ML102280124
| ML102280124 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar |
| Issue date: | 08/02/2010 |
| From: | - No Known Affiliation |
| To: | Division of Operating Reactor Licensing |
| References | |
| Download: ML102280124 (33) | |
Text
1 WBN2Public Resource From:
Hamill, Carol L [clhamill@tva.gov]
Sent:
Monday, August 02, 2010 2:26 PM To:
Wiebe, Joel; Raghavan, Rags; Milano, Patrick; Campbell, Stephen Cc:
Crouch, William D; Arent, Gordon; Knuettel, Edward Terry
Subject:
7-30-10_TVA letter to NRC--RAI--Instrument and Controls response Attachments:
7-30-10_RAI--Instrument and Controls response_NRC letter.pdf Please see attached letter that was mailed to the NRC today.
Carol L. Hamill Licensing/QualityAssurance WBNUnit2Project,EQB1BWBN
4233653177
4233653833
ccllhhaam miillll@
@ttvvaa..ggoovv
Hearing Identifier:
Watts_Bar_2_Operating_LA_Public Email Number:
69 Mail Envelope Properties (25547F570B005144A141ECCA95DA1AB20CEDA1C8)
Subject:
7-30-10_TVA letter to NRC--RAI--Instrument and Controls response Sent Date:
8/2/2010 2:26:00 PM Received Date:
8/2/2010 2:27:04 PM From:
Hamill, Carol L Created By:
clhamill@tva.gov Recipients:
"Crouch, William D" <wdcrouch@tva.gov>
Tracking Status: None "Arent, Gordon" <garent@tva.gov>
Tracking Status: None "Knuettel, Edward Terry" <etknuettel@tva.gov>
Tracking Status: None "Wiebe, Joel" <Joel.Wiebe@nrc.gov>
Tracking Status: None "Raghavan, Rags" <Rags.Raghavan@nrc.gov>
Tracking Status: None "Milano, Patrick" <Patrick.Milano@nrc.gov>
Tracking Status: None "Campbell, Stephen" <Stephen.Campbell@nrc.gov>
Tracking Status: None Post Office:
TVACOCXVS2.main.tva.gov Files Size Date & Time MESSAGE 226 8/2/2010 2:27:04 PM 7-30-10_RAI--Instrument and Controls response_NRC letter.pdf 247269 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
U.S. Nuclear Regulatory Commission Page 2 July 30, 2010 cc (Enclosures):
U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Resident Inspector Unit 2 Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381
U.S. Nuclear Regulatory Commission Page 3 July 30, 2010 bcc (Enclosures):
Lakshminarasimh Raghavan U.S. Nuclear Regulatory Commission MS 08H4A One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 Stephen Campbell U.S. Nuclear Regulatory Commission MS 08H4A One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 Patrick D. Milano, Senior Project Manager U.S. Nuclear Regulatory Commission MS 08H4 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 Loren R. Plisco, Deputy Regional Administrator for Construction U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 1 of 18
- 1. NRC Request (Item Number 6)
Amendment 95 of the FSAR, Chapter 7.3, shows that change 7.3-1 consists of updating a reference from revision 5 to revision 7 and making it applicable to Unit 1 only, while adding a new reference, applicable only to Unit 2.
Reagan, J. R., "Westinghouse Setpoint Methodology for Protection Systems, Watts Bar Units 1 and 2, Eagle 21 Version," WCAP-12096 Rev. 7, (Westinghouse Proprietary Class 2). Unit 1 Only WCAP Westinghouse Setpoint Methodology for Protection System, Watts Bar Unit 2, Eagle 21 Version, WCAP-17044-P. Unit 2 Only.
Please provide both setpoint methodology documents identified above.
TVA Response:
TVA responded to this request in its letter dated March 12, 2010 (Reference 5) (Enclosure 1, Item Number 6 on Page 5 of 15). As stated in Reference 5, TVA provided the Unit 2 setpoint methodology (WCAP-177044-P Revision 0, dated December 2009) in a February 5, 2010 letter (Reference 10) and WCAP-12096, Revision 7 was submitted in a June 4, 1997 letter (Reference 11).
Revised Request and Responses:
- a. TVA to docket Rev. 8 and identify that Rev. 8 is the current revision for Unit 1. TVA to identify any NRC approval of Rev. 8.
In accordance with item 2 below, there is no change to the methodology; therefore, Revision 8 is not included in this response.
Westinghouse letter WAT-D-10502 (Attachment 1) describes the two changes to WCAP-12096 Revision 8. The first change addresses the containment sump level transmitter replacement.
This change was submitted under 50.59 summary report (ML073460444, Page 77). The second change is to delete the power range negative flux rate trip. This item was submitted as a Technical Specification change (ML073201052). The Technical Specification change was subsequently approved.
The current revision of Unit 1 WCAP-12096 is Revision 9. Revision 9 was issued to make the changes required by the Steam Generator Replacement Project. Unit 2 is using the original steam generators; therefore, the changes in Revision 9 are not applicable to Unit 2.
- b. TVA to describe how TVA calculations for Unit 2 are different than Unit 1. If they are the same, TVA to docket such statement under oath and Affirmation.
TVA addressed this request in Reference 5 (see Enclosure 1, Item Number 7). However, that letter was not submitted under oath and affirmation. This letter fulfills the oath and affirmation requirements for the previous response.
TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 2 of 18
- 2. NRC Request (Item Number 7)
The setpoint methodology has been reviewed and approved by the NRC staff in Section 7.1.3.1 of NUREG-0847 (ML072060490), NUREG-0847 Supplement No.4 (ML072060524), and NUREG-0847 Supplement No. 15 (ML072060488).
