ML121020065
| ML121020065 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/16/2012 |
| From: | Joseph Sebrosky Plant Licensing Branch IV |
| To: | Pacific Gas & Electric Co |
| Sebrosky J, NRR/DORL/LPL4 301-415-1132 | |
| References | |
| TAC ME7522, TAC ME7523 | |
| Download: ML121020065 (33) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 16, 2012 LICENSEE:
Pacific Gas and Electric Company FACILITY:
Diablo Canyon Power Plant, Unit Nos. 1 and 2
SUBJECT:
SUMMARY
OF APRIL 4, 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 April 4, 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.
The teleconference meeting is one in a series of publicly noticed teleconference meetings to be held periodically to discuss issues associated with the NRC staff's LAR review. 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.
It was noted during the meeting that the response to the first nine issues of Enclosure 2 was provided to the NRC staff in a letter dated April 2, 2012 (ADAMS Accession No. ML12094A072).
The nine issues found in Enclosure 2 are the same set of issues that were provided to PG&E in the January 13. 2012, letter from the NRC staff accepting the LAR for review (ADAMS Accession No. ML120120005). The staff indicated that it had not yet had a chance to fully review the responses and further feedback could be provided in future public phone calls. The NRC staff and PG&E determined that because of availability. only one public meeting in May would be scheduled. The staff took an action to issue a meeting notice for a May 16, 2012.
meeting.
- 2 Please direct any inquiries to me at 301-415-1132 or at:.,==c:..:..:.:=.:..:..:~f'S=~~:":'
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 APRIL 4, 2012, TELECONFERENCE MEETING WITH PACIFIC GAS AND ELECTRIC COMPANY REGARDING DIABLO CANYON POWER PLANT DIGITAL UPGRADE NAME Ken Schrader Scott Patterson Bob Lint John Hefler J. Basso W.Odess-Giliet Roman Shaffer Bill Kemper Rich Stattel Rossnyev Alvarado Joe Sebrosky Shiattin Makor Gordon Clefton David White Ken Thompson DOCKET NO. 50-273 AND 50-323 ORGANIZATION Pacific Gas and Electric Pacific Gas and Electric Altran Altran Westinghouse Westinghouse Invensysrrriconex 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 Nuclear Energy Institute Areva Avila Valley Advisory Council
April 2, 12 DCPP PPS Open Item Summary Table Page 1 of 29 No SrclRI Issue Description P&GE response:
Status RAI No.
RAI Comments (Date Sent)
Response
(Due Date) 001 AR
[ISG-06 Enclosure B, Item 1.3] Deterministic Nature of Software:
Open N/A No further (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; discussion necessaQ! until resl;!onse received March 29s 2012.
- a. has been implemented in conformance with the ALS Topical Report desig n basis,
- b. is deterministic, and
Response
- 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.
acceptable; waiting on PG&E to provide the time As stated in the LAR, information pertaining to response time performance will be submitted as a Phase 2 document. Please ensure this matter is response calculation for the addressed accordingly.
V10 Tricon PPS Replacement P&GE response:
ALS Diablo Canyon PPS document 6116-00011, "ALS System Design architecture by April 16, 2012.
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 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 Attachment 8 of the LAR. the 0.409 seconds PPS processing instrumentation response time is allocated between the ALS and Tricon as follows:
April 2, 12 DCPP PPS Open Item Summary Table Page 2 of 29 Issue Description No SrclRI
-~~~~~~~~
P&GE response:
(Date Sent)
Response
(Due Date)
ALS: 175 ms for RTD processing Tricon: 200 ms Contingency: 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 AT RT and Overpower AT 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 12/31112.
Tricon Invensys provided detailed information on the deterministic operation of the V10 Tricon in Invensys Letter No. NRC V1 0-11-001, dated January 5, 2011.
In support of the V10 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 V10 Tricon configuration. The time response calculation for the V10 Tricon PPS Replacement architecture will be submitted by April 16, 2012. The System Response Time Confirmation Report, 993754-1-818, 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 The staff will likely Tricon PPS Replacement.
need the Tricon time response The Tricon response time will be verified as part of the FAT and the results will
April 2, 12 DCPP PPS Open Item Summary Table Page 3 of 29 No SrclRI Issue Description P&GE response:
Status RAI No.
