Dungeness B DPS Replacement Project Stage Submission Five

Title of document
F
PROJECT ASSESSMENT REPORT
Unique Document ID and
Revision No:
ONR-CNRP-PAR-14-016
Revision 0
Project:
Dungeness B Changeover from the Data Processing System
(DPS) to the Data Processing and Control System (DPCS) for
Reactor 21
Site:
Dungeness B
Title:
Dungeness B DPS Replacement Project Stage Submission Five
Part Two: Changeover for Reactor 21
Licence Instrument No:
TRIM Ref: 2014/358099
Agreement No 545
(if applicable)
Nuclear Site Licence No:
61
Licence Condition:
22(1)
Document Acceptance and Approval for Issue / Publication
Role
Name
Author
Reviewer
Accepted by
1
Approval for
publication 2
Position
Signature
Date
Principal Inspector
27 10 2014
Inspector
27 10 2014
Superintending
Inspector
27 10 2014
Superintending
Inspector
27 10 2014
Revision History
Revision
Date
A
27 10 2014
0
27 10 2014
1
2
Author(s)
Reviewed By
Accepted By
n/a
Description of
Change
1st draft for AUH
review
First accepted
issue
Acceptance of the PAR to allow release of LI
Approval is for publication on ONR web-site, after redaction where relevant
Template Ref: ONR-DOC-TEMP-005 Revision 9
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Circulation (latest issue)
Organisation
Name
Date
Office for Nuclear Regulation
Files:
4.4.1.2605.
4.4.2.11437.
4.6.1266.
Environment Agency
Licensee
Office for Nuclear Regulation
Nuclear Regulator
TSSM, Dungeness B
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Dungeness B Changeover from the Data Processing System (DPS) to the Data
Processing and Control System (DPCS) for Reactor 21
Dungeness B DPS Replacement Project Stage Submission Five Part Two: Changeover
for Reactor 21
Project Assessment Report ONR-CNRP-PAR-14-016
Revision 0
27 October 2014
Office for Nuclear Regulation
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Report ONR-CNRP-PAR-14-016
TRIM Ref: 2014/358099
© Office for Nuclear Regulation, 2014
If you wish to reuse this information visit http://www.onr.org.uk/copyright.htm for details.
Published 11/14
For published documents, the electronic copy on the ONR website remains the most current publicly
available version and copying or printing renders this document uncontrolled.
Office for Nuclear Regulation
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Report ONR-CNRP-PAR-14-016
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EXECUTIVE SUMMARY
Dungeness B Changeover from the Data Processing System (DPS) to the Data
Processing and Control System (DPCS) for Reactor 21
Dungeness B DPS Replacement Project Stage Submission Five Part Two: Changeover
for Reactor 21
Permission Requested
In accordance with arrangements made under Licence Condition 22(1) – Modification or
Experiment on Existing Plant, attached to nuclear site licence No 61, EDF Energy Nuclear
Generation Limited (NGL) has requested ONR’s Agreement for their proposal to the
changeover for Reactor 21 from the existing Data Processing System to the new Data
Processing and Control System as described in the document titled: EC No.: 340804 000
Proposal Version No.: 03 – DNB DPS Replacement Stage Submission Five Part Two:
Changeover, (SS5 Part 2) dated 21 August 2014 and as requested in the licensee’s letter
NSLDNB50887Y dated 19th September 2014.
Background
The existing Data Processing System (DPS) for Reactors 21 and 22 at Dungeness B is the
original equipment installed during the construction of the Station and is now obsolete. NGL
has proposed that the existing DPS is replaced by a modern equivalent referred to as a Data
Processing and Control System (DPCS) which will use modern computer-based systems and
equipment.
In 2013, ONR issued an Agreement to allow the DPCS to move into commissioning as
Licence Instrument (LI) 542. The issue of LI 542 showed that ONR was content for the
licensee to begin commissioning. In order to issue this LI for changeover on Reactor 21, ONR
needs to be content that the concerns raised on the design safety case have been
satisfactorily addressed and that NGL has successfully completed commissioning on
Reactor 21. Following ONR Agreement, the licensee will move the system into commissioned
operational service (COS) for Reactor 21, although not Reactor 22. During COS, there will be
further testing, but the system will be in operation on the reactor.
Assessment and inspection work carried out by ONR in consideration of this request
ONR has carried out a programme of control and Instrumentation (C&I) assessment work on
the DPCS, which has resulted in two assessment reports:


