ML11136A052

OL - FW: Updated Open Items List 4-15-11

ML11136A052
Person / Time
Site:	Watts Bar
Issue date:	04/15/2011
From:	Office of Nuclear Reactor Regulation
To:	Division of Operating Reactor Licensing
References
Download: ML11136A052 (63)

Text

WBN2Public Resource From: Poole, Justin Sent: Friday, April 15, 2011 5:19 PM To: Crouch, William D Cc: Clark, Mark Steven; Hilmes, Steven A; WBN2HearingFile Resource

Subject:

FW: Updated Open Items List 4-15-11 Attachments: 20110415 Open Item List Master NRC Update 04-15-11.docx Justin C. Poole Project Manager NRR/DORL/LPWB U.S. Nuclear Regulatory Commission (301)4152048 email: Justin.Poole@nrc.gov From: Darbali, Samir Sent: Friday, April 15, 2011 2:29 PM To: Poole, Justin Cc: Rahn, David; Carte, Norbert; Wilson, George; Kemper, William

Subject:

Updated Open Items List 4-15-11

Justin, Attached is the updated open items list to be sent to TVA.

Thanks, Samir 1

Hearing Identifier: Watts_Bar_2_Operating_LA_Public Email Number: 343 Mail Envelope Properties (19D990B45D535548840D1118C451C74D7F6E4FCCA3)

Subject:

FW: Updated Open Items List 4-15-11 Sent Date: 4/15/2011 5:19:24 PM Received Date: 4/15/2011 5:19:28 PM From: Poole, Justin Created By: Justin.Poole@nrc.gov Recipients:

"Clark, Mark Steven" <msclark0@tva.gov>

Tracking Status: None "Hilmes, Steven A" <sahilmes@tva.gov>

Tracking Status: None "WBN2HearingFile Resource" <WBN2HearingFile.Resource@nrc.gov>

Tracking Status: None "Crouch, William D" <wdcrouch@tva.gov>

Tracking Status: None Post Office: HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 459 4/15/2011 5:19:28 PM 20110415 Open Item List Master NRC Update 04-15-11.docx 521764 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N B (

1.

001 All All A The Watts Bar Nuclear Plant FSAR red-line for Unit 2 (Agency 12/15/2009 Presentation Slides Y Closed Closed EICB RAI 3/12/2010 NNC 11/19/09: The FSAR contains B (

2.

002 All All A Are there I&C components and systems that have changed to a 12/15/2009 Presentation Slides Y Closed Closed EICB RAI 3/12/2010 NNC 11/19/09: The FSAR contains B (

3.

003 All All A Because a digital I&C platform can be configured and programmed 12/15/2009 Presentation Slides Y Closed Closed EICB RAI 3/12/2010 NNC 11/19/09: The FSAR contains

( ( ( ( B 004 All All Please identify the information that will be submitted for each Responder: Webb 1/13/10 Public Meeting 4. Y Closed Closed EICB RAI January 13, 2010 NNC 11/19/09: LIC-110 Rev. 1 Section 005 7.1.3. By letter date February 28, 2008 (Agencywide Documents Access Responder: Craig/Webb 5. Y Closed Closed EICB RAI TVA Letter dated 006 Amendment 95 of the FSAR, Chapter 7.3, shows that change 7.3-1 By letter dated February 5, 2010: TVA provided the Unit 2 6. Y Closed Closed EICB RAI TVA Letter dated NNC: WCAP-12096 Rev. 7 D D D D 007 7.1.3. The setpoint methodology has been reviewed and approved by the TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 7 7. Y Closed Closed EICB RAI TVA Letter dated TVA to provide Rev. 8 of the Unit 1

( ( ( ( (

008 7.3 There are several staff positions that provide guidance on setpoint TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 8 8. Y Closed Closed EICB RAI TVA Letter dated a a a a (

009 7.3.2 5.6, Change 7.3-2, identified in Watts Bar Nuclear Plant FSAR red-line TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 9 9. Y Closed Closed EICB RAI 3/12/10, G G G G G 010 7.3 7.3 The original SER on Watts Bar (NUREG-0847) documents that the TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 10 10. Y Closed Closed EICB RAI 3/12/10, 011 7.3.2 5.6, NUREG-0847 Supplement No. 2 Section 7.3.2 includes an TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 11 11. Closed Closed EICB RAI ML101680598, A

Y 012 7.4 7.4 The original SER on Watts Bar (NUREG-0847) documents that the TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 12 12. Y Closed Closed EICB RAI TVA Letter dated 013 7.1.3. Chapter 7 and Chapter 16 of Amendment 95 to the FSAR do not TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 13 13. Y Closed Closed EICB RAI TVA Letter dated TS have been docketed.

( ( B 014 All All Provide the justification for any hardware and software changes Date: 4/27/10 14. Y Closed Closed NRC Meeting TVA Letter dated 015 Verify that the refurbishment of the power range nuclear Date: 4/27/10 15. Y Closed Closed NRC Meeting TVA Letter dated 016 Identify the precedents in license amendment requests (LARs), if Date: 4/27/10 16. Y Closed Closed NRC Meeting TVA Letter dated

( D D (

017 7.3.1 7.3.1, Identify precedents in LARs, if any, for the solid state protection Date: 4/27/10 17. Y Closed Closed NRC Meeting TVA Letter dated

( ( ( ( ( (

018 Identify any changes made to any instrumentation and control Date: 4/27/10 18. Y Closed Closed NRC Meeting TVA Letter dated 019 Verify that the containment purge isolation radiation monitor is the Date: 4/27/10 19. Y Closed Closed NRC Meeting TVA Letter dated C a a C (

020 Provide environmental qualification information pursuant to Section Date: 4/27/10 20. Y Closed Closed NRC Meeting TVA Letter dated NNC 4/30/10: SRP Section 7.0 states:

G G G G G G 021 7.3 For the Foxboro Spec 200 platform, identify any changes in Date: 5/25/10 21. Y Closed Closed NRC Meeting TVA Letter dated The resolution of this item will be A

022 7.3.2 5.6, Verify the auxiliary feedwater control refurbishment results in a like- Date: 4/27/10 22. Y Closed Closed NRC Meeting TVA Letter dated 023 Provide environmental qualification (10 CFR 50.49) information for Date: 4/27/10 23. Y Closed Closed NRC Meeting TVA Letter dated NNC 4/30/10: SRP Section 7.0 states:

024 Provide a schedule by the January 13, 2010, meeting for providing During the January 13, 2010 meeting, TVA presented a 24. Y Closed Closed NRC Meeting N/A - Request for NNC 4/30/10: Carte to address

( ( ( ( ( (

025 7.5.2 7.5.1 For the containment radiation high radiation monitor, verify that the Date: 4/27/10 25. Y Closed Closed NRC Meeting ML101230248, 026 Provide environmental qualification (10 CFR 50.49) information for Date: 4/27/10 26. Y Closed Closed NRC Meeting TVA Letter dated NNC 4/30/10: SRP Section 7.0 states:

( ( ( (

027 7.7.1. For Foxboro I/A provide information regarding safety/non-safety- Date: 4/27/10 27. Y Closed Closed NRC Meeting TVA Letter dated 028 For the turbine control AEH system, verify that the refurbishment Responder: Mark Scansen 28. Y Closed Closed NRC Meeting TVA Letter dated C C C C C S 029 For the rod control system, verify that the refurbishment results in a Date: 4/27/10 29. Y Closed Closed NRC Meeting TVA Letter dated G G G G 030 Regarding the refurbishment of I&C equipment, identify any Responder: Clark 30. Y Closed Closed NRC Meeting TVA Letter dated 031 For the rod position indication system (CERPI), provide information Date: 4/27/10 31. Y Closed Closed NRC Meeting TVA Letter dated CERPI is non-safety related.

i 032 For the process computer, need to consider cyber security issues Date: 4/27/10 32. Y Closed Closed NRC Meeting TVA Letter dated EICB will no longer consider cyber 033 For the loose parts monitoring system, provide information Date: 4/27/10 33. Y Closed Closed NRC Meeting TVA Letter dated The loose parts monitoring system is 034 2/4/2010 Responder: TVA 34. Y Closed Closed N/A TVA Letter dated 034. ( Chapter 7.1 - Introduction 35. Y Closed Closed N/A N/A

( a 034. D Chapter 7.2 - Reactor Trip System 36. Y Closed Closed N/A N/A M ( r 034. 7.3 7.3 a Chapter 7.3 - ESFAS 37. Y Closed Closed N/A N/A a G g 034. 7.5.1. 7.5.2 Chapter 7.5 - Instrumentation Systems Important to Safety 38. Y Closed Closed N/A N/A Closed 034. 7.5.1. 7.5.2 Chapter 7.6 - All Other Systems Required for Safety 39. Y Closed Closed N/A N/A Closed r

c u

034. Chapter 7.7 Control Systems 40. Y Closed Closed N/A N/A n

g h

/

035 ( 2/18/2010 Responder: Clark 41. Y Closed Closed RAI No. 1 TVA Letter dated LIC-110 Section 6.2.2 states: Design

( (

M 036 7.5.2 7.5.1 C S February 18, 2010 Date: 5/25/10 42. Y Closed Closed NRC Meeting NNC: Unit 2 FSAR Section 7.5.1, Post a

i 037 7.5.1. 7.5.2 2/18/2010 Responder: Clark Date: 5/25/10 43. Y Closed Closed N/A TVA Letter dated FSAR Amendment 100 provides

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 038 7.5.1. 7.5.2 ( 2/18/2010 Responder: Clark Date: 5/25/10 44. Y Closed Closed EICB RAI TVA Letter dated The slides presented at the December 039 ( ( M January 13, 2010 Responder: Clark Date: 5/25/10 45. Y Closed Closed EICB RAI FSAR amendment The equation for the calculation of the G G a 040 January 13, 2010 Responder: Clark Date: 5/25/10 46. Y Closed Closed EICB RAI EICB RAI FSAR amendment The equation for the calculation of the 041 7.5.2 7.5.1 2/19/2010 Responder: WEC 1. N Open Open-NRC Review NRC Meeting TVA Letter dated See also Open Item Nos. 226 & 270.

EICB (Carte)

Summary NRC 6/18/10 Please provide the following Westinghouse documents: Items (1) and (2) were docketed by TVA letter dated April 8, Pending Submittal of the Test Due 3/29/11 Meeting Summary (1) WNA-DS-01617-WBT Rev. 1, "PAMS System Requirements 2010. Summary Report due 3/29/11 ML093560019, Item TVA Letter dated Specification" NNC 1/27/11: Issues No. 11 10/5/10 (2) WNA-DS-01667-WBT Rev. 0, "PAMS System Design Item (3) will be addressed by Revision 2 of the Licensing Final Response included in with the STP were Specification" Technical Report. Due 12/3/10 letter dated 12/3/10 discussed in the weekly (3) WNA-CD-00018-GEN Rev. 3, "CGD for QNX version 4.5g" public meetings.

Please provide the following Westinghouse documents or pointers Item (4) will be addressed by Westinghouse developing a Partial Response is included in Westinghouse to:

to where the material was reviewed and approved in the CQ TR or WBN2 Specific Test Plan to compensate for the fact that the letter dated 10/5/10. (1) perfrom STP self SPM: NRC disapproved WNA-PT-00058-GEN during the original The SysRS and SRS assessment., and (4) WNA-PT-00058-GEN Rev. 0, "Testing Process for Common Q Common Q review. Due 12/7/10 incorporate requirements from (2) Augment Test Safety systems" many other documents by Summary report to (5) WNA-TP-00357-GEN Rev. 4, "Element Software Test Item (5) Procedures that are listed in the SPM compliance reference. provide missing test Procedure" table in the Licensing Technical Report revision 1 supersede plan information that test procedure WNA-TP-00357-GEN.Due 10/22/10 NNC 8/25/10: (3) An earlier version of this report was NNC 2/3/11: At next For Item 3, Attachment 19 contains the Westinghouse docketed for the Common Q audit compare &

document Post-Accident Monitoring System (PAMS) topical report; therefore, there discuss:

Licensing Technical Report, WNA-LI-00058-WBT, Revision should be no problem to docket (1) WNA-PT-00058-2, dated December 2010. Attachment 20 contains the this version. (4) Per GEN Rev. 0 Westinghouse Application for Withholding for the Post- ML091560352, the testing (2) WNA-PT-00138-Accident Monitoring System (PAMS) Licensing Technical process document does not WBT Rev. 0 Report, WNA-LI-00058-WBT, Revision 2, dated December address the test plan (3) AP1000 STP 2010. requirements of the SPM.

Please provide a test plan that For Item 4, Attachment 9 contains the Westinghouse implements the requirements of document Nuclear Automation Watts Bar 2 NSSS the SPM.

Completion Program I&C Projects, Post Accident Monitoring System Test Plan, WNA-PT-00138-WBT, Revision 0, dated November 2010. Attachment 10 contains the Westinghouse Application for Withholding for the WNA-PT-00138-WBT, Revision 0 Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Post Accident Monitoring System Test Plan, WNA-PT-00138-WBT, Revision 0, dated November 17, 2010.

TVA Response to Follow-up NRC Request:

(1) WEC presented the results of the self assessment to the NRC on February 2, 2011.

(2) By agreement between TVA, WEC and the NRC, the Post Accident Monitoring System Test Plan, WNA-PT-00138-WBT, Revision 0 will not be revised. Instead a non-proprietary Common Q PAMS Test Summary Report will be developed and submitted to address the issues with the STP. Attachment 1 contains non-proprietary WNA-TR-02451-WBT, Revision 0, Test Summary Report for the Post Accident Monitoring System, dated March 2011.

B (

47. Y 042 All All A February 25, 2010: Telecom Date: 5/25/10 Closed Closed EICB RAI TVA Letter dated The drawing provided did not have the 043 7.5.2 7.5.1 CB (C 2/19/2010 Responder: WEC 2. N Open Open-NRC Review EICB RAI TVA Letter dated NNC 8/25/10: A CQ PAMS ISG6 art Date: 5/25/10 ML102910002 2/5/10 compliance matrix was docketed on: (1)

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N The PAMS ISG6 compliance matrix supplied as Enclosure 1 to Pending Submittal of Revision 3 Due 3/29/11 Item No. 2 February, 5 12010, (2) March 12, 2010, TVA letter dated February 5, 2010 is a first draft of the information The PAMS ISG6 compliance matrix supplied as Enclosure 1 of the Licensing Technical TVA Letter dated & (3) June 18, 2010. The staff has needed. The shortcomings of the first three lines in the matrix are: to TVA letter dated February 5, 2010 is a first draft of the Report due 3/29/11. NNC 2/2/11: Issues 5/12/10 expressed issued with all of these information needed. with Common Q TR & compliance evaluations. The staff is still Line 1: Section 11 of the Common Q topical report did include a Revised response included in SPM compliance were TVA Letter dated waiting for a good compliance commercial grade dedication program, but this program was not By letter dated April 8, 2010 TVA provided the PAMS letter dated 12/22/10. discussed in the weekly 6/18/10 evaluation.

approved in the associated SE. Westinghouse stated that this was Licensing Technical Report provided additional information. public meetings.

the program and it could now be reviewed. The NRC stated that Response is included in letter Westinghouse to TVA Letter dated NNC 11/23/10: WNA-LI-00058-WT-P TVA should identified what they believe was previously reviewed Attachment 3 contains the revised Common Q PAMS ISG-6 dated 10/5/10. perform Common Q TR 10/5/10 Rev. 1 Section 7 does not include the and approved. Compliance Matrix, dated June 11, 2010, that addresses & SPM compliance self RSED documents, and it should. Table these items (Reference 13). Revised compliance matrix is assessment; his will be 6-1 Item No. 15 should also include the Line 2: TVA stated the D3 analysis was not applicable to PAMS, unacceptable. discussed in detail on RSED RTMs.

but provided no justification. The NRC asked for justification since By letter Dated June 18, 2010 (see Attachment 3) TVA the next audit.

SRP Chapter 7.5 identified SRM to SECV-93-087 Item II.Q as provided a table, "Watts Bar 2 - Common Q PAMS ISG-6 NNC 8/12/10: It is not quite being SRP acceptance criteria for PAMS. Compliance Matrix." enough to provide all of the documents requested. There Line 3: TVA identified that the Design report for computer integrity It is TVAs understanding that this comment is focused on are two possible routes to was completed as part of the common Q topical report. The NRC the fact that there are documents that NRC has requested review that the NRC can noted that this report is applicable for a system in a plant, and the that are currently listed as being available for audit at the undertake: (1) follow ISG6, and CQ topical report did no specifically address this PAMS system at Westinghouse offices. For those Common Q PAMS (2) follow the CQ SPM. The Watts Bar Unit 2. documents that are TVA deliverable documents from TVA response that was Westinghouse, TVA has agreed to provide those to NRC. originally pursued was to follow NRC then concluded that TVA should go through and provide a Westinghouse documents that are not deliverable to TVA will ISG6, but some of the more complete and thorough compliance matrix. be available for audit as stated above. Requirements compliance items for ISG6 were Traceability Matrix issues will be tracked under NRC RAI addressed by referencing the Matrix Items 142 (Software Requirements Specification) and SPM. The NRC approved the 145 (System Design Specification). Commercial Item CQ TR and associated SPM; it Dedication issues will be tracked under NRC RAI Matrix may be more appropriate to Item 138. This item is considered closed. review the WBN2 PAMS application to for adherence to TVA Response to Follow-up NRC Request: the SPM that to ISG6. In either path chosen, the applicant WNA-LI-00058-WT-P, Revision 2, Post-Accident Monitoring should provide documents and a System (PAMS) Licensing Technical Report submitted in justification for the acceptability TVA Letter to NRC dated December 3, 2010, (Reference 1) of any deviation from the path contains the following changes to address the NRC chosen. For example, it requests: appears that the Westinghouse's CDIs are (1) While RSEDs are not specifically mentioned, Section 7 commercial grade dedication has been revised to be applicable to both hardware and plans, but Westinghouse software which includes the RSEDs. maintains that they are (2) Table 6-1 item 15 reference added for WNA-VR-00280- commercial grade dedication WBT (RESD) reports; this apparent deviation should be justified or explained.

TVA Response to Second Follow-up NRC Request:

The NRC audited the Westinghouse commercial item dedication process for both hardware and software during the week of February 28 to March 4, 2011. The audif found the processes acceptable. Westinghouse and TVA previously agreed to provide additional information to address this item in Revision 3 of the Licensing Technical Report.

Attachment 2 contains WNA-LI-00058-WBT-P, Post-Accident Monitoring System (PAMS) Licensing Technical Report, Revision 3, dated March 2011 (proprietary).

Attachment 3 contains WNA-LI-00058-WBT-NP, Post-Accident Monitoring System (PAMS) Licensing Technical

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Report, Revision 3 dated March 2011 (non-proprietary).

Attachment 4 contains CWA-11-311, Application for Withholding Proprietary Information from Public Disclosure, WNA-LI-00058-WBT-P, Revision 3 Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Post-Accident Monitoring System (PAMS) Licensing Technical Report, dated March 14, 2011.

( ( ( ( ( ( (

044 7.5.2 7.5.1 February 25, 2010 Date: 5/25/10 48. Y Closed Closed EICB RAI TVA Letter dated 045 February 25, 2010 Date: 5/25/10 49. Y Closed Closed EICB RAI TVA Letter dated

(

046 February 25, 2010 Date: 5/25/10 50. Y Closed Closed N/A - Request for N/A C C C C C C C 047 7.5.2 7.5.1 4/8/2010 Responder: WEC/Hilmes Date: 5/25/10 51. Y Closed Closed EICB RAI TVA Letter dated 048 7.5.2 7.5.1 April 8, 2010 Date: 5/25/10 52. Y Closed Closed EICB RAI TVA Letter dated G

049 7.5.2 7.5.1 4/8/2010 Responder: WEC Date: 5/25/10 53. Y Closed Closed EICB RAI TVA Letter dated 050 7.5.2 7.5.1 4/8/2010 Responder: WEC Date: 5/25/10 54. N Closed Closed EICB RAI TVA Letter dated NNC 11/18/10: SysRS Rev. 2 contains 051 April 15, 2010 Date: 5/25/10 55. Y Closed Closed N/A N/A Review addressed by another Open

(

052 7.5.2 7.5.1 April 19, 2010 Date: 5/25/10 56. Y Closed Closed RAI No. 12 S

i

(

053 7.5.2 7.5.1 April 19, 2010 Date: 5/25/10 57. Y Closed Closed RAI No. 13 S

i

(

054 7.5.2 7.5.1 4/19/2010 Responder: Slifer/Clark Date: 5/25/10 58. Y Closed Closed RAI No. 14 TVA Letter dated S

i

(

055 7.5.2 7.5.1 4/19/2010 Responder: Slifer/Clark Date: 5/25/10 59. Y Closed Closed RAI No. 15 TVA Letter dated S

i

(

056 April 19, 2010 Date: 5/25/10 60. Y Closed Closed RAI No. 16 TVA Letter dated Sorrento Radiation Monitoring S

i

(

057 7.5.2 7.5.1 4/19/2010 Responder: TVA I&C Staff Date: 5/25/10 61. Y Closed Closed RAI No. 17 TVA Letter dated S

i

(

058 7.5.0 7.5 April 19, 2010 Date: 5/25/10 62. Y Closed Closed RAI No. 18 TVA Letter dated S

i

( ( ( ( ( ( ( (

059 7.5.2 7.5.1 April 19, 2010 Date: 63. Y Closed Closed RAI No. 19 TVA Letter dated 060 7.5.2 7.5.1 April 19, 2010 Date: 5/25/10 64. Y Closed Closed N/A N/A Addressed by Open Item No. 47 061 7.5.2 7.5.1 April 19, 2010 Date: 5/25/10 65. Y Closed Closed N/A N/A Addressed by Open Item No. 48 C C C C C C C S 062 7.5.2 7.5.1 April 19, 2010 Date: 5/25/10 66. Y Closed Closed N/A N/A Addressed by Open Item No. 49 063 7.5.2 7.5.1 April 19, 2010 Date: 5/25/10 67. Y Closed Closed N/A N/A Addressed by Open Item No. 50 i

064 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: Webb Date: 4/8/2010 68. Y Closed Closed N/A - No question TVA Letter dated 065 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 69. Y Closed Closed N/A - No question TVA Letter dated 066 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 70. Y Closed Closed N/A - No question TVA Letter dated 067 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 3. N Open Open-NRC Review N/A - No question TVA Letter dated EICB (Carte) date for the "Commercial Grade Dedication Instructions for AI687, Due: 3/29/11 was asked. Item 6/18/10 AI688, Upgraded PC node box and flat panels." was September The following status is from the revised WB2 Common Q Pending Submittal of Revision 3 was opened to track 28, 2010. PAMS ISG-6 Compliance Matrix submitted in response to of the Licensing Technical comm8ittment Item 43: Report due 3/29/11. NNC 2/2/11: Section 7 made by applicant.

of the WBN2 PAMS

a. AI687, AI688 - Scheduled for September 28, 2010 Response included in letter LTR should be updated dated 12/22/10. to include:

b. Upgraded PC node box and flat panel displays - Per (1) non-proprietary Westinghouse letter WBT-D-2024 (Reference 7), these items This item is addressed in Rev. 2 description of are available for audit at the Westinghouse Rockville office. of the Licensing Technical commercial grade Report dedication, and

c. Power supplies - Per Westinghouse letter WBT-D-2035 (2) Software example (Reference 12), these items are available for audit at the Westinghouse Rockville office. Commercial grade dedication will also be To be addressed during 9/20-9/21 audit addressed at the next audit.

TVA Response to Follow-up NRC Request:

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N WNA-LI-00058-WT-P, Revision 2, Post-Accident Monitoring System (PAMS) Licensing Technical Report submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1) contains the following change to address the NRC request:

Section 7, Commercial Grade Dedication Process, has been revised to describe the general commercial grade dedication process for both hardware and software and uses a description of the AI687 dedication process as an example of how the process is applied.

TVA Response to Follow-up NRC Request dated 2/2/11:

The non-proprietary commercial grade dedication discussion is included in Attachment 3, WNA-LI-00058-WBT-NP, Post-Accident Monitoring System (PAMS) Licensing Technical Report, Revision 3 dated March 2011 (non-proprietary)

Section 7. The software example is included in Attachment 2, WNA-LI-00058-WBT-P, Post-Accident Monitoring System (PAMS) Licensing Technical Report, Revision 3, dated March 2011 (proprietary) Section 7.

068 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 4. N Open Open-NRC Review N/A - No question TVA Letter dated EICB (Carte) date for the "Summary Report on acceptance of AI687, AI688, was asked. Item 6/18/10 Upgraded PC node box, flat panels, and power supplies." was The following status is from the revised WB2 Common Q Response included in letter NNC 2/2/11: was opened to track September 28, 2010. PAMS ISG-6 Compliance Matrix submitted in response to dated 12/22/10. Commercial grade comm8ittment Item 43: dedication will be made by applicant.

addressed at the next

a. AI687, AI688 - Scheduled for September 28, 2010 This item is addressed in Rev. 2 audit. Summary of the Licensing Technical reports for AI687 &

b. Upgraded PC node box - Per Westinghouse letter WBT- Report AI688 were docketed D-2024 (Reference 7), this item is available for audit at the one month late.

Westinghouse Rockville office.

c. Flat panel displays - Per Westinghouse letter WBT-D-2024 (Reference 7), this item is available for audit at the Westinghouse Rockville office.

d. Power supplies - Per Westinghouse letter WBT-D-2035 (Reference 12), these items are available for audit at the Westinghouse Rockville office.

