ML110680661
| ML110680661 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 02/28/2011 |
| From: | - No Known Affiliation |
| To: | Division of Operating Reactor Licensing |
| References | |
| Download: ML110680661 (26) | |
Text
WBN2Public Resource From: Boyd, Desiree L [dlboyd@tva.gov]
Sent: Monday, February 28, 2011 7:52 AM To: Epperson, Dan; Poole, Justin; Raghavan, Rags; Milano, Patrick; Campbell, Stephen Cc: Crouch, William D; Boyd, Desiree L; Hamill, Carol L; Knuettel, Edward Terry
Subject:
TVA letter to NRC_02-25-11_I&C RAI Response Attachments: 02-25-11_I&C RAI Response_Final.pdf Please see attached TVA letter that was sent to the NRC today.
The attachments are too large to send by email. For those of you who receive a cc in the mail, the attachments will be included with your letter Thank You,
~*~*~*~*~*~*~*~*~*~*~*~*~*~*~
Désireé L. Boyd WBN 2 Licensing Support Sun Technical Services dlboyd@tva.gov 4233658764
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Hearing Identifier: Watts_Bar_2_Operating_LA_Public Email Number: 293 Mail Envelope Properties (7AB41F650F76BD44B5BCAB7C0CCABFAF1BDF0A9A)
Subject:
TVA letter to NRC_02-25-11_I&C RAI Response Sent Date: 2/28/2011 7:51:58 AM Received Date: 2/28/2011 7:52:04 AM From: Boyd, Desiree L Created By: dlboyd@tva.gov Recipients:
"Crouch, William D" <wdcrouch@tva.gov>
Tracking Status: None "Boyd, Desiree L" <dlboyd@tva.gov>
Tracking Status: None "Hamill, Carol L" <clhamill@tva.gov>
Tracking Status: None "Knuettel, Edward Terry" <etknuettel@tva.gov>
Tracking Status: None "Epperson, Dan" <Dan.Epperson@nrc.gov>
Tracking Status: None "Poole, Justin" <Justin.Poole@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: TVANUCXVS2.main.tva.gov Files Size Date & Time MESSAGE 491 2/28/2011 7:52:04 AM 02-25-11_I&C RAI Response_Final.pdf 226427 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
Attachments 2, 5, 6, 7, 8, 9, 12, 15, 18 and 23 are to be withheld from public disclosure under 10 CFR 2.390. When separated from these attachments, this letter is decontrolled.
Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 February 25, 2011 10 CFR 50.4 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 NRC Docket No. 50-391
Subject:
WATTS BAR NUCLEAR PLANT (WBN) UNIT 2 - INSTRUMENTATION AND CONTROLS STAFF INFORMATION REQUESTS
Reference:
- 1. Licensee Open Items to be Resolved for SER Approval List The purpose of this letter is to provide TVAs responses to NRCs information requests on the referenced Licensee Open Items to be Resolved for SER Approval List. Enclosure 1 to this letter provides TVAs responses to the information requested by NRC. contains the attached supporting documents for TVAs responses to NRCs requests/questions provided in Enclosure 1. Enclosure 3 contains a list of references on which TVAs responses are based. Enclosure 4 provides a list of the new regulatory commitments contained in this letter.
Attachments 2, 5 through 8, and 23 contain information proprietary to General Atomics Electronic Systems Inc. (GA-ESI). TVA requests that the GA-ESI proprietary information be withheld from public disclosure in accordance with 10 CFR § 2.390. An affidavit for withholding proprietary information from public disclosure and non-proprietary versions of the documents will be submitted within two weeks of receipt from GA-ESI.
U.S. Nuclear Regulatory Commission Page 3 February 25, 2011 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 4 February 25, 2011 bcc (Enclosures):
Stephen Campbell U.S. Nuclear Regulatory Commission MS 08H4A One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 Charles Casto, 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 Hukam C. Garg U.S. Nuclear Regulatory Commission MS 09D2 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 George A. Wilson, Jr.
U.S. Nuclear Regulatory Commission MS 09E3 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738
Enclosure 1 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval For some NRC RAI requests, this letter provides TVAs initial response. For the other NRC RAI requests in this letter, a response has been provided in previous TVA letters to the NRC and the NRC has subsequently requested additional information. For these requests, the initial TVA response is not repeated below. The additional NRC information requests are identified as Follow-up NRC Requests. TVA responses to these items are identified as TVA Response to Follow-up NRC Request.
- 1. NRC Request (Item Number 081)
The Post Accident Monitoring System (PAMS) Licensing Technical Report (WNA-LI-00058-WBT Rev. 0, Dated April 2010), in Section 7, lists codes and standards applicable to the Common Q PAMS. This list contains references to old revisions of several regulatory documents, for example:
(1) RG 1.29 - September 1978 vs. March 2007 (2) RG 1.53 - June 1973 vs. November 2003 (a) IEEE 379-1994 vs. -2000 (3) RG 1.75 - September 1975 vs. February 2005
- a. IEEE 384-1992 vs. -1992 (4) RG 1.100 - June 1988 vs. September 2009
- a. IEEE 344-1987 vs. -2004 (5) RG 1.152 - January 1996 vs. January 2006
- a. IEEE 7-4.33.2-1993 vs. -2003 (6) RG 1.168 - September 1997 vs. February 2004
- a. IEEE 1012-1986 vs. -1998
- b. IEEE 1028-1988 vs. -1997 (7) IEEE 279-1991 vs. 603-1991 (8) IEEE 323-1983 vs. -1974 (RG 1.89 Rev. 1 June 1984 endorses 323-1974)
However, LIC-110, "Watts Bar Unit 2 License Application Review," states: "Design features and administrative programs that are unique to Unit 2 should then be reviewed in accordance with the current staff positions." Please identify all differences between the versions referenced and the current staff positions. Please provide a justification for the acceptability PAMS with respect to these differences.
