ML120720062
| ML120720062 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/20/2012 |
| From: | Joseph Sebrosky Plant Licensing Branch IV |
| To: | Pacific Gas & Electric Co |
| Sebrosky J, NRR/DORL/LPL4, 415-1132 | |
| References | |
| TAC ME7522, TAC ME7523 | |
| Download: ML120720062 (28) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555..(1001 l\\1arch 20, 2012 LICENSEE:
Pacific Gas and Electric Company FACILITY:
Diablo Canyon Power Plant, Unit Nos. 1 and 2
SUBJECT:
SUMMARY
OF MARCH 7, 2012, TELECONFERENCE MEETING WITH PACIFIC GAS AND ELECTRIC COMPANY ON DIGITAL REPLACEMENT OF THE PROCESS PROTECTION SYSTEM PORTION OF THE REACTOR TRIP SYSTEM AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEM AT DIABLO CANYON POWER PLANT (TAC NOS. ME7522 AND ME7523)
On March 7, 2012, a Category 1 teleconference public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Pacific Gas and Electric Company (PG&E, the licensee) at NRC Headquarters, One White Flint North, 11555 Rockville, Maryland. The purpose of the teleconference meeting was to discuss the license amendment request (LAR) submitted by PG&E on October 26, 2011, for the Digital Replacement of the Process Protection System (PPS) Portion of the Reactor Trip System and Engineered Safety Features Actuation System at Diablo Canyon Power Plant, Unit Nos. 1 and 2 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML113070457). A list of attendees is provided in Enclosure 1.
Preliminary issues that the NRC staff identified during its initial review and the licensee's responses to these preliminary issues were discussed during the teleconference meeting. The list of preliminary issues is provided in Enclosure 2. The first nine issues found in Enclosure 2 are the issues that were identified in the NRC's acceptance review letter for the PPS LAR dated January 13, 2012 (ADAMS Accession No. ML120120005). In the acceptance review letter, the staff indicated that it was expecting a written response to these issues within 60 days. Based on the discussions during the meeting and the licensee's preliminary responses to the first nine issues found in Enclosure 2, the staff determined that the licensee should formally respond to these issues by March 29, 2012. The licensee agreed to this new schedule.
The NRC staff indicated that it intends to have phone calls every 2 weeks with the licensee to discuss issues and the status of the review. These future phone calls will continue to be noticed as public meetings. The staff expects that these phone calls will be held for the next several months. The issues found in Enclosure 2 will be updated to reflect the status of the staff's review and will serve as the agenda for these publicly noticed phone calls. This process is similar to the process that was followed for the Watts Bar Unit 2 digital instrumentation and control review. At an appropriate time, the staff will issue requests for additional information based on these interactions with the licensee.
- 2 Please direct any inquiries to me at 301-415-1132 or at.:;.Jo;;.ost=-=e=.:...:==.:...:=-"..,.,~;;,o:a;~
h M. Se ros 4£.J;ijill.IQ.I:.JFlfO) lant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323
Enclosures:
- 1. List of Attendees
- 2. Staff identified issues cc w/encls: Distribution via Listserv
LIST OF ATTENDEES MARCH 7. 2012. TELECONFERENCE MEETING WITH PACIFIC GAS AND ELECTRIC COMPANY REGARDING DIABLO CANYON POWER PLANT DIGITAL UPGRADE DOCKET NO. 50-273 AND 50-323 NAME Ken Schrader Scott Patterson Bob Lint John Hefler Edward Quinn J. Basso Warren Odess-Gillett Roman Shaffer Bill Kemper Rich Stattel Bernard Dittman Rossnyev Alvarado Joe Sebrosky James Byam Gordon Clefton ORGANIZATION Pacific Gas and Electric Pacific Gas and Electric Altran Altran Altran Westinghouse Westinghouse Invensys U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Exelon Nuclear Energy Institute
001 March 6, 12 DCPP PPS Open Item Summary Table Page 1 of 24 RAI RAI No.
Response
(Date (Due No PG&E response:
Status SrclRI Issue Description Sent)
Date)
Comments Open AR
[ISG-06 Enclosure B, Item 1.3] Deterministic Nature of Software:
N/A (BD)
The Diablo Canyon Specific Application should identify the board access sequence and provide corresponding analysis associated with digital response time performance. This analysis should be of sufficient detail to enable the NRC staff to determine that the logic-cycle;
- a. has been implemented in conformance with the ALS Topical Report design basis,
- b. is deterministic, and
- c. the response time is derived from plant safety analysis performance requirements and in full consideration of communication errors that have been observed during equipment qualification.
As stated in the LAR, information pertaining to response time performance will be submitted as a Phase 2 document. Please ensure this matter is addressed accordingly.
PG&E response:
ALS Diablo Canyon PPS document 6116-00011, "ALS System Design Specification", Section 7.5, identifies the ALS board access sequence and provides an analysis associated with digital response time performance.
a) The Diablo Canyon PPS ALS system is configured in accordance with the qualification requirements of the ALS platform topical report, b) The analysis in Diablo Canyon PPS document 6116-00011, "ALS System Design Specification", Section 7, describes a logic cycle that is deterministic.
c) The requirements for the response time of the PPS processing instrumentation (from input conditioner to conditioned output signal) is specified as not to exceed 0.409 seconds in Section 3.2.1.10 of the "Diablo Canyon Power Plant Units 1 & 2 Process Protection System Replacement Functional Requirements Specification (FRS)", Revision 4 submitted as Attachment 7 of the LAR. In Section 1.5.8 of the "Diablo Canyon Power Plant Units 1 & 2 Process Protection System Replacement Interface Requirements Specification (IRS)", Revision 4, submitted as of the LAR, the 0.409 seconds PPS processing
March 6, 12 DCPP PPS Open Item Summary Table Page 2 of 24 No SrclRI Issue Description PG&E response:
Status RAI No.
(Date Sent)
Response
(Due Date)
Comments The staff will likely need the Tricon time response calc's submitted on the docket. It is not efficient for the staff to travel to a remote facility to audit SP calc's.