To be addressed during 9/20-9/21 audit TVA Response to Follow-up NRC Request:

For the commercial grade dedication process, please see the response to Request for Additional Information (RAI) item 3 in this letter, NRC Matrix Item 067.

The component level EQ/Seismic summary reports for the hardware listed above are available for NRC review/audit as described below:

(1) AI687 and AI688, the following documents were submitted in TVA Letter to NRC dated October 26, 2010, Watts Bar Nuclear Plant (WBN) Unit 2 -

Instrumentation and Controls Staff Information

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Requests, (Reference 5):

a. EQ-EV-62-WBT, Revision 0, Common Q PAMS Comparison of Tested Conditions for the AI687 and AI688 Common Q Modules and Supporting Components to the Watts Bar Unit 2 (WBT)

Requirements, dated September 10, 2010

b. EQLR-171, Revision 0, Environmental and Seismic Test Report, Analog Input (AI)687 &

AI688 Modules for use in Common Q PAMS, dated September 10, 2010

c. CN-EQT-10-44, Revision 0, Dynamic Similarity Analysis for the Watts Bar Unit 2 Post Accident Monitoring System (PAMS), dated September 28, 2010 (2) Upgraded PC Node Box - As stated in Westinghouse letter WBT-D-2024, dated June 9, 2010 NRC Access to Common Q Documents at the Westinghouse Rockville Office, (Reference 6), the following documents are available for NRC audit at the Westinghouse Rockville office:

a. CDI-3722, Revision 7, Next Generation PC Node Box Commercial Dedication Instruction

b. LTR-EQ-10-50 PC Node Box/Flat Panel Display System Components Qualification Summary (3) Flat Panel Displays - As stated in Westinghouse letter WBT-D-2024, dated June 9, 2010 NRC Access to Common Q Documents at the Westinghouse Rockville Office, (Reference 6), the following documents are available for NRC audit at the Westinghouse Rockville office:

a. CDI-3803, Revision 8, Next Generation Flat Panel Display (FPD) Commercial Dedication Instruction

b. LTR-EQ-10-50 PC Node Box/Flat Panel Display System Components Qualification Summary (4) Power supplies - As stated in Westinghouse letter WBT-D-2035 dated June 11, 2010 NRC Access to Common Q Documents at the Westinghouse Rockville Office (Reference 7), the following documents are available for NRC audit at the Westinghouse Rockville office:

a. CDI- 4057, Revision 4, Commercial Dedication Instruction

b. EQ-TP-1 05-GEN, Revision 0, Electromagnetic Compatibility Test Plan and Procedure for Quint Power Supplies and Safety System Line Filter

c. Breakers, EQ-TP-114-GEN, Revision 0, Seismic Qualification Test Procedure For Common Q Power Supplies, Quint Power Supplies, Line Filter Assemblies, and South Texas Units 3 & 4 Circuit

d. EQ-TP-117-GEN, Revision 0, Environmental Qualification Test Procedure For Common Q Powe Supplies, Quint Power Supplies, and Line Filter Assemblies 069 7.5.2 7.5.1 CB (C By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 5. N Open Open-NRC Review N/A - No question N/A art date for the "Watts Bar 2 PAMS Specific FAT Report" was October Due 3/29/11 was asked. Item

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 2010. Attachment 1 contains non-proprietary WNA-TR-02451- Pending Submittal of the Test was opened to track WBT, Revision 0, Test Summary Report for the Post Summary Report due 3/29/11 NNC 2/3/11: The comm8ittment As agreed, the Watts Bar 2 PAMS Specific FAT Report will not be Accident Monitoring System, dated March 2011. current due dated made by applicant.

submitted. Instead a non-proprietary PAMS Test Summary Report Awaiting for document to be above is 4 months will be submitted. docketed by TVA. later than planned.

( ( ( (

070 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 71. N Closed Closed N/A - No question TVA Letter dated NNC 11/23/10: The dues date in this 071 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 72. N Closed Closed N/A - No question N/A NNC 11/23/10: The dues date in this C C C C 072 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 73. Y Closed Closed N/A - No question N/A 073 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 74. N Closed Closed N/A - No question N/A 074 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 6. N Open Open-NRC Review N/A - No question N/A Rev. 4 will be available for the NRC EICB (Carte) date for the Post FAT IV&V Phase Summary Report was was asked. Item audit on 2/28/11. This document will not November 30, 2010. Attachment 1 contains WNA-VR-00283-WBT-P, IV&V Response in letter dated March Due TBD was opened to track be submitted. Rev. 5 will be submitted Summary Report for the Post Accident Monitoring System, 16, 2011 commitment made after resolution of the datastorm display Revision 4, dated March 2011 (proprietary). Attachment 2 NNC 2/3/11: At least 3 by applicant. issue.

contains WNA-VR-00283-WBT-NP, IV&V Summary Report months later than for the Post Accident Monitoring System, Revision 4, dated planned.

March 2011 (non-proprietary). Attachment 3 contains CWA-11-3121, Application for Withholding Proprietary Information from Public Disclosure, WNA-VR-00283-WBT-P, Revision 4 Nuclear Automation IV&V Summary Report for the Post Accident Monitoring System" (Proprietary), dated March 3, 2011.

( ( (

075 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 75. N Closed Closed N/A - No question N/A

( (

076 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: Clark Date: 5/25/10 76. Y Closed Closed N/A - No question N/A C C C 077 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 77. Y Closed Closed N/A - No question TVA Letter dated G G 078 4/26/2010 Responder: Clark Date: 5/25/10 78. Y Closed Closed EICB RAI TVA Letter dated 079 4/26/2010 Responder: Clark Date: 5/25/10 79. Y Closed Closed EICB RAI TVA Letter dated Reviewed under Item 154

(

080 4/26/2010 Responder: WEC 80. Y Closed Closed RAI No. 2 TVA Letter dated S

i 081 7.5.2 7.5.1 5/6/2010 Responder: Merten/WEC 7. N Open Open-NRC Review EICB RAI TVA Letter dated NNC 1/5/11: See Also Open Item No.

EICB (Carte)

ML102910002 6/18/10 86 and 202.

The PAMS Licensing Technical Report (WNA-LI-00058-WBT Rev. The codes and standards documents listed in Section 7 of ML101600092 Item No.1: There Due 2/25/11 Item No. 9 0, Dated April 2010), in Section 7, lists codes and standards the Common Q PAMS Licensing Technical Report are the are three sets of regulatory NNC 4/125/2011: See Open Item No.

applicable to the Common Q PAMS. This list contains references documents that the Common Q platform was licensed to criteria that relate to a Common TVA to provide 364.

to old revisions of several regulatory documents, for example: when the NRC approved the original topical report and Q application (e.g. WBN2 requested information.

(1) RG 1.29 - September 1978 vs. March 2007 issued the approved SER. The WBN Unit 2 Common Q PAMS):

(2) RG 1.53 - June 1973 vs. November 2003 PAMS is designed in accordance with the approved (a) Common Q platform NNC 2/3/11: The (a) IEEE 379-1994 vs. -2000 Common Q topical report and approved SER and the codes components - Common Q TR above due date has (3) RG 1.75 - September 1975 vs. February 2005 and standards on which the SER was based. Since the (b) Application Development been missed by at (a) IEEE 384-1992 vs. -1992 current versions referenced are not applicable to WBN Unit Processes - Common Q SPM least 2 months.

(4) RG 1.100 - June 1988 vs. September 2009 2, there is no basis for a comparison review. (c) Application Specific - current Please provide new (a) IEEE 344-1987 vs. -2004 regulatory criteria due date.

(5) RG 1.152 - January 1996 vs. January 2006 Bechtel to develop a matrix and work with Westinghouse to The Common Q Topical Report (a) IEEE 7-4.33.2-1993 vs. -2003 provide justification. and associated appendices (6) RG 1.168 - September 1997 vs. February 2004 primarily addressed (a) and (b).

(a) IEEE 1012-1986 vs. -1998 TVA Response to Follow-up NRC Request: The Common Q SER states:

(b) IEEE 1028-1988 vs. -1997 (7) IEEE 279-1991 vs. 603-1991 Attachment 4 contains the results of the TVA analysis of Appendix 1, Post Accident (8) IEEE 323-1983 vs. -1974 (RG 1.89 Rev. 1 June 1984 endorses standards and regulatory guides applicable to the Common Monitoring Systems, provides 323-1974) Q PAMS. Based on the results of the analysis, the Common the functional requirements and However, LIC-110, "Watts Bar Unit 2 License Application Review," Q PAMS design meets the applicable requirements and is conceptual design approach for states: "Design features and administrative programs that are acceptable. upgrading an existing PAMS unique to Unit 2 should then be reviewed in accordance with the based on Common Q current staff positions." Please identify all differences between the components (page 58, Section versions referenced and the current staff positions. Please provide 4.4.1.1, Description)On the

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N a justification for the acceptability PAMS with respect to these basis of the above review, the differences. 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.

Awaiting TVA Response.

( ( ( (

082 7.5.2 7.5.1 5/6/2010 Responder: WEC Date: 6/18/10 81. N Closed Closed EICB RAI TVA Letter dated NNC 11/18/10: See also Open Item No.

083 7.5.2 7.5.1 May 6, 2010 Date: 6/18/10 82. Y Closed Closed EICB RAI TVA Letter dated C C C C 084 7.5.2 7.5.1 May 6, 2010 Date: 6/18/10 83. Y Closed Closed EICB RAI TVA Letter dated 085 7.5.2 7.5.1 5/6/2010 Responder: WEC 84. N Closed Closed EICB RAI 086 7.5.2 7.5.1 5/6/2010 Responder: WEC Date: 5/24/10 8. N Open Open-NRC Review EICB RAI TVA Letter dated NNC 1/6/11: See Also Open Item No.81 EICB (Carte)

ML102910002 6/18/10 & 202 The PAMS Licensing Technical Report (WNA-LI-00058-WBT Rev. The regulatory documents listed in the Common Q PAMS TVA to address with item OI Due 2/25/11 Item No. 14 0, Dated April 2010), in Section 6, lists references applicable to the Licensing Technical Report are the documents that the 81.

Common Q PAMS. This list contains references to old revisions of Common Q platform was licensed to when the NRC NNC 2/3/11: The several regulatory documents, for example: approved the original topical report and issued the approved above due date has (1) DI&C-ISG04 - Rev. 0 (ML072540138) vs. Rev. 1 SER. The WBN Unit 2 Common Q PAMS is designed in been missed by at (ML083310185) accordance with the approved Common Q topical report and least 2 months.

However, LIC-110, "Watts Bar Unit 2 License Application Review," approved SER and the regulatory documents on which the Please provide new states: "Design features and administrative programs that are SER was based. Since the current versions referenced are due date.

unique to Unit 2 should then be reviewed in accordance with the not applicable to WBN Unit 2, there is no basis for a

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N current staff positions." Please identify all differences between the comparison review.

versions referenced and the current staff positions. Please provide a justification for the acceptability PAMS with respect to these Rev 0 of the Licensing Technical Report references Rev. 1 of differences. ISG4 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 on December 22, 2010. 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.

(

087 7.5.2 7.5.1 May 6, 2010 Date: 5/24/10 85. Y Closed Closed RAI No. 20 TVA Letter dated S

i 088 7.5.2 7.5.1 ( May 6, 2010 Date: 5/24/10 86. Y Closed Closed RAI No. 21 TVA Letter dated 089 D ( ( ( 5/6/2010 Responder: Clark 87. Y Closed Closed EICB RAI TVA Letter dated NNC: Docketed response states that 090 a C C S 5/6/2010 Responder: Clark Date: 5/25/10 88. Y Closed Closed EICB RAI TVA Letter dated i

091 7.4 7.4 May 20, 2010 Date: 5/25/10 89. Y Closed Closed EICB RAI No.1 TVA Letter dated 092 5/20/2010 Responder: Hilmes 1. Y Open Open-TVA/Oversight Continuous review as items are added DORL Due SER Issue (Poole) TVA to review Licensee Open Item list and determine which items This item will close when we are no longer using this Due: SER Issue are proprietary. document as a communications tool.

( ( ( (

093 May 20, 2010 Date: 5/25/10 90. Y Closed Closed N/A N/A Will be reviewed under item 154 094 5/20/2010 Responder: Clark Date: 5/25/10 91. Y Closed Closed N/A N/A Information was found in FSAR 095 7.8.1, XX D D D D May 20, 2010 Date: 92. Y Closed Closed EICB RAI No. 2 TVA Letter dated 096 7.7.5 XX ( ( 5/20/2010 Responder: 93. Y Closed Closed EICB RAI No.3 TVA Letter dated a a a a G G 097 7.4.2 7.4 May 20, 2010 Date: 94. Y Closed Closed EICB RAI No.4 TVA Letter dated 098 7.4.2 7.4 May 25, 2010 Date: 95. Y Closed Closed EICB RAI No.5 TVA Letter dated 099 ( ( April 12, 2010 Date: 96. Y Closed Closed Closed to Item 129 C B a 97. Y 100 5/20/2010 Responder: WEC Closed Closed N/A - No question N/A 101 4/12/2010 Responder: Slifer 9. Y Open Open-NRC Review N/A TVA is working with the vendor to meet DORL (Poole) the 6/30 date, however there is the The non-proprietary versions of the following RM-1000, The documents, and affidavits for withholding for the listed Documents provided in letter Due 10/14/10 potential this will slip to 7/14.

Containment High Range Post Accident Radiation Monitor documents were submitted to the NRC on TVA letter to the dated 07/15/10 documents will be provided by June 30, 2010. NRC dated July 15, 2010. Confirm receipt.

1. V&V Report 04508006A

2. System Description 04508100-1TM

3. Qualification Reports 04508905-QR, 04508905-1 SP, 04508905-2SP, 04508905-3SP

4. Functional Testing Report 04507007-1TR 102 ( ( May 24, 2010 Date: 5/24/10 98. Y Closed Closed N/A TVA Letter dated Request for schedule not information.

103 7.4 7.4 D D ( 5/27/2010 Responder: Ayala Date: 5/27/10 99. Y Closed Closed EICB RAI No.1 TVA Letter dated Submittal date is based on current a a C 104 7.4 7.4 5/27/2010 Responder: Merten Date: 5/27/10 100. Y Closed Closed EICB RAI No.1 TVA Letter dated Submittal date is based on current

(

105 G April 29, 2010 Date: 101. Y Closed Closed N/A N/A Will be reviewed under item 154.

106 May 6, 2010 Date: 5/25/10 102. Y Closed Closed RAI No. 9 TVA Letter dated

(

S i

107 ( ( May 6, 2010 Date: 5/28/10 103. Y Closed Closed RAI No. 22 TVA Letter dated G S i 104. Y 108 May 6, 2010 Date: 5/25/10 Closed Closed N/A N/A Will be reviewed under OI#154

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

( (

109. 5/6/2010 Responder: N/A 105. Y Closed Closed N/A N/A Duplicate of another open Item.

109. 7.8 XX 5/6/2010 Responder: N/A 106. Y Closed Closed N/A N/A 110 May 6, 2010 Date: 107. Y Closed Closed N/A N/A Information was found.

111 May 6, 2010 Date: 5/28/10 108. Y Closed Closed N/A TVA Letter dated Request to help find, not a request for D ( ( D (

112 June 1, 2010 Date: 109. Y Closed Closed N/A N/A Information was received

( ( ( ( ( (

113 6/1/2010 Responder: Clark 110. Y Closed Closed EICB RAI TVA Letter dated a C C a C 114 7.2 7.2 6/1/2010 Responder: WEC 111. Y Close Closed EICB RAI TVA Letter dated 115 2/25/2010 Responder: Clark 112. Y Closed Closed EICB RAI TVA Letter dated G G G G G G 116 6/3/2010 Responder: WEC 113. Y Closed Closed EICB RAI TVA Letter dated Letter sent to Westinghouse requesting 117 7.1 7.1 6/3/2010 Responder: Hilmes 114. Y Closed Closed EICB RAI TVA Letter dated 118 7.4 7.4 6/8/2010 Responder: Merten 115. Y Closed Closed EICB RAI No.1 TVA Letter dated Submittal date is based on current

( ( ( (

119 June 10, 2010 Date: 116. Y Closed Closed RAI No. 23 TVA Letter dated 120 5/6/2010 Responder: Hilmes/Merten/Costley 117. Y Closed Closed EICB RAI TVA Letter dated 121 5/6/2010 Responder: Webb/Webber 118. Y Closed Closed EICB RAI TVA Letter dated D D D D ( ( ( (

122 June 14, 2010 Date: 119. Y Closed Closed N/A - Request for N/A

( (

123 7.7.3 7.4.1, 6/14/2010 Responder: 120. Y Closed Closed ML101720589, TVA Letter dated a a a a C C C S 124 7.7.5 XX 6/14/2010 Responder: 121. Y Closed Closed ML101720589, Item TVA Letter dated G G 125 7.7.8 7.7.1.12 6/14/2010 Responder: 122. Y Closed Closed ML101720589, Item TVA Letter dated 126 7.8 7.8 June 14, 2010 Date: 123. Y Closed Closed ML101720589, Item TVA Letter dated i

127 7.2 7.2 6/16/2010 Responder: WEC/Clark 124. Y Closed Closed EICB RAI TVA Letter dated 128 7.2 7.2 6/18/2010 Responder: WEC Drake /TVA Craig 125. Y Closed Closed EICB RAI TVA Letter dated Track through SE open item

(

129 P 6/12/2010 Responder: WEC 126. Y Closed Closed N/A TVA Letter dated

(

130 P 6/28/2010 Responder: Clark 127. Y Closed Closed N/A TVA Letter dated

(

131 P 6/28/2010 Responder: Clark 128. Y Closed Closed N/A TVA Letter dated

(

132 P 6/28/2010 Responder: Clark 129. Y Closed Closed N/A TVA Letter dated

(

133 P 6/28/2010 Responder: Clark 130. Y Closed Closed TVA Letter dated

( (

134 6/28/2010 Responder: Clark 131. Y Closed Closed TVA Letter dated 135 7.3.1 7.3.1 6/30/2010 Responder: Clark 132. Y Closed Closed RAI not necessary TVA Letter dated

( D D (

136 7.3.2, 7.4, 5.6, 6/30/2010 Responder: Clark 133. Y Closed Closed RAI not necessary TVA Letter dated C a a P 137 Several WBN2 PAMS documents contain a table titled, Document Responder: WEC 134. Y Closed Closed ML101650255, Item TVA Letter dated 138 By letter dated February 3, 2010, Westinghouse informed TVA that Responder: WEC 10. N Open Open-NRC Review ML101650255, Item See also No. 82.

EICB (Carte) certain PAMS documentation has been completed. No. 2 This item is used to track all Commercial Grade Pending Submittal of Revision 3 NNC 2/2/11:

(a) The draft ISG6 states that a commercial grade dedication plan Dedication issues. of the Licensing Technical Commercial grade should be provided with an application for a Tier 2 review. Report due 3/29/11. dedication will be

a. WNA-LI-00058-WT-P, Revision 2, Post-Accident addressed at the next By letter dated February 5, 2010, TVA stated that the commercial Monitoring System (PAMS) Licensing Technical Report Revised response included in audit.

grade dedication plan was included in the Common Q Topical submitted in TVA Letter to NRC dated December 3, letter dated 12/22/10 Report Section 11, Commercial Grade Dedication Program. 2010, (Reference 1) contains the following changes to NNC 2/17/11: The Section 11 includes a description of the Common Q Commercial address the NRC request: TVA agreed to include a description of the Grade Dedication Program, and states: A detailed review plan is description of the generic commercial grade developed for each Common Q hardware or software component Section 7, Commercial Grade Dedication Process has Westinghouse hardware dedication process in that requires commercial grade dedication. been revised to describe the general commercial grade commercial grade dedication the CQ PAMS LTR dedication process for both hardware and software and process in the PAMS licensing Rev. 2 should be Please provide the commercial grade dedication plans for each uses a description of the AI687 dedication process as technical report. (see updated to include a Common Q hardware or software component that has not been an example of how the process is applied. ML102920031 Item No 1) non-proprietary previously reviewed and approved by the NRC. description and to

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N As listed in Table 6-3. Westinghouse Watts Bar 2 TVA agreed to include (in the include a software (b) The draft ISG6 states that a commercial grade dedication report Common Q PAMS Documents at Westinghouse PAMS licensing technical report) example.

should be provided within 12 months of requested approval for a Rockville Office, the following commercial grade an evaluation of WBN2 critical Tier 2 review. dedication documents are available for NRC audit at the characteristics for commercial Westinghouse Rockville office: (list included in letter) Westinghouse hardware (i) Please provide 00000-ICE-37722 Rev. 0, Commercial Grade components against the generic Dedication Report for the QNX Operating System for Common Q b. It is TVAs understanding that the submittal of the critical characteristics. (see Applications. documents listed in (b.i) and (b.ii) is no longer required. ML102920031 Item No 2)

Rather, it was agreed, that the inclusion of a description (ii) Please provide WNA-CD-00018-GEN Rev. 3, Commercial of the commercial grade dedication process in revision TVA agreed to include a Dedication Report for QNX 4.25G for Common Q Applications. 2 of the Post-Accident Monitoring System (PAMS) description of the generic Licensing Technical Report, WNA-LI-00058-WT-P, Westinghouse software would be sufficient to address this request. commercial grade dedication process in the PAMS licensing TVA Response to Follow-up NRC Request: technical report. (see ML102920031 Item No 3)

The non-proprietary commercial grade dedication discussion is included in Attachment 3, WNA-LI-00058-WBT-NP, Post- TVA agreed to include (in the Accident Monitoring System (PAMS) Licensing Technical PAMS licensing technical report)

Report, Revision 3 dated March 2011 (non-proprietary) an evaluation of WBN2 critical Section 7. The software example is included in Attachment characteristics for commercial 2, WNA-LI-00058-WBT-P, Post-Accident Monitoring System software components against (PAMS) Licensing Technical Report, Revision 3, dated the generic critical March 2011 (proprietary) Section 7. characteristics. (see ML102920031 Item No 4)

( ( (

139 The WBN2 PAMS System Requirements Specification (WBN2 Responder: WEC 135. Y Closed Closed ML101650255, Item TVA Letter dated WBN2 PAMS System Requirements 140 The first requirement in the WBN2 PAMS SysRS (i.e., R2.2-1) Responder: Clark 136. N Closed Closed ML101650255, Item TVA Letter dated WBN2 PAMS System Requirements C C C 141 Deleted by DORL Date: 137. Y Closed Closed ML101650255, Item WBN2 PAMS System Requirements 142 The applicable regulatory guidance for reviewing the WBN2 PAMS Responder: WEC 11. N Open Open-NRC Review ML101650255, Item WBN2 PAMS System Requirements EICB (Carte)

SysRS would be IEEE 830 as endorsed by Regulatory Guide 1.172 No. 6 Specification and BTP 7-14 Section B.3.3.1, Requirements Activities - Software This item is used to track all traceability issues with the Due 2/25/11 (document Requirements Specifications. IEEE 830-1994 Section 4.3.8, Software Requirements Specification (SRS). Revised response included in submittals) TVA docketed WNA-DS-01617-WBT Traceable, states: A [requirements specification] is traceable of letter dated 02/25/11 Rev. 1, RRAS Watts Bar 2 NSSS the origin of each of its requirements is clear NNC 2/2/11: Updated Completion Program I&C Projects Post Response included in letter Specifications and Accident Monitoring System- System

1. How did TVA ensure the traceability of each requirement in TVA Response to 1: dated 12/22/10 RTMs to be provided by Requirements Specification, dated the WBN2 PAMS SysRS. Traceability of requirements for the WBN Unit 2 Common Q TVA December 2009.

PAMS is ensured by: TVA/Westinghouse agreed to

a. Preparation of the TVA Contract Compliance Matrix include the V&V evaluation of Tracability to be contained in WNA-LI-00058-WBT-P, Revision 2, Post- their reusable software element addressed during the Accident Monitoring System (PAMS) Licensing development process in the next audit.

Technical Report submitted in TVA Letter to NRC V&V design phase summary dated December 3, 2010 (Reference 1). report. This evaluation would

b. Engineering review/comment/status of each revision include an evaluation against of: the development process

i. WNA-DS-01617-WBT, Post Accident requirements. This evaluation Monitoring System - System Requirements would also include an evaluation Specification of how the WBN2 specific ii. WNA-DS-01667-WBT, Post Accident requirements were addressed Monitoring System - System Design by the reusable software Specification (hardware) elements. (see ML102920031 iii. WNA-SD-00239-WBT, Software Requirements Item No 5)

Specification for the Post Accident Monitoring System (software)

TVA Response to 2:

2. Explain the source(s) of the requirements present in the Post As documented in the RTM, some software requirements

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Accident Monitoring Systems Software Requirements are taken from generic documents. The decision to include Specification. To clarify, many documents have requirements generic software requirements was to reduce the overall that are incorporated by reference into the SRS, but what scope for Common Q features that are unchanged across served to direct the author to include those various projects. Westinghouse reviewed the generic PAMS documents in the SRS or, if the requirement is based on the requirements and included those requirements that were System Requirements Specification, what directed the author applicable to WBN Unit 2 PAMS.

to include the requirement there?

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

3. Clarify whether the unnumbered paragraphs in the Post TVA Response to 3:

Accident Monitoring Systems Software Requirements Unnumbered paragraphs in the Post Accident Monitoring Specification, such as in the section headings, or are all such Systems Software Requirements Specification, such as in sections simply considered to be informative? the section headings, are informative and are not to be interpreted as requirements. All requirements are explicitly Does the same apply to documents referenced by the SRS? numbered.

