L-2022-166, Response to Request for Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement
| ML22278A076 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/05/2022 |
| From: | Strand D Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML22278A075 | List: |
| References | |
| L-2022-166 | |
| Download: ML22278A076 (24) | |
Text
l=PL.
L-2022-166 10 CFR 50.90 Framatome Inc. Proprietary (Not proprietary when separated from Attachment 1)
October 5, 2022 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555-0001 RE:
Turkey Point Nuclear Plant, Unit 3 and 4 Docket Nos. 50-250 and 50-251 Renewed Facility Operating Licenses DPR-31 and DPR-41 Response to Request for Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement Project
References:
- 1.
FPL Letter L-2022-120 to NRC dated July 30, 2022, Turkey Point Nuclear Plant, Units 3 & 4, License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement Project (ADAMS Accession No. ML22213A045)
- 2.
NRC Letter L-2022-040 to FPL dated September 15, 2022, Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Supplemental Information Needed for Acceptance of Requested Licensing Action RE: License Amendment Requests to Replace Instrumentation with Digital System (EPID L-2022-LLA-0105) (ADAMS Accession No. ML22255A050)
Per Reference 1, and pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) submitted a request to amend Subsequent Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Nuclear Plant Units 3 and 4 (Turkey Point), respectively. The proposed license amendments replace the Reactor Protection System (RPS), Engineered Safety Features Actuation System (ESFAS), and Nuclear Instrumentation System (NIS) with digital systems that are based on the Framatome Tricon Programmable Logic Controller (PLC) Version 10 digital based platform.
Per Reference 2, the NRC notified FPL that the Staff determined that supplemental information was needed to complete its acceptance review of the proposed amendment. Attachment 1 provides FPL's response for the requested supplemental information. to this letter provides FPL's response for the requested supplemental information. contains information that Framatome, Incorporated, considers to be proprietary in nature.
Pursuant to 10 CFR 2.390(a)(4), FPL requests that the proprietary information be withheld from public disclosure. The request is supported by an affidavit signed by Framatome, Incorporated, the owner of the information, in Attachment 2. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Nuclear Regulatory Commission ("Commission") and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.
Correspondence with respect to the proprietary aspects of this information or the supporting Framatome affidavit should be addressed to Mr. Philip Opsal, Manager, Product Licensing for Framatome, 3315 Old Forest Road, Lynchburg, Virginia 24501. Attachment 3 provides a redacted version of Attachment 1 that is suitable for public dissemination.
The response to the request for supplemental information does not alter the conclusions provided in Reference 1 that the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92, and that there are no significant environmental impacts associated with the proposed change.
Turkey Point Nuclear Plant Docket Nos 50-250 and 50-251 L-2022-166 Page 2 of 2 Should you have any questions regarding this submission, please contact Mr. Kenneth Mack, Fleet Licensing Manager, at 561-904-3635.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on the 5th day of October 2022.
Sincerely, TI1 ~
~~-r==:::;;::~-
Dianne Strand General Manager, Regulatory Affairs Attachments (3) cc: USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant Ms. Cindy Becker, Florida Department of Health
Turkey Point Nuclear Plant L-2022-166 Docket Nos 50-250 and 50-251 Framatome, Incorporated Affidavit in Support of Public Withholding Pursuant to 10 CFR 2.390 (2 Pages)
A F F I D A V I T
- 1.
My name is Philip A. Opsal. I am Manager, Product Licensing for Framatome Inc.
(formally known as AREVA Inc.), and as such I am authorized to execute this Affidavit.
- 2.
I am familiar with the criteria applied by Framatome to determine whether certain Framatome information is proprietary. I am familiar with the policies established by Framatome to ensure the proper application of these criteria.
- 3.
I am familiar with the Framatome information contained in Attachment 1 to Turkey Point Nuclear Plant, Unit 3 and 4 letter L-2022-166 to US NRC Response to Request for Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety System Features Actuation System, and Nuclear Instrumentation System Replacement Project, (herein referred to as this Document).
Information contained in this Document has been classified by Framatome as proprietary in accordance with the policies established by Framatome for the control and protection of proprietary and confidential information.
- 4.
This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by Framatome and not made available to the public.
Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
- 5.
This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4), Trade secrets and commercial or financial information.
- 6.
The following criteria are customarily applied by Framatome to determine whether information should be classified as proprietary:
(a)
The information reveals details of Framatomes research and development plans and programs or their results.
(b)
Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.
(c)
The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for Framatome.
(d)
The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Framatome in product optimization or marketability.