Please describe all changes from the methodology that has been reviewed and approved by the staff.
TVA Response:
TVA responded to this request in Reference 5 (Enclosure 1, Item Number 7 on page 6 of 15).
Revised Request and Responses:
- a. TVA will submit WCAP-12096, Rev. 8 if there is a change to the methodology.
There is no change in methodology. Therefore WCAP-12906, Revision 8 is not submitted.
- b. TVA will supply the 50.59 letter for Rev. 8 Westinghouse letter WAT-D-10502 (Attachment 1) describes the two changes to WCAP-12096 Revision 8. The first change addresses the containment sump level transmitter replacement.
This change was submitted under a 50.59 summary report (ML073460444, Page 77). The second change is to delete the power range negative flux rate trip. This item was submitted and approved as a Technical Specification change (ML073201052).
- c. TVA to locate transmittal letter that submitted Rev. 7.
Refer to reponse to NRC Request Number 1 (Item Number 6) above. TVA responded to this request in Reference 5 (see Enclosure 1, Item Number 6).
- d. TVA to determine the last revision of WCAP-12096 where there was a change in methodology.
Previous revisions to WCAP-12096 have been due to hardware changes. The calculation methodology has not changed since Revision 0.
- 3. NRC Request (Item Number 12)
The original SER on Watts Bar (NUREG-0847) documents that the scope of the review of FSAR Section 7.4, "Systems Required for Safe Shutdown," included single-line and schematic diagrams:
"The scope of the review of the systems required for safe shutdown included the single-line and schematic diagrams and the descriptive information for these systems and for the auxiliary systems essential for their operation."
Please provide the single-line and schematic diagrams for the systems required for safe shutdown that are applicable to Unit 2, and include a description of all changes since these diagrams were reviewed and approved by the NRC staff.
TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 3 of 18 TVA Response:
TVA responded to this request in Reference 5 (Enclosure 1, Item Number 12 on Page 14 of 15)
Revised Request and Response:
a.
Identify the technical differences between Unit 1 and Unit 2 FSAR Section 7.4 There are no technical differences between the Unit 1 and Unit 2 FSAR sections 7.4.
- b. Provide a roadmap between the functions described in FSAR Section 7.4 and where they are described in the FSAR.
The following is the requested road map between functions listed in Section 7.4 and the FSAR sections that describe functions.
Monitoring Indicators FSAR Section(s)
(1)
Water level indicator for each steam generator 7.2.2 (2)
Pressure and saturation temperature indicator for each steam generator 7.2.2 (3)
Pressurizer water level indicator 7.2.2 and 5.6 (4)
Pressurizer pressure indicator 5.6 and 7.2.2 (5)
Source range neutron flux 7.7.1.3.1 (6)
Reactor coolant system hot leg temperature 5.6 (7)
Auxiliary feedwater (AFW) flow to each steam generator 10.4.9.5 (8)
Essential raw cooling water header flow 9.2.1.5.3 (9)
Charging pumps discharge header pressure and flow 9.3.4 (10) Letdown heat exchanger outlet temperature 9.3.4 (11) Emergency boration flow 9.3.6 (12) Component Cooling System (CCS) flow to miscellaneous equipment 9.2.2 (13) CCS surge tank level 9.2.2 (14) CCS pumps discharge header pressure 9.2.2 (15) Volume control tank level 9.3.4 Pumps and Fans FSAR Section(s)
(1)
AFW pumps 10.4.9 (2)
Charging and boric acid transfer pumps 9.3.4 and 9.3.6 (3)
Essential raw cooling water pumps 9.2.1 (4)
Component cooling water pumps 9.2.2 (5)
Auxiliary control air compressors 9.3.1 (6)
Reactor containment fan cooler units 9.4.7 TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 4 of 18 Valves and Heaters FSAR Section(s)
(1)
Charging flow control valves 9.3.4 and 9.3.6 (2)
Letdown orifice isolation valves 9.3.4 (3)
AFW control valves 10.4.9 (4)
Steam dump/atmospheric steam dump 7.7, 10.3 and 10.4.4 (5)
Pressurizer heater control 7.7.1.5, 7.2.2.3.3 and 7.2.1.1.2 Equipment and Systems Available for Cold Shutdown FSAR Section(s)
(1)
Reactor coolant pumps 5.5.1 (2)
AFW pumps 10.4.9 (3)
Boric acid transfer pumps 9.3.4 (4)
Charging pumps 9.3.4 and 9.3.6 (5)
Service water pumps (Emergency raw cooling water pumps)
NOTE: This is referring to the Essential Raw Cooling Water System. The text will be revised in FSAR Amendment 100.
9.2.1 (6)
Containment fans 9.4.7 (7)
Control room ventilation 9.4.1 (8)
Component cooling pumps 9.2.2 (9)
Residual heat removal pumps 5.5.7 (10) Class 1E power systems 8.3 (11) Controlled steam release and feedwater supply 7.7, 10.3, 10.4.4 and 10.4.7 (12) Boration capability 9.3.4 and 9.3.6 (13) Nuclear instrumentation system (source range or intermediate range) 7.2 and 7.7.1.3.1 (14) Reactor coolant inventory control (charging and letdown) 9.3.4 and 9.3.6 (15) Pressurizer pressure control including opening control for pressurizer relief valves heaters and spray valves 7.7.1.5, 7.2.2.3.3 and 7.2.1.1.2
- 4. NRC Request (Item Number 45)
For each system implemented using a digital technology, please identify (1) any communications between divisions, or (2) between safety-related equipment and non-safety-related equipment. (3)
Please describe the implementation of the associated communications isolation.