Such as WCAP-16096-NP-A, Rev. 1A, Software Program Manual for Common Q Systems, which is incorporated by It depends on the document type. The statement would be reference in requirement R2.3-2 in the SRS. true for requirements documents (such as the SysRS or SDS) if they were incorporated by reference. However, for R2.3-2 [The PAMS software shall comply with the the specific item cited, WCAP-16096-NP-A, Rev. 1A, it does requirements and guidelines defined in WCAP-16096-NP-A, not contain numbered requirements. The requirements Software Program Manual for Common Q Systems contained in this document are contained within the text of (reference 5).] the various sections.

If any requirements are expressed in such unnumbered Source: E-mail from Westinghouse (Matthew A. Shakun) to paragraph form instead of individually identified requirements, Bechtel (Mark S. Clark), RE: December 22 letter review, please list them, describe why they satisfy the fundamental dated December 17, 2010 (Reference 13) requirement of unambiguity, and describe how they were verified.

4. Are there any sources of requirements in parallel with the TVA Response to 4:

Post Accident Monitoring Systems Software Requirements The Westinghouse SRS, WNA-SD-00239-WBT, Revision 3 Specification? Meaning does the SRS contain, explicitly or contains references to other Westinghouse software by reference, all the requirements that were used in the requirements documents. Specifically, design phase for the application specific software, or do software design phase activities use requirements found in 00000-ICE-3238, Revision 5, Software Requirements any other source or document? If so, what are these Specification Post Accident Monitoring System sources or documents?

00000-ICE-3239, Revision 13, Software Requirements Specification for the Common Q Generic Flat Panel Display Software Source: E-mail from Westinghouse (Matthew A. Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

5. References 12, 27, 29, and 31-44 in the Post Accident TVA Response to 5:

Monitoring Systems Software Requirements Specification Requirements for the reusable software elements (RSEDs) are various types of Reusable Software Element. are evaluated in WNA-VR-00283-WBT-P, Revision 3, IV&V Summary Report for the Post Accident Monitoring System, These references are used in the body of the SRS, for dated December 2010 (Attachment 10).

example:

RSED traceability is contained in WNA-VR-00280-WBT, R5.3.14-2 [The Addressable Constants CRC error signal shall Revision 2, Watts Bar 2 NSSS Completion Program I&C be TRUE when any CAL CRC's respective ERROR terminal Projects Requirements Traceability Matrix for the Reactor

= TRUE (WNA-DS-00315-GEN, "Reusable Software Element Vessel Level Indication System (RVLIS) Custom PC Document CRC for Calibration Data" [Reference 12]).] Elements. This document can be made available for audit

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N at the Westinghouse Rockville office.

They are also included via tables such as found in requirement R7.1.2-1 At the September 15 public meeting in Rockville, the following actions were agreed to. These items address the

[The Watts Bar 2 PAMS shall use the application-specific traceability concerns with the Software Requirements type circuits and custom PC elements listed in Table 7.1-1.] Specification.

1. Westinghouse will perform a review of the Do the referenced reusable software element documents include Requirements Traceability Matrix(RTM), using the requirements not explicitly stated in the SRS? If so what is their issues identified at the 9/15 public meeting as a guide origin? (documented below) and update the RTM as required.

TVA Response:

See response to letter Item 13 (NRC Matrix Item 145).

2. The next issue of the IV&V report will include the Requirements phase review of the RTM and a partial review for the Design phase.

TVA Response:

See response to letter Item 13 (NRC Matrix Item 145).

3. Westinghouse will add a comments column in the Requirements Traceability Matrix (RTM) to address items not in the SRS or SysRS.

TVA Response:

A comments column has been added to WNA-VR-00279-WBT, Revision 3, Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System.

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

4. IEEE 830 says you shouldnt have planning information in the SRS. Westinghouse has agreed to remove this information.

TVA Response:

Westinghouse has confirmed that process requirements have been removed from the SRS.

Source: E-mail from Westinghouse (Andrew P. Drake) to Bechtel (Mark S. Clark), RE: Common Q RAI concerns, dated December 8, 2010 (Reference 17)

5. IEEE 830 says you shouldnt have process requirements in the SRS. Westinghouse has agreed to remove these requirements.

TVA Response:

Westinghouse confirmed that process requirements have been removed from the SRS.

Source: E-mail from Westinghouse (Andrew P. Drake) to Bechtel (Mark S. Clark), RE: Common Q RAI concerns, dated December 8, 2010 (Reference 17)

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

6. Westinghouse will perform and document an evaluation of the SRS to ensure compliance with Reg.

Guide 1.172 and justify any deviations.

TVA Response:

WNA-LI-00058-WBT-P, Revision 2, Post-Accident Monitoring System (PAMS) Licensing Technical Report submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1):

Section 9, Compliance Evaluation Of The Watts Bar 2 PAMS Software Requirements Specification To IEEE Standard 830-1998 And Regulatory Guide 1.172 has been added.

7. 25 issues identified by V&V where some requirements have not been included in the System Design Specification (SDS) (14) and SRS (11) at the revisions reviewed by V&V. Have these been addressed?

TVA Response:

The twenty-five (25) issues are captured in Exception Reports (ERs): V&V-769 and V&V-770. These ERs have all been addressed and the ERs have been closed satisfactorily by Westinghouse IV&V.

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

8. Some hardware requirements are contained in the SRS instead of the System Design Specification (SDS). These will be removed from the SRS and incorporated into the next revision of the SDS.

TVA Response:

The hardware requirements in the Software Requirements Specification have been deleted and moved to System Design Specification.

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 16, 2010 (Reference 15)

9. RTM item R4.2-2 protection class software set to 0.

Needs to be fixed internally. Write CAPs to revise the application restrictions document on AC160.

TVA Response:

Westinghouse CAPs IR# 10-259-M034 has been issued. This item will be addressed in revision 4 of the RTM.

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

10. Westinghouse to improve the traceability of the tests

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N that are performed with the function enable (FE) switch in the ENABLE position.

TVA Response:

The tests that are performed with the FE keyswitch in the ENABLE position are defined in the SRS Sections:

6.2 Manually Initiated Testing, 7.2.23 Annunciator Test Display, 7.2.25 Saturation Margin Test Display, and 7.2.26 Analog Output Test Display.

11. Westinghouse to revise documents to be consistent with referring to the FE switch in the ENABLE position.

TVA Response:

Westinghouse has elected to standardize on the terms FE keyswitch and ENABLE. A review of recent documents for compliance with this comment and commitment was performed with the following results:

a. Revision 3 of the SysRS, and SDS have been revised to use the terms FE keyswitch. Revision 3 of the SDS is consistent in use of the term ENABLE.

b. SysRS Revision 3 is not consistent in use of the term ENABLE as noted below:

i. R2.5.2.1-2 uses the term ENABLED instead of ENABLE ii. R2.5.2.1.3-3, R2.6.3.3-1, R2.6.3.3-2, R2.6.3.3-3, and R2.6.3.3-7, use the term Enable instead of ENABLE

c. Revision 3 of the SRS is not consistent in use of the terms FE keyswitch and ENABLE as noted below:

i. Tables 7.2-1 Train A PAMS Data Transmitted to the Plant Computer and 7.2-2 Train B PAMS Data Transmitted to the Plant Computer items 101 and 102 in the SRS refer to the FE switch.

All other items in the SRS refer to the FE keyswitch.

ii. Section 2.1, page 2-4, uses the term Enable instead of ENABLE iii. Requirements R7.2.14-6 and R7.2.16-7 use the term active instead of ENABLE iv. Requirements R7.2.23-2, R7.2.25-2, R7.2.26-2, R7.2.31-4, 7.2.56 FPDS Availability, and R7.2.57-4 use the term enabled instead of ENABLE

d. WNA-AR-00180-WBT-P, Revision 0, Failure Modes and Effects Analysis (FMEA) for the Post Accident Monitoring System, dated October 2010, submitted in TVA letter to NRC dated (Reference

12) is not consistent in use of the term FE keyswitch as noted below:

i. Section 2.2 System Description and Table 3-1 WB2 PAMS FMEA refer to the FE switch.

ii. Table 3-1 describes the switch as the Functional Enable (FE) switch and the FE key-switch

e. Revision 2 of the Licensing Technical Report is not

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N consistent in use of the term FE keyswitch as noted below:

i. Sections 2.2, 5.3 use the term (FE) keylock switch on pages 2-3 (2 places), page 5-3, page 5-6 (4 places)

The identified discrepancies in the use of the terms FE keyswitch and ENABLE in the SysRS, SRS, FMEA and Licensing Technical Report, will be corrected in the next revision of the documents.

12. The flow of information is from the SysRS to the SDS (hardware) and SRS (software). Describe how the documents are used. Describe in 1.1 of the SysRS.

Need a good write up of how the process works.

TVA Response:

See response to letter item 13 (NRC Matrix Item 145).

13. Westinghouse and TVA will develop a revised schedule for document submittals and provide it to the NRC no later than 9/30/10 TVA Response:

The revised document submittal schedule was included as item 3 NRC Request (Matrix Item Number 142, TVA Commitments Nos. 10 and 17) in TVA letter to NRC dated October 26, 2010 (Reference 5).

14. TVA will update the Procurement Requisition Resolution Matrix and submit it to show how the Common Q PAMS design meets the contract requirements.

TVA Response:

The Procurement Requisition Resolution Matrix has been updated and is included in WNA-LI-00058-WBT-P, Revision 2, Post-Accident Monitoring System (PAMS)

Licensing Technical Report submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1), as Section 11, TVA Contract Compliance Matrix.

15. Westinghouse to add the Software Design Descriptions to the RTM TVA Response:

The Software Design Description documents were added to the RTM in WNA-VR-00279-WBT, Rev 2.

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

16. Westinghouse to clarify how requirements or documents are incorporated by reference into the Common Q PAMS requirements.

TVA Response:

When a Common Q PAMS requirements document

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N references a section of another document, all requirements in that section are applicable.

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

17. Westinghouse to review the use of shall outside of numbered paragraphs in requirements documents to ensure that all requirements are captured and clearly identified.

TVA Response:

See response in letter dated December 22, 2010, item 2 (NRC Matrix Item 050).

18. Westinghouse to resolve the following questions concerning Software Design Descriptions (SDDs)

a. Is the SDD a standalone document or will it incorporate the generic SDD by reference?

b. What are the SDDs?

c. PAMS is a delta document so how do we capture all the generic requirements for traceability.

TVA Response:

a. There are three SDDs prepared specifically for the Watts Bar 2 PAMS project. These are listed below in Item b. These documents and superior requirements documents refer to other generic SDDs also listed in Item b.

b. The SDDs developed for this project are:

i. WNA-SD-00248-WBT, Revision 1, Watts Bar 2 NSSS Completion Program I&C Projects Software Design Description for the Post Accident Monitoring System Flat Panel Display ii. WNA-SD-00250-WBT, Revision 1, Watts Bar 2 NSSS Completion Program I&C Projects Software Design Description for the Post Accident Monitoring System AC160 Software iii. WNA-SD-00277-WBT, Revision 2, Watts Bar 2 NSSS Completion Program I&C Projects Software Design Description for the Post Accident Monitoring System Flat Panel Display System Screen Design Details iv. Other generic SDDs referenced by the PAMS project are:

(a) 00000-ICE-20157, Revision 18, Software Design Description for the Common Q Generic Flat-Panel Software (b) 00000-ICE-30152, Revision 5,

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Software Design Description Post Accident Monitoring System AC160 (c) 00000-ICE-30140, Revision 4, Software Design Description for the Common Q Core Protection Calculator System Database and Utility Functions

c. Refer to WNA-VR-00279-WBT, Revision 3.

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

19. For Reusable Software Elements, Westinghouse to describe as qualified libraries by following the SPM and qualified using the Software Elements Test procedure under Appendix B program. Provide a summary of RSEDs generic WCAP. Westinghouse to determine if the WCAP was docketed under the AP1000. RSED concept is not in the SPM. WCAP-15927 AP-1000 does not discuss RCEDs. WCAP process was acceptable. RSEDs are listed in the SDD References.

TVA Response:

Section 3.2.4.1 of WCAP-15927 describes the RSED design process for custom PC elements and type circuits. The Glossary of Terms in the SPM defines custom PC elements and type circuits as modules.

Therefore, the relationship between WCAP-15927 describing the RSED process as circuits, is defined in the SPM requirements for software module development.

WCAP-15927 is on the AP1000 docket.

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

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 scheduled to be available for audit at the Westinghouse Rockville office February 21, 2011. 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

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 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.

143 The WBN2 PAMS Software Requirements Specification (WBN2 Responder: WEC 12. N Open Open-NRC Review ML101650255, Item WBN2 PAMS System Requirements EICB (Carte)

PAMS SRS - ML101050202) contains a table (see page iii) titled, No. 7 Specification Document Traceability & Compliance, which states that the Addressed in the 9/15 public meeting and 9/20 - 9/21 audit. Response included in letter Due 2/25/11 (document WBN2 PAMS SRS was created to support the three documents A detailed explanation will be provided. dated 12/22/10 submittals) TVA docketed WNA-DS-01617-WBT identified (one of which is the WBN2 PAMS SysRS). Section 1.1, Rev. 1, RRAS Watts Bar 2 NSSS Overview, of the WBN2 PAMS SRS states: This document TVA Response: To be addressed by Completion Program I&C Projects Post describes requirements for the major software components Revision of the RTM, Accident Monitoring System- System (a) and (b) The requested information is provided in the SRS, SysRS, and Requirements Specification, dated (a) Please list and describe each of the major software following documents: SysDS. December 2009.

components. Please include a description of any NRC review for i. WNA-LI-00058-WBT-P, Revision 2, Post-each of these components. Accident Monitoring System (PAMS) Licensing NNC 2/2/11: Updated Technical Report, Table 6-1, Document Specifications and (b) Please list and describe each of the other software Requirements which lists the software RTMs to be provided by components. Please include a description of any NRC review for documentation requirements for the Common Q TVA each of these components. PAMS and Section 11 TVA Contract Compliance Matrix submitted in TVA Letter to NNC 2/3/11: The (c) What other documents contain the requirements for the other NRC, dated December 3, 2010 (Reference 1). above due date has software components? ii. WNA-DS-01617-WBT-P, Revision 3, Post been missed by at Accident Monitoring System- System least 2 months.

The WBN2 PAMS System Design Specification (WBN2 PAMS Requirements Specification, dated December Please provide new SDS) contains a table (see page iii) titled, Document Traceability 2010 (Attachment 1) due date.

& Compliance, which states that the WBN2 PAMS SysRS was iii. WNA-SD-00239-WBT-P, Revision 3, Software created to support the WBN2 PAMS SysRS. Section 1.1, Requirements Specification for the Post Accident Purpose, of the WBN2 PAMS SDS states: The purpose of this Monitoring System, dated December 2010 document is to define the hardware design requirements (Attachment 7) iv. WNA-VR-00279-WBT, Revision 3, Watts Bar 2 (c) Do the WBN2 PAMS SRS and SDS, together, implement all of NSSS Completion Program I&C Projects the requirements in the WBN2 PAMS SysRS? Requirements Traceability Matrix for the Post

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Accident Monitoring System (available for NRC (e) Please briefly describe all of the documents that implement audit at the Westinghouse Rockville office) the WBN2 PAMS SysRS. To the best of TVAs knowledge, no prior NRC review of the software components has been performed.

(c) WNA-VR-00280-WBT, Revision 2, Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Reactor Vessel Level Indication System (RVLIS) Custom PC Elements (available for NRC audit at the Westinghouse Rockville office)

(d) No. Please see Item (e) below.

(e) The documents that describe the requirements that implement the WBN Unit 2 SysRS are:

i. WNA-VR-00279-WBT, Revision 3, Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System (available for NRC audit at the Westinghouse Rockville office) ii. WNA-VR-00280-WBT, Revision 2, Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Reactor Vessel Level Indication System (RVLIS) Custom PC Elements (available for NRC audit at the Westinghouse Rockville office)

Source: E-mail from Westinghouse (Matthew A. Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

TVA Response to Follow-up NRC Request:

See Response to item 3 (Item number 142) 144 The WBN2 PAMS Software Requirements Specification (WBN2 Responder: WEC 13. N Open Open-NRC Review ML101650255, Item TVA Letter dated WBN2 PAMS Software Requirements EICB (Carte)

PAMS SRS) contains a table (see page iii) titled, Document No. 8 10/5/10 Specification Traceability & Compliance, which states that the WBN2 PAMS (a) The purpose of NABU-DP-00014-GEN document is to Pending Submittal of Revision 3 Due 3/29/11 SRS was created to support the three documents identified (two ofdefine the process for system level design, software design of the Licensing Technical By letter dated April 8, 2010 these documents have been provided on the docket). and implementation, and hardware design and Report due 3/29/11. Responses to items a (ML10101050203), TVA docketed implementation for Common Q safety system development. and e provided. WNA-SD-00239-WBT, Revision 1, (a) Please describe the third document (i.e., NABU-DP-00014-GEN This document supplements the Common Q SPM, WCAP- "RRAS Watts Bar 2 NSSS Completion Revision 2, Design Process for Common Q Safety Systems). 16096-NP-A. The scope of NABU-DP-00014-GEN includes Revised response included in NNC 11/18/10: Program I&C Projects, Software the design and implementation processes for the application letter dated 12/22/10 (1) Items b-d closed to Requirements Specification for the Post (b) Please describe the flow of information between these three development. For a fuller description of the design process other Open Item nos. Accident Monitoring System, dated documents. described in NABU-DP-00014-GEN please refer to the Response provided in letter (2) The point of these February 2010 (ML101050202).

Design Process for AP1000 Common Q Safety Systems, dated 10/5/10 questions was to (c) Does the PAMS SRS implement the requirements in these WCAP-15927 on the AP1000 docket. Since this is a understand how the three documents? Westinghouse process document that is not specifically NRC Review and WEC to origin of the referenced in the SRS, it will be removed in the next revision complete response. requirements in the (d) Please describe if and how these three documents are used in of the document. requirements the development of the PAMS Software Design Description. b-d to be addressed at public specifications were (b) - Closed to items 142 and 145 meeting and audit. Will require documented. TVA (e) Do the WBN2 V&V activities include verification that the information to be docketed. stated that the origin of requirements of these three documents have been incorporated (c) - Closed 142 the requirements would into the WBN2 PAMS SRS. be demonstrated in (d) - Closed to Item 142 Rev. 2 of the CQ PAMS LTR.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N (e) WBN2 PAMS Software Requirements Specification (WNA-SD-00239-WBT, Rev. 1) refers to Document NNC 2/3/11: CQ Traceability & Compliance table on page iii. This table has PAMS LTR Rev. 2 three entries; Design Process for Common Q Safety Section 11 & 12 do not Systems (NABU-DP-00014-GEN, Rev. 2), RRAS Watts Bar adequately 2 NSSS Completion Program I&C Projects Post Accident demonstrate the origin Monitoring System - System Requirements Specification of requirements in (WNA-DS-01617-WBT, Rev. 1), and RRAS Watts Bar 2 SysRS. TVA to NSSS Completion Program I&C Projects Post Accident describe how to Monitoring System - System Design Specification (WNA- address concern.

DS-01667-WBT, Rev. 1).

IV&V performed a Requirements Traceability Assessment during which it reviewed Software Requirements Specification (WBN2 PAMS SRS, WNA-SD-00239-WBT, Rev. 1) against System Requirements Specification (WNA-DS-01617-WBT, Rev. 1) and System Design Specification (WNA-DS-01667-WBT, Rev. 1). Requirements within Software Requirements Specification that are referring to NABU-DP-00014-GEN, Rev 2, Design Process for Common Q Safety Systems, have also been reviewed for traceability and compliance. During IV&V's RTA effort the anomaly reports V&V-769 and V&V- 770 have been initiated and reported in the IV&V Phase Summary Report for the System Definition Phase, WNA-VR-00283-WBT, Rev. 0.

IV&V has verified that the requirements in SRS are derived from the specified documents listed in the Document Traceability and Compliance Table of WBN2 PAMS SRS.

TVA Response to Follow-up NRC Request:

(1) Item (a) in the original list, NABU-DP-00014-GEN Revision 2, Design Process for Common Q Safety Systems, is available for NRC audit at the Westinghouse Rockville office.

(2) WNA-LI-00058-WT-P, Revision 2, Post-Accident Monitoring System (PAMS) Licensing Technical Report submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1) contains the following change to address the NRC request:

Section 11, TVA Contract Compliance Matrix showing the origin of the requirements was added.

TVA Response to Second Follow-up NRC Request:

Section 13, Origin Tracing of WBN2 PAMS System Requirements Specification was added to the Licensing Technical Report Revision 3 to address this concern.

Attachment 2 contains WNA-LI-00058-WBT-P, Post-Accident Monitoring System (PAMS) Licensing Technical Report, Revision 3, dated March 2011 (proprietary).

145 The WBN2 PAMS System Design Specification (WBN2 PAMS Responder: WEC 14. N Open Open-NRC Review ML101650255, Item WBN2 PAMS System Design EICB SDS) contains a table (see page iii) titled, Document Traceability No. 9 Specification (Carte) & Compliance, which states that the WBN2 PAMS SDS was (1) The review and update of the RTM is complete. The Response included in letter Due 2/25/11 created to support the WBN2 PAMS SysRS. revised RTM can be made available for NRC audit at dated 12/22/10 TVA docketed WNA-DS-01667-WBT

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N the Westinghouse office in Rockville. To be addressed by Rev. 1, RRAS Watts Bar 2 NSSS (a) Does the WBN2 PAMS SDS implement all of the hardware During the September 20-21, Revision of the RTM, Completion Program I&C Projects Post requirements in the WBN2 PAMS SysRS? (2) Please see letter Item 10 (NRC Matrix Item 142, sub 2010 audit at Westinghouse, it SRS, SysRS, and Accident Monitoring System- System item 13). was acknowledged that SysDS. Design Specification, dated December (b) Please briefly describe all of the documents that implement the TVA/Westinghouse had 2009.

hardware requirements of the WBN2 PAMS SysRS. (3) Please see letter Item 10 (NRC Matrix Item 142, sub previously (in September 15, item 12). 2010 public meeting) stated:

This item is used to track all traceability issues with the System Design Specification (SDS). (4) Section 11 TVA Contract Compliance Matrix was TVA would provide the RSED added to WNA-LI-00058-WBT-P, Revision 2, Post- RTM. (see ML102920031 Item At the September 15 public meeting in Rockville, the following Accident Monitoring System (PAMS) Licensing No 6) actions were agreed to. These items partially address the Technical Report submitted in TVA Letter to NRC traceability concerns with the System Design Specification. dated December 3, 2010, (Reference 1). TVA would revise and resubmit This item will be updated with the results of the September 20 the PAMS RTM to address all and 21 Commercial Grade Dedication and SDS RTM audit. (5) WNA-VR-00283-WBT, Revision 1, IV&V Summary types of issues identified in the Report for the Post Accident Monitoring System, public meeting. (see

1. Westinghouse will perform completed a review of the submitted in TVA to NRC letter dated December 3, ML102920031 Item No 7)

Requirements Traceability Matrix(RT), using the issues 2010 (Reference 1) includes the Requirements and identified at the 9/15 public meeting as a guide (documented Design phase reviews. TVA would revise and resubmit below) and update the RTM as required. the Software Verification and (6) Per Westinghouse letter WBT-D-2268 NRC Access to Validation phase summary

2. Some hardware requirements are contained in the SRS Common Q Documents at the Westinghouse Rockville report for the requirements instead of the System Design Specification (SDS). These will Office dated August 16, 2010 (Reference 9) System phase to document the be removed from the SRS and incorporated into the next Requirements Specification for the Common Q Generic completion of the requirements revision of the SDS. Flat Panel Display, 00000-ICE-30155, Revision 9 is phase review. (see available for audit at the Westinghouse Rockville office. ML102920031 Item No 8)

3. 25 issues identified by V&V where some requirements have not been included in the SDS (14) and SRS (11) at the The generic AC160 specifications are contained in the revisions reviewed by V&V. Have these been addressed? documents listed below. The documents are available Yes. The next revisions of the SDS and SRS address these for NRC audit at the Westinghouse Rockville office in issues. accordance with the letter number referenced. List is contained in letter.

4. TVA will update the Procurement Requisition Resolution Matrix and submit it to show how the Common Q PAMS (7) A schedule was developed and is reviewed weekly by design meets the contract requirements. Westinghouse and TVA project management.

5. The next issue of the IV&V report will include the (8) The revised document submittal schedule was Requirements phase review of the RTM and a partial review included as item 3 NRC Request (Matrix Item Number for the Design phase. 142, TVA Commitments Nos. 10 and 17) in TVA letter to NRC dated October 26, 2010.

6. Westinghouse to provide the generic AC160 and flat panel specifications. (9) The flow of documentation information was provided to the NRC inspector during the Common Q PAMS audit.

7. Westinghouse and TVA to develop a schedule of licensing document submittals that can be met by the project team. Source: E-mail from Westinghouse (Andrew P. Drake) to Bechtel (Mark S. Clark), RE: RAI on SysRS, dated

8. The flow of information is from the SysRS to the SDS December 8, 2010 (hardware) and SRS (software). Describe how the documents are used. Describe in 1.1 of the SysRS. Need a TVA Response to Follow-up NRC Request:

good write up of how the process works.