(e)
The information is vital to a competitive advantage held by Framatome, would be helpful to competitors to Framatome, and would likely cause substantial harm to the competitive position of Framatome.
The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d), and 6(e) above.
- 7.
In accordance with Framatomes policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside Framatome only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8.
Framatome policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
- 9.
The foregoing statements are true and correct to the best of my knowledge, information, and belief.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on October 5, 2022.
Philip A. Opsal
Turkey Point Nuclear Plant L-2022-166 Docket Nos 50-250 and 50-251 RESPONSE TO REQUEST FOR SUPPLEMENTAL INFORMATION (RSI)
LICENSE AMENDMENT REQUEST 274 REACTOR PROTECTION SYSTEM, ENGINEERED SAFETY FEATURES ACTUATION SYSTEM, AND NUCLEAR INSTRUMENTATION SYSTEM REPLACEMENT PROJECT (REDACTED)
(18 Pages)
Turkey Point Nuclear Plant L-2022-166 Docket Nos 50-250 and 50-251 Page 1 of 18 RESPONSE TO REQUEST FOR SUPPLEMENTAL INFORMATION (RSI)
LICENSE AMENDMENT REQUEST 274 REACTOR PROTECTION SYSTEM, ENGINEERED SAFETY FEATURES ACTUATION SYSTEM, AND NUCLEAR INSTRUMENTATION SYSTEM REPLACEMENT PROJECT RSI Section(s)
Issue and Summary of NRC Request Response - Description and Schedule DETAILED DESCRIPTIONS OF IMPLEMENTATION ITEMS AND TIMING OF AVAILABILITY 1.1 and 1.2 Environmental Qualification (EQ)
Supplement / Revised Tricon Platform Components 1.1 For each of the implementation items listed in the letter dated July 30, 2022, please provide a detailed description of the information that will be provided as a supplement to the license amendment requests or made available for audit, and the date (i.e., month, day, and year) that FPL will either provide the information on the docket as a supplement or make the information available for audit.
1.2 The NRC staff does not know what specific EQ summary reports will be provided in the supplement. Also, the license amendment request identifies several Tricon components that have been revised since the Description of Information to be Provided Equipment Qualification (EQ) plan (Framatome Document No.: 51-9324222-008) for the Florida Power and Light (FPL) Digital Modernization equipment to be installed at Turkey Point (PTN)
Units 3 and 4 is available for NRC review and will be posted to the Electronic Reading Room by October 16, 2022. EQ Summary Qualification Reports summarize test methods, test results and analyses necessary to establish mild environment qualification for conditions inclusive of normal and abnormal environments and Design Basis Event (DBE) seismic conditions for the locations where the equipment will be installed onsite at the Turkey Point facility. Also, in accordance with the EQ Plan, the I&C components and electronic subcomponents are subjected to Electromagnetic Compatibility (EMC) and electrical isolation testing.
EQ Summary Qualification Reports document the suitability of the 1E Digital Modernization equipment to meet the safety-related performance requirements set forth in the EQ plan and referenced standards as defined in the RPS/ESFAS/NIS SyRS (LAR Attachment 7.7). The qualification process described in the EQ Plan is performed in accordance with the EQ Plan under the Framatome Quality Assurance Program.
There will be multiple EQ Qualification Summary Reports for the RPS/NIS/ESFAS replacement scope. These EQ Qualification Summary Reports will include identification of all equipment qualified, a summary of each test and analysis(es) performed, results of the functional tests performed, any anomalies and resulting design changes made as a result of test anomalies, testing conclusions, and evaluations.
Turkey Point Nuclear Plant L-2022-166 Docket Nos 50-250 and 50-251 Page 2 of 18 RSI Section(s)
Issue and Summary of NRC Request Response - Description and Schedule topical report was last approved by the NRC, the revised TR does not contain EQ test summary reports for these modified components.
The EQ test summary reports should document the results of the qualification testing. The summary should compare the standards and test limits to which the equipment has been qualified and should compare the equipment qualification test limits to the licensee-established plant environmental conditions.
Please provide a detailed description of the information mentioned in the first implementation item that will be provided as a supplement to the license amendment request and the date (i.e., month, day, and year) that FPL will provide the information on the docket as a supplement.
Safety Video Display Unit (SVDU), Development Project Equipment Qualification Summary Report, Schneider Electric Document USSVDU2-EQSR-XXSR-001, dated 3/22/2019 - Is included as Attachment 7.3 to the LAR.
The following EQ Qualification Summary Reports will be issued:
- a. EQ Qualification Summary Report for Nuclear Instrumentation. This report covers Nuclear Instrumentation Signal Conditioning Chassis (power range, intermediate range, and source range), the Source Range Pre-amplifier, and connection boxes.