RAI Comments (Date Sent)
Response
(Due Date) be included in the FAT summary report to be submitted by 12/31/12.
002 AR
[ISG-06 Enclosure B, Item 1.4]
(RA)
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 0J&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 Open N/A 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.
No further discussion necessarl until reseonse received March 291 2012.
Response
acceptable; waiting on revised W/ALS PPS MP, which is due on March 29.
2012.
April 2, 12 DCPP PPS Open Item Summary Table Page 4 of 29 No SrciR/
P&GE response:
Status RA/ No.
RA/
Issue Description Comments (Date Sent)
Response
(Due Date)
I~~
reconciled during the LAR and ALS L TR reviews.
P&GE 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 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 March 29, 2012.
[ISG-06 Enclosure 8, Item 1.9]
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."
The Triconex V&V plan states that the Engineering Project Plan defines the Open N/A No further discussion necessa~ until resRonse received March 291 2012.
Status: Fig. 3 of the PPS SWP (Pg. 16/46) indicates sufficient organizational independence between the
April 2, 12 DCPP PPS Open Item Summary Table Page 5 of 29 No SrclRI Issue Description P&GE response:
Status RAI No.
(Date Sent)
RA/
Response
(Due Date)
Comments scope for V&V activities. As mentioned before, the Triconex EPP is not listed in the ISG6 matrix.
These items will need further clarification during the LAR review to demonstrate compliance with Regulatory Guide (RG) 1.168, Revision 1, "Verification, Validation, Reviews and Audits for Digital Computer Software Used in Safety Systems of Nuclear Power Plants,"
Nuclear Delivery (Design)
Organization and the IV&V Organization.
Fig. 3 of the PPS PMP (993754-1 905) (pg. 22/81) also denotes the DCPP PPS project organization, and P&GE response:
ALS The Westinghouse 6116-00000 Diablo Canyon PPS Management Plan is being revised to include details on how the IV&V team has an independent organizational reporting structure from the design and implementation team; the Scottsdale Operations Director and the ALS Platform & Systems Director 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 March 29, 2012.
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 V10 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 V10 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 provides sufficient independence between the NO and IV&V Organizations.
Close the Invensys part of the 01.
W/ALS response acceptable; waiting on revised W/ALS PPS MP, which is due on March 29. 2012.
April 2. 12 DCPP PPS Open Item Summary Table Page 60f29 No SrclRI Issue Description P&GE response:
Status RAI No.
RAI Comments (Date Sent)
Response
(Due Date) issues related to the V10 Tricon platform.
Status: Fig. 3 of the PPS SWP The NRC applied ISG-06 to the V1 0 Tricon safety evaluation. Invensys (Pg.16/46) submitted a number of documents pertaining to the design of the V1 0 Tricon indicates platform as well as process and procedure documents governing Invensys sufficient Engineering activities, including the EPP. In most cases, these platform-organizational related documents are preceded with document number 9600164. The independence platform-level documents reviewed by the staff during the V1 0 Tricon safety between the evaluation will not be resubmitted by Nuclear Delivery during application-Nuclear Delivery specific system integration projects.
(Design)
Organization and In support of the PG&E LAR for the DCPP PPS Replacement, Invensys the IV&V Nuclear Delivery is required to submit the application design documents as Organization.
defined in ISG-OS. These project documents are preceded by document number 993754. The Phase 1 submittal under Invensys Project Letter Fig. 3 of the PPS 993754-026T, dated October 26, 2011, contained, in part, the following:
PMP (993754-1 PPS Replacement Project Management Plan (PMP), 993754-1-905. "Project 905) (pg. 22/81)
Management Plan" was used to more closely match BTP 7-14 with regard to also denotes the "management plans"; and DCPP PPS project PPS Replacement Software Verification and Validation Plan (SWP),
993754-1-802.
organization, and provides The PMP describes the PPS Replacement Project management activities sufficient within the Invensys scope of supply. The guidance documents BTP 7-14 and independence NUREG/CR-6101 were used as input during development of the PMP.
between the ND and IV&V With regard to compliance with RG 1.168, the PPS Replacement PMP and Organizations.