Follow-up NRC Request:
ML101600092 Item No.1: There are three sets of regulatory criteria that relate to a Common Q application (e.g. WBN2 PAMS):
(a) Common Q platform components - Common Q TR (b) Application Development Processes - Common Q SPM (c) Application Specific - current regulatory criteria The Common Q Topical Report and associated appendices primarily addressed (a) and (b). The Common Q SER states:
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Enclosure 1 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval Appendix 1, Post Accident Monitoring Systems, provides the functional requirements and conceptual design approach for upgrading an existing PAMS based on Common Q components (page 58, Section 4.4.1.1, Description)On the basis of the above review, the staff concludes that Appendix 1 does not contain sufficient information to establish the generic acceptability of the proposed PAMS design (page 56, Section 4.4.1.3, PAMS Evaluation)
The NRC did not approve the proposed PAMS design. Section 6, References, and Section 7, Codes and Standards Applicable to the Common Q PAMS, of the PAMS Licensing Technical Report contain items that are not the current regulatory criteria.
Please provide an explanation of how the WBN2 PAMS conforms with the application specific regulatory criteria applicable to the WBN2 PAMS design. For example IEEE Std. 603-1991 Clause 5.6.3, Independence Between Safety Systems and Other Systems, and Clause 6.3, Interaction Between the Sense and Command Features and Other Systems, contain application specific requirements that must be addressed by a PAMS system.
TVA Response to Follow-up NRC Request:
Attachment 4 contains the results of the TVA analysis of standards and regulatory guides applicable to the Common Q PAMS. Based on the results of the analysis, the Common Q PAMS design meets the applicable requirements and is acceptable.
- 2. NRC Request (Item Number 086)
The PAMS Licensing Technical Report (WNA-LI-00058-WBT Rev. 0, Dated April 2010),
in Section 6, lists references applicable to the Common Q PAMS. This list contains references to old revisions of several regulatory documents, for example:
(1) DI&C-ISG04 - Rev. 0 (ML072540138) vs. Rev. 1 (ML083310185)
However, LIC-110, "Watts Bar Unit 2 License Application Review," states: "Design features and administrative programs that are unique to Unit 2 should then be reviewed in accordance with the current staff positions." Please identify all differences between the versions referenced and the current staff positions. Please provide a justification for the acceptability PAMS with respect to these differences.
Follow-up NRC Request:
TVA to address with Open Item 81.
TVA Response to Follow-up NRC Request:
The analysis for compliance with DI&C-ISG04, Revision 0 to Revision 1 was previously submitted as part of the Common Q PAMS Licensing Technical Report Revision 2 in TVA to NRC letter dated December 22, 2010 (Reference 1). Attachment 4 contains the results of the TVA analysis of standards and regulatory guides applicable to the Common Q PAMS. Based on the results of the analysis, the Common Q PAMS design is acceptable.
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Enclosure 1 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval
- 3. NRC Request (Item Number 142)
The applicable regulatory guidance for reviewing the WBN2 PAMS System Requirements Specification (SysRS) would be IEEE 830 as endorsed by Regulatory Guide 1.172 and BTP 7-14 Section B.3.3.1, Requirements Activities - Software Requirements Specifications. IEEE 830-1994 Section 4.3.8, Traceable, states: A [requirements specification] is traceable of the origin of each of its requirements is clear Follow-up NRC Request:
Updated Specifications and Requirements Traceability Matrix (RTM) to be provided by TVA TVA Response to Follow-up NRC Request:
WNA-VR-00279-WBT, Revision 4, Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System is available for NRC audit at the Westinghouse Rockville office. The document will be available at the Westinghouse Cranberry offices to support the NRC Common Q PAMS audit.
Attachment 9 contains the proprietary version of WNA-DS-01617-WBT-P, Revision 4, Post Accident Monitoring System - System Requirements Specification, dated February 2011. Attachment 10 contains the non-proprietary version WNA-DS-01617-WBT-NP, Revision 4, Post Accident Monitoring System - System Requirements Specification, dated February, 2011. Attachment 11 contains the Application for Withholding Proprietary Information from Public Disclosure, WNA-DS-01617-WBT-P, Revision 4, Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Post Accident Monitoring System - System Requirements Specification (Proprietary), dated February 10, 2011.
Attachment 12 contains the proprietary version of WNA-DS-01667-WBT-P, Revision 4, Post Accident Monitoring System - System Design Specification, dated February 2011.
Attachment 13 contains the non-proprietary version WNA-DS-01667-WBT-NP, Revision 4, Post Accident Monitoring System - System Design Specification, dated February 2011. Attachment 14 contains the Application for Withholding Proprietary Information from Public Disclosure, WNA-DS-01667-WBT-P, Revision 4, Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects Post Accident Monitoring System - System Design Specification (Proprietary), dated February 11, 2011.
Attachment 15 contains the proprietary version of WNA-SD-00239-WBT-P, Revision 4, Software Requirements Specification for the Post Accident Monitoring System, dated February 2011. Attachment 16 contains the non-proprietary version WNA-SD-00239-WBT-NP, Revision 4, Software Requirements Specification for the Post Accident Monitoring System, dated February 2011. Attachment 17 contains the Application for Withholding Proprietary Information from Public Disclosure, WNA-SD-00239-WBT-P, Revision 4, Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Software Requirements Specification for the Post Accident Monitoring System (Proprietary), dated February 10, 2011.