See Response to item 3 (Item number 142)

( ( (

146 6/17/2010 Responder: 138. Y Closed Closed ML101650255, Item PAMS System Requirements

( (

147 6/17/2010 Responder: 139. Y Closed Closed ML101650255, Item PAMS System Requirements C C C 148 6/17/2010 Responder: 140. Y Closed Closed ML101650255, Item PAMS System Requirements G G 149 7.2 7.2 FSAR Section 7.1.1.2(2), Overtemperature delta T and Responder: Tindell 141. Y Close Closed ML101720589, Item TVA Letter dated 150 7.2 7.2 Many of the changes were based on the Westinghouse document Responder: Clark 142. Y Close Closed ML101720589, Item TVA Letter dated

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

( ( ( ( ( ( ( ( ( ( ( ( (

151 7.2 7.2 Provide the EDCR 52378 and 54504 which discusses the basis for Responder: Clark 143. Y Close Closed ML101720589, Item TVA Letter dated 152 7.2 7.2 Deleted portion of FSAR section 7.2.3.3.4 and moved to FSAR Responder: Merten/Clark 144. Y Close Closed ML101720589, Item TVA Letter dated 153 7.2 7.2 FSAR section 7.2.1.1.7 added the reference to FSAR section Responder: Craig/Webb 145. Y Close Closed ML101720589, Item TVA Letter dated 154 7.2 7.2 FSAR section 7.2.1.1.10, setpoints: NRC staff has issued RIS Responder: Craig/Webb 146. Y Closed Closed ML101720589, Item TVA Letter dated EICB RAI ML102861885 sent to DORL 155 7.2 7.2 Summary of FSAR change document section 7.2 states that Date: 147. Y Closed Closed ML101720589, Item 156 7.2 7.2 FSAR section 7.2.2.1.1 states that dashed lines in Figure 15.1- Responder: WEC 148. Y Closed Closed ML101720589, Item TVA Letter dated Response on hold pending 157 7.2 7.2 FSAR section 7.2.2.1.1, fifth paragraph was deleted except for the Responder: Tindell 149. Y Close Closed ML101720589, Item TVA Letter dated G G G G G G G G G G G G G 158 7.2 7.2 FSAR section 7.2.2.1.1, paragraph six was changed to state that Responder: Tindell 150. Y Closed Closed ML101720589, Item TVA Letter dated 159 7.2 7.2 FSAR section 7.2.2.1.2 discusses reactor coolant flow Responder: Craig 151. Y Close Closed ML101720589, Item TVA Letter dated 160 7.2 7.2 FSAR section 7.2.2.2(7) deleted text which has references 12 and Responder: Tindell 152. Y Close Closed ML101720589, Item TVA Letter dated 161 7.2 7.2 FSAR section 7.2.2.3 states that changes to the control function Responder: Clark 153. Y Closed Closed ML101720589, Item TVA Letter dated 162 7.2 7.2 FSAR section 7.2.2.2(14) states that bypass of a protection Responder: Tindell 154. Y Closed Closed ML101720589, Item TVA Letter dated 163 7.2 7.2 Deleted by DORL Date: 155. Y Closed Closed ML101720589, Item 164 7.2 7.2 FSAR section 7.2.2.2(20) has been revised to include the plant Responder: Perkins 156. Y Closed Closed ML101720589, Item TVA Letter dated Item No. 8 sent to DORL a

165 7.2 7.2 FSAR section 7.2.2.3.2, last paragraph of this section has been Responder: Clark 157. Y Closed Closed ML101720589, Item TVA Letter dated 166 7.2 7.2 Changes to FSAR section 7.2.2.2(20) are justified based on the Responder: Clark 158. Y Closed Closed ML101720589, Item TVA Letter dated

( (

167 7.2 7.2 FSAR section 7.2.2.4, provide an analysis or reference to chapter Responder: Clark 159. Y Close Closed ML101720589, Item TVA Letter dated 168 7.2 7.2 FSAR table 7.2-4, item 9 deleted loss of offsite power to station Responder: Clark 160. Y Close Closed ML101720589, Item TVA Letter dated

( ( ( ( r 169 6/18/2010 Responder: Clark 161. Y Closed Closed 170 6/17/2010 Responder: Clark 162. Y Closed Closed M M ( ( ( ( ( ( ( ( ( ( ( (

171 7.2 7.2 6/17/2010 Responder: Craig 163. Y Closed Closed EICB RAI TVA Letter dated Closed to SE Open Item 172 6/17/2010 Responder: Craig 164. Y Closed Closed EICB RAI 173 7.1 7.1 6/17/2010 Responder: Craig/Webb/Powers 165. Y Closed Closed EICB RAI C C C C g 174 6/28/2010 Responder: Hilmes/Craig 166. Y Closed Closed EICB RAI 175 June 28, 2010 Responder: 167. Y Closed Closed EICB RAI a a G G G G G G G G G G G G 176 7.1 7.1 6/28/2010 Responder: Craig/Webb 168. Y Closed Closed EICB RAI 177 7.5.2. 7.5.1 7/15/2010 Responder: Clark 169. Y Closed Closed N/A TVA Letter dated RAI not required l

178 7.5.2. 7.5.1 7/15/2010 Responder: Clark 170. Y Closed Closed N/A TVA Letter dated RAI not required 179 An emphasis is placed on traceability in System Requirements Responder: WEC 171. Y Closed Closed N/A - Closed to NA 180 The SRP, BTP 7-14, Section B.3.3.1 states that Regulatory Guide Responder: WEC 172. Y Closed Closed N/A - Closed to NA 181 An emphasis is placed on traceability in System Requirements Responder: WEC 173. Y Closed Closed N/A - Closed to NA 182 Characteristics that the SRP states that a Software Requirements Responder: WEC 174. Y Closed Closed N/A - Closed to NA 183 7/15/2010 Responder: WEC 15. Y Open Open-NRC Review EICB RAI TVA Letter dated EICB (Carte)

ML102980066 Item 10/21/10 An emphasis is placed on traceability in System Requirements The generic Software Requirements Specification applies Pending Submittal of Revision 3 Due 3/29/11 No. 9 Enclosure 1 Item Specifications in the SRP, in the unmodified IEEE std 830-1993, except as modified by the WBN Unit 2 System Requirements of the Licensing Technical No. 4 and even more so given the modifications to the standard listed in Specification. Report due 3/29/11. NNC 11/18/10: The Regulatory Guide 1.172, which breaks with typical NRC use of the point behind this open word should to say Each identifiable requirement in an SRS must TVA Response to Follow-up NRC Request: item was that TVA must be traceable backwards to the system requirements and the design Revised response included in demonstrate that the bases or regulatory requirements that is satisfies Please see the response to RAI item 12 in letter dated letter dated 12/22/10. origin of each 12/22/10, NRC Matrix Item 144. requirement in the On page 1-2 of the Post Accident Monitoring Systems Software WEC requirements Requirements Specification in the background section, is the TVA Response to Second Follow-up NRC Request: Response provided in letter specification is known sentence Those sections of the above references that require dated 10/21/10 and documented. TVA modification from the generic PAMS are defined in the document This item was addressed by updating the Contract stated that this

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N referring purely to the changes from WNA-DS-01617-WBT Post Compliance Matrix and adding Section 13, Origin Tracing of information would be in Accident Monitoring System-System Requirements Specification WBN2 PAMS System Requirements Specification to the CQ PAMS LTR Rev. 2.

or is it saying that there are additional changes beyond those and Licensing Technical Report Revision 3 to address this that the SRS defines them? concern. Attachment 2 contains WNA-LI-00058-WBT-P, NNC 2/3/11: CQ PMS Post-Accident Monitoring System (PAMS) Licensing LTR Rev. 2 Sections 11 If there are additional changes, what is their origin? Technical Report, Revision 3, dated March 2011 & 12 do not prove this (proprietary). information. TVA to proive a plan to address requested information.

(

184 C 7/15/2010 Responder: WEC 175. Y Closed Closed N/A - Closed to N/A 185 7/15/2010 Responder: WEC 16. N Open Open-NRC Review EICB RAI EICB (Carte)

ML102980066 Item An emphasis is placed on the traceability of requirements in Steve Clark to look at how to combine traceability items. Response included in letter NNC 11/18/10: (1)The No. 17 Software Requirements Specifications in the SRP, in the dated 12/22/10. point behind this open unmodified IEEE std 830-1993, and even more so given the Was addressed to during the 9/15 meeting and 9/20 - 9/21 item was that TVA must modifications to the standard listed in Regulatory Guide 1.172, audit. demonstrate that the which breaks with typical NRC use of the word should to say origin of each Each identifiable requirement in an SRS must be traceable TVA Response to Follow-up NRC Request: requirement in the backwards to the system requirements and the design bases or (1) See NRC Matrix Item 144 WEC requirements regulatory requirements that is satisfies Also the NRC considers (2) There is no RTM for development of the individual specification is known that the SRS is the complete set of requirements used for the reusable software elements. As listed in item 15 of and documented. TVA design of the software, whether it is contained within one document Table 6-1 Document Requirements of WNA-LI-00058- stated that this or many. In order to evaluate an SRS against the guidance in the WT-P, Revision 2, Post-Accident Monitoring System information would be in SRP the staff needs access to all the requirements. (PAMS) Licensing Technical Report submitted in TVA CQ PAMS LTR Rev. 2.

Letter to NRC, dated December 3, 2010, a RTM for (2) TVA also said it References 12, 27, 29, and 31-44 in the Post Accident Monitoring implementation of the RSEDs (WNA-VR-00280-WBT) would provide a RTM Systems Software Requirements Specification are various types of for the WBN Unit 2 Common Q PAMS has been for the RSED Reusable Software Element. developed. This document is available for NRC audit at the Westinghouse Rockville office. NNC 2/3/11: To be These references are used in the body of the SRS, for example: addressed during next audit.

R5.3.14-2 [The Addressable Constants CRC error signal shall be TRUE when any CAL CRC's respective ERROR terminal = TRUE (WNA-DS-00315-GEN, "Reusable Software Element Document CRC for Calibration Data" [Reference 12]).]

They are also included via tables such as found in requirement R7.1.2-1

[The Watts Bar 2 PAMS shall use the application-specific type circuits and custom PC elements listed in Table 7.1-1.]

Do the referenced reusable software element documents include requirements not explicitly stated in the SRS? If so what is their origin?

186 7.7.8 7.7.1.12 ( 7/15/2010 Responder: Perkins/Clark 176. Y Closed Closed EICB RAI No.6 TVA Letter dated 187 ( ( D By letter dated June 18, 2010, TVA docketed responses to NRC Responder: Merten 177. N Closed Closed ML101970033, Item TVA Letter dated Are these connections already C C a 188 By letter dated June 30, 2010, TVA docketed, Tennessee Valley Responder: Clark 178. Y Closed Closed ML101970033, Item TVA Letter dated

(

189 7.6.7 7/20/2010 Responder: Clark 179. Y Closed Closed RAI No. 3 TVA Letter dated S

i 190 7.9 ( ( FSAR Table 7.1-1 states: Regulatory Guide 1.133, May 1981 Responder: Clark 180. Y Closed Closed RAI No. 4 TVA Letter dated Closed to OI-331.

( (

191 7.9 M M NUREG-0800 Chapter 7, Section 7.9, "Data Communication Responder: Jimmie Perkins 181. Y Closed Closed ML10197016, Item TVA Letter dated C S 192 7.5.1. 7.5.2 a a The NRC Staff is using SRP (NUREG-0800) Chapter 7 Section Responder: Clark 182. Y Closed Closed Item No. 1 sent to TVA Letter dated EICB RAI ML1028618855 sent to i

193 7.5.1. 7.5.2 The WBU2 FSAR, Section 7.5.2, Plant Computer System, Responder: Clark 183. Y Closed Closed Item No. 2 sent to TVA Letter dated EICB RAI ML1028618855 sent to

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 194 7.5.1. 7.5.2.1 ( ( ( The WBU2 FSAR Section 7.5.2.1, Safety Parameter Display Responder: Costley/Norman 184. Y Closed Closed Item No. 3 sent to TVA Letter dated EICB RAI ML1028618855 sent to 195 7.5.1. 7.5.2.2 M M M Bypassed and Inoperable Status Indication (BISI) Responder: Costley/Norman 185. Y Closed Closed Item No. 4 sent to TVA Letter dated EICB RAI ML1028618855 sent to a a a 196 7.5.1. 7.5.2.2 Bypassed and Inoperable Status Indication (BISI) Responder: Costley/Norman 186. Y Closed Closed Item No. 5 sent to TVA Letter dated EICB RAI ML1028618855 sent to 197 ( ( Open Item 197 was never issued. 187. Y Closed Closed 198 7.5.1. 7.5.2.2 M M X SRP Section 7.5, Subsection III, Review Procedures states: Responder: Costley/Norman 188. Y Closed Closed Item No. 6 sent to TVA Letter dated EICB RAI ML1028618855 sent to a a 199 7.5.1. 7.5.2.3 The WBU2 FSAR Section 7.5.2.3, Technical Support Center and Responder: Costley/Norman 189. Y Closed Closed Item No. 7 sent to TVA Letter dated Related SE Section 7.5.5.3 EICB RAI 200 7.2 7/21/2010 Responder: Clark 190. Y Closed Closed EICB RAI TVA Letter dated

(

201 7.7.1. 7.7.11 C 7/21/2010 Responder: Webb 191. Y Closed Closed EICB RAI TVA Letter dated 202 7.5.2 7/22/2010 Responder: WEC 17. N Open Open-NRC Review EICB RAI TVA Letter dated NNC 1/5/11: See Also Open Item No.

EICB (Carte)

ML102980066 Item 10/5/10 81 and 86.

The letter (ML0003740165) which transmitted the Safety Revision 1 of the Licensing Technical Report will provide Pending Submittal of Revision 3 Due 2/25/11 & No. 4 Evaluation for the Common Q topical report to Westinghouse more detailed information on the changes to the platform. of the Licensing Technical 3/29/11 stated: "Should our criteria or regulations change so that our Report due 3/29/11.

conclusions as to the acceptability of the report are invalidated, CE to provide information Nuclear Power and/or the applicant referencing the topical report Rev. 2 of the Licensing Technical Report will include the Response included in letter requested.

will be expected to revise and resubmit their respective applicability of guidance. dated 12/22/10 documentation, or submit justification for continued applicability of Due TBD the topical report without revision of the respective documentation." TVA Response to Follow-up NRC Request: Partial Response provided in Question No 81 identified many criteria changes; please revise the WNA-LI-00058-WBT-P, Revision 2, Post-Accident letter dated 10/5/10 respective documentation or submit justification for continued Monitoring System (PAMS) Licensing Technical Report applicability of the topical report. (LTR) submitted in TVA Letter to NRC dated December 3, NNC 1/5/11: Summary provided 2010, contains the following change to address the NRC in Licensing Technical Report request: R2 has been reviewed and found to be unacceptable.

Section 9, Compliance Evaluation of the Watts Bar 2 PAMS Software Requirements Specification to IEEE Standard 830- LTR Section 9 evaluates the 1998 and Regulatory Guide 1.172 to show the origin of the compliance of the SRS to IEEE requirements has been added. 830-1998. There are two issues with this evaluation:

The descriptions and commitments in the Topical Report (1) IEEE 830-1998 is not the (TR) still apply. The LTR provides compliance evidence to current SRP acceptance criteria.

the new ISG-04 criteria. The statement in the SE means that IEEE 830-1998 has not been the TR can be evaluated against later NRC criteria when it formally endorsed by a appears. regulatory guide.

(2) Westinghouse committed to Source: E-mail from Westinghouse (Matthew A. Shakun) to evaluate the SRS against 830 Bechtel (Mark S. Clark), RE: December 22 letter review, when the NRC identified several dated December 17, 2010 inconsistencies.

Partial TVA Response to Follow-up NRC Request: Yes ISG-4 is one new criteria, and an evaluation against it has Attachment 4 contains the results of the TVA analysis of been provided.

standards and regulatory guides applicable to the Common Q PAMS. Based on the results of the analysis, the Common In addition, LTR Rev. 2 Section Q PAMS design is acceptable. 13 states: The applicable NRC regulatory guides, IEEE and The final response is pending submittal of the Licensing EPRI industry standards fo the Technical Report Revision 3 scheduled for March 29, 2011. common Q PAMS are shown below. Compliance to these TVA Response to Follow-up NRC Request: codes and standards are stated in Section 4 of Reference 1.

(1) As discussed on page 9-1 of the Licensing Technical Reference 1 is the common Q Report (Attachment 2) a comparison of IEEE 830-1993 topical report.

and IEEE 830-1998 was performed and it was determined that the 1998 version enveloped all the

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N requirements of the 1993 version which is endorsed by Regulatory Guide 1.172. Therefore the use of IEEE 830-1998 is acceptable.

(2) Table 9.1 IEEE Std 830-1998 Compliance of the Licensing Technical Report (Attachment 2) evaluates the Software Requirements Specification against the requirements of IEEE 830-1998.

(3) See TVA to NRC letter Watts Bar Nuclear Plant (WBN)

Unit 2 - Instrumentation And Controls Staff Information Requests, dated February 25, 2011 Attachment 4 Common Q PAMS Regulatory Guide and IEEE Standard Analysis.

(4) This section of the Licensing Technical Report (Attachment 2) has been relocated to section 15. The comment has been addressed by adding Reference 40 to TVA to NRC letter dated February 25, 2011, Attachment 4 which is the Common Q PAMS Regulatory Guide and IEEE Standard Analysis.

( ( ( ( ( (

203 7.5.1. 7.5.2 7/26/2010 Responder: Clark 192. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 204 7.5.1. 7.5.2 7/26/2010 Responder: Costley/Norman 193. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL

( (

205 7/26/2010 Responder: Clark 194. Y Closed Closed EICB RAI TVA Letter dated Question B related to prior NRC M M M M ( M M 206 7.5.1. 7.5.2 7/27/2010 Responder: Clark 195. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 207 July 27, 2010 Date: 196. Y Closed Closed C C 208 7.5.2. 7.5.1 7/27/2010 Responder: Clark 197. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL a a a a G a a 209 7.5.2. 7.5.1 7/27/2010 Responder: Clark 198. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 210 7.5.2. 7.5.1 7/27/2010 Responder: Clark 199. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 211 7.5.1. 7/27/2010 Responder: Clark 200. Y Closed Closed EICB RAI TVA Letter dated Relates to SE Sections:

212 7.5.2 7/27/2010 Responder: WEC 18. N Open Open-NRC Review EICB RAI EICB (Carte)

ML102980066 Item By letter dated June 18, 2010 (ML101940236) TVA stated Application specific requirements for testing. This cannot be Partial Response included in No. 10 (Enclosure 1, Attachment 3, Item No. 3) that the PAMS system addressed in a topical report. Evaluation of how the letter dated 03/16/11 design specification and software requirements specification hardware meets the regulatory requirements.

contain information to address the "Design Report on Computer Final response due 3/29/11 Integrity, Test and Calibration..." The staff has reviewed these WEC to provide the information and determine where the documents, and it is not clear how this is the case. information will be located.

(1) Please describe how the information provided demonstrates compliance with IEEE 603-1991 Clauses 5.5, 5.7, 5.10, & 6.5. IEEE-603 1991:

(2) Please describe how the information provided demonstrates 5.5 System Integrity. The safety systems shall be NNC 2/17/2011: IEEE conformance with IEEE 7-4.3.2-2003 Clauses 5.5 & 57. designed to accomplish their safety functions under the 603 Clause 5.5 full range of applicable conditions enumerated in the basically states that design basis. conditions identified in IEEE 603 Clauses 4.7 TVA Response: The applicable conditions and & 4.8 must be Common Q PAMS system compliance are contained in addressed in the WNA-LI-00058-WBT-P, Rev. 2, Post-Accident design. Energy supply Monitoring System (PAMS) Licensing Technical conditions have not Report submitted in TVA Letter to NRC dated been identified, or December 3, 2010, Section 11, Contract Compliance explicitly addressed.

Matrix items:

87 and 88 Seismic 89, 90, 91, 92 and 185 EMI/RFI

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 300, 301 and 302 Environmental Seismic qualification of the equipment to meet the design basis requirements NNC 2/18/11: Clause 5.7 is acceptably 5.7 Capability for Test and Calibration. Capability for addressed.

testing and calibration of safety system equipment shall be provided while retaining the capability of the safety systems to accomplish their safety functions.

The capability for testing and calibration of safety system equipment shall be provided during power operation and shall duplicate, as closely as practicable, performance of the safety function. Testing of Class 1E systems shall be in accordance with the requirements of IEEE Std 338-1987. Exceptions to testing and calibration during power operation are allowed where this capability cannot be provided without adversely affecting the safety or operability of the generating station. In this case:

(1) appropriate justification shall be provided (for example, demonstration that no practical design exists),

(2) acceptable reliability of equipment operation shall be otherwise demonstrated, and (3) the capability shall be provided while the generating station is shut down.

TVA Response: The requirements for test and calibration and Common Q PAMS system compliance, are contained in WNA-LI-00058-WBT-P, Rev. 2, Post-Accident Monitoring System (PAMS) Licensing Technical Report Section 11, TVA Contract Compliance Matrix items:

202 self test 350 Maintenance Bypass NNC 2/18/2011: WNA-351 Loop Tuning Parameters, AR-00189-WBT Rev. 0 Table 5-2 shows a 400 and 401 3.7.2 Testing, Calibration, and MTTR of 7.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. It Verification is not clear how this 402, 403 and 404, 3.7.3 Channel Bypass or satisfies the Removal from Operation contractual item No.

179.

5.10 Repair. The safety systems shall be designed to facilitate timely recognition, location, replacement, The Contract repair, and adjustment of malfunctioning equipment.

Compliance Matrix Item 179 in Revision 3 of the TVA Response: The requirements for repair and LTR has been revised Common Q PAMS system compliance are contained in to show this item as a WNA-LI-00058-WBT-P, Rev. 2, Post-Accident deviaition and to reflect Monitoring System (PAMS) Licensing Technical TVAs acceptance of Report Section 11, TVA Contract Compliance Matrix the 7.2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> MTTR items:

value. Attachment 2 179 Mean time to repair contains WNA-LI-202 self test 00058-WBT-P, Post-398 3.7 Maintenance Accident Monitoring 399 3.7.1 Troubleshooting System (PAMS)

Licensing Technical 6.5 Capability for Testing and Calibration Report, Revision 3, dated March 2011

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 6.5.1 Means shall be provided for checking, with a high (proprietary).

degree of confidence, the operational availability of each sense and command feature input sensor required for a safety function during reactor operation.

This may be accomplished in various ways; for example:

(1) by perturbing the monitored variable, (2) within the constraints of 6.6, by introducing and varying, as appropriate, a substitute input to the sensor of the same nature as the measured variable, or (3) by cross-checking between channels that bear a known relationship to each other and that have readouts available.

6.5.2 One of the following means shall be provided for assuring the operational availability of each sense and command feature required during the post-accident period:

(1) Checking the operational availability of sensors by use of the methods described in 6.5.1.

(2) Specifying equipment that is stable and retains its calibration during the post-accident time period.

TVA Response: The requirements for sense and command feature testing and Common Q PAMS system compliance are contained in WNA-LI-00058-WBT-P, Revision 2, Post-Accident Monitoring System (PAMS) Licensing Technical Report Section 11 TVA Contract Compliance Matrix items:

10, display of sensor diagnostic information 202 self test 205 self diagnostics and watchdog timer 264 through 271, system self checks 311 system status displays, 341 alarms, 344 on-line diagnostics IEEE 7-4.3.2-2003 5.5 System integrity In addition to the system integrity criteria provided by IEEE Std 603-1998, the following are necessary to achieve system integrity in digital equipment for use in safety systems:

Design for computer integrity Design for test and calibration Fault detection and self-diagnostics 5.5.1 Design for computer integrity The computer shall be designed to perform its safety function when subjected to conditions, external or internal, that have significant potential for defeating the safety function. For example, input and output processing failures, precision or round off problems, improper recovery actions, electrical input voltage and frequency fluctuations, and maximum credible number of coincident signal changes.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N If the system requirements identify a safety system preferred failure mode, failures of the computer shall not preclude the safety system from being placed in that mode. Performance of computer system restart operations shall not result in the safety system being inhibited from performing its function.

TVA Response: Common Q PAMS system reliability and failure modes are described in:

WNA-AR-00180-WBT, Revision 0, Failure Modes and Effects Analysis (FMEA) for the Post Accident Monitoring System WNA-AR-00189-WBT, Revision 0 Post Accident Monitoring System Reliability Analysis The requirements for mean time between failure and Common Q PAMS system compliance are contained in WNA-LI-00058-WBT-P, Revision 2, Post-Accident Monitoring System (PAMS) Licensing Technical Report, Section 11 TVA Contract Compliance Matrix item 178.

5.5.2 Design for test and calibration Test and calibration functions shall not adversely affect the ability of the computer to perform its safety function. Appropriate bypass of one redundant channel is not considered an adverse effect in this context. It shall be verified that the test and calibration functions do not affect computer functions that are not included in a calibration change (e.g., setpoint change).

V&V, configuration management, and QA shall be required for test and calibration functions on separate computers (e.g., test and calibration computer) that provide the sole verification of test and calibration data.

V&V, configuration management, and QA shall be required when the test and calibration function is inherent to the computer that is part of the safety system.

V&V, configuration management, and QA are not required when the test and calibration function is resident on a separate computer and does not provide the sole verification of test and calibration data for the computer that is part of the safety system.

TVA Response: The requirements for test and calibration and Common Q PAMS system compliance are contained in WNA-LI-00058-WBT-P, Revision 2, Post-Accident Monitoring System (PAMS) Licensing Technical Report Section 11 TVA Contract Compliance Matrix items:

202 self test 350 Maintenance Bypass 351 Loop Tuning Parameters, 400 and 401 3.7.2 Testing, Calibration, and Verification

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 402, 403 and 404, 3.7.3 Channel Bypass or Removal from Operation 5.5.3 Fault detection and self-diagnostics Computer systems can experience partial failures that can degrade the capabilities of the computer system, but may not be immediately detectable by the system.

