ML21159A189

Non-Proprietary - FPL NRC Presubmittal Meeting June 9th Closed Slides

ML21159A189
Person / Time
Site:	Turkey Point
Issue date:	06/09/2021
From:	Moul D Florida Power & Light Co
To:	Ellen Brown Plant Licensing Branch II
Brown E
Shared Package
ML21159A162	List: ML21159A171 ML21159A189
References
L-2021-LRM-0007
Download: ML21159A189 (38)

Text

Turkey Point Unit 3 and Unit 4 Reactor Protection System Engineered Safety Feature Actuation System Nuclear Instrumentation System Replacements Safety System Replacement Project LAR NRC 5th Pre-submittal Meeting Telecon June 9th ,2021 CLOSED MEETING 1 Non-proprietary information suitable for public disclosure

FRAMATOME INC. PROPRIETARY Proprietary information statement has been removed in this redacted file.

2

Agenda - Closed Portion

• RPS/ESFAS/NIS LAR Outline/Attachments and Discussion on Commitments

• D3 Overview of Progress to Completion

• Technical Specification Surveillance Extension/Reduction

• Project Lifecycle Schedule

• Action Items/Follow-up 3 Non-proprietary information suitable for public disclosure

RPS/ESFAS/LAR Updated Table of Contents Following the ISG-06, Rev 2 AR Process RPS/ESFAS/NIS LAR Table of Contents

• Intro/Justification/Safety Analysis

• Detailed Description

• Technical Evaluation

- Existing Plant System Description (ISG-06 D1)

- Existing and New Architecture (ISG-06 D2)

- New Safety System Equipment

- New System Functions (ISG-06 D2.3)

- Functional Allocation (ISG-06 D2.4)

- New Augmented Quality System Functions

- System Interfaces (ISG-06 D2.5)

- Defense-In-Depth and Diversity (D2.6)

- Setpoint Methodology and Calculations (D2.7)

- Response Time Performance 4 Non-proprietary information suitable for public disclosure

RPS/ESFAS/LAR Updated Table of Contents Following the ISG-06, Rev 2 AR Process RPS/ESFAS/NIS LAR Table of Contents (Cont.)

• Technical Evaluation (Cont.)

- Summary System Development Process (D.4)

- Equipment Qualification (D.3)

- Applying a Referenced Topical Report (D.5)

- Tricon Plant Specific Action Items (D.5)

- Human Factors Engineering (B.1.4)

- Tests and Self Diagnostics

- System Failure Analysis

- Fundamental Design Principles in the new Architecture

- Compliance with IEEE Std. 603-1991 and IEEE 7-4.3.2-2003 (D.6)

- NRC ISG-04 Compliance Matrix

- Reliability

- Secure Development and Operational Environment (D.8) 5 Non-proprietary information suitable for public disclosure

RPS/ESFAS/LAR Updated Table of Contents Following the ISG-06, Rev 2 AR Process RPS/ESFAS/NIS LAR Table of Contents (Cont.)

• Technical Evaluation (Cont.)

- Summary of Vendor Oversight Plan (C2.2)

- Technical Specification Surveillance Reduction (a non ISG-06 item)

• Regulatory Evaluation Basis Turkey Point is a pre-IEEE 279-1971 plant and plans on maintaining its existing licensing basis. The new RPS\ESFAS\NIS system will be designed to more current RGs and Industry standards. There are too many to list, but key ones for discussion and feedback:

- Key Regulatory Basis documents addressed in LAR RG 1.153 and IEEE 601-1991 RG 1.152, Rev 3 and IEEE 7-4.3.2-2003 Qualification - IEEE 323-1974, IEEE 344-1987, and RG 1.180, Rev 1

- Key NRC Review Guidance ISG-04 and ISG-06, Rev 2 NUREG 0800, BTP 7-19, Rev 8, and 7-17, Rev 6 6 Non-proprietary information suitable for public disclosure

RPS/ESFAS/LAR Updated Table of Contents Following the ISG-06, Rev 2 AR Process RPS/ESFAS/NIS LAR Table of Contents (Cont.)

• ATTACHMENTS (Available thru Electronic Reading Room)

- Markup Technical Specification Pages

- Markup Technical Specification Bases (Information Only)

- Qualification Summary Reports

- Defense-In-Depth and Diversity Analysis (D3)

- HFE Program Plan

- RPS/ESFAS/NIS SyRS

- Technical Specification Surveillance Reduction Report

- Framatome Affidavit in support of Attachments

- Listing of Regulatory Commitments 7 Non-proprietary information suitable for public disclosure

PS/ESFAS/NIS LAR - Commitments Discussion

• FPL does not anticipate any new Commitments.