TVA Response:
- 1) Communications between divisions This question applies to digital safety-related systems. The only safety-related systems implemented using digital technology are Eagle 21, the Common Q Post Accident Monitoring System (PAMS) and the Containment High Range Radiation Monitors.
TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 5 of 18 a) Eagle 21 - There are no communications between divisions. The divisions are physically separate with no interconnection from the input to the outputs. See Reference 3, Section 2.3.4.
b) Common Q PAMS - There are no communications between divisions. The divisions are physically separate with no interconnection from the input to the displays. Refer to WNA-LI-00058-WBT-P, Tennessee Valley Authority (TVA) Watts Bar Unit 2 (WBN2) Post-Accident Monitoring System (PAMS) Licensing Technical Report Revision 0 (Reference 4), Figure 2.2-1, Watts Bar Unit 2 PAMS Hardware Architecture, submitted under TVAs June 30, 2010 letter (Reference 12).
c) Containment High Range Radiation Monitors - The monitors are independent standalone devices with no physical connection to each other.
- 2) Communications between digital safety-related and non-safety-related equipment a) The safety related Eagle 21 system communicates with the following non-safety related systems:
i)
Plant Computer ii) Foxboro Intelligent Automation (IA) Distributed Control System (DCS) iii) Annunciator System b) The safety-related Common Q PAMS communicates with the following non-safety-related system:
i)
Plant Computer c) The safety-related Containment High Range Radiation Monitors communicates with the following non-safety-related systems:
i)
Annunciator System ii) Plant Computer System
- 3) Describe the implementation of communications isolation between digital safety-related systems and non-safety-related systems a) Eagle 21 i)
The digital communications isolation between Eagle 21 and the plant computer is described in TVA letter dated August 25, 2008, Enclosure 1, Response to NRC Question 1 (Reference 2). Some analog outputs are sent directly to the plant computer. These outputs use the same qualified analog output module as the Foxboro 1A interface described below.
ii) The communications between Eagle 21 and the annunciator system are via the Contact Output Module, which is a qualified isolation device, as described in Reference 3, Section 3.2.4, and the Partial Trip Output Module, which is a qualified isolation device, as described in Reference 3, Section 3.2.5.
TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 6 of 18 iii) The communications between Eagle 21 and the Foxboro IA DCS system are via the safety-related Analog Output Module, which is a qualified isolation device as described in Reference 3, Section 3.2.3.
b) Common Q - The communications isolation between the safety-related Common Q PAMS system and the plant computer are unidirectional via the qualified Maintenance Test Panel software (required by Reference 1, R7.2.34-4 and confirmed in Reference 4, Section 5.3, Criterion 4) and a non-safety-related data diode described in NRC Request Number 14 (Item Number 120) below.
c) Containment High Range Radiation Monitors
- i. The communications isolation between the safety-related radiation monitors and the non-safety-related annunciator system is provided by the output relay contacts in the monitor. Per exception EX-WB-DC-30-4-48 Revision 1 (Attachment 9), separation between the field wiring and the panel wiring is not required.
ii. The communication to the non-safety-related plant computer is from the analog output of the monitor via qualified isolation cabinets 2-R-163 (Train A) and 2-R-164 (Train B).
- 5. NRC Request (Item Number 47)
The PAMS System Requirements Specification (SysRS) references RG 1.97 Rev. 3 where the FSAR References Rev. 2. Please explain.
TVA Response:
The licensing basis for WBN Unit 2 is Regulatory Guide 1.97, Revision 2. The Common Q PAMS system was designed to Regulatory Guide 1.97, Revision 3, which is the basis for the System Requirements Specification referencing Revision 3. In order to resolve this discrepancy, an engineering evaluation of the Common Q PAMS was performed. contains an engineering evaluation of the Common Q PAMS design against the requirements of Reg. Guide 1.97, Revision 2. The evaluation concluded that the Common Q PAMS meets all requirements of Reg, Guide 1.97, Revision. 2. This evaluation will be added to design criteria WB-DC-30-7, Post Accident Monitoring Instrumentation, by October 1, 2010.
- 6. NRC Request (Item Number 80)
FSAR Table 7.1-1, Note 12 has been added to the table but it's justification has not been provided to the staff for review and approval.
Note 12 will be revised as shown below in FSAR Amendment 100 (the proposed revision is in bold print).
TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 7 of 18 Note 12:
Conforms except as noted below. Refer to Section 7.6.7 for a discussion of the digital metal impact monitoring system (DMIMS) which is the Watts Bar Unit 2 loose part monitoring system.
Position C.5.a. states that the sensor location should be noted in the Technical Specifications. The Watts Bar Loose-Part Detection System Technical Specifications were relocated to the Technical Requirements Manual. The Technical Requirements Manual describes the sensor locations (TRM B3.3.6, Loose Parts Detection System).
Positions C.3.a.(3) and C.5.c. recommend a channel calibration be performed at least once per 18 months. In lieu of this recommendation, the DMIMS will be calibrated at the frequency stated in subsection TSR 3.3.6.3 of TR 3.3.6 (Loose-Part Detection System).