PG&E stated that they will provide the Tricon Time response calc's in a document submitted on the docket.
instrumentation response time is allocated between the ALS and Tricon as follows:
ALS:
Tricon:
Contingency:
175 ms for RTD processing 200 ms 34 ms The 0.409 seconds PPS processing instrumentation value is the same as the value that is currently allocated to PPS processing instrumentation. As long as the 0.409 second PPS processing instrumentation value is not exceeded, the total response time values assumed in the plant safety analyses contained in FSAR Table 15.1-2 will not be exceeded; 7 seconds for Overtemperature
~T RT and Overpower ~T RT functions, 2 seconds for High pressurizer pressure RT, Low pressurizer pressure RT, and Low Low SG water level RT functions, 1 second for Low reactor coolant flow RT function, 25 seconds for Low pressurizer pressure, High containment pressure, and Low steam line pressure Safety Injection initiation, 60 seconds for Low low SG water level auxiliary feedwater initiation, 18 seconds for High containment pressure, Low pressurizer pressure, and Low steam line pressure Phase A containment isolation, 48.5 seconds for High High containment pressure containment spray initiation, 7 seconds for High High containment pressure steam line isolation, 66 seconds for High High SG water level auxiliary feedwater isolation, and 8 seconds for Low steam line pressure steam line isolation.
The ALS response time will be verified as part of the FAT and the results will be included in the FAT summary report to be submitted by 12/31/12.
Tricon Invensys provided detailed information on the deterministic operation of the V10 Tricon in Invensys Letter No. NRC V10-11-001, dated January 5,2011.
In support of the V1 0 Tricon safety evaluation, Invensys submitted document 9600164-731, Maximum Response Time Calculations, describing the worst case response time for the V1 0 Tricon Qualification System. Included in document 9600164-731 are the standard equations for calculating worst-case response time of a given V1 0 Tricon configuration. The time response calculation for the V1 0 Tricon PPS Replacement architecture will be submitted by April 16, 2011. The System Response Time Confirmation Report, 993754
S Tabl P
3 of 2 No SrclRI Issue Description PG&E response:
Status RAI No.
(Date Sent)
Response
(Due Date)
I Comments 1-818, will be submitted to the staff as part of the ISG-06 Phase 2 submittals at the completion of factory acceptance testing of the V1 0 Tricon PPS Replacement.
The Tricon response time will be verified as part of the FAT and the results will be included in the FAT summary report to be submitted by 12/31/12.
I I
I I
PG&ENV/ALS will provide a more detailed description in the next update to this response, of the changes planned to address this 01.
Specifically, it was I
agreed that the correct V&V reporting structure would be described in the updated I
response.
[ISG-06 Enclosure B, Item 1.4]
Software Management Plan: Regulatory Guide (RG) 1.168, Revision 1, "Verification, Validation, Reviews and Audits for Digital Computer Software Used in Safety Systems of Nuclear Power Plants," dated February 2004 endorses IEEE (Institute of Electrical and Electronics Engineers) 1012-1998, "IEEE Standard for Software Verification and Validation," and IEEE 1028 1997,"IEEE Standard for Software Reviews and Audits," with the exceptions stated in the Regulatory Position of RG 1.168. RG 1.168 describes a method acceptable to the NRC staff for complying with parts of the NRC's regulations for promoting high functional reliability and design quality in software used in safety systems. Standard Review Plan(SRP) Table 7-1 and Appendix 7.1-A identify Regulatory Guide 1.168 as SRP acceptance criteria for reactor trip systems (RTS) and for engineered safety features Westinghouse/ALS 6116-00000 Diablo Canyon PPS Management Plan, Figure 2-2, shows the Verification and Validation (V&V) organization reporting to the Project Manager. This is inconsistent with the information described in the ALS Management Plan for the generic system platform, where the V&V organization is independent form the Project Manager. This is also inconsistent with the criteria of RG 1.168 and will need to be reconciled during the LAR and ALS L TR reviews.
Open N/A PG&E response:
ALS The PPS Replacement LAR referenced Westinghouse document 6116-00000 Diablo Canyon PPS Management Plan, dated July 25, 2011, that was based on CSI document 6002-00003 ALS Verification and Validation Plan, Revision
- 4. CS Innovations subsequently submitted a revised V&V plan, "6002-00003 ALS Verification and Validation Plan", Revision 5, on November 11, 2011, that revised the required V&V organization structure such that the management of the verification personnel is separate and independent of the management of
Tabl March 6. 12 DCPP PPS 0.- - -- ItemS -- - -- - - --- #
Response
(Date (Due No SrclRI Issue Description PG&E response:
Status Sent)
Date)
Comments the development personnel. The Westinghouse 6116-00000 Diablo Canyon PPS Management Plan is being revised to require a V&V organization structure in which the management of the verification personnel is separate and independent of the management of the development personnel. PG&E will submit the revised Westinghouse 6116-00000 Diablo Canyon PPS Management Plan document by TBD.
[ISG-06 Enclosure B, Item 1.9]
Open 3
N/A (RA)
Software V&V Plan: The ALS V&V plan states that Project Manager of the supplier is responsible for providing directions during implementation of V&V activities. Also, the organization chart in the Diablo Canyon PPS Management Plan shows the IW manager reporting to the PM.
The ALS V&V plan described in ISG6 matrix for the ALS platform and the Diablo Canyon PPS Management Plan do not provide sufficient information about the activities to be performed during V&V. For example, the ALS V&V Plan states that for project specific systems, V&V activities are determined on a project by project basis and are described in the project Management Plan, in this case, 6116-00000, "Diablo Canyon PPS Management Plan." However, the 6116-00000 Diablo Canyon PPS Management Plan states: "See the ALS V&V Plan for more information and the interface between the IV&V team and the PPS Replacement project team."
PG&EIW/ALS will scope for V&V activities. As mentioned before, the Triconex EPP is not listed The Triconex V&V plan states that the Engineering Project Plan defines the provide a more in the ISG6 matrix.
detailed description in the next update to These items will need further clarification during the LAR review to this response, of the demonstrate compliance with Regulatory Guide (RG) 1.168, Revision 1, changes planned to "Verification, Validation, Reviews and Audits for Digital Computer Software address this 01.
Used in Safety Systems of Nuclear Power Plants."
Scope ofV&V PG&E response:
activities to be performed is to be ALS defined.
I The Westinghouse 6116-00000 Diablo Canyon PPS Management Plan is being revised to include details on how the IV&V team has an independent I
organizational reporting structure from the design and implementation team; the Scottsdale Operations Director and the ALS Platform & Systems Director
March 6, 12 DCPP PPS Open Item Summary Table Page 5 of 24 No SrclRI I Issue Description PG&E response:
Status RAI No.