• Implementation Items discussion 8 Non-proprietary information suitable for public disclosure

Plant Specific Action Items (PSAIs)

• The Turkey Point LAR will address the 19 Tricon PSAIs following DI&C-ISG-06, Rev. 2, Section D.5.1.2, Resolution of Topical Report Plant-Specific Action Items states

- Based on a topical report review in accordance with SRP BTP 7-14, some topical reports include plant-specific items stating that the NRC staff should review detailed design, implementation, testing and ongoing life cycle activities. For the Alternate Review Process, the licensee will provide oversight of the performance of these activities, in accordance with the licensees QA program and Vendor Oversight Plan.

- 15 of the 19 Plant Specific Action Items were addressed for Turkey Point specifically as regards the validation of completion, in a similar manner that was done for Diablo Canyon, but specific to Turkey Point 3&4. The following four (4) PSAIs, not previously addressed for Diablo Canyon due to its specific application, will be addressed for Turkey Point:

9 Non-proprietary information suitable for public disclosure

Plant Specific Action Items (Turkey Point Specific)

• Tricon V10 PSAI 8 (Section 3.4.3, Diagnostic and Test Capabilities, of the Tricon V10 SE): The Turkey Point 3&4 LAR will provide the engineering basis for crediting the diagnostic and self-test capabilities of the Tricon for review by NRC and inclusion in the SER.

• Tricon V10 PSAI 12 (Section 3.7.3.2, DI&C-ISG-04, Staff Position 2 - Command Prioritization, of the Tricon V10 SE):

The Turkey Point 3&4 LAR will include the design of field device interface and the determination of means for command prioritization because the relay logic replacement scope is included in the LAR for NRC review.

10 Non-proprietary information suitable for public disclosure

Plant Specific Action Items (Turkey Point Specific)

• Tricon V10 PSAI 13 (Section 3.7.3.3, DI&C-ISG-04, Section 3 -

Multidivisional Control and Display Stations, of the Tricon V10 SE). The Turkey Point 3&4 LAR will address the role of information displays and operator work stations for the determination of information sources and interconnections.

This information will be included in the LAR; [

]

• Tricon V10 PSAI 18 (Section 3.7.1, Tricon-Based PPS Equipment Communications, of the Tricon V10 SE). The Turkey Point 3&4 LAR will include a description of the application-specific communication and functions for the SVDU including any testing and verification of the session announcement protocol library for control room interface.

11 Non-proprietary information suitable for public disclosure

Overview of RPS/ESFAS/NIS Architecture (Scope of Replacement) 12 Non-proprietary information suitable for public disclosure

RPS/ESFAS/NIS D3 Update Since Our Last Presentation on February 18, 2021 13 Non-proprietary information suitable for public disclosure

ATWS Requirement 14 Non-proprietary information suitable for public disclosure

Key D3 Assumptions 15 Non-proprietary information suitable for public disclosure

D3 Assumptions (Continued) 16 Non-proprietary information suitable for public disclosure

D3 Evaluation Process-Step 1 17 Non-proprietary information suitable for public disclosure

Platform Diversity -Step 2 18 Non-proprietary information suitable for public disclosure

D3 Block Selection Process-Step 3 19 Non-proprietary information suitable for public disclosure

D3 Evaluation Process-Step 4 20 Non-proprietary information suitable for public disclosure

D3 Validation Process after Initial Development of the D3 Report -- March - May, 2021

• Project Team retained Zachry Nuclear Engineering to perform

[ ] quantitative analyses and [ ] detailed qualitative analyses to address verification of bounding analyses based on final selected automatic actuations.

• Validation completed May 24, 2021

• Analyses included:

21 Non-proprietary information suitable for public disclosure

DAS 22 Non-proprietary information suitable for public disclosure

DAS automatic actuations-Step 5 Validated Results included in Final D3 Report 23 Non-proprietary information suitable for public disclosure

D3 Conclusions

• Turkey Point I&C upgrade architecture is designed with a high level of Quality, Diversity and Defense-In-Depth

• The I&C Diversity and Defense-in-Depth qualitative methodology conforms with regulatory guidance and meets criteria with the addition of certain DAS functions 24 Non-proprietary information suitable for public disclosure

Tech Spec Surveillance Test Extension/Reduction For RPS/ESFAS/NIS LAR - Re-review Turkey Points Plan forward for Surveillance Reduction

• Continue to utilize the NEI 04-10 surveillance frequency control program to extend SR frequencies (not a part of this LAR).

