ML21175A173

Digital Modernization Project LAR Pre-submittal Meeting

ML21175A173
Person / Time
Site:	Limerick
Issue date:	06/29/2021
From:	Exelon Generation Co, Exelon Nuclear
To:	Division of Operating Reactor Licensing
Marshall M
References
Download: ML21175A173 (19)

Text

Limerick Generating Station Digital Modernization Project LAR Pre-submittal Meeting NRC Pre-submittal Meeting June 29, 2021

Agenda / Opening Remarks Open / Public Session

• Introductions

• Project update

• Vendor Oversight Plan (VOP) update

• Project scope - LAR vs. 50.59

• HFE Evaluation Overview Closed Session

• Architecture

• Defense-in-Depth and Diversity (D3) Approach

• SECY 93-087 Position 4 Discussion

• Regulatory Guide 1.97 Discussion

• Software Design Process for RRCS & DPS

• Next pre-submittal meeting topics

• NRC & Exelon Closing Remarks 1

Introductions - Exelon Project Team

• Licensing

• Dave Helker, Licensing Manager

• Frank Mascitelli, Licensing Lead

• Laura Lynch, LGS Regulatory Assurance Manager

• George Budock, LGS Regulatory Assurance

• Pareez Golub, Digital Licensing SME

• Engineering

• John Connelly, Central Design Organization (CDO) Manager

• Mark Samselski, CDO - Lead Responsible Engineer

• George Bonanni, CDO - Senior Staff Engineer

• Mike Foote, CDO - Senior Staff Engineer

• Scott Schumacher, Systems Engineering 2

Introductions - Exelon Project Team

• Project Management

• Steve Hesse, Project Director

• Dave Molteni, Senior Manager and Station Lead

• Jerry Segner, Principal Project Manager

• Kayla Marriner, Project Manager

• Operations

• Paul Krueger, Operations

• Craig Myers, Operations Support

• Nuclear Oversight

• Dave Peiffer, Performance and Assessment Lead 3

Introductions - Westinghouse Project Team

• Project Management

• Chris Crefeld, Project Director

• Stefan Levine, Senior Manager

• Dominic Mocello, Project Manager

• Tom Pietryka, Program Manager

• Engineering

• Terry Tuite, PPS Lead - Engineering

• Dan Zenger, DCS Lead - Engineering

• Warren Odess-Gillett, Lead - Licensing

• Steve Seaman, System Integration Lead

• Cal Tang, BWR Technical Advisor 4

Project Update 5

Project Design/Licensing Timeline Design timeline Requirements Phase Design Phase Test Phase Complete Complete Complete December 2021 December 2022 December 2023 2021 2022 2023 2024 2025 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Submit LAR to NRC LAR Approval Installation Unit 1 Installation Unit 2 August 2022 August 2023 Q2 2024 Q2 2025 Licensing timeline 2 Timeline Supporting Alternate Review Process (ARP)

Licensing Review 6

Vendor Oversight Plan 7

VOP Scope The VOP is a critical part of the Project Quality Management Plan (QMP):

• Leverages existing Exelon Quality Assurance, Engineering, and Project Management processes for oversight of Westinghouse Common Q development

• Ensures high quality vendor products through QA program implementing procedures

• Includes NRC acceptance criteria provided to industry, adapted for project use (ML19087A230)

• Performs vendor observations as part of oversight activities

• Ensures vendor is complying with NRC approved Common Q Software Program Manual (WCAP-16096-P-A, Rev. 5)

• Validate PSAIs have been properly addressed 8

VOP Objectives The VOP establishes the overall approach - goals, priorities, performance metrics, and resource management strategies for vendor oversight.

Establishes Four Objectives:

1. Verify vendor activities are fulfilling the regulatory obligations by performing vendor inspections, with acceptance criteria, that verify the implementation of QA program &

activities are conducted in accordance with WEC SPM and Quality Management System .

2. Effectively communicate with all stakeholders by entering nonconformances in Exelon CAP and SFMS that describes vendor deviations from contract or requirements.

Engineering deliverables will be reviewed using Exelon Owners Acceptance Review Procedures.

3. Perform timely and adequate follow-up & closure by utilizing CAP to assign activities to owners for remediation of nonconformance and complete corrective action in a timely manner consistent with the VOP metrics.

4. Ensure the Exelon inspectors have the necessary knowledge and skills to successfully validate acceptance criteria by conducting inspections with qualified individuals and management oversight in accordance with Exelon process and procedures.

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VOP Scope

• The vendor oversight plan provides the activities to be completed at each phase of the vendors design life cycle.