(Date Sent)
Response
(Due Date)
Comments report to different Westinghouse Vice Presidents. The IW Manager and Scottsdale Operations Director both report to the same Westinghouse Vice President, but via independent reporting structures.
Description of 6116-00000 Diablo Canyon PPS Management Plan V&V activity updates - IN PROGRESS PG&E will submit the revised Westinghouse 6116-00000 Diablo Canyon PPS Management Plan that includes the above changes by TBD.
Tricon The organizational structure of Invensys Operations Management comprises, in part, Engineering and Nuclear Delivery. Each of these organizations plays a specific role in the V1 0 Tricon application project life cycle. Invensys Engineering is responsible for designing and maintaining the V1 0 Tricon platform, and Nuclear Delivery is responsible for working with nuclear customers on safety-related V1 0 Tricon system integration projects. Invensys Engineering department procedures require "Engineering Project Plans (EPP)," whereas Nuclear Delivery department procedures require "Project Plans." Invensys Engineering is not directly involved in system integration, but Nuclear Delivery may consult with Engineering on technical issues related to the V1 0 Tricon platform.
The NRC applied ISG-06 to the V1 0 Tricon safety evaluation. Invensys submitted a number of documents pertaining to the design of the V1 0 Tricon platform as well as process and procedure documents governing Invensys Engineering activities, including the EPP. In most cases, these platform related documents are preceded with document number 9600164. The platform-level documents reviewed by the staff during the V1 0 Tricon safety evaluation will not be resubmitted by Nuclear Delivery during application specific system integration projects.
In support of the PG&E LAR for the DCPP PPS Replacement, Invensys Nuclear Delivery is required to submit the application design documents as defined in ISG-06. These project documents are preceded by document number 993754. The Phase 1 submittal under Invensys Project Letter 993754-026T, dated October 26, 2011, contained, in part, the following :
I nvensys believes these documents satisfy these requirements. The staff will review and confirm-N RC Action: TBD.
March 6. 12 DCPP PPS 0.- --- Item 5 ---------.1 Tabl P
6 of 24 No SrclRI
~
Issue Description PG&E response:
PPS Replacement Project Management Plan (PMP), 993754-1-905.
"Project Management Plan" was used to more closely match BTP 7-14 with regard to "management plans"; and PPS Replacement Software Verification and Validation Plan (SWP),
993754-1-802.
Status RAI No.
(Date Sent)
Response
(Due Date)
Comments The PMP describes the PPS Replacement Project management activities within the Invensys scope of supply. The guidance documents BTP 7-14 and NUREG/CR-6101 were used as input during development of the PMP.
With regard to compliance with RG 1.168, the PPS Replacement PMP and SWP both describe the organizational structure and interfaces of the PPS Replacement Project. The documents describe the Nuclear Delivery (ND) design team structure and responsibilities, the Nuclear Independent Verification and Validation (IV&V) team structure and responsibilities, the interfaces between ND and Nuclear IV&V, lines of reporting, and degree of independence between ND and Nuclear IV&V. In addition, the PMP describes organizational boundaries between Invensys and the other external entities involved in the PPS Replacement project: PG&E, Altran, Westinghouse, and Invensys suppliers. The combination of the PMP and SWP demonstrate compliance of the Invensys organization with RG 1.168.
[ISG-06 Enclosure B, Item 1.10]
Software Configuration Management Plan: The LAR includes PG&E CF2.ID2, "Software Configuration Management for Plant Operations and Operations Support," in Attachment 12. However, the document provided in Attachment 12 only provides a guideline for preparing Software Configuration Management (SCM) and SQA plans. Though it is understood that the licensee will not perform development of software, PGE personnel will become responsible for maintaining configuration control over software upon delivery from the vendor.
Open N/A The staff requires the actual plan to be used by the licensee for maintaining configuration control over PPS software in order to evaluate against the acceptance criteria of the SRP. For example, the ALS Configuration Management (CM) Plan (6002-00002) describes initial design activities related to ALS generic boards. This plan does describe the configuration management activities to be used for the development and application of the
Tab P
7 of No SrclRI Issue Description PG&E response:
Status RAINo.
(Date Sent)
Response
(Due Date)
Comments ALS platform for the Diablo Canyon PPS System. The staff requires that configuration management for this design be described in the DCPP project specific plan. These items will need further clarification during the LAR review to demonstrate compliance with BTP-14.
PG&E response:
PG&E will develop a SyCMP procedure to address configuration control after shipment of equipment from the vendor and will submit the document by May 31,2012.
[ISG-06 Enclosure B, Item 1.11]
Software Test Plan: The V10 platform documents identified in ISG6 matrix state that the interface between the NGIO (Next Generation Input Output)
Core Software and 10-specific software will not be tested. It is not clear when and how this interface will be tested, and why this test is not part of the software unit testing and integration testing activities.
Further, the 993754-1-813 Diablo Canyon Triconex PPS Validation Test Plan states that the DCPP's TSAP will not be loaded on the system; instead Triconex will use another TSAP for the validation test. It is not clear why the DCPP's TSAP will not be used for the validation test or when the DCPP's TSAP will be loaded on the system and validated for the Diablo Canyon PPS System. These items will need further clarification during the LAR review to demonstrate compliance with BTP-14.
Open N/A NGIO Core software is tested and qualified as a platform component.
As such, it does not need to be separately tested during the application development process.
TSAP is a Test Specimen Application Program used for purposes of platform qualification.
Invensys stated that The Diablo Canyon Application will be loaded onto plant PG&E response:
Tricon The next-generation input/output (I/O) modules qualified for the V1 0 Tricon are the 3721 N 4-20 mA, 32-point analog input (AI) module, and the 3625N 24 Vdc, 32-point digital output (DO) module. Technical data on these two modules was provided to the NRC in support of the V10 Tricon safety evaluation. Configuration and functional testing is performed when the I/O modules (hardware and embedded core firmware) are manufactured. From the factory the I/O modules are shipped to Invensys Nuclear Delivery for use in nuclear system integration projects, i.e., application specific configurations.
Because the module hardware and embedded core firmware are within the scope of the V1 0 Tricon safety evaluation, the verification and validation of the
March 6, 12 DCPP PPS Open Item Summary Table Page 8 of 24 RAI RAI No.