SWP both describe the organizational structure and interfaces of the PPS Replacement Project. The documents describe the Nuclear Delivery (ND)
Close the design team structure and responsibilities, the Nuclear Independent Invensys part of Verification and Validation (IV&V) team structure and responsibilities, the the 01.
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
April 2, 12 DCPP PPS Open Item Summary Table Page 7 of 29 No SrclRI Issue Description P&GE response:
Status RAI No.
RAI Comments (Date Sent)
Response
(Due Date) 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 Open N/A CF2.ID2, "Software Configuration Management for Plant Operations and Operations Support," in Attachment 12. However, the document provided in 2 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.
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 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.
P&GE 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.
April 2,12 DCPP PPS Open Item Summary Table Page 80f29 No SrclRI Issue Description P&GE response:
Status RA/ No.
(Date Sent)
RA/
Response
(Due Date)
Comments 5
[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.
Closed 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 system hardware during FAT.
P&GE response:
Tricon The next-generation input/output (1/0) 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 1/0 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 V10 Tricon safety evaluation, the verification and validation of the 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 (TS 1131), 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
April 2, 12 DCPP PPS Open Item Summary Table Page 9 of 29 No SrclRI Issue Description P&GE response:
Status RAI No.
(Date Sent)
Response
(Due Date)
Comments 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 110 module. The design items Staff re-examined configured in TS1131 will be within the scope of validation activities Invensys doc.
conducted by Invensys Nuclear IV&V for application-specific system "Validation Test integration projects. The necessary collateral (system build documents, Plan (VTP),
configuration tables, test procedures, test results, etc.) will be submitted to 993754-1-813,"
the NRC to support the staff's technical review of the PPS Replacement LAR Section 1.3.2 of the in accordance with ISG-06.
VTP that describes the Hardware The Phase 1 submittal under Invensys Project Letter 993754-026T, dated October 26, 2011, contained, in part, the Validation Test Plan (VTP), 993754 Validation Test activities and 1-813. This document describes the scope, approach, and resources of the Section 1.3.3 of the testing activities that are required for validation testing of the V10 Tricon VTP and portion of the PPS Replacement, including:
determined that the 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) application program TSAP will be used for the FAT (Section 5.1.5 FAT)
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 Close this portion of the 01.
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.
April 2, 12 DCPP PPS Open Item Summary Table Page 10 of 29 No Comments SrclR/
Issue Description RA/ No.
RA/
P&GE response:
Status (Date Sent)
Response
[ISG-06 Enclosure B, 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, Section 6.2 lists 19 application specific actions Items (ASAI'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.
P&GE 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.
7 AR (BK)
[ISG-06 Enclosure B, Item 1.16]
Design Analysis Reports: The LAR does not appear to comply with the SRP (ISG-04) regarding the connectivity of the Maintenance Work Station to the PPS. The TriStation V10 platform relies on software to effect the disconnection of the 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 V10 platform does not comply with the NRC guidance provided in ISG-04, Highly Integrated Control Rooms-Closed Open Develop a
generic RAlto provide a
respons eto ASAls for both plattor ms when the SERs are issued.
RA#XX N/A Staff agreed that PG&E should submit a separate submittal (LAR amendment) to address the ASAls for both platforms.
it is not necessary to delineate exactly what will be done for each ASAI in this 01 matrix.
3/21 update: it was agreed that PG&E/lnvensys and PG&EIWestinghou se/CSI would provide a report (LAR supplement)
April 2, 12 DCPP PPS Open Item Summary Table Page 11 of 29 No SrclRI Issue Description P&GE response:
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--including 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 V10 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.
P&GE response:
Tricon The OMC keyswitch controls only the mode of the V1 0 Tricon 3008N MPs.
Status RAI No.
(Date Sent)
RA/
Response
(Due Date)
Comments to explain how these two issues will be resolved and submit to NRC-Date to be provided TBD.
Waiting for t he the V10 Tricon portion of the PPS Replacement Failure Modes and Effects Analysis, an ISG-06 Phase 2 document to be submitted to NRC in May 2012.
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.
This issue will also have to be addressed for the ALS platform.