Positions C.3.a.(2) (a) and (e) state that the alert levels for startup and power operation be submitted to the Commission within 90 days (60 days for subsection (e)) following the completion of the startup test program or when there is a change to the preexisting alert levels for power operation. Watts Bar Unit 2 will report changes in the alert level alarm to the Commission when they exceed the setpoint determination criteria described in Section 7.6.7.
Justification for Note 12:
Position C.5.a. - The relocation of the Loose Part Detection System to the Technical Requirements Manual was approved as part of the original Unit 1 License.
Positions C.3.a.(3) and C.5.c - Relocation of the Loose Part Detection System to the Technical Requirements Manual allows the licensee to adjust the channel calibration frequency in accordance with 10CFR50.59. The current frequency is 18 months. This exception is in accordance with the ability to change under 10CFR50.59.
Positions C.3.a.(2) (a) and (e) - In accordance with the design and operation of the DMIMS as described in FSAR Section 7.6.7, alert levels are established during system startup and are not expected to change during power operation. No exceptions to the timeliness requirements are taken.
- 7. NRC Request (Item Number 82)
The PAMS Licensing Technical Report (WNA-LI-00058-WBT Rev. 0, Dated April 2010), in Section 2.3, lists hardware/software changes to the Common Q PAMS previously reviewed by the NRC.
However the Common Q ISG-6 Compliance Matrix does not contain activities that address qualification of all changes specifically:
2.c - CI527 AF100 Peripheral Component Interconnect (PCI) interface card
- 3. - Common Q TC514 AF100 Fiber Optic Modems (Evolutionary Product Maintenance/Improvements)
TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 8 of 18 4.a - PM646A Processor Module 4.b - CI631 AF100 Communication Interface Module 4.e - DO620 Digital Output Card Please provide sufficient detail regarding the changes for the NRC to independently evaluate the acceptability of the changes.
TVA Response:
The revised Common Q PAMS ISG-6 Compliance Matrix was submitted in TVAs June 18, 2010 letter (Reference 6). The items listed above have been added to the matrix. In accordance with the revised matrix, the items are available for audit at the Westinghouse Rockville office.
- 8. NRC Request (Item Number 83)
Please identify all FPGAs in the new or changed PAMS hardware.
TVA Response:
The Field Programmable Gate Arrays (FPGAs) used in the Common Q PAMS AC160 module are listed in Westinghouse letter WBT-D-2166 (Attachment 5), which provides both the proprietary and non-proprietary information. Attachment 6 contains the affidavit for withholding the WBT-D-2166-P-Attachment (contained in Attachment 5).
Additionally, Westinghouse states in Westinghouse Letter WBT-D-2170 (Reference 9) that its review of flat panel displays and PC node boxes concluded that they do not contain any FPGAs.
- 9. NRC Request (Item Number 95)
TVA to review SER supplements (Q1) 5 and 14 item 7.8.1 and (Q2) supplement 4 item 7.8.4 and confirm if they are identical to Unit 1. If not provide differences.
TVA Response:
Q1: Monitoring of the reactor coolant system relief valve position is the same as Unit 1.
Q2: The reactor trip on turbine trip is the same as Unit 1.
- 10. NRC Request (Item Number 96)
TVA to provide information on implementation of IEN 79-22 and how it is addressed in the FSAR.
TVA Response:
IEN 79-22 is not specifically listed or discussed in the WBN Unit 1 UFSAR or Unit 2 FSAR. IEN 79-22 is one of the precursors to 10 CFR 50.49 environmental qualification. The initial SQN and WBN TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 9 of 18 Unit 1 response was developed prior to TVA implementing 10 CFR 50.49. As such, the discussion of safety-related actuations is no longer valid. In implementing 10 CFR 50.49, TVA upgraded susceptible safety-related devices located in harsh environments to fully qualified devices. For WBN Unit 2, only fully qualified safety-related devices are installed in areas susceptible to a high energy line break. The non-safety-related device/systems within the scope of IEN 79-22 are:
- 1. Steam generator power operated relief valve control system
- 2. Pressurizer power operated relief valve control system
- 3. Main feedwater control system
- 4. Automatic rod control system Failure of these systems/devices due to a high energy line break is fully addressed in Chapter 15, Accident Analysis, of the WBN Unit 2 FSAR.
- 11. NRC Request (Item Number 97)
TVA to review SER Supplement 7 item 7.4.25 deviation on Aux Control Room display of RCS cold leg temperature for applicability to Unit 2.
TVA Response:
The deviation to not have RCS cold leg temperature displayed in the Auxiliary Control Room was approved as part of the WBN Unit 1 initial license. WBN Unit 2 complies with the WBN Unit 1 licensing bases, and this deviation is applicable to Unit 2.
- 12. NRC Request (Item Number 98)
Unit 1 SER Supplement 7, RCS Cold Leg Temperature instrumentation. How does Unit 2 address this change?
TVA Response:
Refer to the response to NRC Request Number 11 (Item Number 97) above.
- 13. NRC Request (Item Number 119)
Submit the non-proprietary version of Sorrento/GA software V&V report version 1.1 04508005 and withholding affidavit TVA Response:
This item was submitted in TVAs letter to the NRC dated July 15, 2010 (Reference 8).
- 14. NRC Request (Item Number 120)
In reviewing the Maintenance Test Panel (MTP) link to the plant computer, the reviewer noted that the MTP software is not purely one directional in that it does allow low level handshaking to support the communications protocol.
TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 10 of 18
- a. The reviewer stated that this was a potential concern and requested additional information on how the software protected the MTP from feedback from the plant computer.