Response
(Date (Due No SrclRI I Issue Description PG&E response:
Status Sent)
Date)
Comments embedded core firmware will not be repeated as part of application-specific system integration projects.
There are certain design items that must be done with TriStation 1131 (TS1131), such as specifying which 1/0 module is installed in a particular physical slot of the Tricon chassis, resulting in each module having a unique hardware address in the system. Also, TS1131 is used to specify which application program parameters (i.e., program variable tag names) are assigned to a particular point on a given 1/0 module. The design items configured in TS1131 will be within the scope of validation activities conducted by Invensys Nuclear IV&V for application-specific system integration projects.
The necessary collateral (system build documents, configuration tables, test procedures, test results, etc.) will be submitted to the NRC to support the staff's technical review of the PPS Replacement LAR in accordance with ISG
- 06.
The Phase 1 submittal under Invensys Project Letter 993754-026T, dated October 26, 2011, contained, in part, the Validation Test Plan (VTP), 993754 1-813. This document describes the scope, approach, and resources of the testing activities that are required for validation testing of the V1 0 Tricon portion of the PPS Replacement, including:
Preparing for and conducting system integration tests Defining technical inputs to validation planning Defining the test tools and environment necessary for system validation testing
- Scheduling (and resource loading of the schedule)
Section 1.3.2 of the VTP describes the Hardware Validation Test activities and Section 1.3.3 of the VTP describes the V1 0 Tricon portion of the Factory Acceptance Test activities for the V10 Tricon portion of the PPS Replacement.
Details on the application program are proprietary and need to be provided to the staff separately.
system hardware during FAT.
Staff will re-examine Invensys doc.
"Validation Test Plan (VTP), 993754-1 813," Section 1.3.2 of the VTP that describes the Hardware Validation T est activities and Section 1.3.3 of the VTP to determine that this 01 is addressed. NRC Action: TBD 6
[ISG-06 Enclosure 8, Item 1.14]
Equipment Qualification Testing Plans - The LAR Sections 4.6,4.10.2.4 and 4.11.1.2 provide little information on the plant specific application environmental factors. The Tricon V10 Safety Evaluation, ML11298A246,
h6 DC S
S Tabl 9 of 24
~
~
~
No SrclRI Issue Description PG&E response:
Status RAI No.
(Date Sent)
Response
(Due Date)
Comments Section 6.2 lists 19 application specific actions Items (ASAl's) that the licensee should address for plant specific applications. The licensee should address each of these for Tricon portion of the PPS replacement. Similar information for the ALS portion of the PPS replacement will also be required.
PG&E response:
ALS PG&E will respond to ALS ASAl's when they are available.
Tricon IN PROGRESS. All of the Application Specific Action Items will be addressed by March 21 2012.
ASAI1 As noted in Section 2.1, 10M also submitted the Nuclear Safety Integration Program Manual (NSIPM). The NSIPM governs application specific development activities that occur at 10M's facility. The NRC staff reviewed this document, but made no safety determinations and it is not approved by this SE. It is an ASAI for the NRC staff to perform a review of any application specific development activities governed by the NSIPM when requesting NRC approval for the installation of a SR system based on the Tricon V1 0 platform.
PG&E response:
For the Diablo Canyon Power Plant (DCPP) Process Protection System (PPS)
Replacement Project, Invensys Operations Management (Invensys) will provide the documents listed in Interim Staff Guidance 6 (ISG-06).
Documents generated by Invensys Nuclear Delivery for the PPS Replacement Project will be preceded by 993547. See Invensys document 993754-1-905, Project Management Plan, for details on the project-specific document number scheme. Document 993754-1-905 was enclosed in Invensys Project Letter 993754-26T, dated October 26, 2011, to the NRC.
ASAI2 IN PROGRESS ASAI3
Tabl P
10 of 24
RAI RAINo.
Response
(Date (Due Issue Description PG&E response:
Status No SrclRI Sent)
Date)
Comments IN PROGRESS ASAI4 Section 3.1.3.2 of this SE discusses the use of the TriStation 1131. That section noted that the Tricon V1 0 PLC system is designed such that the Tricon PLC system should not be connected to a TriStation PC during SR operation. The plant-specific procedures which ensure that the TriStation PC is not connected to the Tricon PLC system during SR operation will be reviewed by the NRC staff when an applicant requests NRC approval for the installation of a SR system based on the Tricon V10 platform. In addition, the testing of the operational software produced by the TriStation 1131, and these test plans, procedures, and results will be reviewed by the NRC staff when an applicant requests NRC approval for the installation of a SR system based on the Tricon V1 0 platform.
PG&E response:
By Invensys Letter NRC-V10-12-002, dated February 7,2012, Invensys provided comments to the staff on the draft V1 0 Tricon Safety Evaluation Report (SER), including this ASAI 4. Invensys comments stated that Invensys places no restrictions on duration of the connection of the computer with TS1131 installed to the V10 Tricon. This is because TS1131 has no affect on the TriStation Application Program (TSAP) executing on the V1 0 Tricon when the key switch is in RUN. The V1 0 Tricon rejects all programming messages from TS1131 while in RUN mode. The operating mode of the V1 0 Tricon is not changed by TS 1131. The operating mode of the V1 0 Tricon is changed by the key switch to PROGRAM to allow accepting the programming messages from TS 1131. For the PPS Replacement Project, the TS 1131 TSAP will include an alarm output for the operator when the V1 0 Tricon key switch is not in RUN. A combination of physical access controls and administrative controls will be utilized by PG&E during TSAP changes. See Invensys response to ASAI 19 for additional technical details on the key switch.
The Invensys NSIPM describes the Invensys nuclear system integration process, while the Invensys Project Procedures Manual (PPM) contains the set of implementing procedures. For the PPS Replacement project, Invensys will generate the necessary test documentation to satisfy the guidance I
1
- f
~
No SrclRI Issue Description PG&Eresponse:
Status RAI No.
(Date Sent)
Response
(Due Date)
I Comments contained in ISG-06, including, but not limited to, test plans, test procedures, and test reports for TSAP software verification and V1 0 Tricon PPS Replacement validation activities. Furthermore, the documentation will be made available to the staff for review in accordance with ISG-06, whether as submittals to support the LAR review or as audit items. Invensys document 993754-1-905, Project Management Plan, discusses the documents and their purpose that will be generated for the V1 0 Tricon portion of the PPS Replacement Project. Document 993754-1-905 was enclosed in Invensys Project Letter 993754-26T, dated October 26, 2011, to the NRC.
