ML22153A360
| ML22153A360 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/09/2022 |
| From: | Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation |
| Marshall M, NRR/DORL/LPL1 | |
| References | |
| EPID L-2020-LRM-0041 | |
| Download: ML22153A360 (25) | |
Text
Limerick Generating Station Digital Modernization Project LAR Pre-submittal Meeting NRC Pre-submittal Meeting June 9, 2022 Click to add text
oLicensing Dave Helker, Licensing Manager Frank Mascitelli, Licensing Lead Laura Lynch, LGS Regulatory Assurance Manager George Budock, LGS Regulatory Assurance Pareez Golub, Digital Licensing SME Richard Paese, HFE SME John Schrage, Licensing SME oEngineering 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 Introductions - Constellation Project Team 1
oProject Management Steve Hesse, Project Director Dave Molteni, Senior Manager and Station Lead Jerry Segner, Principal Project Manager Kayla Marriner, Project Manager oOperations Paul Krueger, Senior Operations Specialist oNuclear Oversight Dave Peiffer, Performance and Assessment Lead oPRA Support Jeffrey Stone, Director, Corporate Engineering PRA Suzanne Loyd, Senior Manager, Engineering Risk Management Introductions - Constellation Project Team 2
oProject Management
- Dominic Mocello, Project Manager
- Boyan Setchenski, Program Manager oEngineering
- Warren Odess-Gillett, Lead - Licensing
- Steve Seaman, System Integration Lead
- Cal Tang, BWR Technical Advisor Introductions - Westinghouse Project Team 3
oHFE Specialists Paul Hunton Jeffrey Joe Introductions - Idaho National Labs Project Team 4
oOpen / Public Session
- Introductions
- LAR Update
- Project Update / Schedule
- Human Factors Engineering Evaluation / Integrated System Validation
- Response to NRC Questions
- Next Pre-submittal Meeting Topics Agenda / Opening Remarks 5
6 LAR Update
Constellation will be submitting three LARs to support the Limerick Digital Modernization Project:
- Digital Modernization Project LAR
- Plan to submit in August 2022 to support April 2024 Refuel Outage on Unit 1
- Includes elimination of the automatic Turbine Main Steam High Temperature Isolation similar to HATCH Precedent (NRC ADAMS Accession No. ML21286A595)
- Includes Elimination of Redundant Reactivity Control System (RRCS) Feedwater Runback
- Installation Support LAR
- Plan to submit October 2022 and request a one-year NRC review time frame
- Needed to support pre-outage demolition activities and facilitate installation of the new PPS system within given outage duration
- Technical Evaluation is not linked/dependent on Digital Modernization LAR
- Plan to submit March 2023 and request a one-year NRC review time frame
- Plan so that Unit 1 would be able to restore instrument related RICTs at end of 2024 Refuel Outage
- Technical Evaluation is linked to Limerick Digital Modernization LAR but will not be an Acceptance Review Issue LAR Status 7
- Installation Support LAR
- RRCS demolition 30 days prior to outage
- Request a temporary one-time Allowable Outage Time (AOT) extension for Technical Specifications (TS) Section 3.3.4.1 ATWS Recirculation Pump Trip System Instrumentation Actions D and E, from 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 30 days and 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 30 days, respectively.
- Deterministic technical evaluation with risk Insights (hybrid LAR)
- Implement TSTF 582 (RPV WIC Enhancements)
- Needed to facilitate TS compliance during outage installation configurations
- LOP Instrumentation Applicability (TSTF-583-T)
- TS change to facilitate Mode Switch inoperability and continued Core Alterations
- Issue: During installation of the digital modification on the Reactor Protection System, including the "Reactor Mode Switch Shutdown Position" and "Manual Scram" functions (i.e., TS Table 3.3.3-1, functions 11 and 12), the unit will be in OPERATIONAL CONDITION (OPCON) 5 with the Reactor Mode Switch locked in the Refuel position, and considered inoperable (i.e., due to the modification work on the RPS). Similarly, the Manual Scram function will be inoperable.