• The VOP includes document sections for each life cycle phase (Concept, Requirements, Design, Implementation, & Test Phases).

• Each section of the VOP provides the activities to be performed, for example:

- Conducting Quality Surveillances of vendor activities under Licensee Quality Assurance (QA) program including activities for validating procurement criteria.

- Reviewing vendor design artifacts (e.g., specifications, drawings, analyses)

- Observing or witnessing specific vendor activities.

- Coordinating multi-disciplined interactions between various stakeholders.

- Communicating status, schedule, and results of oversight activities through periodic Licensee/Westinghouse Project Management team teleconferences,

- Capturing issues in Licensee/Westinghouse corrective action programs.

- Elevating emerging risks and issues (if necessary) to decision makers with higher authority.

- Updating the VOP (if necessary) based on emerging results.

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VOP Scope Exelon Quality Management Attributes Applicable to VOP:

• Leverages existing Exelon Quality Assurance, Engineering, and Project Management processes for oversight of Westinghouse Plant Protection System development.

• Ensures high quality vendor products through QA program implementing procedures.

-NO-AA-10, Quality Assurance Topical Report

-NO-AA-50, Nuclear Oversight Vendor Audit Process Description

-CC-AA-103-1003, Owners Acceptance Review of External Engineering Technical Products

-SM-AA-404, Nuclear Material Procurement

-PC-AA-1017, Quality Management

-NO-AA-210-1006, Nuclear Oversight of Major Projects 11

Project Scope LAR vs. 50.59 12

Scope of Work Proposed Under 50.59 (vs. LAR)

• Temporary Control panels, if required, for installation

• Pre-outage work (raceway, cable pulls, penetration work, etc.)

• Calculation revisions

• Procedures (new/revised)

• Annunciator replacement

• Relocation of existing MCR equipment (SR and NSR)

-Relocation of plant equipment to facilitate installation of the modification. All existing design bases will be maintained.

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Scope of Work Proposed Under 50.59 (vs. LAR)

• Plant Process Computer (PPC) changes and impacts from the modification:

Network changes Interface impacts Ovation upgrades Cyber Security Center Infrastructure Upgrade Operating System - software version Power / Mod Acceptance Testing (bounded by the LAR details)

Non-mod related MCR changes (e.g., lighting and ceiling) 14

HFE Evaluation Overview 15

HFE Evaluation Overview

• Cooperative Research and Development Agreement (CRADA) in place

• Scope: Conceptual Design - through Implementation

• The HFE Program Plan for Limerick will reflect the latest NRC Guidance (NUREG-0711, Revision 3)

• To directly support the Scope of the Digital Safety Related I&C Upgrade and associated License Amendment Request

• To lay a foundation for future I&C upgrades (standard approach)

NUREG 0711 HFE Program Elements 16

HFE Evaluation Overview

• Preparatory work has already commenced to enable HFE Efforts

• 33 documents have been identified by Exelon to support NUREG-0711 Planning and Analysis Efforts, including:

- Control Room Design Review (CRDR): June 1984

- Identified 189 Human Engineering Discrepancies

- 88 corrected by fuel load

- 36 scheduled for correction subsequent to fuel load

- 61 were assessed to be acceptable, corrected, or no change required

- 4 were held out for further review

• CRDR Supplement 1 (October 1984), Supplement 2 (June 1985)

• RAIs on the CRDR and associated responses

• The final SER that concludes that the Limerick 1 and 2 Main Control rooms meet the requirements of NUREG 737, Supplement 1 for a CRDR (1989)

• Control Room Layout Drawings for indications and controls impacted by the upgrade Understand Current HFE Commitments, Design Basis, and Westinghouse Capabilities 17

HFE Evaluation Overview

• Key Planning / Analysis Phase Deliverables

• HFE Program Plan

• Operator Experience Review Report

• Function Analysis / Allocation Report

• Task Analysis Report INL Human Systems Simulation Laboratory - Operator Engagement

• Report evaluation Potential Impacts on MCR Staffing & Qualifications

• Important Human Actions - Identification and Treatment Report

• HFE Style Guide

• Conceptual Design Safety Displays / Navigation Strategy

• Report establishing Simulator Strategy to Support ISV

• Key Design / Verification & Validation Activities

• Human System Interface Design Support Ergonomic Design and HFE Verification

• Design and Task Support Verification

• Integrated System validation.

Support for Utility Integrated System Validation Develop Reports to Provide Objective Quality Evidence Reports Will Support License Amendment Request 18