DCL-11-104, Attachment 1: List of Regulatory Commitments
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Enclosure Attachment 1 PG&E Letter DCL-1 1-104 List of Regulatory Commitments Commitment 1 Phase 2 documents that have not been previously submitted to the staff will be submitted within 12 months of the requested approval date, by May 30, 2012, except for the specific Phase 2 documents identified below that require manufacture and factory acceptance testing to complete.
Commitment 2 The following Invensys Operations Management Phase 2 documents will be submitted by December 2012:
Summary Test Reports (including Factory Acceptance Tests)
Summary Test Results (including Factory Acceptance Tests)
Summary of Final Digital Electromagnetic Interference, Temperature, Humidity, and Seismic Testing Results for 3601 TN Module System Response Time Confirmation As-Manufactured, System Configuration Documentation The following Westinghouse Phase 2 documents will be submitted by December 2012:
Summary Test Reports (including Factory Acceptance Tests)
Summary Test Results (including Factory Acceptance Tests)-
As-Manufactured, System Configuration Documentation Commitment 3 The FSAR changes and Technical Specification Bases changes will be submitted within 12 months of the requested approval date by May 30, 2012.
Commitment 4 The controls for access to maintenance workstation functions beyond displaying data is security-related information per 10 CFR 2.390 and will be provided in a separate letter to the NRC staff.
Commitment 5 Disabling points in the Tricon for any reason will be under administrative control using an approved procedure.
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Enclosure Attachment 1 PG&E Letter DCL-1 1-104 Commitment 6 PG&E practices power supply quality monitoring per the guidance of NRC RG 1.180.
As-found and as-left Total Harmonic Distortion measurements will be performed at PPS 120 V AC power supply input terminals before and after installation of equipment powered from the 120 V AC vital instrument power supply. If needed, corrective measures will be implemented during installation.
Commitment 7 The Tricon and the Advanced Logic System subsystem in each Protection Set are provided with its own pair of safety-related adjustable redundant loop power supplies capable of powering all 4-20 mA instrument input loops associated with that subsystem.
Operating voltage will be selected during detailed design to power instrument loops without exceeding voltage limitations of instrument loop sensors (transmitters).
Commitment 8 The cabinets will be evaluated for seismic considerations as part of the detailed PPS replacement design. Non-safety-related hardware mounted in the PPS cabinets will be evaluated for seismic interactions during the detailed design.
Commitment 9 The PPS rack locations is security-related information per 10 CFR 2.390 and will be provided separately.
Commitment 10 A Modification Test Plan (MTP) will be developed for the project. The MTP specifies the necessary testing to be performed during and after installation of the PPS replacement systems and components.
Commitment 11 Installation of the PPS replacement systems and components will be performed in accordance with written installation procedures and work orders. The scope of the installation procedures and work orders inclujdes safety tagging requirements, demolition and removal of old components, modification of racks for seismic requirements, installation of new equipment, modification of supporting structures, cabling, terminations, checkout, and system power up.
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Enclosure Attachment 1 PG&E Letter DCL-1 1-104 Commitment 12 The analysis for the PPS processing instrumentation response times will be provided in Phase 2 for NRC review.
Commitment 13 During the Site Acceptance Test PG&E will test the Protection Set communications paths illustrated in Figure 4-13 to verify that there is no inbound communications path associated with port aggregator network tap Port 1. That is, PG&E will verify that communications from Port 1 to either the TCM on Port A or the MWS on Port B of the port aggregator network tap are not permitted. Results of this test will be documented in final System Verification and Validation Report.
Commitment 14 Port aggregator dual in-line package (DIP) switch positions will be controlled.
Commitment 15 Access to MWS functions beyond displaying data, such as the maintenance bypass, will be under administrative and physical controls.
Commitment 16 The MWS interface will also have protective measures built in, such as password-protected log-on, role-based security functions to ensure only authorized individuals have the ability to update tuning parameters.
Commitment 17 The Software Design Description (SDD) for the IOM scope of the PPS Replacement Project will be submitted to the NRC for review in Phase 2.
Commitment 18 Analysis of all components being installed as part of the Tricon portion of the PPS replacement to PG&E Environmental Quality requirements will be provided in Phase 2.
Commitment 19 The communication architecture has been analyzed for hazards and performance deficits as reflected in the final Advanced Logic System communication design.
Unneeded functionality and complications are eliminated and will be rechecked and eliminated during the application design.
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Enclosure Attachment 1 PG&E Letter DCL-1 1-104 Commitment 20 System setpoints require evaluation to determine if changes are needed. The current setpoint methodology approved for the Eagle 21 PPS is provided in WCAP-1 1082.