ASAI5 Section 3.2 of this SE discusses verification and validation. Although 10M did not strictly follow guidelines of IEEE Std 1012, the NRC staff determined that the combination of the internal 10M review, the TOV certification, and the review by independent consultants provided acceptable verification and validation for software that is intended for SR use in nuclear power plants.
However, the NRC staff noted that a significant portion of its acceptance is predicated upon the independent review by TOV-Rheinland, and licensees using any Tricon PLC system beyond V10.5.1 must ensure that similar or equivalent independent V&V is performed; without this, the Tricon PLC system will not be considered acceptable for SR use at nuclear power plants.
Should licensees use future Tricon PLC systems beyond V1 0.5.1 which have not received TOV-Rheinland certification, the NRC staff will review the acceptability of the independent V&V during the plant-specific safety evaluation.
PG&E response:
The Invensys Nuclear Qualified Equipment List (NQEL) shows those products that have been qualified by Invensys under its approved 10 CFR Part 50 Appendix B program for nuclear safety-related applications. For the V10 Tricon specifically, before a given release (e.g., 10.5.1) can be put on the NQEL it must first be certified by TOV in accordance with the Invensys Engineering Department Manual (EDM). The Invensys EDM was reviewed by the staff during the V1 0 Tricon safety evaluation. The PPS Replacement Project will utilize a version of the V1 0 Tricon that is on the Invensys NQEL.
The version used is later than V10.5.1, and Invensys will provide the staff a I
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I
c s
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12 of 2 I
No SrclRI Issue Description PG&E response:
Status RAI No.
(Date Sent)
Response
(Due Date)
Comments Reference Design Change Analysis report in accordance with ISG-06, Section 0.8.2. The number assigned to this document is 993754-1-916. This document will be provided to the staff in May 2012 along with the Phase 2 submittals.
ASAI6 Sections 3.3 and 3.10.2.4 of this SE discuss environmental qualification. EPRI 31 TR-107330, "Generic Requirements Specification for Qualifying a Commercially Available PLC for Safety-Related Applications in Nuclear Power Plants," which was accepted by NRC SE dated July 30, 1998, presents a set of requirements to be applied to the generic qualification of PLCs for application to SR I&C systems in nuclear power plants. It is intended to provide a qualification envelope for a plant-specific application. As noted in section 3.3 of this SE, several EQ tests did not fully meet the acceptance criteria of TR-107330 (e.g., EMC and Seismic Withstand). The licensee must make a determination that the as-tested envelope bounds the requirements of the specific application. Also, licensees must verify that the maximum test voltages cited in Section 3.3 envelop the maximum credible voltages applied to Non-Class 1 E interfaces at their facility. Furthermore, licensees must provide further testing or mitigations for equipment that does not meet plant specific requirements such as the multi-mode fiber optic cable noted in Section 3.3.1. This determination will be reviewed by the NRC staff when an applicant requests NRC approval for the installation of a SR system based on the Tricon V10 platform.
PG&E response:
Verification of as-tested envelope and maximum test voltages - IN PROGRESS Fiber optic cable Because Invensys does not manufacture fiber optic cables they are procured from third parties. Therefore safety-related applications of the V1 0 Tricon utilizing fiber optic communications will require procurement of qualified fiber optic cables. This will be handled on a case-by-case basis, and thus must be review by the staff for each safety-related application of the V1 0 Tricon. For the PPS Replacement Project in particular, Invensys document 993754-1-914,
f 24
~-
~-
~
~--#
~---
No SrclRI Issue Description PG&E response:
Status RAI No.
(Date Sent)
Response
(Due Date)
Comments System Architecture Description, shows the hardware configuration of the V1 0 Tricon portion of the PPS Replacement. There are two points at which the safety-related equipment is interfacing to non-safety equipment: 1) The connection between the safety-related Primary RXM Chassis and the non-safety Remote RXM Chassis; and 2) The connection between the safety-related Tricon Communications Module (TCM) and the NetOptics Port Aggregator Tap (to allow communications with the non-safety Maintenance Workstation). In both cases the electrical and communications isolation is at the safety-related component (i.e., the Primary RXM Chassis and the TCM, respectively). In both cases the fiber optic cable is performing a non-safety function because it is the medium for non-vital (i.e., non-safety) communications. Therefore, for the PPS Replacement application, the fiber optic cable is not required to be qualified as safety-related. Document 993754-1-914 was enclosed in Invensys Project Letter 993754-26T, dated October 26, 2011, to the NRC.
ASAI7 IN PROGRESS ASAI8 IN PROGRESS ASAI9 IN PROGRESS ASAI10 Section 3.7.2.2 of this SE discusses non-safety I/O connected to a remote RXM chassis. The NRC staff concluded that adequate protection is provided to the safety side I/O bus and the overall safety function. All data received from a non-safety remote RXM must be treated as non-safety data. The licensee must make a determination that adequate isolation is maintained in the design and that no data received from the nonsafety I/O is used to make a safety determination. This determination will be reviewed by the NRC staff when an applicant requests NRC approval for the installation of a SR system based on the Tricon V1 0 platform.
March 6. 12 DCPP PPS 0.- - -- Item S ---------, Tabl
.P-v-14 of 24 No SrclRI Issue Description PG&E response:
PG&E response:
Status RAI No.
(Date Sent)
Response
(Due Date)
Comments For the V1 0 Tricon portion of the PPS Replacement, the TSAP will be developed such that non-safety data from the non-safety I/O will not prevent the safety function when demanded by plant conditions, nor will failures of non-safety I/O points (whether field inputs or non-safety V1 0 Tricon components) prevent the safety function. As with the safety-related portions, the V1 0 Tricon utilizes built-in system diagnostics for the non-safety portions of the V1 0 Tricon system. However, the diagnostics associated with the non-safety portions of the system will not prevent the safety function nor cause spurious trips. The system diagnostics related to the non-safety portions will be provided as alarm outputs (e.g., for use at the non-safety main annunciator system), but will not be used in any TSAP logic for safety-related trip functions.