- b. EQ Qualification Summary Report for RPS/ESFAS. This report covers components in the RPS/ESFAS system design not covered by other reports and includes:
[
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[
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[
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Commercial Ancillary Equipment being integrated into the overall system designs, including but not limited to, the following generic applications. Additional equipment may be specified and included based on the completion of detailed design:
Fasteners/Hardware, Standoffs, etc.
Turkey Point Nuclear Plant L-2022-166 Docket Nos 50-250 and 50-251 Page 3 of 18 RSI Section(s)
Issue and Summary of NRC Request Response - Description and Schedule Cable Management Devices (wireways, zip ties, cable clamps, etc.)
Power distribution equipment (terminal blocks, circuit breakers, line filters, fuses/fuse blocks, disconnects, etc.)
Relays Isolators Cabinet Lighting, door switches Keys switches, toggle switches, and/or pushbuttons Channel to Voter Tricon' module Class 1E Isolation Qualification Test - Architecture specific test of hardwired Tricon to Tricon interdivisional communication Tricon Product Line Changes and Supplemental Testing. Engineering evaluations on the changes to the Tricon product line and test reports are available as supplemental information to the existing product qualification and will be made available for audit. These documents include:
Document No.
Title Revision 9600164-527 MPR Document Tricon v10 EMI/RFI Test Report 4.0 TR018386-PLC-EMI NTS Document Test Report for EMI/RFI Retest of the Tricon v10 Programmable Logic Controller Qualification Test Specimen 0.0 TP018386-PLC-EMI Completed NTS Procedure Test Procedure for EMI/RFI Retest of the Tricon v10 Programmable Logic Controller Qualification Test Specimen 1.0 9600506-510A Completed MPR Procedure Invensys Digital Control Equipment EMI/RFI Qualification Retesting Project, Tricon v10 PLC EMI/RFI Retest Procedure 0.0 0449-1202-TPR-001 Completed MPR Procedure Invensys Digital Control Equipment EMI/RFI Qualification Retesting Project, Tricon v10 PLC Conducted Emissions Retest Procedure 0.0
Turkey Point Nuclear Plant L-2022-166 Docket Nos 50-250 and 50-251 Page 4 of 18 RSI Section(s)
Issue and Summary of NRC Request Response - Description and Schedule 9600506-500 MPR Document Invensys Digital Control Equipment EMI/RFI Qualification Retesting Project, Qualification Retest Plan 1.0 0449-1202-QAP-01 MPR Document Quality Assurance Plan for the Invensys Digital Control Equipment EMI/RFI Qualification Retesting Project 2.0 9600506-540 MPR Document Invensys Digital Control Equipment EMI/RFI Qualification Retesting Project, Master Configuration List 7.0 Framatome 8310N2 Tricon' Power Supply for use with a high voltage DC input voltage Framatome 8310N2 Tricon' Power Supply for use with a high voltage DC input voltage 0.0 Commercial Grade Dedication (CGD) Reports will be available for audit in the Electronic Reading Room. The following documents will be included:
Framatome Gmbh TXS SCV2, subcomponent of the NI Source Range and Intermediate Range Signal Conditioning Chassis, CGD Report.
Framatome Gmbh TXS SSR1, Subcomponent of the NI Source Range Signal Conditioning Chassis, CGD Report.
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Schedule for planned Submittals Document Title Date of Submittal EQ Qualification Summary Report for Nuclear Instrumentation.
6/15/2023 EQ Qualification Summary Report for RPS/ESFAS 9/15/2023
Turkey Point Nuclear Plant L-2022-166 Docket Nos 50-250 and 50-251 Page 5 of 18 RSI Section(s)
Issue and Summary of NRC Request Response - Description and Schedule Schedule for documents available for audit Document Title Date Available Tricon Supplemental Testing (multiple) 10/16/2022 Framatome Gmbh TXS SCV2 CGD Report 04/01/2023 Framatome Gmbh TXS SSR1 CGD Report 04/01/2023
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9/15/2023
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9/15/2023 1.1 Software Installation Plan, Software Maintenance Plan, and Software Operation Plan For each of the implementation items listed in the letter dated July 30, 2022, please provide a detailed description of the information that will be provided as a supplement to the license amendment requests or made available for audit, and the date (i.e., month, day, and year) that FPL will either provide the information on the docket as a supplement or make the information available for audit.
Description of Information to be Provided The following plans and reports will be available for audit.