April 2, 12 DCPP PPS Open Item Summary Table Page 12 of 29 No SrclRI Issue Description P&GE response:
Status RAI No.
(Date Sent)
Response
(Due Date)
Comments I
I In RUN position the 3008N MPs ignore* all commands from external devices, whether WRITE commands from external operator interfaces or program-related commands from TS1131.
The keyswitch is a four-position, three-ganged switch so that the three Main Processor (MP) modules can monitor the pOSition of the switch independently. The Operating System Executive (ETSX) executing on the MP application processor monitors the position of the keyswitch. The three MPs vote the position of the keyswitch. The voted position of the keyswitch is available as a read-only system variable that can be monitored by the TSAP. This allows alarming the keyswitch position when it is taken out of the RUN position. TS1131 messages to and from the Tricon (i.e., ETSX executing on the MPs) are of a defined format. TS1131 messages for control program (Le., TSAP) changes whether download of new control programs or modification of the executing control program - are uniquely identifiable. Such messages are received by ETSX and appropriate response provided depending upon, among other things, the position of the keyswitch.
When a request from TS1131 is received by ETSX to download a new control program or modify the executing control program, ETSX accepts or rejects the req uest based on the voted keyswitch position. If the keyswitch is in RUN, all such messages are rejected. If the keyswitch is in PROGRAM, the Tricon is considered out of service and ETSX runs through the sequence of steps to download the new or modified control program, as appropriate.
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 TS 1131 installed) in order for the application program to be inadvertently reprogrammed. Therefore, there is no credible single failure on the V10 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,
April 2, 12 DCPP PPS Open Item Summary Table Page 13 of 29 No S
SrclRI Issue Description P&GE response:
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 Administrative controls on use of keyswitch will be provided with commitment to include in procedures in response.
Note, TS 1131 is not used to change setpoints and protection set is inoperable when keyswitch is not in RUN position.
[ISG-06 Enclosure B, Item 1.21]
(RS)
Setpoint Methodology: The NRC staff understands that a summary of SP (setpoint) Calculations will be provided in Phase 2, however, section 4.10.3.S 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 0.9.4.3.S without a condition of TSTF 493 LAR approval t-=-
P&GE 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 Status Open RAINo.
RAI (Date Sent)
Response
{Due Date)
NIA Comments I
PG&E/lnvensys needs to provide a technical explanation of how the MP300SN processor actually ignores all commands when in RUN-address the items in the 01.
3/7/12 update:
PG&E stated that all setpoints determinations will be addressed as part of this LAR, and NOT submitted as a TSTF-493 licensing action.
3/21/12 update:
The staff may chose to review the Westinghouse calculations at the Westinghouse
April 2, 12 DCPP PPS Open Item Summary Table Page 14 of 29 No SrclRI Issue Description P&GE response:
Status RAINo.
RAI (Date Sent)
Response
(Due Date)
Comments 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.
office in Washington DC.
However, if the safety finding is dependent on these calculations, then the setpoint calculations will be required to be submitted on the docket per NRC licensing procedures 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 inspection of Westinghouse calculations in Washington DC has been performed for another recent utility project involving setpoints.
9 AR (BK)
LTR Safety Conclusion Sco!;1e and A!;1!;1licability - 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 L TR 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 LTR to ensure Open N/A i
April 2, 12 DCPP PPS Open Item Summary Table Page 15 of 29 No 10 SrclRI RS Issue Description P&GE response:
Status 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.
P&GE response:
PG&E and Westinghouse have reviewed the LAR 11-07 and the ALS topical report to verify information is provided to justify compliance with IEEE 603-1991, IEEE 7-4.3.2-2003, and ISG-04 in either the LAR or the ALS topical report. As a result of the review, it was identified that neither the LAR nor the ALS topical report contain a matrix that documents compliance with ISG-04 Table 5-4 for the DCPP ALS platform. PG&E will submit a matrix that documents compliance with ISG-04 Table 5-4 for the DCPP ALS platform by May 31,2012.
Plant Variable PPS Scope - In the Description section of the LAR, section Closed 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.
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.
P&GE response:
The PPS Replacement LAR Sections 4.1.3 and 4.1.4 describe the plant RAI No.