- TS change to facilitate Mode Switch inoperability and continued Core Alterations by using a similar note or exclusion to the one in ITS LAR Status 8
- RICTs were excluded from Digital Modernization Project LAR to facilitate timely NRC review
- Restore about 19 existing RICTs that cover about 97 instrument TS functions that are being excluded from the Digital Modernization Project LAR
- Add several new RICTs for PPS Division inoperable LCOs
- Anticipating final design for Digital Modernization Project LAR completed to the point where PRA model update changes can start to be developed in the October 2022 time frame
- Re-perform Loss of Functions Reviews for applicable TS per functions impacted by instrument consolidations
- Application of RICT Program changes will be evaluated using the methodology and probabilistic risk guidelines contained in NEI 06-09-A, "Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines," Revision 0
- Review is in in progress to determine if any Newly Developed Methods (NDMs) are involved for the PRA model changes
- The anticipated changes to the PRA model will meet the definition of a PRA Upgrade
- The PRA upgrade will require a Focused Scope Peer Review LAR Status 9
10 Project Update/Schedule
Project Schedule 11
12 Human Factors Engineering Evaluation / Integrated System Validation
- NUREG-0711 is being used as a tool to develop the LGS HFE program plan and to identify the pertinent HFE activities to perform for the project.
- LGS is obligated to meet their regulatory and license basis HFE requirements, which are most explicitly defined in:
- Generic Letter 82-33 (NUREG-0737 Supplement 1)
- UFSAR Section 1.13
- Detailed Control Room Design Review (DCRDR) program plan.
- The conclusions in the NRCs SER for the LGS LAR are to be based on the actual requirements (i.e., not NUREG-0711 or 10 CFR 50.34(f))
- Therefore, LGS is proposing to submit to the NRC only those documents necessary to show compliance to the LGS HFE regulatory and license basis requirements.
LAR HFE Supporting Document Submittals 13
HFE Execution Summary, Status at LAR Submittal, and Expected Final Disposition 14 NUREG-0711 Element Current Status Final Disposition HFE Program Plan Complete Included in the LAR Submittal Operating Experience Review Complete Results Summary Report (RSR) available for audit (Q3 2022)
Functional Analysis and Allocation Workshop at Limerick Simulator (Complete)
Combined RSR included in LAR Submittal Task Analysis Workshop at INL Human Systems Simulation Laboratory (Complete)
Staffing & Quals Implementation description in HFE Plan Combined RSR included in LAR Submittal Treatment of Important Human Actions Implementation description in HFE Plan
HFE Execution Summary, Status at LAR Submittal, and Expected Final Disposition 15 NUREG-0711 Element Current Status Final Disposition HSI Design Initial Prototype displays to support CONOPS developed for Task Analysis Workshop based on HSI Style Guide This element is covered by Design Verification RSR.
Impacts to Procedures Implementation description in HFE Plan Combined RSR available for NRC audit (Q2 2023)
Impacts to Training Implementation description in HFE Plan Task Support Verification Implementation description in HFE Plan RSR will be submitted as a LAR supplement (Q1 2023)
HFE Execution Summary, Status at LAR Submittal, and Expected Final Disposition 16 NUREG-0711 Element Current Status Final Disposition Design Implementation Part of Constellation Engineering Change Package Installed per the design and implementation process date range.
No additional information included in the LAR for this element.
Integrated System Validation Developing implementation and simulator strategy for ISV.
Implementation description in HFE plan Perform ISV in Q3 2023.
RSR available in Q4 2023.
Design Verification Implementation description in HFE Plan Occurs as part of I&C design.
RSR, including any ISV updates, will be available for inspection (Q1 2024).
LAR will include a Regulatory Commitment to complete Design Verification activity.
Human Performance Monitoring Implementation description in HFE Plan Items are identified, post-installation, in CAP for evaluation and resolution.
Project Schedule 17
- Conceptual Verification (Q2 2023)
- Impacts to Procedures and Training (Combined RSR)
- HSI Design refinement
- Static HSI workshop
- Preliminary Validation (Q1 2023)
- Task Support Verification - Procedures & HSIs (RSR)
- HSI Design Refinement
- Dynamic HSI workshop
- Perform Preliminary Validation per NUREG-0800, Chapter 18, Attachment A, Guidance for Evaluating Credited Manual Operator Actions in efforts listed above.
- Integrated System Validation
- ISV Implementation Plan (Q2 2023)
- Execute ISV (Q3 2023)
- RSR available (Q4 2023)
- Design Verification RSR (Q1 2024)
Phased Verification/Validation Activities 18
19 Response to NRC Questions
- NRC Question If alternative approaches to a full-scope, plant-referenced Limerick simulator will be used to support the verification and validation process, please clarify how that will be achieved and what methods are planned to be used.