ASAI11 IN PROGRESS ASAI12 IN PROGRESS ASAI13 IN PROGRESS ASAI14 Section 3.8.1 of this SE discusses the secure development environment. The NRC staff observed elements of the secure development environment during the December, 2010, audit at 10M's Irvine, California facility. The NRC staff also reviewed Sections 4.2 and 5.1 of the V9 SE and find that the previous conclusions still apply. Based on a review of NTX-10-14, Section 3.1,
regarding secure development environment and a comparison to the previously reviewed development environment from the V9 SE combined with direct observations of the current development environment at 10M's facility in Irvine, California, the NRC staff finds that 10M meets the requirements for secure development environment in RG 1.152, Revision 3. The licensee must make a determination that the secure development environment has not changed and confirm that the application secure development environment is
March 6. 12 DCPP PPS 0 r Item 5 Tabl P
15 of 24 I
. -v-No SrclRI Issue Description PG&E response:
the equivalent or otherwise meets the requirements of RG 1.152, Revision 3.
This determination will be reviewed by the NRC staff when an applicant requests NRC approval for the installation of a SR system based on the Tricon V1 0 platform.
Status RAI No.
(Date Sent)
Response
(Due Date)
Comments PG&E response:
Invensys document 993754-1-913, Regulatory Guide 1.152 Conformance Report, for the PPS Replacement Project describes the secure development environment at the Invensys facility at Lake Forest, California. The document describes the secure development environment, including a conformance matrix to Regulatory Guide 1.152. The Lake Forest facility provides enhanced physical access controls to nuclear system integration areas while maintaining the network, personnel, and manufacturing controls that were previously reviewed and approved by the staff for the facility in Irvine, California.
Invensys will gladly support the staff's audit of the Lake Forest facility to confirm Invensys is maintaining its regulatory commitments in 993754-1-913.
Document 993754-1-913 was enclosed in Invensys Project Letter 993754-26T, dated October 26, 2011, to the NRC.
ASAI15 IN PROGRESS ASAI16 IN PROGRESS ASAI17 IN PROGRESS ASAI18 IN PROGRESS ASAI19 7
AR (BK)
[I SG-06 Enclosure B, Item 1.16]
Design Analysis Reports: The LAR does not appear to comply with the SRP Open N/A
March 6, 12 DCPP PPS Open Item Summary Table Page 16 of 24 No SrclRI I Issue Description PG&E response:
Status RAI No.
(Date Sent)
Response
(Due Date)
Comments (ISG-04) regarding the connectivity of the Maintenance Work Station to the PPS. The TriStation V10 platform relies on software to effect the disconnection ofihe TriStation's capability to modify the safety system software. Based on the information provided in the L TR, the NRC staff determined that the Tricon V1 0 platform does not comply with the NRC guidance provided in ISG-04, Highly Integrated Control Rooms Communications Issues, (ADAMS Accession No. ML083310185), Staff Position 1, Point 10, hence the DCPP PPS configuration does not fully comply with this guidance.
In order for the NRC staff to accept this keyswitch function as an acceptable deviation to this staff position, the staff will have to evaluate the DCPP PPS specific system communications control configuration--inciuding the operation of the keyswitch, the software affected by the keyswitch, and any testing performed on failures of the hardware and software associated with the keyswitch. The status of the ALS platform on this matter is unclear at this time and will be resolved as the ALS L TR review is completed.
Moreover, the Tricon V10 system Operational Mode Change (OMC) keyswitch does change operational modes of the 3008N MPs and enables the TriStation 1131 PC to change parameters, software algorithms, etc, related to the application program of the safety channel without the channel or division being in bypass or in trip. As stated in Section 3.1.3.2 of the Tricon V10 SER, the TriStation 1131 PC should not normally be connected while the Tricon V10 is operational and performing safety critical functions. However, it is physically possible for the TriStation PC to be connected at all times, and this should be strictly controlled via administrative controls (e.g., place the respective channel out of service while changing the software, parameters, etc). The LAR does not mention any administrative controls such as this to control the operation of the OMC (operational mode change) keyswitch.
Furthermore, in order to leave the non-safety TriStation 1131 PC attached to the SR Tricon V1 0 system while the key switch is in the RUN position, a detailed FMEA of the TriStation 1131 PC system will be required to ascertain the potential effects this non-safety PC may have on the execution of the safety application program/operability of the channel or division. These issues must be addressed in order for the NRC staff to determine that the DCPP PPS complies with the NRC Staff Guidance provided in Staff Position 1, Point 11. The status of the ALS platform on this point is unclear at this time.
PG&Ellnvensys needs to provide a technical explanation of how the MP3008N processor actually ignores all commands when in RUN-address the items in the 01.
- c
- - - - - - -- - I
No SrclRI Issue Description PG&E response:
PG&E response:
Status RAI No.
(Date Sent)
Response
(Due Date)
Comments Tricon The OMC keyswitch controls only the mode of the V10 Tricon 3008N MPs. In RUN position the 3008N MPs ignore* all commands from external devices, whether WRITE commands from external operator interfaces or program-related commands from TS 1131. Multiple hardware and software failures would have to occur on the V1 0 Tricon (in combination with human-performance errors in the control room and at the computer with TS1131 installed) in order for the application program to be inadvertently reprogrammed. Therefore, there is no credible single failure on the V1 0 Tricon that would allow the safety-related application program to be inadvertently programmed, e.g., as a result of unexpected operation of the connected computer with TS 1131 installed on it.
The above conclusion will be confirmed (for the V1 0 Tricon portion of the PPS Replacement) in the Failure Modes and Effects Analysis, an ISG-06 Phase 2 document planned for submittal to NRC in May 2012. Additionally, Invensys Operations Management will support the staff's review of the hardware and software associated with the OMC keyswitch by making all of the technical data available for audit.
- TS1131 contains function blocks that allow WRITE-access to a limited set of parameters programmed into the application software, but only for a limited duration after which the capability is disabled until WRITE-access is re-enabled. However, without these function blocks programmed into the application program neither the application program nor application program parameters can be modified with the OMC keyswitch in the RUN position.
PG&E 8
AR (RS)
Administrative controls on use of keyswitch will be provided with commitment to include in procedures in response. Note, TS1131 is not used to change setpoints and protection set is inoperable when keyswitch is not in RUN position.