- 1. Software Installation Plan,
- 2. Software Maintenance Plan,
- 3. Software Operation Plan Schedule for documents available for audit Document Title Date of Submittal Software Installation Plan 6/19/2023 Software Maintenance Plan 6/9/2023 Software Operation Plan 6/7/2023
Turkey Point Nuclear Plant L-2022-166 Docket Nos 50-250 and 50-251 Page 6 of 18 RSI Section(s)
Issue and Summary of NRC Request Response - Description and Schedule 1.1 System-Level Failure Modes and Effects Analysis (FMEA)
For each of the implementation items listed in the letter dated July 30, 2022, please provide a detailed description of the information that will be provided as a supplement to the license amendment requests or made available for audit, and the date (i.e., month, day, and year) that FPL will either provide the information on the docket as a supplement or make the information available for audit.
Description of Information to be Provided A System Level Failure Modes and Effects Analysis (FMEA), Framatome document 51-9330940 RPS/ESFAS/NIS FMEA, for the RPS/ESFAS/NIS replacement will be submitted. This FMEA applies to the design of the RPS/ESFAS/NIS replacement for Florida Power and Light (FPL) Turkey Point Units 3 and 4. The purpose of this document is to provide a detailed FMEA for the replacement design in accordance with FPL, industry, and regulatory requirements.
The System Level FMEA covers the Framatome provided equipment and system interfaces.
The FMEA will be a living document throughout the PTN replacement project design and will be updated to address detailed design information required by the RPS/ESFAS/NIS FMEA implementation. Revisions will be reviewed for impacts to the PTN LAR and will be available for NRC inspection.
The System Level FMEA is a systematic qualitative analysis of the RPS/ESFAS/NIS design with the primary objectives of identifying credible failure modes, evaluating the consequence and effects of failures, and verifying that the design satisfies single-failure criterion applicable to the replacement RPS/ESFAS/NIS. The guidance of IEEE Std. 352, "IEEE Guide for General Principles of Reliability Analysis of Nuclear Power Generating Station Safety Systems, will be used to perform the FMEA, however, a quantitative analysis will not be included in the document. The FMEA includes consideration of common-cause failures to ensure independence of the D3 support indications and the DAS.
The System FMEA addresses:
- 1. Regulatory Requirements
- a. Criteria per IEEE 603-1991 Single Failure, Clause 5.1 using IEEE 379-2000 Control/Protection Interaction, Clause 6.3
Turkey Point Nuclear Plant L-2022-166 Docket Nos 50-250 and 50-251 Page 7 of 18
- b. Criteria of IEEE 379-2000 Credible Single Failures in conjunction with any identified non detectable failures, Clause 4 Spurious Actuations with any identified non detectable failures, Clause 4 Common Cause Failures, Clause 5.5 Cascaded Failures, Clause 5.3
- 2. Design Requirements, including the following:
- a. Define the credible failure modes and ensure their effects have been considered
- b. Failure modes and isolation capabilities for interdivisional wired and digital communications.
- c. SVDU Failure Modes and Effects on the Tricon systems and safety applications.
- d. Potential failures in the DCS, effects on the HSI, and safety related equipment.
- e. Independence between protection, control, and D3 required components.
- f.
Failure modes of the keyswitch, mitigating factors, and the effects on PTN specific communications identified in ASAI 19 of the LAR
- 3. Impacts of existing and new field failures on protection system and non-system control system outputs
- a. Protection system inputs (i.e., sensors, relays, etc.)
- b. Protection system outputs (i.e., relays, analog outputs)
- c. Electric and Motive power (common power associations that could result in new single points of failures)
Platform FMEAs are used as input into the System FMEA and are available for NRC review.
These platform FMEAs include but are not limited to:
- 1. Framatome 38-9327603-001, Failure Modes and Effects Analysis (FMEA) For the Tricon Version 10.2 Programmable Logic Controller dated 04/11/2022 (Tricon Platform FMEA)
Turkey Point Nuclear Plant L-2022-166 Docket Nos 50-250 and 50-251 Page 8 of 18 RSI Section(s)
Issue and Summary of NRC Request Response - Description and Schedule
- 2. Framatome Schneider Electric Doc. No. USSVDU2-FMEA-XXSR-0001, Rev. 00, North America Nuclear, SVDU 2.0 Development Project, Qualification Failure Modes and Effects Analysis, March 2019 (Framatome Platform FMEA)
- 3. Framatome Doc. No. 51-9328643-000, DCS Failure Modes and Effects Analysis-Unit 3 (Foxboro IA System FMEA)
- a. Power Range FMEA (51-9354789)
- b. Intermediate Range FMEA (51-9354788)
- c. Source Range FMEA (51-9354787)
FMEDA Implementation-RPS/ESFAS, Attachment 7.8 to the LAR (Supports Technical Specification Surveillance Reduction implementation supporting the RPS/ESFAS System FMEA)
Schedule for Submittal The System FMEA will be submitted by January 16, 2023.