Assessment of the design of the DPCS (AR-13-091)
Assessment of the proposal for changeover from DPS to DPCS (AR-14-064)
Assessment of the design in AR-13-091 was not complete at the time that LI 542 was issued,
although the shortfalls were not sufficient to prevent commissioning proceeding. The design
assessment has now been completed and the report has concluded that:


the claims and related arguments of the licensee’s safety case have been
sufficiently substantiated by the evidence provided; and
the assessor is satisfied with the claims, arguments and evidence laid down
within the licensee’s safety case.
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Overall, the assessment concludes that the design of the DPCS is adequate to allow
changeover from the existing DPS at Dungeness B, subject to the ONR assessment of SS5
Part 2.
The assessment in AR-14-064 specifically considers the safety case for the changeover and
the adequacy of the development of the safety case during commissioning of the system.
AR-14-064 concludes that the safety case adequately supports the changeover from the
current DPS to the replacement DPCS on Reactor 21. Furthermore, this report judges that
the ONR technical assessment supports the site being operationally ready to make the
changeover.
Matters arising from ONR's work
For this assessment, effort has been concentrated on control and instrumentation. This has
concluded that there are no outstanding issues and hence no matters arising.
Conclusions
This report concludes that:


The licensee has completed its due process for the proposal.
The technical assessment supports ONR providing Agreement to the proposal.
It further concludes that ONR should provide its Agreement to the licensee’s proposal to
changeover from the DPS to the DPCS for Dungeness B Reactor 21.
Recommendation
I recommend that the Superintending Inspector:

Signs this Project Assessment Report to confirm support for the ONR technical
and regulatory arguments that justify issuing Dungeness B Licence Instrument
545.

Signs this Project Assessment Report approving its release for publication, after
redaction where appropriate.
Office for Nuclear Regulation
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LIST OF ABBREVIATIONS
ALARP
As Low As Reasonably Practicable
AR
Assessment Report
COS
Commissioned Operational Service
C&I
Control and Instrumentation
DPS
Data Processing System
DPCS
Data Processing and Control System
INSA
Independent Nuclear Safety Assessment
LI
Licence Instrument
NGL
EDF Energy Nuclear Generation Limited
NSC
Nuclear Safety Committee
ONR
Office for Nuclear Regulation
PAR
Project Assessment Report
SS5
Stage Submission 5 (part of licensee’s safety case)
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TABLE OF CONTENTS
1 PERMISSION REQUESTED............................................................................................... 9 2 BACKGROUND ................................................................................................................... 9 3 ASSESSMENT AND INSPECTION WORK CARRIED OUT BY ONR IN
CONSIDERATION OF THIS REQUEST ............................................................................. 9 4 MATTERS ARISING FROM ONR’S WORK...................................................................... 11 5 CONCLUSIONS ................................................................................................................ 11 6 RECOMMENDATIONS ..................................................................................................... 11 7 REFERENCES .................................................................................................................. 12 Office for Nuclear Regulation
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1
PERMISSION REQUESTED
1.
In accordance with arrangements made under Licence Condition 22(1) – Modification
or Experiment on Existing Plant, attached to nuclear site licence No 61, EDF Energy
Nuclear Generation Limited (NGL) has requested ONR’s Agreement for their proposal
to the changeover for Reactor 21 from the existing Data Processing System to the new
Data Processing and Control System as described in the document titled:
EC No.: 340804 000 Proposal Version No.: 03 – DNB DPS Replacement Stage
Submission Five Part Two: Changeover, (SS5 Part 2) dated 21 August 2014 (Ref 1)
and as requested in the licensee’s letter NSLDNB50887Y dated 19th September 2014
(Ref 2).
2
BACKGROUND
2.
The existing Data Processing System (DPS) for Reactors 21 and 22 at Dungeness B is
the original equipment installed during the construction of the Station and is now
obsolete. NGL has proposed that the existing DPS is replaced by a modern equivalent
referred to as a Data Processing and Control System (DPCS) which will use modern
computer-based systems and equipment. The DPCS, in common with the existing
DPS, which it is to replace, provides the Central Control Room with alarms and
indications on computer display screens and a number of control functions.
3.
In 2013, ONR issued an Agreement to allow the DPCS to move into commissioning as
Licence Instrument (LI) 542 (Ref 3). During the assessment of the safety case for
commissioning, the ONR Control & Instrumentation (C&I) specialist inspector raised
concerns about the visibility of the design safety case in his Assessment Report (AR)
that was ongoing (Ref 4). He judged that this issue was not sufficiently significant to
prevent commissioning proceeding, but that it would need to be fully resolved before
changeover on the first reactor. As a result, he recommended that NGL should not
proceed with changeover to the lead reactor until ONR had issued a Licence
Instrument agreeing to the changeover. This was supported in the Project
Assessment Report (PAR) for the permission to commence commissioning of the
DPCS (Ref 5).
4.
As required under its arrangements, NGL has now requested ONR Agreement to the
changeover from the DPS to the DPCS for Reactor 21 in its letter NSLDNB50887Y
dated 19th September 2014 (Ref 2).
5.
The issue of LI 542 showed that ONR was content for the licensee to begin
commissioning. In order to issue LI 545 for changeover, ONR needs to be content that
the concerns raised on the design safety case have been satisfactorily addressed and
that NGL has successfully completed commissioning on Reactor 21. Following ONR
Agreement, the licensee will move the system into commissioned operational service
(COS) for Reactor 21, although not Reactor 22. During COS, there will be further
testing, but the system will be in operation on the reactor.
3
ASSESSMENT AND INSPECTION WORK CARRIED OUT BY ONR IN
CONSIDERATION OF THIS REQUEST
3.1
LICENSEE’S DUE PROCESS
6.
Under the licensee’s arrangements, the safety case submission for the proposed
activity is categorised as 2. This requires the licensee to complete an Independent
Nuclear Safety Assessment (INSA), but not to submit the case for review by its
Nuclear Safety Committee (NSC). The INSA Approval Statement (Ref 6) notes that
there were a number of issues to be resolved and it was issued with a number of
caveats to be addressed to the satisfaction of the INSA engineer, before approval to
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implement changeover. To ensure that these have been addressed, INSA has issued
a concurrence statement (Ref 7). The content of the concurrence statement has been
considered in the technical assessment in §3.2 below. For the purposes of this
section, issue of the concurrence statement is sufficient to support the licensee
completing its due process.
7.
I conclude that the licensee has completed its due process for the proposal.
3.2
TECHNICAL ASSESSMENT
8.
ONR has carried out a programme of C&I assessment work on the DPCS, which has
resulted in two ARs:


9.
Assessment of the design of the DPCS (AR-13-091) (Ref 4).
Assessment of the proposal for changeover from DPS to DPCS (AR-14-064)
(Ref 8).
As noted in paragraph 3, assessment of the design in AR-13-091 was not complete at
the time that LI 542 was issued. This has now been completed and the C&I specialist
inspector has concluded that:


the claims and related arguments of the licensee’s safety case have been
sufficiently substantiated by the evidence provided; and
he is satisfied with the claims, arguments and evidence laid down within the
licensee’s safety case.
Overall, the assessment concludes that the design of the DPCS is adequate to allow
changeover from the existing DPS at Dungeness B subject to the ONR assessment of
SS5 Part 2.
10.
The assessment in AR-14-064 specifically considers the safety case for the
changeover in SS5 Part 2 and the adequacy of the development of the safety case
during commissioning of the system. AR-14-064 concludes that the licensee has
demonstrated that:



The risks associated with implementing changeover from the existing DPS to
the DPCS are As Low As Reasonably Practicable (ALARP).
Adequate provision has been made to support operation and maintenance of
the DPCS post changeover.
There are no significant residual issues that could compromise safety claims
made on the DPCS when in operational service.
The report concludes that SS5 Part 2 adequately supports the changeover from the
current DPS to the replacement DPCS on Reactor 21.
11.
AR-14-064 also concludes that:




