ML14188A970

14-07-08 ISG-06 Experience Presentation July 8 2014 Digital IC Meeting

ML14188A970
Person / Time
Site:	Diablo Canyon
Issue date:	07/08/2014
From:	Schrader K Pacific Gas & Electric Co
To:	Division of Policy and Rulemaking
Holonich J, DPR/PLPB, 415-7297
References
Download: ML14188A970 (15)

Text

DIABLO CANYON POWER PLANT PROCESS PROTECTION SYSTEM REPLACEMENT LICENSING EXPERIENCE USING ISG 6 NRC Meeting on Digital I&C July 8 8, 2014 Ken Schrader, MS Senior Advisor, Engineering, PG&E Vice Chairman, PWROG kjse@pge.com 805-545-4328 1

Agenda ISG 6 ISG 6 Pilot Application PG&E ISG 6 Lesson Learned 2

ISG 6 ISG 6 - Licensing Process for Digital I&C System Modifications Roadmap to success to develop acceptable License Amendment Request (LAR)

ISG 6 process will reduce licensing uncertainty and effort for future licensees/vendors Facilitate increased safety to nuclear safety systems t

3

ISG 6 Pilot Application Diablo Canyon is pilot plant for use of ISG 6 PG&E participated in ISG 6 working group PG&E submitted pilot application 10/26/11 (ML11307A331)

Process Protection System replacement Invensys Tricon V10 (PLC bbased) d)

Westinghouse Advanced Logic System

- (ALS) (FPGA based) 4

ISG 6 Pilot Application Both vendors obtained NRC approval of platform topical reports (TR) during Pilot Application pp review Invensys Tricon V10, April, 2012 (ML1209008902)

Westinghouse g ALS,, September p 9,, 2013 (ML13210A309)

Approved vendor TRs allow use of ISG 6 Tier 1 for systems with approved TR (fast-track)

Significantly simplifies future licensee LARs, NRC review and safety evaluation review, 5

ISG 6 Pilot Application Project Scope 6

ISG 6 Pilot Application Process Protection System Replacement A hit t Architecture 7

ISG 6 Pilot Application Current Status Completed ACRS reviews in February and March Completing final ISG 6 milestones NRC supportt off application li ti h has b been excellent ll t Resources Use of sharepoint site for documentation Efficient resolution of open items Identifying lessons learned from Oconee project ACRS presentations/meetings 8

ISG 6 Pilot Application Outstanding Milestones Invensys Tricon Factory Acceptance Test (FAT) in progress, first of four protection sets tested acceptable Expect to submit FAT results to NRC in October Westinghouse ALS Final detailed design in progress FAT expected spring 2015 S b it FAT results Submit lt summer 2015 PG&E to respond to final set of RAIs 9

ISG-06 Lessons Learned Most significant NRC issue, testing and software requirements on proposed common maintenance workstation for both Tricon and ALS subsystems PG&E changed design to use separate maintenance computer for each subsystem in each division Simplifies factory acceptance testing requirements and eliminates potential software interaction issues 10

ISG-06 Lessons Learned PG&E issued single Functional Requirements Specification for project (covered both platforms)

Resulted in unnecessary difficulty for vendor design, vendor d

documentation, t ti and d NRC review i

Contributed to vendors not meeting all applicable requirements, requiring redesign Extended vendor schedules Complicated NRC review and resulted in vendor audit issues 11

ISG-06 Lessons Learned PG&E did not incorporate I&C maintenance personnel expectations to support troubleshooting and maintenance into initial Functional Requirements S

Specifications ifi ti Required revision to Functional Requirements Specification Caused vendors to have to redesign to meet new functional requirements 12

ISG-06 Lessons Learned Vendors did not fully understand meaning of some functional requirements Nuclear requirements and terminology are unique Some vendor design personnel did not have prior nuclear project experience (most PLC and FPGA business is non-nuclear)

Clarifying questions on requirements from vendors occurred late in detailed design, required some redesign Utilities need to proactively ensure vendor design and IV&V personnel have correct understanding of all requirements 13

ISG-06 Lessons Learned Vendors underestimated effort for detailed design First-of-Its-Kind large scope application of each vendor platform to US nuclear plant protection system N l Nuclear requirements i t andd processes are more complex l

Vendor document revisions required to address ISG 6 requirements 14

Closing Comments ISG 6 process will reduce licensing uncertainty and effort for future Digital I&C applications pp

• Initial applications *Routine applications

• No p precedents

• TRs TR review/approved i / d *Multiple M lti l TR TRs

• No current TRs

• Medium uncertainty approved/current

• High uncertainty

• Medium Cost *Acceptable uncertainty

• High Cost

• Reduced cost

< 2008 2009 - 2015 2016 +

15