Self-diagnostics are one means that can be used to assist in detecting these failures. Fault detection and self-diagnostics requirements are addressed in this sub-clause.

The reliability requirements of the safety system shall be used to establish the need for self-diagnostics. Self diagnostics are not required for systems in which failures can be detected by alternate means in a timely manner. If self-diagnostics are incorporated into the system requirements, these functions shall be subject to the same V&V processes as the safety system functions.

If reliability requirements warrant self-diagnostics, then computer programs shall incorporate functions to detect and report computer system faults and failures in a timely manner. Conversely, self-diagnostic functions shall not adversely affect the ability of the computer system to perform its safety function, or cause spurious actuations of the safety function. A typical set of self-diagnostic functions includes the following:

Memory functionality and integrity tests (e.g.,

PROM checksum and RAM tests)

Computer system instruction set (e.g., calculation tests)

Computer peripheral hardware tests (e.g.,

watchdog timers and keyboards)

Computer architecture support hardware (e.g.,

address lines and shared memory interfaces)

Communication link diagnostics (e.g., CRC checks)

Infrequent communication link failures that do not result in a system failure or a lack of system functionality do not require reporting.

When self-diagnostics are applied, the following self-diagnostic features shall be incorporated into the system design:

a) Self-diagnostics during computer system startup b) Periodic self-diagnostics while the computer system is operating c) Self-diagnostic test failure reporting TVA Response: The requirements for fault detection and self diagnostics and Common Q PAMS system compliance are contained in WNA-LI-00058-WBT-P, Rev. 2, Post-Accident Monitoring System (PAMS)

Licensing Technical Report Section 11 TVA Contract

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Compliance Matrix items:

107 error free download 202 self test 205 self diagnostics and watchdog timer 263 primary and backup communication 264 through 271, continuous on-line self checks 311 system status displays, 341 alarms, 344 on-line diagnostics 5.7 Capability for test and calibration No requirements beyond IEEE Std 603-1998 are necessary.

TVA Response: No response required.

Concurrence: E-mail from Westinghouse (Andrew P. Drake) to Bechtel (Mark S. Clark), RE: RAI 212 Response - Errors in the Contract Compliance Matrix, dated December 17, 2010 (a) Energy Supply conditions are specified in WNA-DS-01617-WBT-P, System Requirements Specification Rev.

4, Requirement 4.1-1 which requires 120Vac +/-10% and 60+/-3Hz. Power to the Common Q PAMS is provided from the 120Vac vital power system. Per WBN Unit 2 FSAR section 8.3.1.1 the vital 120 volt ac system specifications are 120Vac +/-2% and 60+/-0.5Hz. Based on this, the power provided meets the system requirements.

Electromagnetic compatibility, seismic and environmental qualification of the equipment to meet the design basis requirements is documented in EQ-QR WBT-P, Revision 0 Qualification Summary Report for Post-Accident Monitoring System (PAMS)" (Proprietary)

(Attachment 4). Attachment 5 contains EQ-QR WBT-NP, Revision 0 Qualification Summary Report for Post-Accident Monitoring System (PAMS)" (non-proprietary). Attachment 6 contains CWA-11-3118, Application for Withholding Proprietary Information from Public Disclosure, EQ-QR-68-WBT-P, Revision 0 Qualification Summary Report for Post-Accident Monitoring System (PAMS), (Proprietary), dated February 28, 2011.

(b) The Contract Compliance Matrix Item 179 in Revision 3 of the Licensing Technical Report will be revised to show this item as a deviation and to reflect TVAs acceptance of the 7.2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> MTTR value. WNA-LI-00058-WBT-P, Post-Accident Monitoring System (PAMS) Licensing Technical Report, Revision 3, (proprietary) dated March 2011, will be submitted no later than March 29, 2011.

213 7.5.2 7/27/2010 Responder: WEC 19. N Open Open-NRC Review EICB RAI EICB ML102980066 Item (Carte) By letter dated June 18, 2010 (ML101940236) TVA stated Conformance with IEEE 603 is documented in the revised Pending Submittal of Revision 3 Due 3/29/11 No. 18 (Enclosure 1, Attachment 3, Item No. 3) that the PAMS system Common Q PAMS Licensing Technical Report and the of the Licensing Technical design specification and software requirements specification Common Q PAMS System Design Specification. Report due 3/29/11. NNC 2/3/11: The

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N contain information to address the "Theory of Operation identified Description." The staff has reviewed these documents, and it is not Attachment 1 contains the proprietary version of Response is included in letter documentation does clear how this is the case. The docketed material does not appear Westinghouse document Tennessee Valley Authority dated 10/25/10 not include the design to contain the design basis information that is required to evaluate (TVA), Watts Bar Unit 2 (WBN2), Post-Accident Monitoring bases. Please provide compliance with the Clause of IEEE 603. System (PAMS), Licensing Technical Report, Revision 1, NNC to review and revise this schedule for providing (1) Please provide the design basis (as described in IEEE 604 WNA-LI-00058-WBT-P, Dated October 2010 question after LTR R2 is the requested Clause 4) of the Common Q PAMS. received. information.

(2) Please provide a regulatory evaluation of how the PAMs Attachment 8 contains the proprietary version of complies with the applicable regulatory requirements for the theory Westinghouse document Nuclear Automation Watts Bar 2 of operation. NSSS Completion Program I&C Projects Post Accident For example: Regarding IEEE 603 Clause 5.8.4 (1) What are the Monitoring System - System Design Specification, WNA-manually controlled protective actions? (2) How do the documents DS-01667-WBT, Rev. 2 dated September 2010.

identified demonstrate compliance with this clause?

TVA Response to Follow-up NRC Request:

The Regulatory Guide 1.97 classification of the Common Q PAMS variables is documented in TVA Design Criteria WB-DC-30-7 Post Accident Monitoring Instrumentation which was submitted as Attachment 5 on TVA to NRC letter Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests dated June 18, 2010 (Reference 1)

The hardware design bases for the Common Q PAMS is described in the WBN Unit 2 FSAR section 7.5.1.8 Post Accident Monitoring System (PAMS).

The Common Q PAMS indications are used to support operator response to events described in chapter 15 of the WBN Unit 2 FSAR such as:

RCCA/RCCA Bank dropped/misaligned Steam Generator Tube Rupture Inadvertent Loading of a Fuel Assembly Into an Improper Position Loss of Shutdown Power Major Reactor Coolant System Pipe Ruptures (Loss Of Coolant Accident)

Major Secondary System Pipe Rupture

(

214 C 7/27/2010 Responder: WEC 201. Y Closed Closed EICB RAI TVA Letter dated

( ( (

215 7/29/2010 Responder: WEC 202. Y Closed Closed 216 7.5.1. 7.5.2 7/29/2010 Responder: Clark 203. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 217 7/6/2010 Responder: Clark 204. Y Close Closed EICB RAI TVA Letter dated

( (

218 7/6/2010 Responder: Clark 205. Y Closed Closed EICB RAI TVA Letter dated 219 8/4/2010 Responder: TVA Licensing 206. Y Closed Closed EICB RAI

( ( M ( ( M ( ( ( ( M 220 8/4/2010 Responder: Ayala 207. Y Closed Closed EICB RAI TVA Letter dated 221 7.7.1. 7.7.1.3 8/4/2010 Responder: Trelease 208. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL C P 222 8/4/2010 Responder: Clark 209. Y Close Closed EICB RAI TVA Letter dated 223 8/4/2010 Responder: Clark 210. Y Closed Closed EICB RAI G G a G G a G G G G a 224 7.5.1. 7.5.2 8/4/2010 Responder: Norman (TVA CEG) 211. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 225 8/4/2010 Responder: Scansen 212. Y Close Closed EICB RAI TVA Letter dated 226 8/4/2010 Responder: TVA Licensing 213. Y Closed Closed N/A - Information TVA Letter dated See also Open Item Nos. 41 & 270.

227 8/4/2010 Responder: Clark 214. Y Close Closed EICB RAI TVA Letter dated

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

( ( (

228 8/4/2010 Responder: Clark 215. Y Closed Closed EICB RAI TVA Letter dated 229 ( 8/4/2010 Responder: Clark 216. Y Closed Closed EICB RAI TVA Letter dated C C C 217. Y G

230 8/4/2010 Responder: Webb Closed Closed EICB RAI TVA Letter dated 231 8/4/2010 Responder: Clark 218. Y Closed Closed EICB RAI TVA Letter dated

( ( ( ( ( (

232 8/4/2010 Responder: Clark 219. Y Closed Closed RAI No. 5 TVA Letter dated 233 8/4/2010 Responder: Clark 220. Y Closed Closed EICB RAI TVA Letter dated

( ( (

234 8/4/2010 Responder: 221. Y Closed Closed N/A - Duplicate N/A C C C C C S 235 8/4/2010 Responder: TVA Licensing 222. Y Closed Closed N/A N/A 236 8/4/2010 Responder: Clark 223. Y Close Closed EICB RAI TVA Letter dated G G G 237 8/4/2010 Responder: Clark 224. Y Closed Closed EICB RAI TVA Letter dated i

238 8/4/2010 Responder: Webb/Hilmes 225. Y Closed Closed N/A - Duplicate N/A 239 8/4/2010 Responder: Hilmes 226. Y Closed Closed N/A - Meeting N/A 240 8/4/2010 Responder: Clark 227. Y Close Closed Ml102910008 TVA Letter dated 241 ( ( 8/4/2010 Responder: Davies 228. Y Closed Closed RAI No. 10 TVA Letter dated

(

242 C S 8/4/2010 Responder: Hilmes 229. Y Close Closed EICB RAI TVA Letter dated G

i 243 8/3/2010 Responder: WEC 230. Y Closed Closed N/A - Closed to N/A 244 8/3/2010 Responder: WEC 20. N Open Open-NRC Review EICB RAI Response is LIC-101 Rev. 3 Appendix B Section 4, EICB (Carte)

ML102980066 Item provided in letter "Safety Evaluation" states: "the Section 8.2.2 of the Common Q SPM (ML050350234) states that The process related requirements have been removed from Revised response is included in Due 2/25/11 Document No. 14 dated 10/25/10. information relied upon in the SE must the Software Requirements Specification (SRS) shall be developed revision 2 of the Software Requirements Specification (SRS). letter dated 12/22/10 revisions be docketed correspondence."

using IEEE 830 and RE 1.172. Clause 4.8, "Embedding project requirements in the SRS," of the IEEE 830 states that an SRS Attachment 3 of letter dated 10/25/10 contains the Response is provided in letter NNC 2/2/11: Issues LIC-101 Rev. 3 states: "The safety should address the software product, not the process of producing proprietary version of Westinghouse document Nuclear dated 10/25/10. with Common Q TR & analysis that supports the change the software. In addition Section 4.3.2.1 of the SPM states "Any Automation, Watts Bar 2 NSSS Completion Program, I&C SPM compliance were requested should include technical alternatives to the SPM processes or additional project specific Projects, Software Requirements Specification for the Post NNC 11/18/10: SysRS Rev. 2 discussed in the weekly information in sufficient detail to enable information for the ...SCMP...shall be specified in the PQP. Accident Monitoring System, WNA-SD-00239-WBT, also contains process public meetings. the NRC staff to make an independent Revision 2, Dated September 2010. requirements that are more Westinghouse to assessment regarding the acceptability Contrary to these two statements in the SPM, the WBN2 PAMS appropriately incorporated into perform Common Q TR of the proposal in terms of regulatory SRS (ML101050202) contains many process related requirements, process documentation. & SPM compliance self requirements and the protection of for example all seventeen requirements in Section 2.3.2, TVA Response to Follow-up NRC Request: assessment; this will be public health and safety."

"Configuration Control," address process requirements for As shown is the listed documents, process related discussed in detail on configuration control. requirements have been deleted from the SRS and SysRS in the next audit.

Revision 3:

Please explain how the above meets the intent of the approved SPM. Attachment 1 contains proprietary version of WNA-DS-01617-WBT-P, Revision 3, Post Accident Monitoring System-System Requirements Specification, dated December 2010.

Attachment 7 contains the proprietary version of WNA-SD-00239-WBT-P, Revision 3, Software Requirements Specification for the Post Accident Monitoring System, dated December 2010.

Source: E-mail from Westinghouse (Andrew P. Drake) to Bechtel (Mark S. Clark), RE: Common Q RAI concerns, dated December 8, 2010 (Reference 17)

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

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Software Program Manual (SPM).

245 8/3/2010 Responder: WEC 21. N Open Open-NRC Review EICB RAI LIC-101 Rev. 3 Appendix B Section 4, EICB (Carte)

ML102980066 Item "Safety Evaluation" states: "the Section 5.8 of the Common Q SPM (ML050350234) identifies the Relates to the commitment to provide the test plan and the Pending Submittal of the Test Due 3/29/11 No. 119 information relied upon in the SE must required test documentation for systems developed using the SPM compliance matrix Summary Report due 3/29/11 be docketed correspondence."

Common Q SPM. Please provide sufficient information for the NNC 2/2/11: Issues NRC staff to independently assess whether the test plan for WBN2 Attachment 9 contains the Westinghouse document Post Response included in letter with the Common Q TR LIC-101 Rev. 3 states: "The safety PAMS, is as described in the SPM (e.g., Section 5.8.1). Accident Monitoring System Test Plan, WNA-PT-00138- dated 12/3/10 & SPM were discussed analysis that supports the change WBT, Revision 0, dated November 2010. Attachment 10 in the weekly public requested should include technical contains the Westinghouse Application for Withholding for Common Q PAMS Test meetings. information in sufficient detail to enable the Post Accident Monitoring System Test Plan, WNA-PT- Summary Report scheduled to Westinghouse to the NRC staff to make an independent 00138-WBT, Revision 0, dated November 2010. be submitted March 29, 2011. perform Common Q TR assessment regarding the acceptability

& SPM compliance self of the proposal in terms of regulatory TVA Response to Follow-up NRC Request: assessment requirements and the protection of public health and safety."

The results of the self assessment were reviewed by Westinghouse with the NRC on February 2, 2011 and were further reviewed by TVA during the NRC Common Q PAMS audit during the week of February 28 to March 4, 2011.

Corrections to WNA-TR-02451-WBT, Test Summary Report for the Post Accident Monitoring System and the self assessment were made as a result of the TVA review to ensure this comment was fully addressed.

By agreement between TVA, WEC and the NRC, the Post Accident Monitoring System Test Plan, WNA-PT-00138-WBT, Revision 0 will not be revised. Instead a non-proprietary Common Q PAMS Test Summary Report will be developed and submitted to address the issues with TR and SPM compliance. Attachment 1 contains non-proprietary WNA-TR-02451-WBT, Revision 0, Test Summary Report for the Post Accident Monitoring System, dated March 2011.

246 8/3/2010 Responder: WEC 22. N Open Open-NRC Review EICB RAI Response is LIC-101 Rev. 3 Appendix B Section 4, EICB (Carte)

ML102980066 Item provided in letter "Safety Evaluation" states: "the Section 4.3.2.1, "Initiation Phase" of the Common Q SPM As agreed ISG6 does not apply to the Common Q PAMS Pending Submittal of Revision 3 Due 3/29/11 No. 15 dated 10/25/10 information relied upon in the SE must (ML050350234) requires that a Project Quality Plan (PQP) be platform. The information required to address this question of the Licensing Technical be docketed correspondence."

developed. Many other section of the SPM identify that this PQP concerning the PQP and SPM has been added to Report due 3/29/11. PQP NNC 2/2/11: Issues should contain information required by ISG6. Please provide the compliance matrix in revision 1 of the Licensing Technical provided for audit the week of with the Common Q TR LIC-101 Rev. 3 states: "The safety PQP. If "PQP" is not the name of the documentation produced, Report. 2/28/11. & SPM implementation analysis that supports the change please describe the documentation produced and provide the were discussed in the requested should include technical information that the SPM states should be in the PQP. Attachment 1 of letter dated 10/25/10 contains the Response is provided in letter weekly public meetings. information in sufficient detail to enable proprietary version of Westinghouse document Tennessee dated 10/25/10 Westinghouse to the NRC staff to make an independent Valley Authority (TVA), Watts Bar Unit 2 (WBN2), Post- perform Common Q TR assessment regarding the acceptability Accident Monitoring System (PAMS), Licensing Technical NNC 11/18/10: PQP has not & SPM compliance self of the proposal in terms of regulatory Report, Revision 1, WNA-LI-00058-WBT-P, Dated October been provided and CQ PAMS assessment requirements and the protection of 2010 LTR Rev. 1 does not contain public health and safety."

comparable information.

TVA Response to Follow-up NRC Request:

The results of the Common Q TR and SPM self assessment were reviewed by Westinghouse with the NRC on February 2, 2011.

The Westinghouse Watts Bar Unit 2 NSSS Completion I&C Projects Project Quality Plan, WNA-PQ-00220-WBT, Revision 1 is available for NRC audit at the Westinghouse Rockville Office and was available for review during the NRC Common Q PAMS audit during the week of February 28 to

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N March 4, 2011. During the audit, the Westinghouse Quality Assurance in process audit of the Common Q PAMS project was reviewed by the NRC inspector with no issues identified.

( ( (

247 8/8/2010 Responder: WEC 231. Y Closed Closed EICB RAI Response is LIC-101 Rev. 3 Appendix B Section 4, 248 8/8/2010 Responder: WEC 232. Y Closed Closed Response is LIC-101 Rev. 3 Appendix B Section 4, C C C 249 8/8/2010 Responder: WEC 233. Y Closed Closed LIC-101 Rev. 3 Appendix B Section 4, 250 8/8/2010 Responder: WEC 23. N Open Open-NRC Review LIC-101 Rev. 3 Appendix B Section 4, EICB (Carte)

"Safety Evaluation" states: "the The SPM describes the software and documents that will be Westinghouse develops Software Release Reports/Records Revised response included in NNC 2/2/11: To be information relied upon in the SE must created and placed under configuration control. The SCMP (e.g., and a Configuration Management Release Report. Describe letter dated 12/22/10 addressed during the be docketed correspondence."

SPM Section 6, Software Configuration Management Plan) the documents and when they will be produced. Summarize next audit.

describes the implementation tasks that are to be carried out. The guidance on how to produce these records, focus on project Response included in letter LIC-101 Rev. 3 states: "The safety acceptance criterion for software CM implementation is that the specific requirements in SPM etc. dated 10/25/10. analysis that supports the change tasks in the SCMP have been carried out in their entirety. requested should include technical Documentation should exist that shows that the configuration TVA Response to Follow-up NRC Request: information in sufficient detail to enable management tasks for that activity group have been successfully the NRC staff to make an independent accomplished. Please provide information that shows that the CM The following documentation shows that the configuration assessment regarding the acceptability tasks have been successfully accomplished for each life cycle management tasks for that activity group have been of the proposal in terms of regulatory activity group. successfully accomplished. requirements and the protection of public health and safety."

1. WNA-LI-00058-WT-P, Revision 2, Post-Accident Monitoring System (PAMS) Licensing Technical Report submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1) contains the following changes to address the NRC requests:

a. Section 2.2.1 Hardware/Software Change Process has been added to describe the process of how changes are evaluated.

b. Section 2.2.2, Software has been expanded to include a table detailing evolutionary software changes that have occurred since the initial submittal and the change evaluation of the life cycle.

2. WNA-PT-00138-WBT, Revision 0, Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Post Accident Monitoring System Test Plan, (Proprietary), dated November 2010 submitted in TVA Letter to NRC, dated December 3, 2010 (Reference 1).

251 8/8/2010 Responder: WEC 24. N Open Open-NRC Review LIC-101 Rev. 3 Appendix B Section 4, EICB (Carte)

"Safety Evaluation" states: "the The SPM describes the software testing and documents that will be The software testing performed and documents created are Pending Submittal of the Test Due 3/29/11 information relied upon in the SE must created. The SPM also describes the testing tasks that are to be addressed by the SPM Compliance matrix contained in Summary Report due 3/29/11 be docketed correspondence."

carried out. The acceptance criterion for software test Revision 1 of the Licensing Technical Report. NNC 2/2/11: Issues implementation is that the tasks in the SPM have been carried out Revised response included in with the Common Q TR LIC-101 Rev. 3 states: "The safety in their entirety. Please provide information that shows that Attachment 1 of the letter dated 10/25/10 contains the letter dated 12/22/10 & SPM were discussed analysis that supports the change testing been successfully accomplished. Proprietary version of Westinghouses document titled: in the weekly public requested should include technical Tennessee Valley Authority (TVA), Watts Bar Unit 2 Partial response is provided in meetings. information in sufficient detail to enable (WBN2), Post-Accident Monitoring System (PAMS), letter dated 10/25/10 Westinghouse to the NRC staff to make an independent Licensing Technical Report, Revision 1, WNA-LI-00058- perform Common Q TR assessment regarding the acceptability WBT-P, Dated October 2010 & SPM compliance self of the proposal in terms of regulatory assessment requirements and the protection of TVA Response to Follow-up NRC Request: public health and safety."

Please see the response to RAI item 21 in letter dated

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 12/22/10, NRC Matrix Item 250.

TVA Response to second Follow-up NRC Request:

The results of the Common Q TR and SPM self assessment were reviewed by Westinghouse with the NRC on February 2, 2011.

By agreement between TVA, WEC and the NRC, the Post Accident Monitoring System Test Plan, WNA-PT-00138-WBT, Revision 0 will not be revised. Instead a non-proprietary Common Q PAMS Test Summary Report will be developed and submitted to address the issues with TR and SPM compliance. Attachment 1 contains non-proprietary WNA-TR-02451-WBT, Revision 0, Test Summary Report for the Post Accident Monitoring System, dated March 2011.

252 8/8/2010 Responder: WEC 25. N Open Open-NRC Review LIC-101 Rev. 3 Appendix B Section 4, EICB (Carte)

"Safety Evaluation" states: "the The SPM contain requirements for software requirements Explain response to AP1000 audit report. Response included in letter Due 2/25/11 (document information relied upon in the SE must traceability analysis and associated documentation (see Section RTM docketed NRC awaiting V&V evaluation of RTM. dated 12/22/10 submittals) be docketed correspondence."

5.4.5.3, Requirements Traceability Analysis). Please provide information that demonstrates that requirements traceability The following responses are based on WBN Unit 2 Common Read ML091560352 NNC 2/2/11: Updated LIC-101 Rev. 3 states: "The safety analysis has been successfully accomplished. Q PAMS traceability: RTMs and analysis that supports the change specifications to be requested should include technical Software requirements traceability analysis is described in provided. information in sufficient detail to enable the following documents: the NRC staff to make an independent Requirements assessment regarding the acceptability

1. WNA-LI-00058-WBT-P, Revision 2, Post-Accident traceability to be of the proposal in terms of regulatory Monitoring System (PAMS) Licensing Technical addressed during he requirements and the protection of Report submitted in TVA Letter to NRC dated next audit. public health and safety."

December 3, 2010, (Reference 1) Section 11, TVA Contract Compliance Matrix

2. WNA-VR-00279-WBT, Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System (available for NRC audit at the Westinghouse Rockville office)

3. WNA-VR-00280-WBT, Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Reactor Vessel Level Indication System (RVLIS) Custom PC Elements (available for NRC audit at the Westinghouse Rockville office) This document addresses the RSEDs used in the WBN Unit 2 Common Q PAMS.

The V&V evaluation of the RTM is documented in section 2.2.2 of the following documents:

1. The Independent Verification & Validation (IV&V) report covering the Concept and Definition phases (Nuclear Automation Watts Bar Unit 2 NSSS Completion Program I&C Projects, IV&V Summary Report for the Post Accident Monitoring System, (Proprietary), WNA-VR-00283-WBT, Revision 1, dated November 2010), submitted in TVA Letter to NRC dated December 3, 2010 (Reference 1).

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

2. The Independent Verification &Validation (IV&V) report covering the Design and Implementation phases (Nuclear Automation Watts Bar Unit 2 NSSS Completion Program I&C Projects, IV&V Summary Report for the Post Accident Monitoring System, (Proprietary), WNA-VR-00283-WBT, Revision 2, dated November 2010), submitted in TVA Letter to NRC dated December 3, 2010 (Reference 1).

3. The integration phase is covered in Attachment 10, the proprietary version of IV&V Summary Report for the Post Accident Monitoring System, WNA-VR-00283-WBT-P, Revision 3, dated December 2010.

Attachment 11 contains the non-proprietary version of IV&V Summary Report for the Post Accident Monitoring System, WNA-VR-00283-WBT-NP, Revision 3, dated December 2010. Attachment 12 contains the Application For Withholding Proprietary Information From Public Disclosure WNA-VR-00283-WBT-P, Revision 3, IV &V Summary Report for the Post Accident Monitoring System (Proprietary), dated December 2010.

TVA Response to Follow-up NRC Request:

See Response to item 3 (Matrix Item Number 142)

( ( ( ( ( ( ( ( ( ( ( ( ( ( ( (

253 8/8/2010 Responder: Clark 234. Y Closed Closed TVA Letter dated Related to Open Item no. 83.