[ISG-06 Enclosure S, Item 1.21]
Setpoint Methodology: The NRC staff understands that a summary of SP Open N/A
c 5
P 18
No SrclRI Issue Description PG&E response:
Status RAINo.
(Date Sent)
Response
(Due Date)
Comments (setpoint) Calculations will be provided in Phase 2, however, section 4.10.3.8 of the LAR also states that PGE plans to submit a separate LAR to adopt TSTF 493. The NRC cannot accept this dependency on an unapproved future licensing action. The staff therefore expects the licensee to submit a summary of setpoint calculations which includes a discussion of the methods used for determining as-found and as-left tolerances. This submittal should satisfy all of the informational requirements set forth in ISG6 section D.9.4.3.8 without a condition of TSTF 493 LAR approval.
PG&E response:
The evaluation of the setpoints for the PPS replacement will need to be performed by Westinghouse in two phases in order to provide sufficient documentation to support 95/95 two-sided uncertainty values for the setpoints.
This is because the NRC staff has been requesting additional information and additional data and analysis to demonstrate that the uncertainties used in the setpoint calculation have been based on a statistically sufficient quantity of sample data to bound the assumed values (to justify the confidence level of the calculation is appropriate) during recent Westinghouse projects involving setpoints. Significant information is required from the transmitter and RTD vendors, that has never been obtained before, to support development of calculations that can support 95/95 two-sided uncertainty values.
The first phase of the evaluation of the setpoints will include evaluation of the PPS replacement setpoints for the Tricon and ALS architecture using expected bounding uncertainty values. A setpoint summary evaluation which includes a discussion of the methods used for determining the as-found and as-left tolerances will be submitted by May 31, 2012. This is a change to the commitment 31 in Attachment 1 to the Enclosure to the PPS Replacement LAR.
The second phase of the evaluation of the setpoints will include development of Westinghouse calculations of the PPS replacement setpoints for the Tricon and ALS architecture using sufficient information from vendors to substantiate that the setpoints are based on 95/95 two-sided uncertainty values. The Westinghouse calculations will be completed by December 31, 2012 and will be available for inspection by NRC staff in Washington DC with support provided by Westinghouse setpoint group personnel. The NRC staff
S Tabl P
19 of 24 RAI No SrclRI Issue Description PG&E response:
Status RAI No.
(Date Sent)
Response
(Due Date)
Comments inspection of Westinghouse calculations in Washington DC has been performed for another recent utility project involving setpoints.
9 AR (BK)
L TR Safety Conclusion Sco!2e and A!2!2licability - Many important sections of the DCPP PPS LAR refer the reader to the ALS licensing topical report (L TR) to demonstrate compliance of the system with various Clauses of IEEE 603 1991, IEEE 7-4.3.2-203, and ISG-04. However, many important sections of the ALS LTR state that compliance with various Clauses of these IEEE Stds and ISG-04 are application specific and refer the reader to an application specific license amendment submittal (i.e., the DCPP PPS LAR in this case).
The staff has not yet had time to evaluate all the LAR information in detail and compare this information with that provided in the ALS L TR to ensure there is no missing information. However, PG&E and its contractors are encouraged to review these two licensing submittals promptly to verify that compliance with these IEEE Stds and ISG-04 are adequately addressed within both licensing documents.
Open N/A PG&E response:
IN PROGRESS, review by Westinghouse and PG&E to date has not found a clause where no justification is provided in LAR.
10 RS Plant Variable PPS Sco!2e - In the Description section of the LAR, section 4.1.3, nine plant variables are defined as being required for RTS and section 4.1.4 lists seven plant variables that are required for the ESFAS. Three additional plant variables were also listed in section 4.10.3.4.
Open 1
Some variables are not listed in section 4.10.3.4 as being PPS monitored plant parameters. It is therefore assumed that these parameters are provided as direct inputs to the SSPS and that the PPS is not relied upon for the completion of required reactor trip or safety functions associated with them.
Please confirm that these plant parameters and associated safety functions will continue to operate independently from the PPS and that the replacement PPS will not adversely impact the system's ability to reliably perform these functions.
PG&E response:
The PPS Replacement LAR Sections 4.1.3 and 4.1.4 describe the plant variables from which RTS and ESFAS protective functions are generated.
March 6, 12 DCPP PPS Open Item Summary Table Page 20 of 24 SrclRI I Issue Description PG&E response:
I Status The initiation signal outputs to the SSPS coincidence logic are generated in the PPS or other, independent systems, or in some cases, by discrete devices. Section 4.1.3 items 6 (RCP bus UF, UV, and breaker position, 8 (Main Turbine trip fluid pressure and stop valve position) and 9 (seismic acceleration) are generated by discrete devices outside the PPS and provide direct contact inputs to the SSPS. Section 1.4 items 6 (Containment Exhaust Radiation) and 7 (RT breaker position Permissive P-4) are also generated outside the PPS and are direct contact inputs to the SSPS. The initiation signals associated with these plant parameters operate independently from the PPS. The replacement PPS will not adversely affect the reliable performance of the safety functions associated with these plant parameters.
No The three Signals (Wide Range RCS Temperature and Pressure and Turbine Impulse Chamber Pressure) not listed in Sections 4.1.3 and 4.1.4 are monitored by the PPS per Section 4.10.3.4. The Wide Range RCS Pressure and Temperature signals are used to generate the L TOP function described in OCPP FSAR Section 5. The PPS uses Turbine Impulse Chamber Pressure to generate an initiation signal that is used by the SSPS coincidence logic to develop Permissive P-13 as discussed in RAI 3, below.
Neutron Flux should be added to Section 4.2 Table 4-2 as follows:
RAI No.
(Date Sent)
Response
(Due Date)
Comments Neutron Flux is an input to Tricon but it is not listed in Table 4-2 "Process Variable inputs to Tricon" Signals not associated with PPS functions will be designated as such in the SE and they will not be described since they are not in scope.
Neutron Flux (Power Input to Overtemperature fj, Temperature (OTDT) RT Range, Upper & Lower)
Input to Overpower fj, Temperature (OPDT) RT RS I Power Range NIS Function -_Section 4.1.7 describes the Existing Power Range N1S Protection Functions and it states that the Power Range nuclear instrumentation provides input to the OTOT, and OPOT protection channels.
It is not entirely clear whether any of the described NIS protection functions will be performed by the PPS system. Please clarify exactly what the role of the PPS system is for these NIS Protection functions.