1.1 Factory Acceptance Testing -
Response Time For each of the implementation items listed in the letter dated July 30, 2022, please provide a detailed description of the information that will be provided as a supplement to the license amendment requests or made available for audit, and the date (i.e., month, day, and year) that Description of Information to be Provided A response time analysis has been performed addressing Safety Analysis response requirements from process detection to the being of rod movement for RPS and Master/Slave actuation for ESFAS. The Tricon RPS/ESFAS maximum scan rates for both the Tricon channels and voters have been calculated and are the bases for validation testing requirements to ensure that the existing safety analysis response time allowances are met during Factory Acceptance Test (FAT). The FAT Procedure including the method and acceptance criteria for response time testing will be available for audit.
A worst-case time response calculation for the RPS/ESFAS/NIS replacement was performed in Framatome document 152-9324949, "Framatome Response Time Calculations for the Turkey
Turkey Point Nuclear Plant L-2022-166 Docket Nos 50-250 and 50-251 Page 9 of 18 RSI Section(s)
Issue and Summary of NRC Request Response - Description and Schedule FPL will either provide the information on the docket as a supplement or make the information available for audit.
Point 3 and 4 RPS/ESFAS/NIS Digital Replacement Project and is available for audit (LAR Reference 5.9). This time response calculation satisfies the plant and application-specific requirements for system response time presented in Chapter 14 of the safety analysis report.
The RPS/ESFAS/NIS equipment response time is verified as part of the Factory Acceptance Test (FAT) to verify that Tricon throughput time is bounded by the calculation and in no case exceeds the replacements allotment (plus margin).
Schedule for documents available for audit
- 1. The Response Time calculation has been issued and is available for NRC review
- 2. Factory Acceptance Test Report - April 8, 2024 1.1 Supplement to Update Technical Specification and Technical Specification Bases Page Mark-ups Based on the NUREG-1431, Revision 5 Format For each of the implementation items listed in the letter dated July 30, 2022, please provide a detailed description of the information that will be provided as a supplement to the license amendment requests or made available for audit, and the date (i.e., month, day, and year) that FPL will either provide the information on the docket as a supplement or make the information available for audit.
Description of Information to be Provided Provide a submittal date to NRC for the supplemental Technical Specification and Bases pages in the ITS format. No other information required.
Schedule for Submittal A LAR supplement will be provided 3 months after NRC ITS SER issuance to update the Technical Specification and Technical Specification Bases (information only) page mark-ups pages based on the NUREG-1431, Revision 5, format, following approval of the Turkey Point Improved Technical Specification (ITS) conversion.
Turkey Point Nuclear Plant L-2022-166 Docket Nos 50-250 and 50-251 Page 10 of 18 RSI Section(s)
Issue and Summary of NRC Request Response - Description and Schedule Note that the description of the fifth implementation item (Technical Specification supplement) is sufficient, so a more detailed description of the fifth implementation item is not needed. However, a date (i.e.,
month, day, and year) is needed.
1.1 and 1.3 Activities and Results of Each Human Factors V&V Testing Stage 1.1 - For each of the implementation items listed in the letter dated July 30, 2022, please provide a detailed description of the information that will be provided as a supplement to the license amendment requests or made available for audit, and the date (i.e., month, day, and year) that FPL will either provide the information on the docket as a supplement or make the information available for audit.
1.3 - To determine whether sufficient technical information, both in scope and depth will be available with an appropriate time frame to support the NRCs Describe at what stage(s) of validation testing, results that will be credited This approach consists of three steps/stages of verification and validation activities:
Step 1 - PV1: Conceptual Design Test. This test is performed using a simplified mock-up that replicates new control room layout and static, paper-based displays, and marked-up/draft procedures as available with the main objective of validating the conceptual design or novel, complex or critical design elements or testing of important human actions to ensure that the proposed design is being validated from a HFE perspective early in the design process. The Result Summary Report (RSR) for the Conceptual Design Test (PV1) will include the implementing procedure and results of the test.