254 8/10/2010 Responder: WEC 235. Y Closed Closed N/A - Request to TVA Letter dated 255 8/10/2010 Responder: WEC 236. Y Closed Closed N/A - Request to TVA Letter dated 256 8/10/2010 Responder: WEC 237. Y Closed Closed N/A - Request to TVA Letter dated 257 8/10/2010 Responder: WEC 238. Y Closed Closed N/A - Request to N/A 258 8/10/2010 Responder: WEC 239. Y Closed Closed N/A - Request to N/A 259 8/10/2010 Responder: WEC 240. Y Closed Closed N/A - Request to TVA Letter dated 260 8/10/2010 Responder: WEC 241. Y Closed Closed N/A - Request to N/A C C C C C C C C C C C C C C C C 261 8/10/2010 Responder: WEC 242. Y Closed Closed N/A - Closed to TVA Letter dated LIC-110 Rev. 1 Section 6.2.2 states:

262 8/10/2010 Responder: WEC 243. Y Closed Closed N/A - Request to N/A 263 8/11/2010 Responder: WEC 244. Y Closed Closed ML101650255, Item 264 8/11/2010 Responder: WEC 245. Y Closed Closed ML101650255, Item 265 8/11/2010 Responder: WEC 246. Y Closed Closed ML101650255, Item 266 8/11/2010 Responder: Webb/Webber 247. Y Closed Closed TVA Letter dated 267 8/11/2010 Responder: WEC 248. Y Closed Closed 268 8/19/2010 Responder: WEC 249. N Closed Closed

( ( (

269 8/20/2010 Responder: NRC 250. Y Closed Closed N/A N/A

( ( (

270 8/23/2010 Responder: Clark 251. Y Closed Closed See also Open Item Nod. 41 & 245.

M M M 271 8/23/2010 Responder: WEC 252. Y Closed Closed N/A - Closed to NA C C P 272 7.5.2. 7.5.1 8/26/2010 Responder: Clark 253. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL a a a 273 7.5.2. 7.5.1 8/26/2010 Responder: Clark 254. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 274. 7.5.2. 7.5.1 8/26/2010 Responder: Clark 255. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

(

274. 8/26/2010 Responder: Stockton 256. Y Closed Closed RAI No. 6 TVA Letter dated S

i

( ( ( ( (

275 8/27/2010 Responder: Clark 257. Y Closed Closed Not Required N/A 276 7.6 7.6 8/27/2010 Responder: Webb 258. Y Closed Closed EICB RAI TVA Letter dated 277 7.6 7.6.3 8/27/2010 Responder: Clark 259. Y Close Closed EICB RAI TVA Letter dated 278 7.6 7.6.6 8/27/2010 Responder: Trelease 260. Y Close Closed EICB RAI TVA Letter dated D D D D D (

279 7.6 7.6.6 8/27/2010 Responder: Mather 261. Y Close Closed EICB RAI TVA Letter dated 280 7.6 7.6.6 8/27/2010 Responder: Trelease 262. Y Closed Closed EICB RAI TVA Letter dated

( ( ( ( ( ( ( (

281 7.6 7.6.8 8/27/2010 Responder: Webb 263. Closed Closed EICB RAI TVA Letter dated a a a a a S 282 7.6 7.6.9 8/27/2010 Responder: Trelease 264. Y Close Closed EICB RAI TVA Letter dated 283 7.7.5 XX 8/27/2010 Responder: Clark 265. Y Closed Closed EICB RAI No.13 TVA Letter dated This item is a follow-up question to item G G G G G G G G 284 7.7.3 7.4.1 8/27/2010 Responder: Webber 266. Y Closed Closed EICB RAI No.14 TVA Letter dated This item is a follow-up question to item 285 7.3.3 7.3 8/27/2010 Responder: McNeil 267. Y Closed Closed EICB RAI No.15 TVA Letter dated This item is a follow-up question to item i

286 7.7.3 9.3.4.2.4 8/27/2010 Responder: Webber 268. Y Closed Closed EICB RAI No.16 TVA Letter dated 287 7.3 7.3-1 8/27/2010 Responder: Elton 269. Y Closed Closed ML102390538, Item Response 288 7.3 9/2/2010 Responder: McNeil 270. Y Closed Closed EICB RAI

( ( ( ( (

289 9/2/2010 Responder: Faulkner 271. Y Closed Closed RAI No. 24 TVA Letter dated 290 7.7 9/7/2010 Responder: Clark 272. Y Closed Closed N/A N/A This item is a duplicate of item 291.

(

291 7.7 9/7/2010 Responder: Clark 273. Y Closed Closed TVA Letter dated

( D D D D D ( ( (

292 7.2.5 7.2 9/7/2010 Responder: Craig 274. Y Closed Closed EICB RAI TVA Letter dated M (

293 7.7.4 7.2.2.3.5 9/8/2010 Responder: Craig 275. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 294 7.3 7.3.1.1.1 9/9/2010 Responder: Elton 276. Y Closed Closed ML102390538, Item Response C a a a a a C C S 295 7.3 7.3.1.1.2 9/9/2010 Responder: Elton 277. Y Closed Closed ML102390538, Item Response a G 296 7.3 7.3.1.2.1 9/9/2010 Responder: Elton 278. Y Closed Closed ML102390538, Item Response i

297 7.3 7.3.1.2.2 9/9/2010 Responder: Elton 279. Y Closed Closed ML102390538, Item Response 298 7.3 XX 9/9/2010 Responder: Clark 280. Y Closed Closed ML102390538, Item Response 299 Provide Common Q Software Requirements Specification Post Attachment 41 of the 10/5 letter contains the Common Q 281. Y Closed Closed TVA Letter dated

(

300 Need Radiation Monitoring System Description/Design Criteria Responder: Temples/Mather 282. Y Closed Closed RAI No. 25 TVA Letter S

i

( (

301 1.TVA is requested to address the consequences of software Responder: WEC/Davies/Clark 283. Y Closed Closed RAI No. 11 TVA Letter dated Note 1:

302 7.5.2. 7.5.1 09/17/2010 Responder: Tindell 284. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL

( ( ( (

303 7.5.2. 7.5.1 09/17/2010 Responder: Tindell 285. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 304 7.5.2. 7.5.1 09/17/2010 Responder: Tindell 286. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL D D (

305 7.5.2. 7.5.1 09/17/2010 Responder: Tindell 287. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 306 7.1 7.1 FSAR amendment 100, page 7.1-12 provides the definition of Responder: Hilmes 288. Y Closed Closed EICB RAI TVA Letter dated

( ( ( ( ( ( ( ( M M M M 307 7.1 7.1 (1) FSAR amendment 100, Section 7.1, page 7.1-12, definition of Responder: Hilmes 289. Y Closed Closed EICB RAI TVA Letter dated 308 7.1 7.1 (1) FSAR Amendment 100, Section 7.1, page 7.1-13, definition of Responder: Hilmes 290. Y Closed Closed EICB RAI TVA Letter dated a a S 309 7.1 7.1.2.1.9 (1) FSAR amendment 100, Page 7.1-14, Westinghouse setpoint Responder: Hilmes 291. Y Closed Closed EICB RAI TVA Letter dated 310 7.1 7.1.2.1.9 292. Y G G G G G G G G a a a a (1) FSAR amendment 100, Page 7.1-14, TVA setpoint Responder: Hilmes Closed Closed EICB RAI TVA Letter dated 311 7.1 7.1 Both Westinghouse and TVA setpoint methodology do not have Responder: Hilmes 293. Y Closed Closed EICB RAI TVA Letter dated i

312 7.0 By letter dated September 10,2010, TVA provided the summary Responder: Stockton 294. Y Close Closed EICB RAI TVA Letter dated 313 7.7.8 7.7.1.12 EDCR 52408 (installation of AMSAC in Unit 2) states that Design Responder: Ayala 295. Y Closed Closed EICB RAI No.18 TVA Letter dated 314 7.3 7.3 The following 50.59 changes were listed in the March 12 RAI Responder: Stockton 296. Y Closed Closed EICB RAI No. 19 TVA Letter dated Related to OI 10 315 7.5.3 7.5.3 IE Bulletin 79-27 required that emergency operating procedures to Responder: S. Smith (TVA Operations) 297. Y Close Closed EICB RAI TVA Letter dated

(

316 7.5.2. 7.5 TVA has provided various documents in support of RM-1000 high Responder: Temples/Mather 298. Y Closed Closed RAI No. 26 S

i

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

(

317 7.5.2. 7.5 TVA has provided a proprietary and a non-proprietary version of Responder: Temples 299. Y Closed Closed RAI No. 27 TVA Letter dated S

i 318 7.5.2. 7.5 TVA has provided the following documents for RM-1000 Responder: Temples 26. Y Open Open-NRC Review RAI No. 28 TVA Letter dated 3 equipment qualification: ML102980005 10/29/10, Encl 1 Revised response is included in Due 2/25/11 10/26/2010 Item 34, and TVA (i) Qualification Test Report for RM-1000 Processor Module letter dated 12/22/10. letter 11/24/10, and Current-To-Frequency Converter 04508905-QR (i) Applicable to WBN Unit 2. 04508905-1QR is Response update Att. 2.

(January 2001) applicable only in regards to the RM-1000, with the Note check 04508905-1QR or required. It is clear that (ii) Qualification Test Report Supplement, RM-1000 Upgrades exception of re-qualification of certain RM-1000 QR. Staff version is QR only. 04508903-2SP and -

04508905-1SP (June 2006) equipment differences covered in the -1SP report. 3SP are not applicable.

(iii) Qualification Test Report Supplement, RM-1000 Upgrades The Current-to-Frequency (I-F) converter module Response is included in letter The response for 04508905-2SP (June 2008) qualifications in the base report and the -1SP report dated 10/29/10 applicability of (iv) Qualification Test Report Supplement, RM-1000 Upgrades are not applicable to the RM-1000s, and will be used 04508905-QR and -

04508905-3SP (May 2008) later as references in the WBN Unit 2 specific 1SP to RM-1000 and IF qualification reports. converter is not clear.

Please clarify whether all of these are fully applicable to WBN2 or are they applicable with exceptions? If with exceptions, then (ii) Applicable to WBN Unit 2. Check page numbers of please clarify what those are. Appendix F (iii) Not applicable to WBN Unit 2 (missing/duplicate Supplement 3 was issued one month prior to supplement 2. (iv) Not applicable to WBN Unit 2 pages).

Please explain the reason for the same. Check applicability of The 04508905-3SP report was prepared for another TVA Appendix C to RM1000 plant, as a monitor system-level report, where the system instead of RM2300?

included equipment mostly based on the base report See items 336 and 337.

equipment items. These two -2SP and -3SP supplement reports were essentially worked concurrently, but the -2SP All equipment document review/release process resulted in the release qualification reports time difference. including supplements 2SP and 3SP have EICB (Singh)

TVA Response to Follow-up NRC Request: been reviewed as vendor drawings for NOTE: The response for the current to frequency (I to F) WBN-2. Please explain converter in item 1 below is a reversal of the the reason for response previously provided in TVA to NRC letter applicability of one dated October 29, 2010 (Reference 22). General report and not the Atomics Electronic Systems Inc. (GA-ESI) notified other.

TVA of this change on December 8, 2010 (Reference 20). Further all TVA/Bechtel reviews seems to be (1) The applicability of the qualification reports from GA- dispositioned as Code ESI e-mail dated December 10, 2010 (Reference 19) is 4, Review not required.

as follows: Work may proceed.

The applicable reports

a. 04508905-QR Qualification Test Report for RM- should have been 1000 Processor Module and Current-to- reviewed prior to Frequency Converter is applicable to the WBN dispositioning them.

Unit 2 RM-1000 and I to F converter modules. Please explain the apparent lack of review

b. 04508905-1SP Supplement to Qualification Test of WBN-2 applicable Report for RM-1000 Processor Module and documents. Was Current-to-Frequency Converter is applicable to appropriate review the WBN Unit 2 RM-1000 module. guidance used?

c. 04508905-1SP is not applicable to the WBN Unit Further update required 2 I to F converter module.

d. 04508905-2SP Qualification Test Report Provide model Supplement, I-F Converter Upgrades is number/part number for applicable to the WBN Unit 2 I to F converter the RM-1000 and I/F converter used for

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N module. WBN-2. This information is needed GA-ESI provided two other reports required to support to verify that the model qualification of the containment high range radiation or part number used is monitors. The report descriptions are from GA-ESI e- the equipment that has mail on December 8, 2010 (Reference 20). The been qualified for WBN-reports are: 2.

e. GA-ESI report 04038903-QSR, Qualification Provide qualification Summary Report for Watts Bar Nuclear Plant Unit reports 04038903-QSR 2 Replacement Radiation Monitors: The report is and 04038903-7SP by the principle report and the starting point for all the dues date of the radiation monitors provided as part of the 1/22/11.

replacement contract. The report describes each monitor; referenced to the technical manual for Submit a copy of any the physical and functional description and lists other relevant reviewed the major components of the monitor system. versions of the Report section 3 identifies the TVA Watts Bar Unit qualification reports.

2 Environmental, Seismic, Electromagnetic Compatibility (EMC), and software requirements Submit copies of the for each monitor. In section 4 a brief description reviewed reports for of GA-ESI generic qualification programs for all 04508905-QR, radiation monitoring equipment in each of the four 04508905-1SP, above areas is provided. The qualification basis 04508905-2SP.

for each monitor is provided in a separate supplement to the principle report and is identified Clarification of in section 5. applicability of existing reports is acceptable.

f. GA-ESI report 04038903-7SP, Qualification Basis for 04034101-001 (2-RE-90-271, -272, -

273, & -274) [TVA Note: These are the containment post accident high range radiation monitors.]: GA-ESI report 04038903-7SP is divided into subsections to address the Environmental, Seismic, EMC, and Software qualification basis for the High Range Area Monitors. Within each subsection, the HRAM is compared to a tested or analyzed article to demonstrate similarity and/or evaluate differences, the tests that were performed, and evaluation to demonstrate qualification. In most cases, the qualification basis references other documents. In addition to qualification, a section is provided that lists the life of those replaceable components that have life expectancy less than 40 years.

(2) This is addressed by response to RAI Question 336 in TVA to NRC letter dated November 24, 2010 (Reference 8)

(3) This is addressed by response to RAI Question 337 in TVA to NRC letter dated November 24, 2010 (Reference 8)

(4) The 04508905-3SP Qualification Test Report Supplement, RM-1000 Upgrades is not applicable to WBN Unit 2 (Reference 19).

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Please see Item 1, above, for applicability of the other reports.

(5) TVA provided the proprietary versions of the reports by letter dated March 12, 2010 (Reference 10). By letter dated July 15, 2010 (Reference 23), TVA provided the non-proprietary version of the reports and included a copy of the proprietary report which had been erroneously marked as having not been reviewed.

04508905-QR report has been reviewed by TVA. The review of the remaining reports is ongoing.

(6) See item 5.

TVA Response to Follow-up NRC Request:

The following documents are the qualification documents associated with the RM-1000 radiation monitors:

Attachment 5 contains the approved proprietary version of General Atomics Electronic Systems 04508905-1SP, Qualification Test Report Supplement, RM-1000 Upgrade.

Attachment 6 contains the approved proprietary version of General Atomics Electronic Systems 04508905-2SP, Qualification Test Report Supplement, I-F Converter Upgrades.

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).

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. In order to meet the NRC submittal schedule, the engineering review of this document was limited to the RM-1000. The document has been accepted for the RM-1000 monitors. Engineering approval will not occur until full review for all covered monitors is complete.

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.

(

319 7.5.2. 7.5 TVA provided System Verification Test Results 04507007-1TR Responder: Temples 300. Y Closed Closed RAI No. 29 TVA Letter dated S

i E

320 I Per Westinghouse letter WBT-D-2340, TENNESSEE VALLEY Responder: Clark 301. Y Closed Closed N/A N/A Duplicate of item 156 321 ( E For the purposes of measuring reactor coolant flow for Reactor Responder: Clark 302. Y Closed Closed N/A N/A Duplicate of OI# 157 C I 322 7.7.1.11 Section 7.7.1.11 will be added to FSAR Amendment 101 to provide Responder: Clark 303. Y Closed Closed 323 WCAP-13869 revision 1 was previously reviewed under WBN Unit Responder: Hilmes/Unit 1 27. Y Open Open-TVA TVA Letter dated EICB(Ga 1 SER SSER 13 (Reference 8). Unit 2 references revision 2. An 10/29/10 rg) analysis of the differences and their acceptability will be submitted Attachment 12 contains the WCAP 13869 Revision 1 to Due 3/29/11 Due: Enclosure 1 Item to the NRC by November 15, 2010 Revision 2 Change Analysis. No. 36

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Revised Response is included in Need to provide TVA Response to Follow-up NRC Request letter dated 10/29/10 additional info on why A FSAR change will be submitted in a future FSAR Rev. 1 is acceptable for amendment to change the revision level back to 1. The staff is confused with the both units.

response since both units have TVA Response to Second Follow-up NRC Request reference leg not insulated Rev 3/10/11 2 should apply to Unit 1 also Staff does not agree The differences between the Revision 1 and Revision 2 and there should be no with the statement that WCAPs is documented in Attachment 12, WCAP 13869 difference between Unit 1 and 2 there is no technical Revision 1 to Revision 2 Change Analysis, to TVA to NRC differences between letter dated October 29, 2010 (Reference 2). The design WCAP-13869 rev.1 and bases for the response to feedwater break inside rev2., but staff agree containment, as documented in Chapter 15 of the WBN Unit that rev1 and change 2 FSAR, is the same for WBN Unit 1. Since WBN Unit 2 is analysis could be basis required to match the WBN Unit 1 licensing basis to the for acceptance for both extent practical, the decision was made to revise the WBN Watts Bar units.

Unit 2 FSAR to agree with the WBN Unit 1 FSAR which uses Revision 1. 4/6/11 TVA response is acceptable, however this item remains open until TVA makes changes to FSAR.

324 B B Per the NRC reviewer, the BISI calculation is not required to be 304. Y Closed Closed

(

( (

325 M The Unit 2 loops in service for Unit 1 that are scheduled to be Responder: TVA Startup Olson 305. Y Closed Closed Closed to open item ?

G G a

326 TVA uses double-sided methodology for as-found and as-left Responder: Webb 306. Y Closed Closed TVA Letter dated 327 Attachment 36 contains Foxboro proprietary drawings 08F802403- Responder: Webber 28. Y Open Open-NRC Review SC-2001 sheets 1 through 6. An affidavit for withholding and non-DORL (Poole) proprietary versions of the drawings will be submitted by January In accordance with correspondence from Foxboro, there is Response Included in letter Due 11/24/10 31, 2011. no proprietary information contained in the 08F802403-SC- dated 11/24/10 2001 drawings. Based on this, no affidavit for withholding is required. Attachment 1 contains versions of the drawings with the proprietary information block removed.

(

328 7.5.2. 7.5 Provide the model number for the four containment high range Responder: Temples 307. Y Closed Closed RAI No. 30 TVA Letter dated S

i

( 308. Y 329 7.6.1 7.6.7 D ( Section 7.6.7 of the FSAR (Amendment 100) states that, The Responder: Clark Closed Closed RAI No. 1 TVA Letter dated a S i 309. Y 330 7.3 7.3 Related to Item 298 Responder: Hilmes/Faulkner Closed Closed EICB RAI No.20 Item 7, TVA letter 331 7.6.1 7.6.7 As a follow up of OI 190, Staff has reviewed the proprietary version Responder: WEC/Harless/Clark 310. Y Closed Closed RAI No. 8 TVA Letter dated Follow-up of OI-190.

of the DMIMS-DX system description to verify the conformance ML102980005 10/29/10 claims in the FSAR. Staff has noted the following insufficiencies TVA Partial Response: Response included in letter TVA letter 12/22/10, 10/26/2010 Enclosure 1 Item and discrepancies between the FSAR and the proprietary version dated 12/22/10 Encl 1, Item 27. No. 40 of the system description for loose parts monitoring system 1) The source of the information is the DMIMS-DXTM provided by TVA. Operations and Maintenance Manual, TS3176, Revision Due 12/22/10 0, dated August 2010. Attachment 14 contains the

1) FSAR, Amendment 100, page 7.6-5 states, During baseline revised system description, Westinghouse DIMMS- Pending FSAR testing, the reactor vessel and steam generator are impacted DXTM Loose Part Detection System Description, Amendment 102 three feet from each sensor with a force of 0.5 ft-lb. Loose Revision 1. The Westinghouse DIMMS-DXTM Loose submittal parts detection is accomplished at a frequency of 1 kHz to 20 Part Detection System Description, Revision 1 will be kHz, where background signals from the RCS are acceptable. added as Reference 9 to section 7.6 in FSAR TVA to reference the Spurious alarming from control rod stepping is prevented by a Amendment 102. DMIMS-DXTM module that detects CRDM motion commands and Operations Manual in automatically inhibits alarms during control rod stepping. 2) The source of the information is the DMIMS-DXTM the FSAR as the source EICB (Singh) seismic qualification report, Westinghouse report EQ- document The online sensitivity of the DMIMS-DX' is such that the QR-33-WBT, Revision 0, Seismic Evaluation of the system will detect a loose part that weighs from 0.25 to 30 Ib Digital Metal Impact Monitoring System (DMIMS-DXTM) TVA to reference the and impacts with a kinetic energy of 0.5 ft-lb on the inside for Watts Bar Unit 2. Attachment 14 contains the source document for

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N surface of the RCS pressure boundary within 3 ft of a sensor. revised system description, Westinghouse DIMMS- item# 4 per the DXTM Loose Part Detection System Description, response.

The source of this information is not cited nor is it described in Revision 1.

the system description. TVA to provide the source of the information and update the system description as needed. 3) The entries for the following items in FSAR Section 7.6.7 will be modified in Amendment 102 as shown in

2) Regulatory Guide (RG) 1.133, rev.1, regulatory position C.1.g Attachment 3 for draft revision to WBN Unit 2 FSAR states that, Operability for Seismic and Environmental Section 7.6.7, Loose Part Monitoring System (LPMS)

Conditions. Components of the loose-part detection system System Description.

within containment should be designed and installed to perform their function following all seismic events that do not Sensors (In Containment) require plant shutdown, i.e., up to and including the Operating Softline Cable (In Containment)

Basis Earthquake (OBE). Recording equipment need not Preamplifier (In Containment) function without maintenance following the specified seismic event provided the audio or visual alarm capability remains Attachment 3 contains the FSAR Amendment 102 functional. The system should also be shown to be adequate Change Markups that reflect these changes.

by analysis, test, or combined analysis and test for the normal operating radiation, vibration, temperature, and humidity 4) The source of the information is Westinghouse Letter environment. WBT-D-2580, Tennessee Valley Authority Watts Bar Nuclear Plant Unit 2 Response to NRC RAIs on LPMS FSAR, Amendment 100, page 7.6-5 states, The DMIMS- (Reference 5). Attachment 14 contains Westinghouse DX' audio and visual alarm capability will remain functional DIMMS-DXTM Loose Part Detection System after an Operating Basis Earthquake (OBE). All of the Description, Revision 1.

DMIMS-DX' components are qualified for structural integrity during a Safe Shutdown Earthquake (SSE) and will not In responding to Item 4, conflicting information was mechanically impact any safety-related equipment. found between the Westinghouse-prepared FSAR Paragraphs 4.c and 4.d of the system description are not section and various Westinghouse technical consistent with the seismic qualifications described in the documents. To fully respond to this item, a change to FSAR. TVA to provide the source of the information the FSAR is required to change the minimum flat sensor contained in the FSAR and update the system description as frequency response from 5 Hz to 10 Hz. Attachment 3 needed. contains the FSAR Amendment 102 Change Markups that reflect the revised frequency response of the

3) The system description clearly describes the In-containment sensor.

equipment and DIMMS-DX Cabinet equipment. The FSAR should be updated to reflect the equipment locations for Westinghouse document 1TS3182, Revision 0, Watts clarification purposes. Bar Unit 2 DMIMS-DXTM System Validation Data Package, dated July 2010 has been added as reference

4) The information regarding frequency ranges of the sensors is 8 to FSAR Section 7.6 in amendment 102. Per included on page 7.6-6 of Amendment 100 of the FSAR but Westinghouse letter WBT-D-2580, this document will be the system description does not contain this information. revised to reflect the 10Hz minimum frequency and Please provide the source of this information and update the provide the basis for the frequency response values in system description to reflect the appropriate information. the FSAR.

5) Please provide information as to how the in-containment 5) In-containment component qualification for vibration as components are qualified for vibration as addressed in addressed in regulatory position C.1.g of RG 1.133, will regulatory position C.1.g of RG 1.133. be addressed in a future RAI response letter.

TVA Partial Response:

Items 1) through 4) were addressed in the partial response provided in TVA to NRC letter dated October 29, 2010. Item 5 is addressed as follows:

TVA has reviewed the information provided by Westinghouse describing how the Loose Part Monitoring System (LPMS) sensor is qualified for normal operating conditions provided in Westinghouse letter WBT-D-2782, dated December 17, 2010 (Reference 11) as addressed in regulatory position C.1.g of Reg. Guide 1.133 and found it

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N acceptable. Vibration qualification is not applicable to the softline cable. Due to the installation location (junction boxes mounted to the shield or fan room walls) and previous seismic qualification, vibration qualification of the charge converter/preamplifier is not required. This completes the response to this item.

