ML21175A173
| 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 2021 Requirements Phase Complete December 2021 2022 Submit LAR to NRC August 2022 2023 LAR Approval August 2023 Design Phase Complete December 2022 2024 Installation Unit 1 Q2 2024 Test Phase Complete December 2023 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Installation Unit 2 Q2 2025 2
Q1 Q2 Q3 Q4 2025 Design timeline Licensing timeline 6
Timeline Supporting Alternate Review Process (ARP)
Licensing Review
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.
9
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.
10
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 plant equipment to facilitate installation of the modification. All existing design bases will be maintained.
13
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 16 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
HFE Evaluation Overview 17
- 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
HFE Evaluation Overview 18
- Key Planning / Analysis Phase Deliverables HFE Program Plan Operator Experience Review Report Function Analysis / Allocation Report Task Analysis Report 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 Design and Task Support Verification Integrated System validation.
Develop Reports to Provide Objective Quality Evidence Reports Will Support License Amendment Request INL Human Systems Simulation Laboratory - Operator Engagement Ergonomic Design and HFE Verification Support for Utility Integrated System Validation