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Enclosure 1 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval
- 4. NRC Request (Item Number 143)
The WBN2 PAMS Software Requirements Specification (WBN2 PAMS Software Requirements Specification (SRS) - ML101050202) contains a table (see page iii) titled, Document Traceability & Compliance, which states that the WBN2 PAMS SRS was created to support the three documents identified (one of which is the WBN2 PAMS SysRS). Section 1.1, Overview, of the WBN2 PAMS SRS states: This document describes requirements for the major software components Follow-up NRC Request:
Updated Specifications and RTMs to be provided by TVA TVA Response to Follow-up NRC Request:
See Response to item 3 (Matrix Item Number 142)
- 5. NRC Request (Item Number 145)
The WBN2 PAMS System Design Specification (WBN2 PAMS System Design Specification(SDS)) contains a table (see page iii) titled, Document Traceability &
Compliance, which states that the WBN2 PAMS SDS was created to support the WBN2 PAMS SysRS.
(a) Does the WBN2 PAMS SDS implement all of the hardware requirements in the WBN2 PAMS SysRS?
(b) Please briefly describe all of the documents that implement the hardware requirements of the WBN2 PAMS SysRS.
Follow-up NRC Request:
To be addressed by Revision of the RTM, SRS, SysRS, and SysDS.
TVA Response to Follow-up NRC Request:
See Response to item 3 (Matrix Item Number 142)
- 6. NRC Request (Item Number 202)
The letter (ML0003740165) which transmitted the Safety Evaluation for the Common Q topical report to Westinghouse stated: "Should our criteria or regulations change so that our conclusions as to the acceptability of the report are invalidated, CE Nuclear Power and/or the applicant referencing the topical report will be expected to revise and resubmit their respective documentation, or submit justification for continued applicability of the topical report without revision of the respective documentation." Question No 81 identified many criteria changes; please revise the respective documentation or submit justification for continued applicability of the topical report.
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Enclosure 1 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval Follow-up NRC Request:
Summary provided in Licensing Technical Report (LTR) Revision 2 has been reviewed and found to be unacceptable.
LTR Section 9 evaluates the compliance of the Software Requirements Specification (SRS) to IEEE 830-1998. There are two issues with this evaluation:
(1) IEEE 830-1998 is not the current Standard Review Plan (SRP) acceptance criteria.
IEEE 830-1998 has not been formally endorsed by a regulatory guide.
(2) Westinghouse committed to evaluate the SRS against 830 when the NRC identified several inconsistencies.
Yes ISG-4 is one new criteria, and an evaluation against it has been provided.
In addition, LTR Revision. 2 Section 13 states: The applicable NRC regulatory guides, IEEE and EPRI industry standards for the common Q PAMS are shown below.
Compliance to these codes and standards are stated in Section 4 of Reference 1.
Reference 1 is the common Q topical report.
Partial TVA Response to Follow-up NRC Request:
(1) and (2) The current version of the IEEE Standard is 830-1993. The following statement was previously added to the LTR, Revision 2:
An analysis was performed to determine the differences between IEEE Standard 830-1993 and IEEE Standard 830-1998. It was determined that IEEE Standard 830-1998 enveloped all of the requirements in IEEE Standard 830-1993. The changes in IEEE Standard 830-1998 were to update the dates of the references, to fix minor wording and formatting, and to add an informative Annex that shows guidelines for compliance with IEEE/EIA 12207.1-1997.
Attachment 4 contains the results of the TVA analysis of standards and regulatory guides applicable to the Common Q PAMS. Based on the results of the analysis, the Common Q PAMS design is acceptable.
The final response to this item is pending submittal of the Licensing Technical Report Revision 3 scheduled for March 29, 2011.
- 7. NRC Request (Item Number 244)
Section 8.2.2 of the Common Q SPM (ML050350234) states that the Software Requirements Specification (SRS) shall be developed using IEEE 830 and RE 1.172.
Clause 4.8, "Embedding project requirements in the SRS," of the IEEE 830 states that an SRS should address the software product, not the process of producing the software. In addition Section 4.3.2.1 of the SPM states "Any alternatives to the SPM processes or additional project specific information for the ...SCMP...shall be specified in the PQP.
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Enclosure 1 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval Contrary to these two statements in the SPM, the WBN2 PAMS SRS (ML101050202) contains many process related requirements, for example all seventeen requirements in Section 2.3.2, "Configuration Control," address process requirements for configuration control.
Please explain how the above meets the intent of the approved SPM.
Follow-up NRC Request:
Issues with Common Q TR & SPM compliance were discussed in the weekly public meetings.
TVA Response to Follow-up NRC Request:
The documents discussed in Item 3 have been revised to address compliance with the Topical Report (TR) and the Software Program Manual (SPM).
- 8. NRC Request (Item Number 252)
The (Software Program Manual) SPM contain requirements for software requirements traceability analysis and associated documentation (see Section 5.4.5.3, Requirements Traceability Analysis). Please provide information that demonstrates that requirements traceability analysis has been successfully accomplished.
Follow-up NRC Request:
Updated Specifications and RTMs to be provided by TVA TVA Response to Follow-up NRC Request:
See Response to item 3 (Matrix Item Number 142)
- 9. NRC Request (Item Number 281)
For FSAR Section 7.6.8 in amendment 96, redline version has completely rewritten this section of the FSAR, however, the staff is not able to determine any changes made to the section. Explain what changes have been made to this FSAR Section.
Follow-up NRC Request:
(1) FSAR Amendment 101 did not reflect the changes in 7.6.8 associated with implementation of the DCS. (2) Provide the basis for acceptance to use Foxboro I/A DCS in place of analog instrumentation and relays.
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Enclosure 1 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval TVA Response to Follow-up NRC Request:
(1) The underlined text from FSAR Amendment 101 Section 7.6.8 reflects the installation of the Foxboro DCS.