Step 2 - PV2: Preliminary Design Test. It is an intermediate test to be performed on a limited platform using preliminary versions of the actual HSI design products. The execution of the Preliminary Design Test (PV2) is scheduled for August 16, 2023, through August 22, 2023, and will be performed in the Turkey Point glass top simulator. The RSR for PV2 will include the evaluation of the glass top simulator as a suitable platform, definition of scenarios, implementation procedures and results of the activity. The PV2 RSR will be submitted by October 31, 2023.
Step 3 - ISV - Integrated System Validation. The final integrated validation planned to be performed on a glass panel simulator (or comparable high-fidelity platform) that replicates the MCR, with all the systems affected by the modification implemented and verified. As it is indicated in Section 5.9 of the HFE Plan (LAR Attachment 7.6). The ISV RSR will be available for audit or inspection on March 28, 2024.
Turkey Point Nuclear Plant L-2022-166 Docket Nos 50-250 and 50-251 Page 11 of 18 RSI Section(s)
Issue and Summary of NRC Request Response - Description and Schedule safety determination regarding the submitted LAR, the following supplemental information is needed:
- a. Identify what stage of validation will be credited and the completion schedule (i.e.,
month, day, and year) of the validation testing.
- b. Provide the schedule (i.e.,
month, day, and year) for submitting the results summary report (RSR) (or an equivalent report) discussing credited validation testing results.
- c. Provide the schedule (i.e.,
month, day, and year) for the availability of supporting documents referenced within the RSR (or equivalent report). This information is needed to enable NRC staff to plan any potential audits.
The activities and results of each human factors V&V testing stage are documented in a Results Summary Report to specifically identify and describe the test and evaluation conditions at each stage as described in the HFE Plan.
Schedule for submitting the results summary report (RSR)
Document Title Date for Submittal Preliminary Design Test (PV2) RSR 10/31/2023 Schedule for the availability of supporting documents referenced within the RSRs Document Title Date Available Conceptual Design Test (PV1) RSR 3/29/2023 Task Support Verification (TSV1) RSR 5/15/2023 Design Verification (DV1) RSR 5/25/2023 Task Support Verification (TSV2) RSR 1/6/2024 Design Verification (DV2) RSR 1/26/2024 Integrated System Validation (ISV) Procedure 11/3/2023 Integrated System Validation (ISV) RSR 3/28/2024 2
System Components Not Previously Reviewed by NRC Figures 2.1-1, 2.2-1, and 2.3-1 of Enclosures 1 and 2 to the letter dated July 30, 2022, indicate that Description of Information to be Provided
- 1. The following is a listing of the non-Tricon equipment that the NRC has not previously reviewed. Equipment Qualification and Commercial Grade Dedication of the components is addressed above.
Turkey Point Nuclear Plant L-2022-166 Docket Nos 50-250 and 50-251 Page 12 of 18 RSI Section(s)
Issue and Summary of NRC Request Response - Description and Schedule a significant number of new system components are identified by the licensee as New Scope -
Not previously reviewed by NRC.
The NRC staff therefore requires additional information as defined in ISG-06 Section D.9 and in Enclosure B for these portions of the replacement RPS, ESFAS, and NIS. This information is not in the request submitted by the licensee.
For each of the topics listed below, please provide a detailed description of the information that will be provided as a supplement to the license amendment request for system components that are not within the Tricon topical report scope and the date (i.e., month, day, and year) that FPL will provide the information on the docket as a supplement.
The following information will need to be provided for the NRC staff to make an independent assessment regarding the acceptability of the proposed amendment request:
- i.
PR Chassis ii.
IR Chassis iii.
SR Chassis iv.
SR Pre-amplifier
- v.
Connector Boxes
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- d. [
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- e. Framatome SVDU (safety-related product)
- f. [
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- g. Commercial ancillary equipment being integrated into the overall system designs, including but not limited to, the following generic applications:
- i.
Fasteners/Hardware, Standoffs, etc.
ii.
Cable Management Devices (wireways, zip ties, cable clamps, etc.)
iii.
Power distribution equipment (terminal blocks, circuit breakers, line filters, fuses/fuse blocks, disconnects, etc.)
iv.
Relays
- v.
Isolators vi.
Cabinet Lighting, door switches vii.
Keys switches, toggle switches, and/or pushbuttons
Turkey Point Nuclear Plant L-2022-166 Docket Nos 50-250 and 50-251 Page 13 of 18 RSI Section(s)
Issue and Summary of NRC Request Response - Description and Schedule
- a. (Summary of) Application Software Planning and Processes (see D.4)
- b. System Response Time Confirmation Report (see D.9.7)
- c. Platform-Level Failure Modes and Effects Analysis (see D.9.8)
- d. (Summary of)
Electromagnetic Interference, Temperature, Humidity, and Seismic Testing Results (see D.3)
- e. Commercial-Grade Dedication Report(s) (see D.9.9)
- 2. The following information addresses the Tricon components that have been revised since the issuance of the original Tricon Topical Report, supporting evaluations of traceability/acceptability of existing EQ basis and any new supplemental qualification reports.