- b. The reviewer stated that in the Oconee review, it was found that the non-safety related data diode was easier to credit than the software barrier. It was suggested we look at changing our position to credit the data diode provided it provided a physical barrier to feedback.
- c. During this discussion, the reviewer asked if we had information from Westinghouse that demonstrated the ability of Common Q PAMs to withstand a data storm. A verbal response was that this was required by contract as part of the Factory Acceptance Test and would not be available until the FAT was completed. Need to docket the verbal response and provide a date the information will be available.
TVA Response:
- a. The MTP link to the plant computer is described in the Common Q PAMS Licensing Technical Report: WNA-LI-00058-WBT, Rev 0. This question originated from a review of this document.
A review found that the following are the Common Q PAMS related documents that contain information on the data link. The information in these documents is consistent with the Technical Report and no new information was found.
- 1. WNA-DS-01617-WBT, Revision 1, System Requirement Specification Section 4.3.3
- 2. WNA-DS-01667-WBT, Revision 1, System Design Specifications Section 5.1
- 3. WNA-SD-00239-WBT, Revision 1, Software Requirement Specifications - Sections 5.4.7, 7.2.34, Tables 7.2-1 and 7.2-2
- 4. TVA/NRC Open Items List (Number 49), 00000-ICE-30156, Revision 6 (Section 4.3.4)
Document Numbers 1, 2, and 3 listed above were submitted in TVA letter dated July 14, 2010 (Reference 13), and Document Number 4 is available at the Westinghouse Rockville office for audit.
Additional detail will be provided in the software design and validation and verification reports.
The schedule for these reports has been previously provided in the Common Q PAMS ISG-6 Compliance Matrix submitted in TVA letter dated June 18, 2010 (Reference 6).
Final hardware details will be provided when the hardware drawings are updated to the as-built configuration. Westinghouse is currently scheduled to complete this activity September 15, 2010. TVA will submit the hardware information by October 1, 2010, two weeks after TVA receipt from Westinghouse.
- b. The data diode will be a DualDiode system from Owl Computing. These devices are specialized network cards where the source side has only an optical transmitter and the destination side only has an optical receiver. Thus it is physically impossible for the instrumentation and control system (ICS) to transmit anything back to Common Q unless the TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 11 of 18 servers are physically compromised. These specialized network cards will be installed in two Dell R200 servers per train. The MTP side is referred to as the source side and the ICS side as the destination side. Red Hat Linux will be installed, and the servers themselves will be in nonqualified cabinets. Refer to Attachment 4 for a detailed discussion of the data diode function.
The DualDiodes will have a maximum bandwidth of 52Mbps (well beyond the bandwidth of Common Q PAMS) and be configured only for TCP/IP communications. The data the MTP transmits is in the format of 100BASE-FX. The servers will be configured with network cards that are compatible. (These are not the same as the DualDiode network cards. Each server has a standard network card along with the DualDiode card.)
The source side server will communicate the required low level handshaking protocols back to the MTP regardless of whether the destination side has received the information. Therefore there will be communication from the non-safety source side server to the safety-related MTP.
The source server will be configured only to transmit back the minimal handshaking communications.
- c. Note that the data storm will send its data directly into the Ethernet port on the MTP. Therefore it simulates the DualDiodes either not being installed or failed in a way that it is transmitting data back into the MTP. The MTP software is designed to handle this situation on its own, as demonstrated by the data storm test.
The resistance to a data storm will be demonstrated as part of the Factory Acceptance Test (FAT). Westinghouse is scheduled to issue the FAT report to TVA on October 22, 2010. TVA will submit this report by November 8, 2010, two weeks after receipt from Westinghouse.
- 15. NRC Request (Item Number 121)
If not previously provided, provide the requested information in items a, b and c for changes to all platforms between Unit 1 and 2. (Specific request for information on Foxboro IA.)
- a. Describe the hardware differences between unit 1 and unit 2
- b. Identify which systems have been transferred to the Foxboro Spec 200 system that utilize a different platform in Unit 1.
- c. Identify the functions (ensure all control functions are addressed) that have been transferred to the Foxboro Spec 200 system that utilize a different platform in Unit 1.
TVA Response:
- a. TVA has previously provided the requested information in the following communications: TVA letter to the NRC dated March 12, 2010 (Reference 5) (see Enclosure 1, Items 1, 2, 3, 4, 10 and 12); TVA letter to the NRC dated April 27, 2010 (Reference 7) (see Enclosure 1, Items 4, 5, 6, 15, 17, 18, 19, 20, 21, 23, 24, and 25); and TVA letter to the NRC dated June 18, 2010 (Reference 6) (see Enclosure 1, Items 1, 2, 6, 32, 33 and 34).
TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 12 of 18 The following information is specific to Foxboro IA:
- i.
Unit 1 has analog modules in panels in the Auxiliary Instrument Room and Auxiliary Control Room performing control, monitoring, and alarm functions. These modules are obsolete. Unit 2 will have a Foxboro IA (digital distributed control) system with functions implemented in software.
ii.
Unit 1 has Foxboro H-line and other obsolete hand/auto stations on the main control room and auxiliary control room benchboards, which interface with the analog modules described in (i) above. Unit 2 will have new hand/auto stations interfacing to the digital control system.
iii.
On Unit 1, a failure of a controller or other analog module will cause a loop to fail. Unit 2 will have redundant control processors executing the control algorithms. For some critical Unit 2 loops, redundant transmitters and redundant outputs to control valves are added to eliminate single point failures.
iv.