However, these calculations are being modified to consider applicable setpoint methodology guidance such as International Society of Automation (ISA) S67.04-2006, Regulatory Information Summary (RIS) 2006-17 and TSTF-493 R4. This setpoint modification will include the impact of replacing the Eagle 21 PPS with the Tricon and Advanced Logic System PPS replacement. When complete, the methodology will show an acceptable margin between all trip setpoints and the respective analytical limits.
This will assure acceptable completion criteria for all of the effected protective functions.
A summary of the calculations will be provided to the NRC during the License Amendment Request Phase 2 submittal period.
Commitment 21 A System Level Failure Modes and Effects Analysis that meets the requirements of IEEE 603-1991 [21], Clause 5.1 will be performed during Phase 2 of the PPS replacement project to ensure the Single Failure Criterion is met at the combined Tricon and Advanced Logic System PPS replacement system level.
Commitment 22 A Tricon application level FMEA will be performed during Phase 2 of the PPS replacement project.
Commitment 23 An Advanced Logic System application level FMEA will be performed during Phase 2 of the PPS replacement project.
Commitment 24 Calibration and testing will be performed according to approved procedures that establish specific surveillance techniques and surveillance intervals intended to maintain the high reliability of the PPS replacement.
Commitment 25 Administrative procedures will provide appropriate guidance in the event a portion of the PPS replacement is in bypass or is manually tripped.
Commitment 26 For both the Triconex and Advanced Logic System subsystems, the platform self-tests and the application specific test and calibration functions will be performed during the 4
Enclosure Attachment 1 PG&E Letter DCL-1 1-104 Factory Acceptance Test to verify that the safety function is not adversely affected by performance of either built-in or application specific test and calibration functions.
Commitment 27 The PPS replacement contains design features that provide means to control physical access to safety related equipment. This includes access to PPS replacement equipment which encompasses the test points and the capabilities for changing setpoints. Keys to the cabinet doors will be maintained under the administrative control of DCPP operating staff.
Commitment 28 Access to equipment rooms and cabinets including the Maintenance Workstation will be controlled by DCPP only to personnel who are intended to have access.
Commitment 29 Test Design Specifications will be provided to NRC in the PPS replacement Phase 2 documentation per DI&C-ISG-06 Section D4.4.2.4.
Commitment 30 The total loop uncertainties are utilized in the safety analyses to ensure that the analyzed values are bounding and conservative. The values calculated for the new Tricon and Advanced Logic System will be provided to NRC in Phase 2 and compared with the analytical limits, total loop uncertainties and current setpoints to ensure that the analyzed values are bounding and conservative.
Commitment 31 The implementation of the as-found tolerance and as-left tolerance guidance from Regulatory Issue Summary 2006-17 and TSTF-493, Revision 4, to all applicable TS setpoints will be addressed as part of the License Amendment Request for TSTF-493.
Commitment 32 For both the Triconex and Advanced Logic System subsystems, the platform self-tests and the application specific test and calibration functions will be verified during the Factory Acceptance Test to ensure that the Protection Set safety function is not adversely affected by performance of either built-in or application specific test and calibration functions.
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Enclosure Attachment 1 PG&E Letter DCL-1 1-104 Commitment 33 For the condition that one Tricon leg in a channel is out of service, the protection function can still be performed and the channel is operable, however the redundancy of the Tricon has been reduced and therefore the situation will be administratively controlled to require restoration of the Tricon leg within 30 days. For the condition that two Tricon legs in a channel are out of service, the protection function can still be performed and the channel is operable, however the redundancy of the Tricon has been significantly reduced and therefore the situation will be administratively controlled to require restoration of one of the two Tricon legs within 7 days.
Commitment 34 For the condition that the Advanced Logic System A or B core is out of service, the protection function can still be performed and the channel is operable, however the redundancy and diversity of the Advanced Logic System has been reduced and therefore the situation will be administratively controlled to require restoration of the Advanced Logic System core within 30 days. For the condition that an Advanced Logic System A or B core is out of service in Protections Sets I and II, TS 3.3.3 Condition A will also need to be entered because the reactor coolant system wide range temperature parameter provided by Advanced Logic System to the Post Accident Monitoring Instrumentation RCS hot leg temperature, RCS cold leg temperature, and reactor vessel water level indication system parameters will be inoperable.
Commitment 35 A description of the security controls to be included in the PPS replacement is security-related information per 10 CFR 2.390 and will be provided in a separate letter the NRC staff.
Commitment 36 The DCPP Tricon Software Requirements Specification will be submitted to the staff by November 11, 2011.
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