7.6.8 Text from FSAR Amendment 101 The wide range temperature signals, as inputs to the Protection Sets I and II, continuously monitor RCS temperature conditions. In Protection Set I, the existing RCS wide range temperature channels on RCS loops 1 and 2 provide inputs to the Eagle 21 digital process protection system. Eagle 21 provides isolated analog signals to the digital process control system. An auctioneer function selects the lowest temperature signal which is then used to calculate an acceptable reference pressure limit (PORV setpoint) considering the plants allowable pressure and temperature Protection Set III. The calculated reference pressure is compared to the actual RCS pressure monitored by the wide range pressure channel. The auctioneered temperature signal will annunciate a main control room (MCR) alarm whenever the measured temperature approaches, within a predetermined amount, the reference temperature for arming the system. Similarly, whenever the measured pressure approaches within a predetermined amount of the programmed setpoint, another MCR alarm will be generated. When the measured RCS pressure is equal to or above the programmed setpoint (nominal values), a PORV open signal is initiated and a MCR alarm is actuated. A manually armed permissive allows this actuation signal to control the Train A PORV (PCV-68-340A). The manually armed permissive also serves to block a spurious PORV opening due to potential instrument failure whenever the RCS temperature is above the arming reference temperature.
The monitored generating station variables that generate the actuation signal for the Train B PORV (PCV-68-334) are processed in a similar manner. The RCS loops 3 and 4 wide range temperature signals and the RCS pressure signal are provided from Protection Set II. Therefore, the generating station variables used for the Train B PORV are derived from a protection set that is independent of the sets from which generating station variables used for the Train A PORV are derived. The wide range temperature auctioneer function and the programmed pressure setpoint calculation for the Train B PORV are performed in a different group of the digital process control system than those for the Train A PORV.
Each of these control groups has a fault tolerant, redundant processor pair and redundant power supplies with different power sources.
(2) At the NRC public meeting, the NRC reviewer identified that the specific question was Foxboro I/A compliance with IEEE 279.
FSAR section 7.6.8.1 addresses compliance of the COMS with IEEE 279 and states:
7.6.8.1 Analysis of Interlock Many criteria presented in IEEE 279-1971 and IEEE 338-1971 do not apply to the interlocks for RCS pressure control during low temperature operation, 7
Enclosure 1 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval because the interlocks do not perform a protective function but rather provide automatic pressure control at low temperatures as a backup to the operator.
However, although IEEE 279-1971 criteria do not apply, some advantages of the dependability and benefits of an IEEE 279-1971 design have occurred by including the pressure and temperature signal elements as noted above in the protection sets and by organizing the control of the two PORVs into dual channels. Either of the two PORVs can accomplish the RCS pressure control function.
The design of the low temperature interlocks for RCS pressure control is such that pertinent features include:
(1) No credible failure at the output of the protection set racks, after the output leaves the racks to interface with the interlocks, will prevent the associated protection system channel from performing its protective function because such outputs that leave the racks go through an isolation device.
(2) Testing capability for elements of the interlocks within (not external to) the protection sets that generate the temperature and pressure process signals for the overpressure mitigation system is consistent with the testing principles and methods discussed in Section 7.2.1.1.3.
(3) A loss of offsite power will not defeat the provisions for an electrical power source for the interlocks because these provisions are through onsite power which is described in Section 8.3.
The design of the COMS as implemented in the Foxboro I/A system fully complies with FSAR section 7.6.8.1. Items (1) and (2) are implemented as part of the Eagle 21 modification. Item (3) is addressed by each processor pair having redundant power supplies with both being battery backed and ultimately backed by an ESF diesel generator.
- 10. NRC Request (Item Number 318)
TVA has provided the following documents for RM-1000 equipment qualification:
(i) Qualification Test Report for RM-1000 Processor Module and Current-To-Frequency Converter 04508905-QR (January 2001)
(ii) Qualification Test Report Supplement, RM-1000 Upgrades 04508905-1SP (June 2006)
(iii) Qualification Test Report Supplement, RM-1000 Upgrades 04508905-2SP (June 2008)
(iv) Qualification Test Report Supplement, RM-1000 Upgrades 04508905-3SP (May 2008) 8
Enclosure 1 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval Please clarify whether all of these are fully applicable to WBN2 or are they applicable with exceptions? If with exceptions, then please clarify what those are.
Supplement 3 was issued one month prior to supplement 2. Please explain the reason for the same.
Follow-up NRC Request:
Provide qualification reports 04038903-QSR and 04038903-7SP by the dues date of 1/22/11.
Submit a copy of any other relevant reviewed versions of the qualification reports.
Submit copies of the reviewed reports for 04508905-QR, 04508905-1SP, 04508905-2SP.
Clarification of applicability of existing reports is acceptable.
TVA Response to Follow-up NRC Request:
The following documents are the qualification documents associated with the RM-1000 radiation monitors:
x Attachment 5 contains the approved proprietary version of General Atomics Electronic Systems 04508905-1SP, Qualification Test Report Supplement, RM-1000 Upgrade.
x Attachment 6 contains the approved proprietary version of General Atomics Electronic Systems 04508905-2SP, Qualification Test Report Supplement, I-F Converter Upgrades.
x Attachment 7 contains the approved proprietary version of General Atomics Electronic Systems 04038903-7SP, Qualification Basis for 04034101 (2-RE-90-271, 272, 273 &
274).
x Attachment 8 contains the proprietary version of General Atomics Electronic Systems 04038903-QSR, Qualification Summary Report for Watts Bar Nuclear Plant Unit 2 Replacement Radiation Monitors. WBN Unit 2 Engineering has reviewed and approved only those portions of this document applicable to the RM-1000 monitors.
Engineering approval of the entire document will take place when a full review of all covered monitors is complete.
x Attachment 23 contains the approved proprietary version of General Atomics Electronic Systems 04508905-QR, Qualification Test Report for RM-1000 Processor Module and Current-To-Frequency Converter.
