analysis Report submitted on April 10, 1984 deceribed the proposed design and presented the parameters selected for monitoring and display on the safety parameter display system.
On July 15, 1985 the NRC sent us a Safety Evaluation Report con-cluding that the design and parameter selection were acceptable and their evaluation of SPDS was complete except for a post implementation review.
For our interim system we are committed to not changing the intent of the system as described in our Safety Analysis Report and approved in the Safety Evaluation Report.
Since some portions of software is vendor specified we may encounter some enanges in our approved design. We will provide details of any differences and justification that these changes do not change the intent of our approved design and the conclusions of the NRC-SER.
We also want to point out an item needing possible clarification.
Part II in the NRC Staff SPDS Safety Evaluation Report (Reference
- 7) stated that "the construction of the fiber optic cable is such that the cable contains no electrically conductive mat'erial.
This
, statement is correct for fiber cables, but if more then one fiber cable is in a bundle it is common design to include a metallic wire leader in the bundle. This leader is used as an additional support means for the bundle and also used for cable pulling.
The attached drawing (Attachment 3) shows the termination details of the wire leader.
This type of termination provides a minimum of four feet of fiber cable (without leader) between the leader and the multiplexer outputs. Wa believe this is acceptable to the NRC Staff.
Based on the information and justification contained in this letter and its attachments NSP is requesting schedule extensions as detailed in this letter to Items 3b and Ib contained in Order dated June 14, 1984 (as revised on March 11, 1985 reference 3 and 6).
Please contact us if you have any questions relating to our request.
DJ bA,e David Musolf Manager - Nuclear Support Services c: Regional Administrator-III, NRC NRR Project Manager, NRC Resident Inspector, NRC G Charnoff Attachmenta
ATTACHMENT 1 NORTHERN STATES POWER CO.
PRAIRIE ISLAND NUCLEAR GENERATING PLANT COMPUTER UPGRADE PROJECT SEQUENCE Date Discussion of Event 1980 NSP joins other Westinghouse Owners to develop a Safety Assessment System (SAS).
1981 NSP initiates work to develop a specification for a replacement plant computer system and plant wide data acquisition system that will support the SPDS requirements.
April 1983 Contract signed with initial vendor for delivery of the Computer System in January of 1985.
November 1983 Computer vendor contract is negotiated for delivery in May of 1985. Delay is claimed by vendor to be the results of scope changes and late design input information..
February 1984 NSP becomes aware that the generic Scan-Log-Alarm package is not available in a useable form to support the project.
March 1984 NSP places a resident engineer in vendors facility to become familiar with projects.
May'1984 Vendor reorganizes the internal project to de-velop the scan log and alarm package and starts over on development.
September 1984 NSP starts twice a month reviews of vendors progress at vendors office.
November 1984-Vendor replaces project management and key per-sonnel on the NSP project and starts over on project definition and-schedule.
January 1985 Vendor presents new schedule for generic scan-log alarm package and preliminary revised NSP specific project schedule.
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i February 1985 Vendor delivers a preliminary version of generic software package to another customer.
This package is not compatible with the hSP project hardware.
March 1985 Vendor reorganizes executive level management -
Company president takes control of division producing generic software package.
June 1985 NSP hires a independent software consultant to review the technical progress and organization of the generic sof tware project.
July 1985 The Scan-Log alarm generic software project misses a key milestone date in the schedule.
July 1985 NSP reduces the scope of the Computer Upgrade Project to only support the SPDS and certain Reg. Guide 1.97 requirements to allow schedule imptovements.
July 1985 NSP starts a industry review to identify alter-nate vendors.
September 1985 Vendor misses a significant milestone in the generic software schedule.
September 1985 NSP cancels contract with vendor and starts to remove hardware.
November 1985 Detailed technical and contractual negotiations are taking place with alternate vendors.
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ATTACHMENT 2 REFERENCES 1.
NSP Letter to NRR April 15, 1983, Supplement I to NUREG-0737 -
Response to Generic Letter 82-33 2.
NSP Letter to NRR dated March 30, 1984, Schedular Commitments for Meeting Requirements of Supplement 1 to NUREG-0737 -
Response to Generic Letter 82-33 3.
NRC Letter to NSP dated June 14, 1984, Order Confirming Licensee Commitments on Emergency Response Capability Sche-dules (Generic Letter 82-33) 4.
NSP Letter to NRR dated November 29, 1984, Request for Detailed Control Room Design Review Summary Report and SPDS Implementation Schedule Update 5.
NSP Letter to NRR dated June 26, 1985, SPDS Implementation Schedule Update 6.
NRC Letter to NSP dated March 11, 1985, Supplement I to NUREG-0737, Request for Modification of Commission Order dated June 14, 1984 7.
NRC Letter to NSP dated July 15, 1985, SPDS Safety Evaluation dated July 15, 1985.
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