332 7.5.2. 7.5.1 ( 10/26/2010 311. Y Closed Closed ML103000105 Item TBD EICB RAI ML103000105 sent to DORL

( (

D 333 7.5.2. 7.5.1 M M 10/27/2010 312. Y Closed Closed ML103000105 Item TBD EICB RAI ML103000105 sent to DORL a

a a 334 7 7 FSAR Figure 7A-3 Mechanical Flow and Control Diagram Responder: Stockton 313. Y Closed Closed RAI not required. N/A RAI not required because the figure is 335 7.6.1 7.6.7 LPMS: Reference to OI-331, sub item 2. Responder: WEC 29. Y Closed Closed RAI# 1, EICB letter TVA letter, dated We need to confirm when MEEB when 11/22/2010 3/31/2011, Item they will complete their review of the Provide analysis, test, or combined analysis and test for normal TVA has reviewed the information provided by Partial Response included in Submit qual report by 15. seismic qualification report.

operating radiation, temperature, and humidity environment per Westinghouse describing how the Loose Part Monitoring letter dated 12/22/10 3/11/11 as stated in The report regulatory position C.1.g of RG 1.133. As an alternate TVA may System (LPMS) sensor is qualified for normal operating TVA letter of 12/22/10, addresses this open confirm that the required equipment has been qualified for the conditions provided in Westinghouse letter WBT-D-2782, As of 3/24/2011: Encl 1, Item 28. item, however, the environments stated in RG 1.133, position C.1.g and that TVA has dated December 17, 2010 (Reference 11) as addressed in The staff reviewed the maximum Rx reviewed the test report and found it acceptable. regulatory position C.1.g of Reg. Guide 1.133 and found it proprietary version of EQ-EV- Due 12/22/10 Containment acceptable. The qualification information on the softline 71-WBT-P, Revision 1, Temperature is not cable and charge converter/preamplifier is being assembled Environmental Evaluation and addressed within and will be submitted by March 11, 2011. Operating History of the the report and the Westinghouse DMIMS-DX staff needs this Preamplifier and Softline Cable information to Partial Response included in TVA to NRC letter dated Used at Watts Bar 2 dated approved the December 22, 2010 (Reference 1). February 2011 (Proprietary). maximum temperature Attachment 18 contains the proprietary version of EQ-EV qualification of 70o WBT-P, Revision 1, Environmental Evaluation and C for the EICB (Singh)

Operating History of the Westinghouse DMIMS-DX preamplifier cable Preamplifier and Softline Cable Used at Watts Bar 2 dated (Microdot February 2011 (Proprietary). Attachment 19 contains the Connector) end.

non-proprietary version EQ-EV-71-WBT-NP, Revision 1, TVA stated that Environmental Evaluation and Operating History of the they will provide the Westinghouse DMIMS-DX Preamplifier and Softline Cable Containment Used at Watts Bar 2, dated February 2011. Attachment 20 maximum temp.

contains the Application for Withholding Proprietary and reference the Information from Public Disclosure, EQ-EV-71-WBT-P, environmental Revision 1, Environmental Evaluation and Operating History report which this of the Westinghouse DMIMS-DX Preamplifier and Softline data is taken from Cable Used at Watts Bar 2, (Proprietary) dated February 18, in their next letter, 2011. which is expected on Tuesday TVA Response to Follow-up NRC Request: 3/29/2011.

The maximum WBN Unit 2 containment upper compartment normal operating temperature of 110 °F (43.3 °C) is shown on TVA environmental drawing 2-47E235-41 Revision 0.

The maximum WBN Unit 2 containment lower compartment normal operating temperature of 150 °F ( 65.6 °C) is shown on TVA environmental drawing 2-47E235-42 Revision 0.

(

336 7.5.2. 7.5 Re: RM-1000 Report 04508905-QR Responder: GA 314. Y Closed Closed S

i

(

337 7.5.2. 7.5 Re: RM-1000 Report 04508905-QR Responder: GA 315. Y Closed Closed S

i

(

338 7.5.2. 7.5 In page 3-15 and appendix B of Qualification Test Report 04508905-QR, Qualification Test Report for RM-1000 316. Y Closed Closed RAI #4 letter dated FSAR amend 103 Note: Item to be added to Section 3.10 S

i

(

339 7.5.2. 7.5 In the Qualification Test Report 04508905-QR, the licensee As agreed to with the reviewer, Attachment 1 contains the 317. Y Closed Closed RAI #5 letter dated FSAR amend 103 Note: Item to be added to Section 3.10 S

i 340 7.5.2. 7.5 CB (Si Provide test result curves for all EMI/RFI tests listed in Table 3.2.3 Responder: GA 2. N Open Open-TVA/Bechtel 3 ng (page 3-8) of the Qualification Test Report 04508905-QR. In Due 4/30/11

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N addition, please provide the standards or the guidance documents The following responses are based on e-mail: GA-ESI to Provide the qual reports used as the source for ENV 50140, ENV 55011 Class A, and EN Bechtel, dated December 8, 2010 (Reference 20), Response included in letter by 1/28/11 per TVA 55022 Class B. dated 12/22/10. letter of 12/22/10.

(1) The EMI/RFI tests described in Table 3-2 are based on GA-ESI report 04509050 and are summarized in GA- Due: 2/25/11 ESI report 04508905-QR. The independent laboratory Clarification Needed:

report, with curves, is part of GA-ESI report 04509050. Per 2/25/11 response Subsequent to issuing GA-ESI report 04508905-QR TVA document SS-additional EMC testing was performed in accordance E18.14.01, Rev. 3 is with TVA specific requirements. The results of the the source document subsequent EMC testing are reported in GA-ESI report for all testing. Please 04038800. GA-ESI report 04038800 includes the test provide this document curves and the report is used as the basis for EMC for staff review. In qualification of the Upper and Lower Inside addition British Containment Post Accident Radiation Monitors (2-RE- Standards (e.g. ENV 90-271 through -274). The results of the testing and 50140) have been cited the acceptability of the RM-1000 monitors for use at in testing which are not WBN Unit 2 are addressed in GA-ESI report per RG 1.180, R1. TVA 04038903-7SP. This report will be submitted no later to describe compliance than January 28, 2010. of SS-E18-14.01 to RG 1.180 with justification (2) ENV 50140, EN 55011, and EN 55022 are British for deviations. No test Standard Institution (BSI) publications concerning curves have been equipment electromagnetic and radio frequency provided in any of the performance. The standard titles are shown below: reports. As a minimum

a. ENV 50140 - Electromagnetic Compatibility - TVA to provide a few Basic Immunity Standard - Radiated Radio- sample test curves or Frequency Electromagnetic Field - Immunity Test justify not supplying

b. EN 55011 - Industrial, scientific and medical them.

equipment - Radio-frequency disturbance characteristics - Limits and methods of No EMI/RFI curves measurement have been provided as

c. EN 55022 - Information technology equipment - yet. TVA to provide Radio disturbance characteristics - Limits and representative curves.

methods of measurement NRC review proceeding TVA Response to Follow-up NRC Request: in parallel.

The total EMI/RFI testing of the RM-1000 and current-to- NRC current review frequency converter is documented in the following reports: guidance is based on compliance with RG Attachment 5 contains the proprietary version of 1.180 or equal with General Atomics Electronic Systems 04508905-1SP, justification for Qualification Test Report Supplement, RM-1000 variations. TVA is Upgrade. See sections 5.1.1, 5.1.2 and 5.1.4 for requested to provide EMI/RFI. the roadmap for Attachment 7 contains the proprietary version of compliance to RG General Atomics Electronic Systems 04038903-7SP, 1.180 with justifications Qualification Basis for 04034101 (2-RE-90-271, 272, for any deviations.

273 & 274). See section 5 for EMC qualification basis. Simply following TVA Attachment 8 contains the proprietary version of standard specification General Atomics Electronic Systems 04038903-QSR, SS E18.14.01, Rev. 3 is Qualification Summary Report for Watts Bar Nuclear not sufficient.

Plant Unit 2 Replacement Radiation Monitors. See section 3.4 for electromagnetic compatibility qualification requirements.

Attachment 23 contains the proprietary version of General Atomics Electronic Systems 04508905-QR,

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 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.

TVA Response to Second Follow-up NRC Request:

GA-ESI qualification report 04038903-7SP, Qualification Basis for 04034101 (2-RE-90-271, 272, 273 & 274)

Revision C dated February 22, 2011(Proprietary), submitted on TVA to NRC letter dated February 25, 2011 (Reference 2), section 5.1 states:

GA-ESI has performed the tests on a 2 channel RM-1000 radiation monitoring system the configuration of which is shown in GA-ESI drawing 04509000 System Installation Configuration, RFI/EMI Test, RM-1000 the results of which are issued in GA-ESI report 04038800, RM-1000 EMC Test Report, TVA and 04509050, RM-1000 EMC Test Report.

The equipment tested used an RM-1000 microprocessor radiation monitor Display/Control NIM Bin Assembly, an I-F Converter, line filter, and an RD-23 detector. The monitor system being qualified is the same as the monitor system tested and includes ECO-17656 modifications to ensure EMC compliance.

Attachment 1 contains the TVA Browns Ferry High Range Radiation Monitor which contains the requested EMI test curves. We have confirmed that the GA-ESI reports (04509050, RM-1000 EMC Test Report, dated 4/22/03 and 04038800, RM-1000 EMC Test Report, dated 11/11/99) included in the TVA report are applicable to the WBN Unit 2 RM-1000 monitors. The non-proprietary versions and affidavit for withholding of GA-ESI reports (04509050 and 04038800) will be submitted within two weeks of receipt from GA-ESI.

GA-ESI qualification report 04038903-7SP, section 5, provides a detailed discussion of the test results in GA-ESi report 04509050.

(

341 7.5.2. 7.5 FSAR Tables 3.10 list seismically qualified equipment. However, A review of WBN Unit 2 FSAR amendment 102 chapters 318. Y Closed Closed RAI #1 letter dated FSAR amend 103 S

i

(

342 7.5.2. 7.5 Please confirm that RM-1000 monitors and the associated The RM-1000 containment high range radiation monitors are 319. Y Closed Closed S

i g

343 7.5.2. 7.5 ( ( Seismic RRS in the 04508905-QR report Figures 3-2 and 3-3 (1) The cause of the difference between the RRS and TRS 320. Y Closed Closed G S i 321. Y 344 7.6.6  ? Unit 1 SE discussed in Section 7.6.5, Valve Power Lockout. (a) In accordance with0PDP-6, Locked Valve/Breaker Close Closed Close based on TVA letter dated

(

345 7.5.2. 7.5 Provide the normal temperatures and expected periods of high/low RM-1000 in a NIM Bin was Tested at 39°F for 72 Hrs and 322. Y Closed Closed Response S

i 346 7.5.2. 7.5 TVA has previously stated in response to open item 319 that RM- Document 04507007-1TR is the RM-1000 System 3. N Open Open-TVA/Bechtel 3 1000 System Verification Test Results report, 04507007-1TR is not Verification Test Results. 04038903-QSR, Qualification Due 4/15/11 EICB (Singh) applicable to WBN-2. However, TVA has not provided a WBN-2 Summary Report for Watts Bar Nuclear Plant Unit 2 Due: 2/25/11 specific test results report. Please identify and provide the Replacement Radiation Monitors (Attachment 8) and and appropriate test results reports to complete the review. 04038903-7SP, Qualification Basis for 04034101 (2-RE The proposed response 271, 272, 273 & 274) (Attachment 7) are the Watts Bar Unit appears to be 2 equipment specific qualification reports. conflicting with the proposed response for

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N TVA Response to Follow up NRC Request: OI-351 regarding not submitting the Report 04507007-1TR RM-1000 System Verification Test 04508905-QR report.

Results is applicable to the WBN Unit 2 monitors. The TVA to re-assess applicability is that 04507007-1TR includes all test cases proposed response for called out in the 04507006 RM-1000 System Test both OIs.

Procedure Specification and contains evidence that the V&V tests were performed with version 1.0 software code. The TVA to re-evaluate verification report for version 1.1 software is document previous responses to 04508005 RM-1000 Software Version 1.1 Software OI-316 and OI-319 Verification Report. Document 04508006 RM-1000 which have conflicting Version 1.2 Software Verification and Validation Report responses regarding shows that the required test was completed to validated the applicability of version 1.2 code for the RM-1000. 04507007-1TR.

The Engineering reviewed and approved proprietary versions of 04507007-1TR, 04508005 and 04508006 will be submitted within two weeks of receipt from GA-ESI. The unreviewed proprietary versions, non-proprietary versions and affidavit for withholding were submitted on TVA to NRC letter July 15, 2010 (Reference 3).

(

347 7.5.2. 7.5 Qualification report 04508905-1SP does not address EMI/RFI Qualification report 04038903-7SP, Qualification Basis for 323. Y Closed Closed S

i

(

348 7.5.2. 7.5 Qualification report 04508905-2SP does not address EMI/RFI Qualification report 04038903-7SP, Qualification Basis for 324. Y Closed Closed S

i 349 7.5.2. 7.5 Radiation testing was not considered in any of the test reports as The design criteria provides the criteria for determining what 4. Y Open Open-TVA/Licensing 3 all the equipment has been assumed to be located in nuclear is a mild environment at WBN Unit 2. Calculation power plant areas with mild environments and radiation dosages WBNAPS4004 Summary of Mild Environment Conditions for Due: 2/25/11 less than 1 x 103 rads for total integrated dose (TID). However, Watts Bar Nuclear Plant provides the actual values for each the radiation monitors and the I/F converters are located in the area of the plant. In accordance with Table 1, the Control TVA to provide the main control room which is defined as mild environment. For Room has a 40 year maximum TID of 3.5x102 RAD and a assessment document WBN-2 mild environment is defined as room or building zone maximum integrated accident dose of 710.5 RAD for a or a summary of the where (1) the temperature, pressure, or relative humidity resulting maximum TID of 1060.5 RAD. document with the from the direct effects of a design basis event (DBE) (e.g., reference to the temperature rise due to steam release) are no more severe than The accident dose of 710.5 RAD is the dose for a 100 day appropriate those which would occur during an abnormal plant operational LOCA at the surface of the HEPA filter in the Mechanical document/documents.

condition, (2) the temperature will not exceed 130ºF due to indirect Equipment Room. This is documented in TVA calculation effects of a DBE, (3) the event radiation dose is less than or equal WBNTSR-005, Dose Due to the Control Building February 25, 2011 EICB (Singh) to 1 x 104 rads, and (4) the total event plus the 40 year TID (total Emergency Air Cleanup Filters Revision 3. However, on response is acceptable.

integrated dose) is less than or equal to 5 x 104 rads (reference page 25 of WBNTSR-005, the shine from this source into the Item will be tracked as WB-DC-40-54). TVA to address lack of radiation qualification for control room is negligible and is not considered in the dose a confirmatory item in WBN-2. calculation for the control room. the SE. TVA to provide calculation or summary Calculation WBNAPS3-126, EQ Dose in the U1/U2 Auxiliary of calculation when Instrument Rooms and the Computer Room in the Control complete.

Building Revision 0 documents the environmental qualification (EQ) radiation dose in the control building. A review of this document by the TVA radiation protection engineer determined that the TID including the normal and accident dose values for the control room is less than 1x103 RAD. Calculation WBNAPS3-126, will be revised to include the control room by July 1, 2011. Since the control room TID has been determined to be less than 1x103 RAD, radiation qualification of the RM-1000.

(

350 7.5.2. 7.5 The seismic required response spectra (RRS) is shown in Figures The RM-1000 was seismically tested in a NIM Bin and the 325. Y Closed Closed RAI # 9, letter FSAR amend 103 Note: Item to be added to Section 3.10 S

i

(

351 7.5.2. 7.5 The replacement schedule for the components that have a The replacement schedules stated in 04508905-1SP, 326. Y Closed Closed S

i

(

352 7.5.2. 7.5 Please clarify how many RM-1000 radiation monitors are being The total number of RM-1000 units procured under MR 327. Y Closed Closed S

i 353 7.5.2. 7.5 Please provide a summary of the [manufacturers] commercial GA-ESI submitted their commercial grade dedication 5. Open Open-TVA/Bechtel

(

N S

i

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 3 dedication plan for radiation monitors with references to the procedure (OP-7.3-240, Safety-Related Commercial Grade Due 4/15/11 guidance document that it follows. Also please include different Item Parts Acceptance, Revision H) to engineering for TVA to note that staff facets (e.g. receiving, inspection, testing etc.) of the plan. review. Engineering review of the procedure found that the has written a safety procedure, Section 5, did not require multiple dedication evaluation and methods for complex CGI or CGI used in digital safety accepted EPRI TR-systems. As a result, it was determined that the GA-ESI 106439 (1996) as an program did not meet the requirements of NUREG-800, acceptable method of Section 7.0A, Revision 5. addressing commercial dedication. EPRI NP-A discussion with GA-ESI found that while not required by 5652 must be used in procedure, GA-ESI does perform vendor surveys as required conjunction with the by Method 2 of NP-5652. The surveys are done based on additional guidance in prudent business practices. Based on this discussion, GA- EPRI TR-106439 for ESI agreed to review the CGI used in the WBN Unit 2 digital commercial dedication safety-related monitors to determine if they had been processes e.g. EPRI dedicated by more than one method. NP-6404, EPRI TR-102260, GL 89-02, and The review of the CGI used in the WBN Unit 2 digital safety- GL-91-05 per Section related monitors determined that all CGI had been dedicated 3.3 of EPRI TR-using Method 1 of EPRI guideline NP-5652. However, in the 106439.

sample of items reviewed, there were CGI that were dedicated using a single method. Based on the results of the engineering procedure review and the results of the GA-ESI CGI review, Service Request 346896 was initiated to document the condition and to place the monitors in Conditional Release status.

Based on the results of the previous reviews, GA-ESI agreed to the following plan of action to resolve the CGD issue:

1. GA-ESI shall revise its commercial grade dedication procedure (OP-7.3-240) to require multiple dedication methods be utilized for complex commercial grade items and commercial grade items for digital safety class systems. The evidence that this has been completed will be provided to TVA by April 15, 2011.

Specifically, Method 1 and at least one additional method from the list below will be used to ensure that the CGD procedure complies with the current SRP.

Method 1 - Special Tests and Inspections Method 2 - Commercial Grade Survey of Supplier Method 3 - Source Verification Method 4 - Acceptable Supplier/Item Performance Record

2. GA-ESI shall take actions consistent with the revised operating procedure to address the CGls used in the WBN Unit 2 safety-related digital monitors. Evidence that those actions have been completed will be provided no later than September 1, 2011.

Based on the above action plan, TVA will resolve the issues with the GA-ESI CGD of CGI used in the WBN Unit 2 monitors and submit documentation of the resolution to the NRC by:

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N GA-ESI procedure OP-7.3-240 revision: April 30, 2011 Resolution of CGD of CGI used in WBN Unit 2 RM-1000 monitors: September 15, 2011

(

354 7.5.2. 7.5 RG 1.180 endorsed the guidance of IEEE-1050-1996 with (1) The WBN Unit 2 grounding system design is in 328. Y Closed Closed The grounding specification used by S

i 355 7.5.2. 7.5 Staff has not found the stated exclusion zone for EMI/RFI Cautions and distance limitations for WBN Unit 1 legacy 6. Y Open Open-TVA/Bechtel 3 interfering devices (e.g. hand-held radio devices) in the submitted equipment are documented in TVA procedure TI-134, Due 4/15/11 documents. TVA to provide the distance for the exclusion zones if Revision 0, Control of Portable Two-Way Radios, TVA to provide not provided already. If it is already a submitted information then (Attachment 7) Appendix B. Where WBN Unit 2 uses the commitment that an please point the source of the information. same legacy equipment, the same cautions and distance EMI/RFI survey will be limitations apply. conducted after the installation of the New equipment is procured and tested to TVA Standard equipment to confirm Specification SS E18.14.01, Revision 3, Electromagnetic the non-susceptibility Interference (EMI) Testing Requirements for Electronic when using portable Devices (Attachment 6). The TVA specification is radio-frequency conservative with respect to Regulatory Guide 1.180, sources such as hand-Revision 1. The specification requires that equipment not be held radios or other susceptible to external interference or create external authorized devices that EICB (Singh) interference. New equipment is either tested by the may be used in the manufacturer or tested in the TVA EMI test facility to ensure control room.

it meets the specification. If issues are found, the equipment Summary of the results is modified and installation documents are revised to to be submitted to NRC eliminate the issue(s). This is true for the RM-1000 radiation to close this item.

monitors which were tested prior to installation in Browns Survey results are to be Ferry at 10v/meter (Browns Ferry High Range Radiation available for audit by Monitor dated December 8, 2006). Based on this, no NRC.

exclusion zone for radio use is required for the RM-1000 radiation monitors in WBN Unit 2.

TVA Response to Follow-up NRC Request:

TVA will perform an EMI survey of the containment high range radiation monitors after installation in WBN Unit 2 and submit the results to the NRC within two weeks of the survey being completed.

(

356 7.5.2. 7.5 The attachment number refers to your February 25, 2011 letter. The loss of the RM-3 output (current to frequency (I/F) 329. Y Closed Closed Closed by TVA S

i 357 7.5.2. 7.5 In Attachment 5, Qualification Test Report Supplement, RM-1000 Attachment 8 contains GA-ESI qualification report 30. N Open-NRC Review 3 (04508905-1SP), Attachment 6, Qualification Test Report 04508903-1TR Seismic Qualification Test Results RM-1000 Supplement, I-F Converter Upgrade (04508905-2SP), and and Current-to Frequency (I/F) Converter original release, EICB (Singh)

Attachment 23, Qualification Test Report for RM-1000 Processor dated April 1999.

Module and Current-To-Frequency Converter (04508905-QR), the applicant made a statement that the results for these tests are provided in SE document 04508903-1TR. Please provide SE document 04508903-1TR for the staff to review. IF this report has been submitted earlier then please advise us the letter number and date by which it was submitted.

358 7.5.2. 7.5 The attachment numbers refer to your February 25, 2011 letter. In An incomplete response was inadvertently submitted in TVA 7. N Open Open-TVA/Bechtel 3 Attachment 2, Wyle Test Report 41991 Safety Shutdown to NRC letter dated March 31, 2011 (Reference 1). The Due 4/15/11 Earthquake (SSE) Test Response Spectra (TRS) Plots all five (5) following response supersedes the previous response in its EICB (Singh) pages, in Attachment 5, General Atomics Electronic Systems entirety.

04508905-1SP, page 5-5, Figure 5-2, and in Attachment 23, Qualification Test Report for RM-1000 Processor Module and 1. Attachment 2, Wyle Test Report 41991 Safety Current-To-Frequency Converter (04508905-QR), page 4-25, Shutdown Earthquake (SSE) Test Response Spectra Figure 4-5 X-Axis SSE Test Response Spectra (TRS) versus (TRS) Plots all five (5) pages. These five Test Required Response Spectra (RRS), it shows that the TRS were Response Spectra (TRS) Plots versus Required below the RRS at various frequency (5% Damping). Please provide Response Spectra (RRS) show that the TRS were

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N an explanation regarding why this is acceptable. below the RRS at various frequency (5% Damping).

Please provide an explanation regarding why this is acceptable.

Attachment 2 of this letter provides five pages from the first seismic test (Wyle Test report 41991) from GA-ESI report 04508903-1TR, submitted in response to OI-357 on TVA to NRC letter dated March 31, 2011 (Reference 1). The following discussion refers to these pages.

Wyle test report 41991 provided the seismic test results for two RM-1000 monitors (one area monitor and one process monitor) and one I/F converter. During the test, the RM-1000 monitor configured as an area monitor was damaged due to the test table impacting its mechanical stop (see page 4 of Wyle Test Report 41991 attached).

This first test was completed for the RM-1000 monitor configured as a process monitor and the I/F converter.

A second seismic test for the RM-1000 monitor configured as an area monitor and two I/F converters (Wyle Test Report 41991-1) is also included in 04508903-1TR. The RM-1000 monitor used in this second test was the same RM-1000 process monitor used in the first seismic test reconfigured (switch in application type 1 mode) as an area monitor. One of the I/F converters tested was the same I/F converter tested in the first seismic test. This second test was performed to complete the testing which could not be performed during the first seismic test due to the damage to the RM-1000 area monitor and the loss of the high voltage power supply to the I/F converter that occurred during the first seismic test. None of the TRS plots in this second seismic test report 41991-1 were below the RRS.

General Atomics Qualification Test Report for RM-1000 Processor Module and Current-To-Frequency Converter (04508905-QR) refers to both Wyle Reports 41991 and 41991-1 included in report 04508903-1TR. It is recognized that the five TRS Plots versus the RRS where the TRS were below the RRS is an exceedance that must be justified. From Wyle report 41991 it can be determined that these five TRS versus RRS plots are for the seismic response in the front to back panel direction.

The RRS used in the Wyle test reports envelopes the TVA standard RRS shown in Fig 3.1 of TVA Standard Specification CEB-SS-5.10, For Seismic Qualification of Electrical, Mechanical and I&C Devices, submitted on TVA to NRC letter dated February 25, 2011, (Reference

2) below 33 Hz. This TVA standard RRS conservatively envelopes the in panel seismic demand for most TVA applications. For specific cases when required the actual in panel RRS can be developed. Calculation WCG-ACQ-0766, In-Cabinet Required Response Spectra for RM-1000 Radiation Monitors in MCR Panel 2-M-30, Revision 0, (Attachment 3) has been issued to generate the 5% RRS for these safety related RM-1000 monitors, I/F converters and NIM bins for the WBN2

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N panel (2-M-30) where they will be installed. As can be seen from the RRS plots in calculation WCG-ACQ-0766 the front to back 5% RRS broad band peak is 9.76 g which is lower than the front to back 5% TRS shown in the subject five (5) plots.

2. Attachment 5, General Atomics Electronic Systems 04508905-1SP, page 5-5, Figure 5-2. The Figure 5-2 Test Response Spectra (TRS) Plots versus Required Response Spectra (RRS) shows the TRS to be below the RRS at various frequency (5% Damping). Please provide an explanation regarding why this is acceptable.