Since the issuance of the 2012 Topical Report, the Tricon Product line has undergone two (2)
Environmental Qualification projects and several evolutionary changes as follows:
1-2013: Tricon v10 EMI/RFI Retesting Project This project was conducted to address deficiencies and non-compliances noted in the initial EMI/RFI testing and to extend the qualified EMI/RFI susceptibility envelope to meet specific Invensys customer requirements. EMI/RFI testing was performed in accordance with the following documentation set with results documented in test report document no. 9600164-527, revision 4.0. These are readily available for review.
Document No.
Title Revision 9600164-527 MPR Document Tricon v10 EMI/RFI Test Report 4.0 TR018386-PLC-EMI NTS Document Test Report for EMI/RFI Retest of the Tricon v10 Programmable Logic Controller Qualification Test Specimen 0.0 TP018386-PLC-EMI Completed NTS Procedure Test Procedure for EMI/RFI Retest of the Tricon v10 Programmable Logic Controller Qualification Test Specimen 1.0 9600506-510A Completed MPR Procedure Invensys Digital Control Equipment EMI/RFI Qualification Retesting Project, Tricon v10 PLC EMI/RFI Retest Procedure 0.0 0449-1202-TPR-001 Completed MPR Procedure Invensys Digital Control Equipment EMI/RFI Qualification Retesting Project, Tricon v10 PLC Conducted Emissions Retest Procedure 0.0
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Issue and Summary of NRC Request Response - Description and Schedule 9600506-500 MPR Document Invensys Digital Control Equipment EMI/RFI Qualification Retesting Project, Qualification Retest Plan 1.0 0449-1202-QAP-01 MPR Document Quality Assurance Plan for the Invensys Digital Control Equipment EMI/RFI Qualification Retesting Project 2.0 9600506-540 MPR Document Invensys Digital Control Equipment EMI/RFI Qualification Retesting Project, Master Configuration List 7.0 2-2012 - 2022: Tricon v10 Evolutionary Changes From 2012 through 2022, a total of 4801 Engineering Change Orders (ECOs) and 1454 Manufacturing Change Orders (MCOs) were issued against the entire Tricon product line (commercial and nuclear Tricon, Priority Logic Modules (not utilized for the Turkey Point RPS/ESFAS/NIS replacement), SVDU, etc.). ECOs/MCOs applicable to the maintenance of the NRC approved nuclear Tricon v10 platform will be identified. A summary of the applicable changes will be produced and individual packages will be made available for review.
3-2018 - 2019: SVDU 2.0 Development Project Equipment Qualification This project was for the generic qualification of the SVDU 2.0 for use in nuclear safety system via technical evaluations and qualification tests. The qualification project was performed in accordance with the following documentation set with results documented in Equipment Qualification Summary Report document no. USSVDU2-EQSR-XXSR-0001, Revision 0.0.
These are readily available for review.
Document No.
Title Revision USSVDU2-EQSR-XXSR-0001 SVDU 2.0 Development Project Equipment Qualification Summary Report 00 USSVDU2MCL XXSR0001 Master Configuration List 09 USSVDU2VTR XXNS0001 Schneider Electric SVDU 2.0 Qualification Test Specimen Application Program (TSAP) Validation Test Report 00
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Issue and Summary of NRC Request Response - Description and Schedule USSVDU2QTR XXSR0001 SVDU 2.0 Prequalification Acceptance Test Report 00 USSVDU2QTR XXSR0002 SVDU 2.0 Qualification Radiation Exposure Withstand Test Report 00 USSVDU2QTR XXSR0003 SVDU 2.0 Qualification Environmental Test Report 00 USSVDU2QTR XXSR0004 SVDU 2.0 Qualification EMI/RFI Test Report 00 USSVDU2QTR XXSR0005 SVDU 2.0 Qualification Electrical Fast Transient Test Report 00 USSVDU2QTR XXSR0006 SVDU 2.0 Qualification Surge Withstand Test Report 00 USSVDU2QTR XXSR0007 SVDU 2.0 Qualification Electrostatic Discharge Test Report 00 USSVDU2QTR XXSR0008 SVDU 2.0 Qualification Seismic Test Report 00 USSVDU2QTR XXSR0009 SVDU 2.0 Qualification Performance Proof Test Report 00 4-2019 - 2022: SVDU 2.0 Evolutionary Changes From 2019 through 2022, following the SVDU 2.0 qualification project, a total of 995 Engineering Change Orders (ECOs) and 417 Manufacturing Change Orders (MCOs) were issued against the entire Tricon product line (commercial and nuclear Tricon, PLM, SVDU, etc.)