- Constellation answer:
The overall plan is to use the LGS ANSI simulator as the platform for ISV.
The simulator plan uses the early release of the safety and non-safety software platforms and will integrate those with the hardware at LGS The simulator plan uses a temporary physical configuration to run with the simulation software for training and testing The simulator software may undergo changes as integration and verification is ongoing and the software will be corrected and revised as necessary to support verification activities up to and including ISV Any HEDs identified during the process will be corrected and updated in the final simulator software release and incorporated in operator training Response to NRC Questions 20
- NRC Question:
With regard to the submitted Limerick defense-in depth and diversity coping analysis, how will the information regarding new and modified manual operator actions be applied going forward into the remainder of the digital I&C submittal?
(with a pointer to NUREG-0800 (SRP) Chapter 18. Attachment A).
- Constellation answer:
The manual actions credited in the D3 Coping Analysis and the Operator Actions which have been determined by PRA Reduction worth have been identified.
Each of these items will be screened to determine if the required action is impacted by the digital modification. Initial screening indicates there are less than 10 operator actions which fall into this category, but this review is preliminary at this time.
Preliminary validation of the implementation of these operator actions is planned to be performed during future static and dynamic workshops as the interface is developed and refined for each of the required actions.
ISV and the developed scenarios will serve to confirm the results of the preliminary validation efforts.
Response to NRC Questions 21
22 Next Pre-submittal Meeting Topics
23 Closing Comments
ADS Automatic Depressurization System FMEDA Failure Modes, Diagnostics, and Effects Analysis PPS Plant Protection System AER Auxiliary Equipment Room FPGA Field Programmable Gate Array PSAI Plant Specific Action Items AOI Advant Ovation Interface FSAR Final Safety Analysis Report QA Quality Assurance ARI Alternate Rod Injection HFE Human Factors Engineering QMP Quality Management Plan ARP Alternate Review Process HPCI High Pressure Core Injection RAI Request for Additional Information ASAI Application Specific Action Item HSL High Speed Link RCIC Reactor Core Isolation Cooling ATWS Anticipated Transient Without Scram IBR Incorporated by Reference RHR Residual Heat Removal BPL Bistable Protection Logic ILP Integrated Logic Processor RPS Reactor Protection System BWR Boiling Water Reactor INL Idaho National Labs RPV Reactor Pressure Vessel CAP Corrective Action Program I/O Input/Output RRCS Redundant Reactivity Control System CCF Common Cause Failure ITAAC Inspection, Test, Analysis, and Acceptance Criteria RWCU Reactor Water Cleanup CDO Central Design Organization LAR License Amendment Request SER Safety Evaluation Report CRDR Control Room Design Review LCL Local Coincidence Logic SFMS Supplier Fundamental Management System CIM Component Interface Module LGS Limerick Generating Station SDC Shutdown Cooling CRADA Cooperative Research and Development Agreement LOOP Loss of Offsite Power SDV Scram discharge volume CPU Central Processing Unit LPCI Low Pressure Coolant Injection SLCS Standby Liquid Control System CS Core Spray LRA Licensee Required Action SPDS Safety Parameter Display System D3 Defense-in-Depth and Diversity LTR Licensing Technical Report SPM Software Program Manual DCS Distributed Control System MCR Main Control Room SR Safety-related DDS Data Display System MPB Manual Partial Bypass SRNC Safety Remote Node Controller DEHC Digital Electro-Hydraulic Control MPT Manual Partial Trip SRV Safety Relief Valve DPS Diverse Protection System MSFIS Main Steam and Feedwater Isolation System SSE Safe Shutdown Earthquake ECCS Emergency Core Cooling System MSIV Main Steam Isolation Valve SyDS System Design Specification EDG Emergency Diesel Generator NSR Nonsafety-related SyRS System Requirements Specification EOP Emergency Operating Procedures NSSSS Nuclear Steam Supply Shutoff System TS Technical Specifications EQSR Equipment Qualification Summary Report OBE Operating basis earthquake TU Trip Unit ESFAS Emergency Safety Function Actuation System PC Personal Computer UFSAR Updated Final Safety Analysis Report FMEA Failure Modes and Effects Analysis PMS Protection and Monitoring System VOP Vendor Oversight Plan PPC Plant Process Computer WEC Westinghouse Acronyms