12.
The Dungeness B DPCS has been adequately commissioned.
Relevant station documentation has been modified.
Dungeness B personnel have been trained to operate/maintain the DPCS.
The changeover strategy is clearly defined with sufficient level of oversight.
I judge that these conclusions demonstrate that, in addition to the conclusions on the
design in the previous paragraph, the ONR technical assessment supports the site
being operationally ready to make the changeover.
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13.
Finally, as noted in paragraph 6, the licensee’s INSA includes caveats, which it has
addressed in a concurrence statement (Ref 7). In AR-14-064 the C&I specialist
inspector notes in a number of places that the concurrence statement satisfactorily
addresses individual caveats in the INSA statement. I therefore conclude that the
content of the concurrence statement adequately covers the caveats.
14.
From the above, I conclude that the technical assessment supports ONR providing
Agreement to the proposal to changeover from the DPS to the DPCS and moving into
COS for Reactor 21.
3.3
CONSULTATION WITH OTHER REGUALTORS
15.
I have judged that there are no matters associated with the proposal that require
consultation with other regulators.
4
MATTERS ARISING FROM ONR’S WORK
16.
For this assessment, effort has been concentrated on control and instrumentation.
This has concluded that there are no outstanding issues and hence no matters arising.
5
CONCLUSIONS
17.
This report presents the findings of the ONR assessment of the NGL proposal to
change over from the DPS to the DPCS for Dungeness B Reactor 21, which includes
moving the DPCS into COS.
18.
I have concluded that:


The licensee has completed its due process for the proposal.
The technical assessment supports ONR providing Agreement to the proposal.
19.
To conclude, I am satisfied with the claims, arguments and evidence laid down within
the proposal and that ONR should provide its Agreement to the proposal. I have
therefore drafted an Agreement to the licensee’s request to changeover from the DPS
to the DPCS for Dungeness B Reactor 21 as LI 545 (Ref 9). The LI is one of the
standard formats given within ONR procedures and does not require review by the
Solicitors Office.
6
RECOMMENDATIONS
20.
I recommend that the Superintending Inspector:


Signs this Project Assessment Report to confirm support for the ONR technical
and regulatory arguments that justify issuing Dungeness B Licence Instrument
545.
Signs this Project Assessment Report approving its release for publication, after
redaction where appropriate.
Office for Nuclear Regulation
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7
REFERENCES
1.
DNB DPS Replacement Stage Submission Five Part Two: Changeover
NGL document EC no 340804 000 Proposal Version No.: 03, dated 21 August 2014
Trim ref 2014/339587 (EC), Trim ref 2014/381807 (EC dates)
2.
Request for Agreement under Arrangements Made Under Licence Condition 22(1)
EC 340804: Dungeness B: DPS Replacement Project Stage Submission 5 Part 2 –
Changeover (Stage Submission 5 Part 2 Under Paper of Principle NP/SC 7373)
NGL letter NSLDNB50887Y dated 19th September 2014
Trim ref 2014/352086
3.
Agreement to NP/SC 7373 DPS Replacement Project Stage Submission 5 Part 1 Commissioning
Licence Instrument 542 issued as ONR letter DNB71251N dated 19 December 2013
Trim ref 2013/392520
4.
Control and Instrumentation Assessment of the design (Stage Submission 2) of the
Dungeness B Data Processing System Replacement (NP/SC 7373)
NP/SC 7373 Data Processing System Replacement: Stage Submission 2 Rev 003 –
Design
ONR Assessment Report ONR-CNRP-AR-13-091 Revision 0 dated 23 October 2014
Trim ref 2014/300623
5.
Dungeness B Power Station
Agreement to DPS Replacement Project Stage Submission 5 Part 1 – Commissioning
ONR Project Assessment Report ONR-DNB-PAR-13-036 Revision 0 dated
19 December 2013
Trim ref 2013/404205
6.
DNB DPS Replacement Stage Submission 5 Part 2: Changeover to the DPCS
NGL Milestone Full INSA Approval Statement for Dungeness B EC No.: 340804 000
Proposal Version No.: 03, dated 21 August 2014
Trim ref 2014/317530
7.
Independent and Nuclear Assurance Division – Concurrence Part B – Replacement
Data Processing System for Reactor 21 at Dungeness B Phase 5 – Changeover from
DPS to DPCS
NGL document SRD/REP/CON/DNB/001B/05 Revision 000 dated October 2014
TRIM Ref. 2014/387502
8.
Dungeness B
Control and Instrumentation assessment of Stage Submission 5 Part 2: Changeover,
EC 340804 000 of the Dungeness B Data Processing System Replacement Project.
DNB DPS Replacement Stage Submission 5 Part 2: Changeover, EC 340804 000, on
Reactor 21
ONR Assessment Report ONR-CNRP-AR-14-064 Revision 0 dated 23 October 2014
Trim ref 2014/361783
9.
Agreement to DNB DPS Replacement Stage Submission 5 Part 2: Changeover for
Reactor 21
Licence Instrument 545 issued as ONR letter DNB71261N dated 27 October 2014
Trim ref 2014/340393
Office for Nuclear Regulation
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