The display module for the RM-1000 monitors procured for WBN2 differs from that used in previous RM-1000 qualification tests. The seismic qualification basis for the WBN2 display module is established by similarity to the display module used in RM-2000 monitor qualification tests shown on page 5-4 and 5-5 of 04508905-1SP (pages attached). The basis for the similarity discussion is provided on pages 5-2 and 5-3 of 04508905-1SP. The TRS non-exceedance at approximately 6-7 Hz shown on page 5-5 is not applicable to WBN2 since the RRS shown on that figure is not used for WBN2 qualification. The correct comparison for WBN2 would be the TVA standard RRS shown in Fig 3.1 of CEB-SS-5.10 for 5% damping. The TRS shown on page 5-5 meets or exceeds all points of the TVA standard RRS. Therefore, the seismic qualification of the WBN2 display module is provided by pages 5-4 and 5-5 for which the TRS completely envelopes the TVA standard RRS shown in Fig 3.1 of CEB-SS-5.10. Additionally, as previously stated, Calculation WCG-ACQ-0766 was issued to generate the 5% RRS for the WBN2 panel (2-M-30) where the safety related RM-1000 monitors will be installed. The vertical 5% RRS plot in calculation WCG-ACQ-0766 broad band peak is 4.2 g which is lower than the 5% TRS shown in 04508905-1SP, page 5-5, Figure 5-2.

3. Attachment 23, Qualification Test Report for RM-1000 Processor Module and Current-To-Frequency Converter (04508905-QR), page 4-25, Figure 4-5 X-Axis SSE Test Response Spectra (TRS) versus Required Response Spectra (RRS) shows the TRS to be below the RRS at various frequency (5% Damping). Please provide an explanation regarding why this is acceptable.

This Figure 4-5 is one of the same figures identified in item 1. See item 1. for the appropriate discussion.

359 7.7.1. Was the CERPI system developed under a 10 CFR 50 Appendix B CERPI is a non-safety related system. Therefore, 10 CFR 8. Open Open-TVA/WEC 1 EICB compliant program? 50 Appendix B is not applicable. Due 4/15/11 (Carte) 360 EICB In order for staff to review the acceptability of the Incore (a) The Watts Bar Unit 2 In-core Instrumentation System 9. Open Open-TVA/WEC (Garg Instrumentation System (IIS): (IIS) replaces all of the functionality provided by the Due 4/15/11

)

Movable Incore Detector System (MIDS) used at Watts

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N (a) Provide a brief system description of IIS and its regulatory Bar Unit 1. The IIS to be used at Watts Bar Unit 2 is a compliance. In your discussion include the discussion of Westinghouse IN-Core Information, Surveillance, and WINCISE and BEACON system which are part of the IIS. Engineering (WINCISE) System that is functionally Also provide the differences between the system used at described in Section 7.7.1.9 of the Watts Bar Unit 2 WBN Unit vs. at Unit 2, e.g. Movable vs. fixed IIS. For Final Safety Analysis Report (FSAR). The WINCISE-WINCISE provide the basis for acceptance. style IIS used at Watts Bar Unit 2 is essentially the same as the in-core power distribution measurement systems (b) If this system has been accepted by the staff previously at used at most Combustion Engineering style of operating some other plant then provide the reference to that SE. reactors that use a type of in-core neutron sensors Identify the document that describes the functionally of the IIS commonly called "Fixed In-core Detectors (FID)." The that is identical to the IIS used in the Westinghouse AP1000 Watts Bar Unit 2 IIS is functionally identical to the IIS reactor design. used in the Westinghouse 1AP1000' reactor design.

The Watts Bar Unit 2 IIS includes the FIDs, Core Exit (c) If this has not been evaluated by the staff previously, then Thermocouples (CET), FID and CET signal cables, the provide the effect of CCF of this system and its effect on FID signal processing hardware, and the FID signal safety system or chapter 15 analysis. processing software. This hardware and software is required to provide the measured signals to the (d) Does this have any interconnection with safety system? associated BEACON System to periodically determine whether the reactor is operating within design core (e) For BEACON provide the acceptability of this system. I peaking factor limits. A detailed description of the Watts believe that this system was accepted at WBN Unit 1. If that Bar Unit 2 IIS hardware is provided in the document is the case then provide the reference to that review. Also titled, Westinghouse Incore Information Surveillance &

provide any differences of this system to the one at WBN Unit Engineering (WINCISE) System Technical Manual, NO-1 system.

WBT-002, Revision 0 supplied by Westinghouse to TVA in September of 2010.

(f) Please provide detailed information about the In-core Instrumentation System (IIS) to be installed in Watts Bar Unit The qualification for the BEACON System to perform the

2. This information should indicate how the system meets the core power distribution measurement function using the requirements established in the Standard Review Plan, Watts Bar Unit 2 WINCISE style IIS instrumentation is including system concept, system requirements, system documented in the generic NRC Safety Evaluation design, and system development, as well as the regulatory Reports (SER) provided with WCAP-12472-P-A, requirements identified for Watts Bar Unit 2.

BEACON Core Monitoring and Operations Support System, Addendum I-A and Addendum 2-A.

(g) Please provide a description on how the system will meet the regulatory requirements identified in Table 7.1-1 of the SRP, (b) The WINCISE style IIS used at Watts Bar Unit 2 is applicable to the IIS.

essentially the same as the in-core power distribution measurement systems used at all Combustion (h) Provide detailed description about the connection and Engineering style of operating reactors that use a type communication for the signals to be transmitted from the Core of in-core neutron sensors commonly called "Fixed In-Exit Thermocouples to the Common Q Post Accident core Detectors (FID)." The Watts Bar Unit 2 IIS is Monitoring System (PAMS). Also, describe how this functionally identical to the IIS described in the communication will meet the NRC communications regulatory Westinghouse AP1000 design documents and approved requirements.

in the Westinghouse AP1000 SER section 7.5.7 as documented in Westinghouse Letter WBT-D-____ ,

(i) Please provide the following Westinghouse document: NO-title, dated April 14, 2011 (Attachment 7)

WBT-002, Westinghouse Incore Information Surveillance &

Engineering (WINCISE') System Technical Manual.

(c) The digital in-core flux monitoring portion of the IIS is non-safety-related. As such, CCF analysis is not (j) Provide the failure modes and effects analyses for the IIS, required by NUREG-800 section 7.0-A. The IIS has no documented in calculation WBNOSG4220 WB Incore impact on any Safety Analysis documented in Chapter Instrumentation System Failure Modes and Effects Analyses, 15 of the Watts Bar Unit 2 FSAR.

and demonstrate how these potential failures do not adversely affect reactor safety.

(d) The IIS includes the 1E qualified CET and CET analog signal cables required to allow the CETs to be directly connected to the Common Q Post Accident Monitoring System (PAMS). There is no other interface to safety systems. The CET signals are electrically isolated from 1

AP-1000 is a registered trademark of the Westinghouse Electric Company LLC

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N signals output from the non-1E FID signals and signal processing electronics.

(e) The qualification for the BEACON System to perform the core power distribution measurement function using the Watts Bar Unit 2 WINCISE style IIS instrumentation is documented in the generic NRC Safety Evaluation Reports (SER) provided with WCAP-12472-P-A. This WCAP generically approves the BEACON System for use at PWR reactors including those using Movable In-core Detector Systems (MIDS) like Watts Bar Unit 1 and, through Addendum I-A and 2-A, those like Watts Bar Unit 2 using a WINCISE type fixed in-core instrumentation system.

The specific differences between the Unit 1 and Unit 2 core power distribution measurement systems are too numerous to simply list. A detailed description of the Watts Bar Unit 2 IIS hardware is provided in section 2 of the WINCISE System Technical Manual NO-WBT-002 (Attachment 5).

(f) NUREG-800 section 7.0-A, Table 7.0-A-1. Review Topics for Various Systems, requires only a limited review for non-safety related system discussed in NUREG-800 section 7.7 Control. WINCISE is a non-safety-related, indication only system within the scope of NUREG-800 section 7.7. The limited review required is:

Control systems receive a limited review as necessary to confirm that control system failures cannot have an adverse effect on safety system functions and will not pose frequent challenges to the safety systems. The only WINCISE interface with a safety-related system is the CET in the IITA which is hardwired to the Common Q PAMS system. See item (g) below for a description of the qualification process that demonstrates that failures in the balance of the WINCISE system do not impact the performance of the safety-related CET function.

(g) With the exception of the IITA hardware, WINCISE is a non-safety-related indication system. The IITA assemblies meet the following criteria:

i. R.G. 1.26 Rev. 3 Quality Group Classification and Standards for Water, Steam and Radioactive Waste Components of Nuclear Power Plants ii. R.G. 1.38 Rev. 2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling of Items for Water-Cooled Nuclear Power Plants iii. R.G. 1.71 Rev. 0 Welder Qualification for Areas of Limited Accessibility iv. R.G. 8.8 Rev. 3 Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power Stations will be As Low As Reasonably

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Achievable

v. R.G. 8.19 Rev. 1 Occupational Radiation Dose Assessment in Light-Water Reactor Plants Design State Man-Rem Estimates vi. R.G. 1.84 Rev. 27 Design and Fabrication Code Case Acceptability - ASME Section III, Division 1R.G. 1.85 Rev. 27 Material Code Case Acceptability - ASME Section III, Division 1 1.1.4 The design, materials, fabrication, inspection, and testing of the IITA shall be in accordance with the ASME Boiler and Pressure Vessel Code,Section III Class 3, and all applicable Code Cases as proposed by the supplier and approved by Westinghouse. Materials shall be in accordance with this specification.

1.1.5 Component Classification - The IITA is classified as an instrument tube, so it is not under the jurisdiction of the ASME per NCA-1130(c). However, the design, primary pressure boundary materials, and NDE Requirements are per ASME Section III, Class 3 and the IITA is classified as Safety Class 2.

The non-safety-related WINCISE Signal Processing System Cabinets are located inside containment and are therefore required to not impact the function of any safety-related equipment. To meet this requirement the cabinets were tested and passed based on the following criteria:

i. In accordance with WB-DC-40-31.2, Watts Bar Nuclear Plant Seismic Qualification of Category 1 Fluid System Components and Electrical or Mechanical Equipment, Revision 8, November 2000 and U.S. N.R.C. Regulatory Guide 1.100, Seismic Qualification of Electrical and Mechanical Equipment for Nuclear Power Plants, Revision 2, June 1988, the equipment must withstand five OBEs and one SSE without creating missiles. Testing was done in accordance with:

(1) IEEE Std 344-1975, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations, Institute of Electrical and Electronics Engineers, Inc., 1975 (2) IEEE Std 344-1987, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations, Institute of Electrical and Electronics Engineers, Inc., 1987 ii. In accordance with U.S NRC Regulatory Guide 1.180

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Guidelines for Evaluating Electromagnetic and Radio-Frequency Interference in Safety-Related Instrumentation and Control Systems, Revision 1, October 2003 and IEEE 323-1983 IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generator Stations, Institute of Electrical and Electronics Engineers, Inc., 1983, the equipment must not generate spurious electromagnetic emissions or suffer some common mode failure due to its operating environment that could directly or indirectly impact the operation of safety-related equipment (1) IEC 61000-6-2, Electromagnetic compatibility (EMC). Generic Standards. Immunity for Industrial Environments, 2005 (2) MIL-STD-461E, Requirements for the control of Electromagnetic interference Characteristics of Subsystems and Equipment, August 1999 (3) IEC 61000-4-4, Electromagnetic compatibility (EMC) - Part 4-4: Testing and Measurement Techniques - Electrical Fast Transient/Burst Immunity Test, 1995 (4) IEC 61000-4-12, Electromagnetic Compatibility (EMC) - Part 4: Testing and Measurement Techniques, Section 12:

Oscillatory Waves Immunity Tests, 1996 iii. In order to demonstrate that a maximum expected surge of 600 volts on the power input to the cabinets would not propagate and damage the CET cables in the IITA, the cabinets were surge tested in accordance with IEC 61000-4-5, Electromagnetic compatibility (EMC) - Part 4-5: Testing and Measurement Techniques - Surge Immunity Test, 1995.

(h) The cables for the CETs separate from the FID cables at the seal table. The CETs are connected directly to the Common Q PAMS cabinet. The FIDs are connected directly to the in-containment signal processing system cabinets.

(i) Attachment 5 is the proprietary section 2 Equipment Description of NO-WBT-002, Westinghouse Incore Information Surveillance & Engineering (WINCISE')

System Technical Manual. This is strictly a proprietary document and a non-proprietary version will not be submitted. An affidavit for withholding will be submitted within two weeks of receipt from Westinghouse.

(j) Attachment 6 is the proprietary WINCISE FMEA. A non-proprietary version and affidavit for withholding will be provided within two weeks of receipt from Westinghouse.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Westinghouse is available to discuss any specific questions on the methodology and hardware used in the Watts Bar Unit 2 IIS that the NRC believes are not well defined in the documents listed above.

361 7.7.1. Was the Foxboro IA system developed under a 10 CFR 50 Foxboro I/A is a non-safety related system. Therefore, 10 10. Open Open-TVA/Bechtel 1 EICB Appendix B compliant program? CFR 50 Appendix B is not applicable. Due 4/15/11 (Carte) 362 7.6.1 7.6.7 OI #331 requested TVA to provide information regarding how the TVA committed to provide a letter on the docket (targeted is 11. Open-TVA Open-TVA/Bechtel Loose Parts Monitoring System (LPMS) in-containment for 4/30/2011) stating why the the in-containment equipment components (e.g., Accelerometer ( including the integral insulated has been qualified for vibration per RG 1.133, Rev. 1.

hardline cable), Softline cable, and Remote Charge Preamplifiers) were qualified for vibration as addressed in regulatory position C.1.g of RG 1.133, Rev. 1. TVA responded by stating that TVA has reviewed the information provided by Westinghouse describing how the Loose Part Monitoring System (LPMS) sensor is qualified for normal operating conditions provided in Westinghouse letter EICB ( Kemper & Singh)

WBT-D-2782, dated December 17, 2010 (Reference 11) as addressed in regulatory position C.1.g of Reg. Guide 1.133 and found it acceptable. Vibration qualification is not applicable to the softline cable. Due to the installation location (junction boxes mounted to the shield or fan room walls) and previous seismic qualification, vibration qualification of the charge converter/preamplifier is not required. This completes the response to this item.

However, the staff still desires further clarification on this response. Specifically, please provide a documented basis that demonstrates the LPMS in-containment equipment is qualified for normal operating conditions (e.g., test results compared to the equipment qualification specification), including vibration qualification. Also, provide justification for why vibration qualification if the Remote Charge Preamplifier is not required.

363 7.5.1. 7.5.2 OI#199 requested TVA to provide information concerning how TVA 12. Due 4/30/11 Open-TVA/Bechtel 1.3 plans to meet regulatory criteria for Quality (10 CFR 50.55a(a)(1))

and associated with the Technical Support Center and Nuclear Data 7.9.1 Link. TVA responded in Letter Dated October 5, 2010, Item 63; however, TVAs response does not address the quality aspects of these system features. A similar question had been asked for Quality Criteria adherence for the SPDS and the BISI functions of the Integrated Computer System. In response to that request EICB (Rahn and Mossman)

(same letter) TVA provided a description of TVA procedures, BISI software development procedures, and various management measures that will be taken to assure high quality in the design, operation, and maintenance of the SPDS and BISI functions of the ICS. Since the TSC and Nuclear Data Link information originates in the SPDS function of the ICS, are there any aspects of the quality measures that apply to the TSC and NDL features developed as part of quality processes for the ICS that are applicable to the data communications features?

Specifically, what is the scope of TVA Procedure SPP-2.6 Computer Software Control? How does it apply to the ICS functions of a) SPDS, b) BISI, and c) TSC and NDL functions?

Wouldnt there be aspects of the quality procedures that apply to the development, maintenance, and operations of the software needed to support the data communications features. Also, what

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N quality measures will be applied to develop, maintain, and operate the hardware that accomplishes the TSC and NDL functions to ensure that these features will be reliable and available when needed?

364 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff 81.

position.

By letter dated 2/25/11 (ML110620219), TVA docketed a response: TVA performed an analysis and concluded that the Common Q PAMS equipment does not need to meet either IEEE 279-1971 or IEEE 603-1991 and so no analysis was performed or provided.

EICB (Carte)

However, SRP (NUREG-0800 Rev. 2 dated March 2007) Section 7.7, Information System Important to Safety, specifically identifies IEEE Std 603-1991 as being applicable to accident monitoring instrumentation. Based upon the review of this item, the staff finds the following open items:

1 TVA to demonstrate that the Common Q PAMS meets the applicable regulatory requirements in IEEE Std 603-1991.

2 TVA to updated FSAR (Amendment 103) Table 7.1-1 to reference IEEE Std 603-1991 for WBN2 Common Q PAMS and Sorento Containment High Radiation Monitors.

365 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff 81.

position.

By letter dated 2/25/11 (ML110620219), TVA docketed a response: that WBN2 is not committed in complying with Reg.

Guide 1.75Since WBN2 is not committed to RG 1.75 or IEEE-384, no comparison is required However, WBN2 is committed to RG 1.75 Rev. 2, Physical Independence of Electric Systems. RG 1.75 Rev. 3 and IEEE Std. 384-1992 are used, in part, to address IEEE Std 603-1991 EICB (Carte)

Clause 5.6.1. The current NRC staff position for RG 1.75 is documented in Rev. 3. Based upon the review of this item, the staff finds the following open item:

1 TVA to updated FSAR (Amendment 103) Table 7.1-1 to include RG 1.75 Rev. 3 for WBN2 Common Q PAMS and the Sorento Containment High Radiation monitor.

The Common Q PAMS was designed to meet the requirements of RG 1.75 Rev. 2. WBN2 did not perform an analysis to RG 1.75 Rev. 3. Based upon the review of this item, the staff finds the following open item:

2 TVA to evaluate Common Q PAMS and the Sorento Containment High Radiation monitor for conformance with RG 1.75 Rev. 3.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 366 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff 81.

position.

By letter dated 2/25/11 (ML110620219), TVA docketed a response: TVA stated that the Common Q PAMS equipment fully meets the RG 1.100 Rev. 0 and is compliant with Rev. 3, with exception of testing above 33 Hz, which is not applicable to Watts Bar.

The WBN2 FSAR (Amendment 103) references Regulatory Guide 1.100 Rev. 1 Seismic Qualification of Electrical Equipment for EICB (Carte)

Nuclear Power Plants. The Common Q PAMS was designed to meet the requirements of RG 1.100 Rev. 2. RG 1.100 Rev. 3 is the current revision of this guide and is endorsed by the NRC. RG 1.100 Rev. 3 endorses IEEE 344-2004.

Based upon the review of this item, the staff finds the following open item:

1 TVA to updated FSAR (Amendment 103) Table 7.1-1 to include RG 1.100 Rev. 3 for WBN2 Common Q PAMS and the Sorento Containment High Radiation monitor.

or 2 TVA to evaluate Common Q PAMS for conformance with RG 1.100 Rev. 1.

367 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff 81.

position.

By letter dated 2/25/11 (ML110620219), TVA docketed a response.

The WBN2 FSAR (Amendment 103) references RG 1.153 Rev. 0, Criteria for Safety Systems. The Common Q PAMS is designed to meet the requirements of RG 1.153 Rev. 1. By letter dated February 25, 2010 (ML110620219), TVA stated:

The subject Regulatory Guides [RG 1.153 Rev. 0 & 1]

endorse and reference other standards. Common Q PAMS EICB (Carte) has been evaluated to comply with the requirements of these other endorsed standards ([Comparison report in this letter titled IEEE-279-1971 to IEEE-603-1991 Comparison]).

Therefore no additional analysis needs to be performed and no further action is necessary.

However, the Comparison report in this letter titled IEEE-279-1971 to IEEE-603-1991 Comparison, stated:

The first of the two standards, IEEE-279, is part of the design basis of WBN2 but is not relevant to Common Q PAMS. The second standard, IEEE-603-1991 is not part of the design basis for the Common Q PAMS forWBN2.

Based on the reasoning quoted above, WBN2 did not evaluate the Common Q PAMS against the criteria of RG 1.153 Rev. 1; therefore, the staff finds the following open item (see also Open Items No. 1 & 2 above.):

1 TVA to evaluate Common Q PAMS for conformance with RG 1.153 Rev. 1.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 368 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff 81.

position.

By letter dated 2/25/11 (ML110620219), TVA docketed a response.

The WBN2 FSAR (Amendment 103) references RG 1.152 Rev. 0, Criteria for Digital Computers in Safety Systems of Nuclear Power Plants. The Common Q PAMS was designed to meet the EICB (Carte) requirements of RG 1.152 Rev. 1. RG 1.152 Rev. 2 is the current revision of this guide and is endorsed by the NRC. By letter dated February 25, 2010 (ML110620219), TVA stated:

RG 1.152 rev 2 endorses ANSI/IEEE-ANS-7-4.3.2-2003, but also provides extra regulatory guidance concerning computer based cyber security. Since this revision was not part of the design basis of WBN2 or Common Q PAMS, the project makes no commitment to the compliance of RG 1.152 rev 2.

Based upon the review of this item, the staff finds the following open item:

1 TVA to evaluate Common Q PAMS for conformance with RG 1.152 Rev. 2.

369 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff 81.

position.

By letter dated 2/25/11 (ML110620219), TVA docketed a response.

The WBN2 FSAR (Amendment 103) references IEEE 7-4.3.2-1982, "IEEE Standard Criteria for Digital Computers in Safety EICB (Carte)

Systems of Nuclear Power Generating Stations" as endorsed by Regulatory Guide (RG) 1.152, "Criteria for Use of Computers in Safety Systems of Nuclear Power Plants," Revision 0 for the Eagle 21 system. The current regulatory position is documented in RG 1.152 Rev. 2 which endorses IEEE Std 7-4.3.2-2003 as an acceptable method for using digital computers to meet IEEE Std 603-1991. Based upon the review of this item, the staff finds the following open item:

1 WBN2 to updated FSAR Table 7.1-1 to reference IEEE 7-4.3.2-2003 as being applicable to WBN2 Common Q PAMS and the Sorento Containment High Radiation monitor.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 370 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff 81.

position.

By letter dated 2/25/11 (ML110620219), TVA docketed a response.

The WBN2 FSAR (Amendment 103) does not reference RG 1.168, EICB (Carte)

IEEE 1012, or IEEE 1028. IEEE Std 7-4.3.2-2003 indentifies IEEE Std 1012-1998 as normative. RG 1.168 Rev. 1 endorses, with clarifications, IEEE 1012-1998. The current staff positions are documented in RG 1.168 Rev. 1, IEEE 1012-1998, and IEEE 1020-1997. Based upon the review of this item, the staff finds the following open item:

1 WBN2 to updated FSAR Table 7.1-1 to reference RG 1.168 Rev. 1, IEEE 1012-1998, and IEEE 1020-1997 as being applicable to WBN2 Common Q PAMS and the Sorento Containment High Radiation monitor.

371 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff 81.

position.

By letter dated 2/25/11 (ML110620219), TVA docketed a response.

The WBN2 FSAR (Amendment 103) does not reference Regulatory Guide 1.209, Guidelines for Environmental EICB (Carte)

Qualification of Safety-Related Computer-Based Instrumentation and Control Systems in Nuclear Power Plants. Based upon the review of this item, the staff finds the following open item:

1 WBN2 to updated FSAR Table 7.1-1 to reference RG 1.209 and IEEE Std. 323-2003 as being applicable to WBN2 Common Q PAMS and the Sorento Containment High Radiation monitor.

TVA did not docket an evaluation against the criteria in RG 1.209.

Based upon the review of this item, the staff finds the following open item:

2 WBN2 to evaluate Common Q PAMS for conformance with RG 1.209 and IEEE Std. 323-2003.

372 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff 81.

position.

By letter dated 2/25/11 (ML110620219), TVA docketed a response.

EICB (Carte)

The requirements in the SysRS and SRS are not traceable back to the design basis (e.g., IEEE Std 603-1991 Section 4) for the system. The SRS does not include any documented evidence that it was ever independently reviewed in accordance with the 10CFR50 Appendix B Criterion III, Design Control. (Note: It appears that the only Common Q or WBN2 PAMS document that was independently reviewed in accordance with 10 CFR 50 Appendix B requirements is the SysRS.)

Based upon the review of the SysRS and SRS, the staff finds that there is reasonable assurance that the systems fully conform to the

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad4A2A9.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N applicable guidelines, except for the following open items:

1 TVA to produce an acceptable description of how the SysRS and SRS implement the design basis requirements of IEEE 603-1991 Clause 4.

2 TVA to produce a final SRS that is independently reviewed in accordance with 10CFR50Appendix B, Criterion III Design Control, requirements.

373 7.5.2. 7.5 The SDDs do not include any documented evidence that they were 2 independently reviewed in accordance with the 10CFR50 Appendix B Criterion III, Design Control.

EICB (Carte)

Based upon the review of the SDDs, the staff the following open item:

1 TVA to produce final SDDs that are independently reviewed in accordance with 10 CFR50 Appendix B Criterion III, Design Control, requirements.

374 7.5.2. 7.5 By letter dated October 29, 2010 (ML103120711), TVA docketed a 2 draft technical evaluation associated with an engineering design change (ML103120712) that states the Common Q PAMS will EICB (Carte) require changes in the technical specifications. The technical specifications (TS) have not be received yet for review. The TS will be reviewed once they are received.

1 Proposed Technical Specification changes associated with Common Q PAMS are acceptable.