ECOs/MCOs applicable to the maintenance of the SVDU will be identified. A summary of the applicable changes will be produced and individual packages will be made available for review.
5-2022: 8310N2 PSM Supplemental EMC Qualification Project This project was conducted to qualify the DC recommended (120 VDC) and extended (95 VDC
- 180 VDC) input voltage operating modes of the 8310N2 Power Supply Module used to power
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Issue and Summary of NRC Request Response - Description and Schedule Tricon v10 chassis modules. These operating modes are not currently included in the 2012 Topical Report. The qualification was achieved by the performance of an engineering evaluation and limited supplemental EMC tests. The project was executed in accordance with the following documentation set with results documented in EQ Summary Report document no. 128-9338138, Revision 000. These are readily available for review and the Supplemental Qualification EQ Summary Report will be provided as part of the project supplemental Equipment Qualification package.
Document No.
Title Revision 128-9338138 8310N2 PSM Supplemental Qualification EQ Summary Report 000 51-9340720 8310N2 PSM Supplemental EMC Qualification Engineering Evaluation 002 38-9338135 AMS Document TEST REPORT EMC Qualification Testing of an 8310N2 Power Supply Module (PSM) - Electrical Fast Transient Immunity 000 38-9338132 AMS Document TEST REPORT EMC Qualification Testing of an 8310N2 Power Supply Module (PSM) - Conducted Interference Immunity 000 38-9338133 AMS Document TEST REPORT EMC Qualification Testing of an 8310N2 Power Supply Module (PSM) - Combination Wave and Ring Wave Immunity 000 185-9338143 8310N2 PSM Supplemental EMC Qualification Master Configuration List 004 51-9338112 8310N2 PSM Supplemental EMC Qualification Master Test Plan 001 56-9338111 8310N2 PSM Supplemental EMC Qualification Nuclear Qualification Quality Plan 000 Schedule for Availability The availability of Tricon platform changes and supplemental testing information is addressed in the EQ section.
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Issue and Summary of NRC Request Response - Description and Schedule 1-2013: Tricon v10 EMI/RFI Retesting Project - These are readily available for review.
2-2012 - 2022: Tricon v10 Evolutionary Changes - These will be available for review on March 1, 2023.
3-2018 - 2019: SVDU 2.0 Development Project Equipment Qualification - These are readily available for review.
4-2019 - 2022: SVDU 2.0 Evolutionary Changes - These will be available for review on March 1, 2023.
5-2022: 8310N2 PSM Supplemental EMC Qualification Project - These are readily available for review.
3 Availability of HFE Results Summary Reports (RSR)
NUREG-0711 specifies, for each program element, the information that should be included in the RSR. NUREG-0711 also clarifies that summaries may be used to address any of the information to be included in each RSR, if references are given for more detailed documents.
The LAR, dated July 30, 2022, includes the Human Factors Engineering Analysis IP and the Human System Interface Design IP as Attachments 5 and 10, respectively.
Description of Information to be Provided The Result Summary Reports are described in the HSI Analysis and HSI Design Interface Implementation Plans attached to the LAR.
Schedule for submitting HFE Analysis and Human System Interface Design RSR(s)
Document Date Available Operating Experience (OER) RSR 01/16/2023 Function Requirements (FRA)/Function Allocation (FA)/ Task Analysis(TA) RSR 01/16/2023 Treatment of Important Human Actions (TIHA) RSR 01/16/2023 Human System Interface Design RSR 6/5/2023 Schedule for the availability of supporting documents referenced within the RSR(s).
Document Date Available HSI Style Guide 11/30/2022 Conceptual Control Room Design Description 11/30/2022
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Issue and Summary of NRC Request Response - Description and Schedule To determine whether sufficient scope of information will be available with an appropriate time frame to support the NRCs acceptance of the submittal LAR, the following additional information is required:
- a. For each of the IPs listed above, provide the schedule (i.e., month, day, and year) for submitting the RSRs (or equivalent reports).
- b. Provide the schedule (i.e.,
month, day, and year) for the availability of supporting documents referenced within the RSRs (or equivalent reports). This information is needed to enable NRC staff to plan any potential audits.