- 11. NRC Request (Item Number 323)
WCAP-13869 revision 1 was previously reviewed under WBN Unit 1 SER SSER 13 (Reference 8). Unit 2 references revision 2. An analysis of the differences and their acceptability will be submitted to the NRC by November 15, 2010 Please clarify whether all of these are fully applicable to WBN2 or are they applicable with exceptions? If with exceptions, then please clarify what those are.
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Enclosure 1 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval Follow-up NRC Request:
The staff is confused with the response since both units have reference leg not insulated.
Rev 2 should apply to Unit 1 also and there should be no difference between Unit 1 and 2 TVA Response to Follow-up NRC Request:
A FSAR change will be submitted in a future FSAR amendment to change the revision level back to revision 1 for WBN Unit 2.
- 12. NRC Request (Item Number 335)
LPMS: Reference to OI-331, sub item 2.
Provide analysis, test, or combined analysis and test for normal operating radiation, temperature, and humidity environment per regulatory position C.1.g of RG 1.133. As an alternate TVA may confirm that the required equipment has been qualified for the environments stated in RG 1.133, position C.1.g and that TVA has reviewed the test report and found it acceptable.
TVA Response to NRC Request:
Partial Response included in TVA to NRC letter dated December 22, 2010 (Reference 1).
Attachment 18 contains the proprietary version of EQ-EV-71-WBT-P, Revision 1, Environmental Evaluation and Operating History of the Westinghouse DMIMS-DX Preamplifier and Softline Cable Used at Watts Bar 2 dated February 2011 (Proprietary).
Attachment 19 contains the non-proprietary version EQ-EV-71-WBT-NP, Revision 1, Environmental Evaluation and Operating History of the Westinghouse DMIMS-DX Preamplifier and Softline Cable Used at Watts Bar 2, dated February 2011. Attachment 20 contains the Application for Withholding Proprietary Information from Public Disclosure, EQ-EV-71-WBT-P, Revision 1, Environmental Evaluation and Operating History of the Westinghouse DMIMS-DX Preamplifier and Softline Cable Used at Watts Bar 2, (Proprietary) dated February 18, 2011.
- 13. NRC Request (Item Number 338)
In page 3-15 and appendix B of Qualification Test Report 04508905-QR, licensee described the selection of seismic required response spectra (RRS) and indicated Figure 3-2 (page 3-17), Figure 3-3 (page 3-18) are the RRSs used. The RRS curves used for actual testing are lower than the RRS curves that are shown on Figures 3-2 and 3-3. The RRS curves used for testing are shown in Figure 4-5, 4-6, 4-7, 4-8, 4-11, 4-12, 4-13, and 4-14 (pages 4-25, 4-26, 4-28, 4-29, 4-37, 4-38, 4-40, 4-41). Please clarify and justify why the RRS curves used in actual tests are lower than the RRS curves determined in Figures 3-2 and 3-3.
In addition please justify that the RRS used for testing envelopes the RRS required for WBN-2 application specific seismic conditions.
10
Enclosure 1 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval TVA Response:
04508905-QR, Qualification Test Report for RM-1000 Processor Module and Current-To-Frequency Converter, (Attachment 23) documents the original baseline testing of the RM-1000 and current-to-frequency converter. The document has been revised to discuss the actual test spectra versus the required WBN response spectra used in the tests (see Attachment 22). 04508905-QR serves as a reference document for the WBN Unit 2 specific seismic qualification of the RM-1000 radiation monitors and current-to-frequency converters documented in 04038903-7SP, Qualification Basis for 04034101 (2-RE 271, 272, 273 & 274), (Attachment 7) and 04038903-QSR, Qualification Summary Report for Watts Bar Nuclear Plant Unit 2 Replacement Radiation Monitors, (Attachment 8). 04038903-7SP makes the comparison of the actual test response spectra used in 04508905-QR and the WBN required response spectra (see Attachment 22).
- 14. NRC Request (Item Number 339)
In the Qualification Test Report 04508905-QR, the licensee provided only eight Safe Shutdown Earthquake (SSE) Test Response Spectra (TRS) as mentioned in the previous open item (OI-338). Please provide all SSE and Operating Basis Earthquake (OBE) TRS plots for NRC review.
TVA Response:
As agreed to with the reviewer, Attachment 1 contains the applicable ARS plots for Elevation 755 where the TRS does not envelope the RRS. Attachment 2 contains the applicable Wyle Test Report 41991 SSE TRS plots.
- 15. NRC Request (Item Number 340)
Provide test result curves for all Electro Magnetic Interference and Radio Frequency Interference (EMI/RFI) tests listed in Table 3.2.3 (page 3-8) of the Qualification Test Report 04508905-QR. In addition, please provide the standards or the guidance documents used as the source for ENV 50140, ENV 55011 Class A, and EN 55022 Class B.
Follow-up NRC Request:
Provide the qualification reports by 1/28/11 per TVA letter of 12/22/10.
TVA Response to Follow-up NRC Request:
The total EMI/RFI testing of the RM-1000 and current-to-frequency converter is documented in the following reports:
x Attachment 5 contains the proprietary version of General Atomics Electronic Systems 04508905-1SP, Qualification Test Report Supplement, RM-1000 Upgrade. See sections 5.1.1, 5.1.2 and 5.1.4 for EMI/RFI.
11
Enclosure 1 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval x Attachment 7 contains the proprietary version of General Atomics Electronic Systems 04038903-7SP, Qualification Basis for 04034101 (2-RE-90-271, 272, 273 & 274). See section 5 for EMC qualification basis.
x Attachment 8 contains the proprietary version of General Atomics Electronic Systems 04038903-QSR, Qualification Summary Report for Watts Bar Nuclear Plant Unit 2 Replacement Radiation Monitors. See section 3.4 for electromagnetic compatability qualification requirements.
x Attachment 23 contains the proprietary version of General Atomics Electronic Systems 04508905-QR, Qualification Test Report for RM-1000 Processor Module and Current-To-Frequency Converter. See sections 3.2.1 through 3.2.5 and 6.2 for EMI/RFI.