In Unit 1, four channels of vital power are available, and loops are assigned to each channel to minimize the impact of losing one channel of power. In Unit 2, there are also four channels of vital power, but control hardware is powered by a channel of vital power based on panel location. In addition, a second redundant power source is provided to each Unit 2 panel. As a result, the loss of a single power source to any Unit 2 panel will not result in a loss of any control or monitoring function.
- b. TVA has addressed systems transferred to a new platform in the following communications:
TVA letter to the NRC dated March 12, 2010 (Reference 5) (see Enclosure 1, Items 1, 2, 3 and 12); TVA letter to the NRC dated April 27, 2010 (Reference 7) (see Enclosure 1, Items 4, 5, 6, 15, 17, 18, 19, 20, 21, 23, 24, and 25); and TVA letter to the NRC dated June 18, 2010 (Reference 6) (see Enclosure 1, Items 1, 2, and 6).
Foxboro IA is used only for non-safety-related functions, indications, and controls. The following table lists the systems with loops within their Foxboro IA System:
System ID System Name 1
Condensate 3A Main Feedwater 3B Auxiliary Feedwater 5
Heater Drains and Vents 15 Steam Generator Blowdown 24 Raw Cooling Water 27 Condenser Circulating Water 30 Ventilation 46A Main Feedwater Control 47 Turbogenerator Control 62 Chemical and Volume Control 63 Safety Injection TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 13 of 18 System ID System Name 65 Emergency Gas Treatment 67 Essential Raw Cooling Water 68 Reactor Coolant 70 Component Cooling Water 72 Containment Spray 74 Residual Heat Removal 77 Waste Disposal 81 Primary Makeup Water 85 Control Rod Drive 92 Neutron Monitoring
Function System(s)
Condenser Steam Dump 1
Atmospheric Steam Dump 1
Condenser Hotwell Level 2
Hotwell Pump Discharge Bypass 2
Steam Generator Level (Main Feedwater Regulating Valve Position) 3A and 46A Main Feedwater Pump Recirculation Flow 3A
- 3 Heater Drain Tank Level 6
- 3 Heater Drain Tank Discharge Pumps Runout Protection 6
- 7 Heater Drain Tank Level 6
Turbine Runback Initiators 6 and 47 Steam Generator Blowdown Flow 15 Exciter Cooling Temperature 24 Hydrogen Heat Exchanger Temperature 24 Main Feedwater Pump Turbine Lube Oil Temperature 24 Main Turbine Lube Oil Temperature 24 Main Turbine Air Side Seal Oil Temperature 24 Main Turbine Hydrogen Side Seal Oil Temperature 24 Stator Cooling Water Temperature 24 Main Feedwater Pump Speed 46A Volume Control Tank Level 62 Boric Acid Blending Flow 62 Reactor Coolant System Letdown Flow 62 Reactor Coolant System Letdown Pressure 62 Reactor Coolant System Letdown Temperature 62 Reactor Coolant System Charging Flow 62 Pressurizer Level 62 and 68 Refueling Water Storage Tank Temperature 63 Accumulator Nitrogen Vent 63 Reactor Building Annulus Pressure Differential 65 Pressurizer Pressure 68 Reactor Coolant System Cold Over Pressure Mitigation 68 Component Cooling System Surge Tank Level 70 TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 14 of 18 Function System(s)
Residual Heat Removal Heat Exchanger Flow Control 74 Residual Heat Removal Heat Exchanger Bypass Flow Control 74 Reactor Building Floor And Equipment Drain Sump Level 74 Primary Makeup Water Storage Tank Level 81 Reactor Control (Rod Speed and Direction) 85 While other systems have been implemented on different platforms, they are limited to monitoring functions and are not part of the control echelon.
- 16. NRC Request (Item Number 123)
Safety Evaluation(SE) Section 7.7.3 Volume Control Tank Level Control System
- 1. Confirm whether or not any Instrumentation & Control (I&C) systems or equipment have been changed in the Volume Control Tank Level Control System.
- 2. In the original Safety Evaluation(SE), NUREG-0847 (ML072060490), Section 7.7.3, the staff addressed a concern that was raised by Westinghouse regarding an adverse control and protection system interaction. (a single random failure in the VCT level control system could cause the letdown flow to be diverted to the liquid holdup tank). Based on your responses to the staffs questions related to this concern, the staff considered the issue resolved. Confirm that your responses are applicable to Unit 2.
TVA Response:
- 1. The devices in the Volume Control Tank Level Control System have been replaced. The Volume Control Tank Level Indication and Control functions have been relocated to the Foxboro IA system. The transmitters and indicators have been replaced with 4-20mA technology, and the transmitters have been changed to Rosemount.
- 2. Upscale failure of LT-62-129A: Flow is diverted to the holdup tank but makeup continues to maintain level and alarms alert the operator.
Upscale failure of LT-62-130A: Unlike Unit 1, the makeup control system uses inputs from both LT-62-130A and LT-62-129A. This results in a more robust design that eliminates a single point of failure for LT-62-130A. If transmitter LT-62-130A fails >20mA, the system disregards the input and uses the LT-62-129A signal for control. If transmitter LT-62-130A is high but <20 mA, the deviation between the two causes an alarm, and the diverter valve loop and makeup control both use the last good value of the average. Once the level goes high or low, alarms on LT 129A alert the operator to take action to mitigate.
TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 15 of 18
- 17. NRC Request (Item Number 124)
SE Section 7.7.5 IE Information Notice 79-22 In the original SE, Section 7.7.5, the staff determined that Information Notice 79-22 was resolved based on your statement that the control and logic functions of the Watts Bar plant were identical to the Sequoyah plant, thus making the Sequoyah evaluation applicable to Watts Bar. Confirm that your statements regarding the control and logic functions are applicable to Unit 2s control and logic functions or describe any changes and why they are acceptable.
TVA Response:
Please see the response to NRC Request Number 10 (Item Number 96) above.
- 18. NRC Request (Item Number 125)
Describe the changes, if any.
- 2. NUREG-0847, Supplement 14 (ML072060486), documents the staffs review of FSAR Amendment 81 that found that the AMSAC automatic initiation signal [to start the turbine-driven and motor-driven AFW pumps] was not added to the logic diagram for the AFW system shown in FSAR Figure 7.3-3, Sheet 2. The issue was resolved in Amendment 88. Confirm that this signal has been incorporated in the Unit 2 drawings.
TVA Response:
- 1. The AMSAC system was not previously installed in Unit 2. Engineering Document Construction Release (EDCR) 52408 installs the system. Attachment 3 contains excerpts from the EDCR that describe the Unit 2 system and how it differs from the Unit 1 system.
- 2. EDCR 52408 incorporates the AMSAC system into the Unit 2 drawings.
- 19. NRC Request (Item Number 126)
SE Section 7.8 NUREG-0737 Items In the SER Cross Reference To FSAR table (06-25-09), section 7.8.5 Confirm Existence of Anticipatory Reactor Trip Upon Turbine Trip (II.K.3.12) has the following scope of change:
Common Station Service Transformers (CSST) A and B, eight (8) vital inverters vs. four, fifth DG will be removed from FSAR, Double breaker, double breaker scheme of the new Watts Bar 500kV switchyard.
Is any I&C system or component affected in the scope of this change?
TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 16 of 18 TVA Response:
There are no I&C components or systems affected by this change.
The following RAIs are clarifications from the phone call from H. C. Garg (NRC) to M. S. Clark (TVA) on July 12, 2010, as a follow-up to a NRC/TVA telecom on July 6, 2010:
- 20. NRC Request Provide excerpts of the EDCRs and DCNs that provide the block and logic diagrams for the Foxboro Spec 200 implementation.
TVA Response:
x contains excerpts of the following change documents that provide the block and logic diagrams for the Foxboro Spec 200 implementation:
x DCN 52376 Note: These changes are scheduled to be implemented after Unit 2 Fuel Load x
DCN 52641 Note: DCNs 52376 and 52641 impact loops already in service for Unit 1 and as such are implemented under 10CFR50.59.
x EDCR 52343 x
EDCR 52427 The following RAI is from the NRC/TVA Telecom on July 6, 2010:
- 21. NRC Request The excerpt of work order WO 08-813412-000 provided with the June 18 letter did not contain the information showing that the new type (Arnold) power supplies had been installed in the Unit 1 Eagle 21 system. Please provide the necessary pages of the work order to verify the installation of Arnold power supplies in the Unit 1 Eagle 21 System.
TVA Response: contains the correct work order excerpt.
TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 17 of 18 Attachments
- 1. Westinghouse letter WAT-D-10502, Tennessee Valley Authority Watts Bar Nuclear Plant Revised Containment Sump Level Transmitter Assessment and WCAP-12096 Revision 8
- 2. Common Q PAMS Design Engineering Evaluation Against the Requirements of Regulatory Guide 1.97 Revsion 2.
- 3. EDCR 52408 Excerpts that Describe the Unit 2 AMSAC System and How It Differs from the Unit 1 System
- 4. Owl Computing Product Overview: Secure One-Way Data Transfer Systems, Owl Computing Technologies, Inc. 38A Grove Street, Suite 101, Ridgefield CT 06877 www.owlcti.com
- 5. Westinghouse Letter, dated July 20, 2010, WBT-D-2166, Tennessee Valley Authority Watts Bar Nuclear Plant Unit 2, NRC RAI for Common Q PAMS
- 6. Application for Withholding Proprietary Information from Public Disclosure, CAW-10-2891, dated July 19, 2010, for Westinghouse Letter WBT-D-2166, Tennessee Valley Authority Watts Bar Nuclear Plant Unit 2, Common Q PAMS Field Programmable Gate Arrays (FPGAs)
- 7. Design Change Excerpts for Foxboro Specification 200 System
- 8. Work Order Number 08-813412-000 Excerpt
- 9. Exception EX-WB-DC-30-4-48 Revision 1, to Design Criteria WB-DC-30-4, Separation/Isolation TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Page 18 of 18 References
- 1.
WNA-SD-00239-WBT-P, Rev. 1, RRAS Watts Bar 2 NSSS Completion Program I&C Projects Software Requirements Specification for the Post Accident Monitoring System (Proprietary), dated February 2010
- 2.
TVA letter dated August 25, 2008, Watts Bar Nuclear Plant (WBN) - Unit 2 - Westinghouse Eagle-21 Process Protection System (TAC NO. MD6311) (T02 080826 001)
- 3.
WCAP-12374, Rev. 1 Topical Report Eagle-21 Microprocessor-Based Process Protection System, dated December 1991 (T33 920221 810)
- 4.
WNA-LI-00058-WBT-P, dated June 2010, Tennessee Valley Authority (TVA) Watts Bar Unit 2 (WBN2) Post-Accident Monitoring System (PAMS) Licensing Technical Report Revision 0
- 5.