Closed*
- RAI still needs to be sent.
2 Only PPS Functions will be described in the SE.
11
- 21 of 2 No SrclRI Issue Description PG&E response:
Status RAINo.
(Date Sent)
Response
(Due Date)
Comments PG&E response:
Power range analog inputs are provided by the NIS to each PPS Protection Set for use in the calculation of the Overpower Delta-T Setpoint in the Delta-TlTavg channels. No other NIS signals interface with the PPS. The NIS Protection functions (RT and power range permissives) are generated independently by Nuclear Instrumentation bistable comparators. The NIS bistable outputs are sent directly to the SSPS and have no physical interface with the PPS.
12 RS Permissive Functions - Several Permissive functions are described within the LAR. It is not clear to the staff whether any of these functions are to be performed by the PPS or if the PPS will only be providing input to external systems that in turn perform the permissive logic described in the LAR.
Section 4.1.9 states that "Settings of the bistable comparators used to develop the permissives are not affected by the PPS Replacement Project", which implies that all of these permissive functions are performed by systems other than the PPS. However, it is still unclear if this statement applies to all permissive functions described throughout the LAR or if it applies only to those permissives relating to Pressurizer Pressure. It is also possible that the permissive functions are being performed by the existing PPS and will continue to be performed by the replacement system and therefore remain "not affected" by the PPS replacement project.
Please provide additional information for the following permissive functions to clearly define what the role of the PPS system will be for each.
P-4 Reactor Trip P-6 Intermediate Range Permissive P-7 Low Power Permissive (Bypasses low Ppzr reactor trip)
- P-8 Loss of Flow Permissive P-9 Power Permissive P-10 Power Range Power Low Permissive Open 3
March 6. 12 c
o
Comments The response states generated in the NIS independently from PPS and it states Which is it?
The response states generated in the NIS independently from PPS and it states Which is it?
Is the coincidence of P7 performed as a function of PPS or Is P9 performed as a function of PPS or No SrclRI Issue Description PG&E response:
P-11 Low Pressurizer Pressure SI Operational Bypass P-12 No-Load Low-Low Tave Temperature Permissive P-13 Turbine Low Power Permissive
- P-14 Hi-Hi Steam Generator Level
Permissive function initiation signals generated within the existing PPS will continue to be performed by the replacement PPS and therefore remain "not affected" by the PPS replacement project. Permissive function initiation signals that are generated independently of the existing PPS will continue to be generated independently.
Permissive P6, P-8, P-9, and P-10 initiation signals are bistable comparator outputs from the independent NIS to the SSPS. There is no interface with the PPS.
Permissive P-4 initiation signals are direct contact inputs to the SSPS coincidence logic generated from contacts in the Reactor Trip Breakers (RTB). There is no interface with the PPS.
Permissive P-11, P-12, P-13, and P-14 initiation signals are generated by bistable comparator outputs generated in the PPS and sent to the SSPS.
Permissive P-7 is generated in the SSPS from 3 out of 4 power range NI channels (from NIS - P-1 0) below setpoint and 2/2 turbine impulse chamber pressure channels below setpoint (From PPS - P13).
The bistable initiation signals described above are monitored by the SSPS.
The SSPS generates the Permissive when appropriate coincidence of initiation signals is detected. No SSPS permissive or safety function coincidence logic is changed by the PPS replacement project.
Permissives P-6, P-7, P-8, P-9, P-10, and P-13 are functionally described in FSAR Table 7.2-2. Permissives P-4, P-11, P-12, and P-14 are functionally described in FSAR Table 7.3-3.
The bistable comparator setpoints for the above-listed permissives are not expected to change at this time.
Status RAI No.
(Date Sent)
Response
(Due Date) that P12 is that P12 is generated by the PPS.
that P14 is that P14 is generated by the PPS.
not?
not?
March -,
Tabl 23 of 24
-0::;}
~--------I.
No 13 SrclRI RS Issue Description PG&E response:
P12 Permissive Contradiction - The second paragraph of section 4.1.20 describes the P-12 interlock and states that "These signals are developed in the PPS". This statement is then contradicted in the third paragraph by the following statement; Status Open RAI No.
(Date Sent) 4 RAI
Response
(Due Date)
Comments "These valves are not safety-related, but are interlocked with the P-12 signal from the SSPS."
In conjunction with the response to RA13, please provide a resolution for this contradiction in section 4.1.20 of the LAR.
PG&E response:
The word "signals" in the referenced Section 4.1.20 sentence, "These signals are developed... " is referring to the bistable comparator outputs which are monitored by the SSPS. The PPS does not generate the P-12 Permissive itself. The actual P-12 Permissive is generated by the SSPS when appropriate coincidence of initiation signals is detected. The SSPS output is interlocked with the valves as stated in the third paragraph of Section 4.1.20.
The LAR Section 4.1.20 is clarified by the following statement:
In the response to item 12 it is stated that; Permissive P-12 initiation signal is generated by bistable comparator outputs that are generated by the PPS.
This contradicts the response to item 13.
"... The P-12 Permissive is developed in the SSPS based on coincidence of the P-12 bistable comparator output initiation signals from the PPS...
14 Section 4.1.1 SSPS contains the following statement in the last paragraph; "Information concerning the PPS status is transmitted to the control board status lamps and annunciators by way of the SSPS control board demultiplexer and to the PPS by way of the SSPS computer demultiplexer."
Why would the PPS status need to be transmitted to the PPS as the sentence suggests in the last phrase?
March 6. 12 DCPP PPS 0.- - -- Item 5 ---------,1 Tabl
.P 24 of 24
-~-
No SrclRI Issue Description PG&E response:
PG&E response:
Status RAINo.
(Date Sent)
Response
(Due Date)
Comments The sentence in Section 4.1.1 contains a a typographical error.
should read:
The sentence "Information concerning the PPS status is transmitted to the control board status lamps and annunciators by way of the SSPS control board demultiplexer and to the Plant Process Computer (PPC) by way of the SSPS computer demultiplexer."
As used in the Section 4.1.1. paragraph, "PPS Status" means "PPS Channel Trip Status."
- 2 Please direct any inquiries to me at 301-415-1132 or at Joseph.Sebrosky@nrc.gov.
IRA!
Joseph M. Sebrosky, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323
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