Attachments 7 and 8 document the EMI/RFI testing specific to the WBN Unit 2 RM-1000 monitors and current-to-frequency converters.
- 16. NRC Request (Item Number 341)
FSAR Table 3.10 list seismically qualified equipment. However, these tables do not list the containment high range radiation monitors. Please add them to the appropriate FSAR table(s) or justify why they should not be included in the FSAR 3.10 series of tables.
TVA Response:
A review of WBN Unit 2 FSAR Amendment 102 sections 3.10, 11 and 12 was performed.
The reviewer was unable to locate seismic qualification information for the radiation monitoring system in those sections. A review of Chapter 3.11 confirmed that radiation monitoring is included in the environmentally qualified systems.
It appears that seismic qualification of the radiation monitoring equipment was unintentionally omitted from FSAR section 3.10. FSAR section 3.10 will be updated to include the qualified radiation monitoring equipment in FSAR Amendment 103.
- 17. NRC Request (Item Number 344)
Unit 1 SE discussed in Section 7.6.5, Valve Power Lockout. There is no section in FSAR which provides discussion on this subject. SE section discusses compliance with PSB-18. (a) Provide a discussion which can be used by the staff to determine similar conclusion as Unit 1 and if the design is similar to Unit 1 then make a statement to that effect. (b) Also provide the list of the valves where power lockout during normal reactor operation is utilized for valves whose inadvertent operation could affect plant safety.
TVA Response:
(a) In accordance with 0PDP-6, Locked Valve/Breaker Program, Revision 1 (Attachment 25), valves locked by design are shown on design output documents (flow diagrams, system descriptions, etc.). As documented in 0PDP-6, valves are locked for multiple reasons. It is anticipated that many of the valves that were locked to provide positive isolation between Unit 1 and Unit 2 will not be locked when Unit 2 becomes operational and will be removed from the locked valve 12
Enclosure 1 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval program. At the same time, Unit 1 valves locked for operational/Appendix R/Single Failure criteria will result in the corresponding Unit 2 valves being locked.
(b) The list of valves locked by design is contained in 0-PI-OPS-17.0, 18 Month Locked Valve Verification, Revision 44 (Attachment 21). Valves locked out by opening the associated circuit breaker are listed in 0-PI-OPS-17.1, 18 Month Locked Breaker Verification, Revision 14 (Attachment 24).
- 18. NRC Request (Item Number 345)
Provide the normal temperatures and expected periods of high/low temperature excursions to assess aging requirements. TVA to further clarify if 86ºF for 40 years was used as the qualification requirement for aging tests. This has been stated in some of the subsections under section 4.2 of the 04508905-QR report but the rationale for using 86ºF (includes an internal temperature rise of 18ºF) for 40 years has not been justified in the 04508905-QR report or the supplement reports. TVA to provide the rationale for this acceptance criteria for WBN-2.
TVA Response:
RM-1000 in a NIM Bin was tested at 39° F for 72 Hrs and tested at 131° F for 72 Hrs per Section 4.2.6 of 04508905-QR (Attachment 23). This is stated in document 04038903-7SP, Section 2.1 (Attachment 7). The ambient temperature used for aging was 86° F (30°C). The NIM Bin has perforated holes in top and bottom covers and has an average internal temperature rise of approximately 18° F due to natural air convection. So the average internal temperature used for aging was 104° F (40° C).
In accordance with Attachment 8, 04038903-QSR, Qualification Summary Report for Watts Bar Nuclear Plant Unit 2 Replacement Radiation Monitors, Section 3.2, the aging is to an ambient equivalent condition of 104° F which is based on an 86° F average ambient temperature of the environment and an enclosure temperature rise of 18° F.
IEEE Std 1205-2000, Table D.8 shows that the upper bounding temperature is 104° F for all plant areas except the reactor building. The intent in qualifying the part for 40 years is to identify each components failure mechanisms and to determine whether 40 years1 of aging has a significant effect of these failure mechanisms.
1 The design life goal for most Class 1E equipment is 40 years, but for most electronic assemblies 20 years, or less, is more realistic. Because of rapidly changing technologies, replacement components sometimes become unavailable in a relatively short period of time.
- 19. NRC Request (Item Number 346)
TVA has previously stated in response to open item 319 that RM-1000 System Verification Test Results report, 04507007-1TR is not applicable to WBN-2. However, TVA has not provided a WBN-2 specific test results report. Please identify and provide the appropriate test results reports to complete the review.
13
Enclosure 1 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval TVA Response:
Document 04507007-1TR is the RM-1000 System Verification Test Results. 04038903-QSR, Qualification Summary Report for Watts Bar Nuclear Plant Unit 2 Replacement Radiation Monitors (Attachment 8) and 04038903-7SP, Qualification Basis for 04034101 (2-RE-90-271, 272, 273 & 274) (Attachment 7) are the WBN Unit 2 equipment specific qualification reports.
- 20. NRC Request (Item Number 347)
Qualification report 04508905-1SP does not address EMI/RFI qualification for the new RM-1000 modules. TVA to provide the updated qualification or explain the basis for not addressing the EMI/RFI qualification.
TVA Response:
Qualification report 04038903-7SP, Qualification Basis for 04034101-001 (2-RE-90-271,
-272, -273, & -274) (Attachment 7), addresses the EMI/RFI qualifications for the entire loop including the RM-1000 and current to frequency (I/F) converter. This report references 04038800, RM-1000 EMC Test Report, TVA, and 04509050, RM-1000 EMC Test Report. The results are summarized in 04038903-7SP.