TVA letter dated March 12, 2010, Watts Bar Nuclear Plant (WBN) Unit 2 - Additional Information Regarding Final Safety Analysis Report (FSAR), Chapter 7, "Instrumentation And Controls" Review (T02 100312 001)
- 6.
TVA letter dated June 18, 2010, Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests (T02 100621 001)
- 7.
TVA letter dated April 27, 2010, Watts Bar Nuclear Plant (WBN) Unit 2 - Staff Information Requests Resulting From NRC December 15, 2009, Meeting With Tennessee Valley Authority (TVA) Regarding Digital Instrumentation And Controls Review And NRC Clarifications To The Requests Provided During February 18, 2010, Telephone Conference Call (TAC NO. ME0853)
(ML101230248) (T02 100427 002)
- 8.
TVA letter dated July 15, 2010, Watts Bar Nuclear Plant (WBN) Unit 2, Instrumentation and Controls Staff Information Request (T02 100719 002)
- 9.
Westinghouse letter dated July 19, 2010, WBT-D-2170, Tennessee Valley Authority Watts Bar Nuclear Plant Unit 2, Response to NRC RAI for Common Q PAMS
- 10. TVA letter dated February 5, 2010, Watts Bar Nuclear Plant Unit 2 - Information Available for NRC Review and Setpoint Methodology for Protections Systems (T02 100205 002)
Cycle 2 Core Reload Changes - Technical Specification Change No.96-013 - Supplement Information (ML073231139) (T04 970604 439)
- 12. TVA letter dated June 30, 2010, Watts Bar Nuclear Plant (WBN) Unit 2 - Additional Information Regarding Final Safety Analysis Report (FSAR) Chapter 7, Instrumentation and Controls Review
- Requested Common Q Proprietary Documents (T02 100630 001)
- 13. TVA letter dated July 14, 2010, Watts Bar Nuclear Plant (WBN) Unit 2 - Additional Information Regarding Final Safety Analysis Report (FSAR) Chapter 7, Instrumentation and Controls Review
- Requested Common Q Proprietary Documents (T02 100714 001)
TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests ATTACHMENT 1 Westinghouse letter WAT-D-10502 Tennessee Valley Authority Watts Bar Nuclear Plant Revised Containment Sump Level Transmitter Assessment and WCAP-12096 Revision 8 TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests ATTACHMENT 2 Common Q PAMS Design Engineering Evaluation Against the Requirements of Regulatory Guide 1.97 Revsion 2 TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests ATTACHMENT 3 EDCR 52408 Excerpts that Describe the Unit 2 AMSAC System and How It Differs from the Unit 1 System TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests ATTACHMENT 4 Owl Computing Product Overview: Secure One-Way Data Transfer Systems Owl Computing Technologies, Inc.
38A Grove Street, Suite 101, Ridgefield CT 06877 www.owlcti.com
Withhold from Public Disclosure Under 10 CFR 2.390 TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests ATTACHMENT 5 Westinghouse letter dated July 20, 2010, WBT-D-2166, Tennessee Valley Authority Watts Bar Nuclear Plant Unit 2, NRC RAI for Common Q PAMS Note: The attached Westinghouse letter contains the following two tables: 1.) Table WBT-D-2166-NP [Proprietary] & 2.) Table WBT-D-2166-NP [Nonproprietary]
TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests ATTACHMENT 6 Application for Withholding Proprietary Information from Public Disclosure CAW-10-2891, dated July19, 2010, for Westinghouse Letter WBT-D-2166 Tennessee Valley Authority Watts Bar Nuclear Plant Unit 2 Common Q PAMS Field Programmable Gate Arrays (FPGAs)
TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests ATTACHMENT 7 Design Change Excerpts for Foxboro Specification 200 System TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests ATTACHMENT 8 Work Order Number 08-813412-000 Excerpt TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests ATTACHMENT 9 Exception EX-WB-DC-30-4-48 Revision 1 To Design Criteria WB-DC-30-4, Separation/Isolation TVA Letter Dated 07/30/2010 Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, and NRC/TVA Telecom On July 6, 2010 Information Requests Commitments
- 1. With respect to mapping functions listed in FSAR Section 7.4 to the FSAR section that describes the equipment that performs the function, the text in the Unit 2 FSAR Amendment 100 will be revised to identify service water pumps (emergency raw cooling water pumps) as equipment available for cold shutdown (Note: This is referring to the Essential Raw Cooling Water System)
- 2. RAI Item Number 3 [Matrix Item Number 12]).
- 3. The evaluation concluded that the Common Q PAMS meets all requirements of Reg. Guide 1.97 Rev. 2. This evaluation will be added to design criteria document WB-DC-30-7, Post Accident Monitoring Instrumentation, by October 1, 2010 (RAI Item Number 5 [Matrix Item Number 47]).
- 4. Unit 2 FSAR Table 7.1-1, Note 12, will be revised in FSAR Amendment 100 to state that the Loose Parts Detection System Technical Specifications have been moved to the TRM (RAI Item Number 6 [Matrix Item Number 80]).
- 5. Hardware details will be provided when the hardware drawings are updated to the as-built configuration. Westinghouse currently shows this activity to complete September 15, 2010.
TVA will submit a hardware listing by October 1, 2010, two weeks after TVA receipt from Westinghouse (RAI Item Number 14 [Matrix Item 120]).
- 6. Westinghouse is scheduled to issue the FAT report to TVA on October 22, 2010. TVA will submit this report by November 8, 2010, two weeks after receipt from Westinghouse (RAI Item Number 14 [Matrix Item 120]).