• FPL Upgrade Project is working in conjunction with the Turkey Point ITS project to ensure proper integration and implementation efficiency both internal and with the staff.

25 Non-proprietary information suitable for public disclosure

Tech Spec Surveillance Test Extension/Reduction For RPS/ESFAS/NIS LAR - Implementation Key Areas for Implementation

• Use of Triconex Approved Topical Report, 7286-545-1-A, Revision 4: Nuclear Qualification of Tricon V10 Triple Modular Redundant (TMR) PLC System, dated May 15, 2012, including U.S. Nuclear Regulatory Commission Safety Evaluation Report dated April 12, 2012 (ML120900889)).

• LAR will address as plant-specific application-dependent issues as required by the NRC SER along with proposed Tech Spec changes and supporting documentation.

• [

]

26 Non-proprietary information suitable for public disclosure

Tech Spec Surveillance Test Extension/Reduction For RPS/ESFAS/NIS LAR - Channel Check 27 Non-proprietary information suitable for public disclosure

Tech Spec Surveillance Test Extension/Reduction For RPS/ESFAS/NIS LAR - Channel Check 28 Non-proprietary information suitable for public disclosure

Tech Spec Surveillance Test Extension/Reduction For RPS/ESFAS/NIS LAR - COTs and ALTs Reduction 29 Non-proprietary information suitable for public disclosure

Tech Spec Surveillance Test Extension/Reduction For RPS/ESFAS/NIS LAR - Surveillance Reduction Analysis 30 Non-proprietary information suitable for public disclosure

Tech Spec Surveillance Test Extension/Reduction For RPS/ESFAS/NIS LAR - System Level FMEA 31 Non-proprietary information suitable for public disclosure

Project LAR and Lifecycle Schedule

• LAR Submittal target is September, 2021

• Design Phase

- June thought November 2021

• Equipment Qualification Schedule

- July 2021 through February 2022

• Implementation Phase

- September through April 2022

• Factory Acceptant Testing

- May through October 2022

• Human Factor Engineering (HFE)

- April 2021 thru October 2022 32 Non-proprietary information suitable for public disclosure

Action Items/Follow-Up

• Future Meeting Subjects

- Vendor Oversight Plan Update

- Cyber Security Scope

- Equipment Scope of Supply not covered by SER

- Project Life Cycle Schedule

- Remaining Open Issues 33 Non-proprietary information suitable for public disclosure

Questions?

34 Non-proprietary information suitable for public disclosure

Acronym List Actuation Logic Test ALT ATWS Mitigation System Actuation Circuitry AMSAC Alternate Review AR Anticipated Transient Without Scram ATWS Branch Technical Position BTP Channel Operational Test COT Diverse Actuation System DAS Digital Instrumentation and Control DI&C Defense-in-Depth and Diversity D3 Engineered Safety Features Actuation System ESFAS Failure Modes and Effects Analysis FMEA Failure Modes and Effects Diagnostic Analysis FMEDA Florida Power and Light FPL Feedwater Isolation FWI Human Factors engineering HFE Instrumentation and Control I&C 35 Non-proprietary information suitable for public disclosure

Acronym List (continued)

Institute of Electrical and Electronic engineers IEEE Interim Staff Guidance ISG International Organization for Standardization ISO Improved Technical Specifications ITS License Amendment Request LAR Main Control Board MCB Main Control Room MCR Nuclear Energy Institute NEI Nuclear Instrumentation System NIS Nuclear Regulatory Commission NRC NRC Publication for Knowledge and Guidance NUREG Programmable Logic Computer PLC Postulated Initiating Event PIE Plant Specific Action Items PSAI Regulatory Guide RG Quality Assurance QA Qualified Display Processing System QDPS 36 Non-proprietary information suitable for public disclosure

Acronym List (continued)

Reactor Protection System RPS Self-Diagnostics SD Safety Evaluation Report SER Safety Injection SI Safety Related SR Safety Requirements Memoranda SRM Standard Review Plan SRP Steam Generator STGR System Requirements Specification SyRS Safety Visual Display Unit SVDU Software Common Cause Failure SWCCF Passive Actuation Device Test TADOT Triple Modular Redundant TMR Turkey Point TP Vendor Oversight Program VOP 37 Non-proprietary information suitable for public disclosure

Any reproduction, alteration, transmission to any third party or publication in whole or in part of this document and/or its content is prohibited unless Framatome has provided its prior and written consent.

This document and any information it contains shall not be used for any other purpose than the one for which they were provided. Legal action may be taken against any infringer and/or any person breaching the aforementioned obligations 38