- 21. NRC Request (Item Number 348)
Qualification report 04508905-2SP does not address EMI/RFI qualification for the new I/F converters. TVA to provide the updated qualification or explain the basis for not addressing the EMI/RFI qualification.
TVA Response:
Qualification report 04038903-7SP, Qualification Basis for 04034101-001 (2-RE-90-271, -
272, -273, & -274), (Attachment 7) addresses the EMI/RFI qualifications for the entire loop including the RM-1000 and I/F converter. This report references 04038800, RM-1000 EMC Test Report, TVA, and 04509050, RM-1000 EMC Test Report. The results are summarized in 04038903-7SP.
- 22. NRC Request (Item Number 349)
Radiation testing was not considered in any of the test reports as all the equipment has been assumed to be located in nuclear power plant areas with mild environments and radiation dosages less than 1 x 103 rads for total integrated dose (TID). However, the radiation monitors and the I/F converters are located in the main control room which is defined as mild environment. For WBN-2 mild environment is defined as room or building zone where (1) the temperature, pressure, or relative humidity resulting from the direct effects of a design basis event (DBE) (e.g., temperature rise due to steam release) are no more severe than those which would occur during an abnormal plant operational condition, (2) the temperature will not exceed 130ºF due to indirect effects of a DBE, (3) the event radiation dose is less than or equal to 1 x 104 rads, and (4) the total event plus the 40 year TID (total integrated dose) is less than or equal to 5 x 104 rads (reference WB-DC-40-54). TVA to address lack of radiation qualification for WBN-2.
14
Enclosure 1 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval TVA Response:
The design criteria provides the criteria for determining what is a mild environment at WBN Unit 2. Calculation WBNAPS4004, Summary of Mild Environment Conditions for Watts Bar Nuclear Plant, provides the actual values for each area of the plant. In accordance with Table 1, the Control Room has a 40 year maximum TID of 3.5x102 RAD and a maximum integrated accident dose of 710.5 RAD for a maximum TID of 1060.5 RAD.
The accident dose of 710.5 RAD is the dose for a 100 day LOCA at the surface of the HEPA filter in the Mechanical Equipment Room. This is documented in TVA calculation WBNTSR-005, Dose Due to the Control Building Emergency Air Cleanup Filters, Revision 3. However, on page 25 of WBNTSR-005, the shine from this source into the control room is negligible and is not considered in the dose calculation for the control room.
Calculation WBNAPS3-126, EQ Dose in the U1/U2 Auxiliary Instrument Rooms and the Computer Room in the Control Building, Revision 0 documents the environmental qualification (EQ) radiation dose in the control building. Considering that the dose from the HEPA filter is negligible to the control room (as discussed above), a review of the WBNAPS3-126 calculation determined that the TID including the normal and accident dose values for the control room is actually less than 1x103 RAD. Calculation WBNAPS3-126 will be revised to add the control room to the calculation with a dose of less than 1x103 RAD by July 1, 2011. Since the control room TID will be documented in calculation WBNAPS3-126 to be less than 1x103 RAD, radiation qualification of the RM-1000 is not required.
- 23. NRC Request (Item Number 350)
The seismic required response spectra (RRS) is shown in Figures 3-1 of 04508905-1SP and Figure 3-1 of 0458905-2SP report. The actual test response spectra are shown in Figures 4-5 and 4-6 of 04508905-QR report. The actual test response spectra does not seem to fully envelope the RRS. However, this statement is based on visual reading of unidentified numbers. TVA to provide clarification to the values at the inflection point of all lines on the RRS and the actual test response spectra. The seismic qualification issue is open till further clarification is received from TVA.
TVA Response:
The RM-1000 was seismically tested in a NIM Bin, and the actual test response spectra fully envelopes the RRS of TVA Standard Specification CEB-SS-5.10, For Seismic Qualification of Electrical, Mechanical and I&C Devices, Revision 3, (Attachment 3)
Figure 3-1 as shown in Section 3.0, Figures 3-4 and 3-5 of 04038903-7SP, Qualification Basis for 04034101 (2-RE-90-271, 272, 273 & 274), (Attachment 7). Seismic qualification of the WBN Unit 2 RM-1000 monitors is summarized in 04038903-QSR, Qualification Summary Report for Watts Bar Nuclear Plant Unit 2 Replacement Radiation Monitors (Attachment 8).
15
Enclosure 1 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval
- 24. NRC Request (Item Number 351)
The replacement schedule for the components that have a qualified life of less than 40 years is noted in Table 6-1 of the supplemental qualification report 04508905-1SP. It is not clear if the components identified for replacement in this report are the only components or if the components which are in addition to the components previously identified in qualification report 04508905-QR.
Are there any age sensitive components for the I/F converter used for WBN-2? (Note:
Report 04508905-2SP does not state any age sensitive components that require replacement during the qualified life).
TVA Response:
The replacement schedules stated in 04508905-1SP, Qualification Test Report Supplement, RM-1000 Upgrade, (Attachment 5) and 04508905-2SP, Qualification Test Report Supplement, I-F Converter Upgrades, (Attachment 6) should be used.
04508905-2SP states in Section 6: None of the Current-to-Frequency converter modules qualified by this supplement contain parts that have significant age related failure mechanisms.
- 25. NRC Request (Item Number 352)
Please clarify how many RM-1000 radiation monitors are being procured for WBN-2, is the quantity 2 or four. MR 25402-011-MRA-HARA-00002, R4 under Item 1.6 indicates that the quantity is 2. If so, is WBN-2 using dual channel indication on each RM-1000 unit. TVA to clarify.
TVA Response:
The total number of RM-1000 units procured under Material Requisition (MR) 25402-011-MRA-HARA-00002 is four. The MR on line item 1.6 is stating the purchase of 2 sets of 2 RM-1000s and I/F Converters making a total of 4 for each type of component.
Each monitor utilizes a single channel display for the 2-RM-90-271, -272, -273 and -274 monitors.
16
Enclosure 2 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval List of Attachments
- 1. Acceleration Response Spectra (ARS) for the El. 755 Auxiliary Control Building
- 2. Wyle Test Report 41991 Safe Shutdown Earthquake (SSE) Test Response Spectra (TRS) Plots
- 3. TVA Standard Specification - CEB-SS-5.10, for Seismic Qualification Of Electrical, Mechanical, and I&C Devices, Revision 3, dated Feberuary 1, 2008
- 4. Common Q PAMS Regulatory Guide and IEEE Standard Analysis
- 5. General Atomics Electronic Systems 04508905-1SP, Qualification Test Report Supplement, RM-1000 Upgrade, Revision B, dated February 10, 2011 (Proprietary)
- 6. General Atomics Electronic Systems 04508905-2SP, Qualification Test Report Supplement, I-F Converter Upgrades Revision A, (Proprietary), dated June 23, 2008
- 7. General Atomics Electronic Systems 04038903-7SP, Qualification Basis for 04034101 (2-RE-90-271, 272, 273 & 274), Revision C, (Proprietary), dated February 22, 2011
- 8. General Atomics Electronic Systems 04038903-QSR, Qualification Summary Report for Watts Bar Nuclear Plant Unit 2 Replacement Radiation Monitors, Revision B, (Proprietary), dated February 10, 2011
- 9. Westinghouse Electric Company WNA-DS-01617-WBT-P, Revision 4, Post Accident Monitoring System - System Requirements Specification, " (Proprietary), dated February, 2011
- 10. Westinghouse Electric Company WNA-DS-01617-WBT-NP, Revision 4, Post Accident Monitoring System - System Requirements Specification," dated February, 2011
- 11. Westinghouse Electric Company CAW-11-3107, Application for Withholding Proprietary Information from Public Disclosure, WNA-DS-01617-WBT-P, Revision 4, Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Post Accident Monitoring System - System Requirements Specification, (Proprietary), dated February 10, 2011
- 12. Westinghouse Electric Company WNA-DS-01667-WBT-P, Revision 4, Post Accident Monitoring System - System Design Specification, (Proprietary), dated February 2011
- 13. Westinghouse Electric Company WNA-DS-01667-WBT-NP, Revision 4, Post Accident Monitoring System - System Design Specification, dated February 2011
- 14. Westinghouse Electric Company CAW-11-3108, Application for Withholding Proprietary Information from Public Disclosure, WNA-DS-01667-WBT-P, Revision 4, Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects Post Accident Monitoring System - System Design Specification (Proprietary), dated February 11, 2011
- 15. Westinghouse Electric Company WNA-SD-00239-WBT-P, Revision 4, Software Requirements Specification for the Post Accident Monitoring System," (Proprietary),
dated February 2011 1
Enclosure 2 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval
- 16. Westinghouse Electric Company WNA-SD-00239-WBT-NP, Revision 4, Software Requirements Specification for the Post Accident Monitoring System," dated February 2011
- 17. Westinghouse Electric Company CAW-11-3102, Application for Withholding Proprietary Information from Public Disclosure, WNA-SD-00239-WBT-P, Revision 4, Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Software Requirements Specification for the Post Accident Monitoring System, (Proprietary), dated February 10, 2011
- 18. Westinghouse Electric Company EQ-EV-71-WBT-P, Revision 1, Environmental Evaluation and Operating History of the Westinghouse DMIMS-DX Preamplifier and Softline Cable Used at Watts Bar 2, (Proprietary), dated February 2011
- 19. Westinghouse Electric Company EQ-EV-71-WBT-NP, Revision 1, Environmental Evaluation and Operating History of the Westinghouse DMIMS-DX Preamplifier and Softline Cable Used at Watts Bar 2, dated February 2011
- 20. Westinghouse Electric Company CAW-11-3115, Application for Withholding Proprietary Information from Public Disclosure, EQ-EV-71-WBT-P, Revision 1, Environmental Evaluation and Operating History of the Westinghouse DMIMS-DX Preamplifier and Softline Cable Used at Watts Bar 2, (Proprietary), dated February 18, 2011
- 21. TVA procedure 0-PI-OPS-17.0, 18 Month Locked Valve Verification, Revision 44
- 22. White paper on Sorrento/GA qualification reports
- 23. General Atomics Electronic Systems 04508905-QR, Qualification Test Report for RM-1000 Processor Module and Current-To-Frequency Converter, Revision A, (Proprietary),
dated February 10, 2011
- 24. TVA procedure 0-PI-OPS-17.1, 18 Month Locked Breaker Verification, Revision 14
Enclosure 3 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval List of References
Instrumentation and Controls Staff Information Requests 1
Enclosure 4 TVA Letter Dated February 25, 2011 Responses to Licensee Open Items to be Resolved for SER Approval List of New Regulatory Commitments
- 1. FSAR Section 3.10 will be updated to include the qualified radiation monitoring equipment in FSAR Amendment 103. [Item 14, (Matrix Item 341)]
- 2. The General Atomics Electronics Systems Inc. (GA-ESI) affidavits for withholding and non-proprietary versions of attachments 5, 6, 7, 8 and 23 will be submitted within two weeks of receipt from GA-ESI. [Cover Letter]
- 3. Calculation WBNAPS3-126 will be revised to include the control room by July 1, 2011.
[Item 22, (Matrix Item 349)]
- 4. A FSAR change will be submitted in a future FSAR amendment to change the revision level for WCAP-13869 from 2 back to 1. [Item 11, (Matrix Item 323)]
1