(Date Sent)
X)
Response
(Due Date)
Comments
April 2,12 DCPP PPS Open Item Summary Table Page 16 of 29 No P&GE response:
Issue Description SrclRI variables from which RTS and ESFAS protective functions are generated.
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.
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 LTOP 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:
Status 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.
Input to Overtemperature /1 Neutron Flux (Power Temperature (OTOT) RT Range, Upper & Lower)
Input to Overpower /1 Temperature (OPOT) RT 11 RS Power Range NIS Function -_Section 4.1.7 describes the Existing Power Closed RAI Range NIS Protection Functions and it states that the Power Range nuclear Require Only PPS 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
- RAI d (RAI #
X)
Functions will be described in the
April 2, 12 DCPP PPS Open Item Summary Table Page 17 of 29 No SrclRI Issue Description P&GE response:
Status RAI No.
(Date Sent)
Response
(Due Date)
Comments the PPS system is for these NIS Protection functions.
still needs to be sent.
SE.
P&GE response:
Power range analog inputs are provided by the NIS to each PPS Protection Set for use in the calculation of the Overtemperature Oelta-T and Overpower Oelta-T Setpoint in the Oelta-TfTavg 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 P-11 Low Pressurizer Pressure SI Operational Bypass P-12 No-Load Low-Low Tave Temperature Permissive Close RAI Require d (RAI #
X)
April 2, 12 No SrclRI DCPP PPS Open Item Summary Table Issue Description P&GE response:
Status P-13 Turbine Low Power Permissive
- P-14 Hi-Hi Steam Generator Level RAI No.
(Date Sent)
Response
(Due Date)
Page 18 of 29 Comments
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-10) below setpoint and 2/2 turbine impulse chamber pressure channels below setpoint (From PPS - P13).
The response states that P14 is generated in the NIS independently from PPS and it states that P14 is generated by the PPS. Which is it?
The coincidence of P7 is not performed as a function of PPS.
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 NRC understands that all permissives are developed within the SSPS system.
Permissives P11 -
P14 use inputs
13 April 2, 12 DCPP PPS Open Item Summary Table Page 19 of 29 No P&GE response:
Status RAI No.
Issue Description SrclRI Comments RA/
(Date Sent)
Response
(Due Date)
The bistable comparator setpoints for the above-listed permissives are not expected to change at this time.
P12 Permissive Contradiction - The second paragraph of section 4.1.20 Closed RAI RS 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; "These valves are not safety-related, but are interlocked with the P-12 signal from the SSPS."
In conjunction with the response to RAI3, please provide a resolution for this contradiction in section 4.1.20 of the LAR.
P&GE 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:
..... The P-12 Permissive is developed in the SSPS based on coincidence of the P-12 bistable comparator output initiation signals from the PPS...
Protection System Permissives (P-11 unblock SI from ALS, P13 Turbine power permissive from Tricon, and P-14 Steam Generator Level high-high Require d (RAI #
X) provided by PPS system. All other permissives use inputs generated by external systems that are independent of the PPS.
See 13 below.
The NRC understands that the P12 signal is generated by the SSPS using Signals developed in the PPS.
April 2, 12 DCPP PPS Open Item Summary Table Page 20 of 29 No 14 SrclRI RS Issue Description P&GE response:
from Tricon) are generated by coincident logic in the SSPS based on initiating signals (bistable outputs) from the PPS as noted in the response to 01 #12. Permissive development, including initiating signals and logic coincidence is shown in FSARU Tables 7.2-2 (RTS) and 7.3-3 (ESFAS).
The PPS does not perform coincident logic functions and does not "generate" any protection system permissives.
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 ofthe SSPS control board demultiplexer and to the PPS by way ofthe SSPS computer demultiplexer."
Why would the PPS status need to be transmitted to the PPS as the sentence suggests in the last phrase?
Status New RAI No.
(Date Sent)
Response
(Due Date)
Comments PG&E response:
The sentence in Section 4.1.1 contains a a typographical error. The sentence should read:
"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."
April 2, 12 DCPP PPS Open Item Summary Table Page 21 of 29 No SrclRI Issue Description P&GE response:
Status RAI No.
RAI Comments (Date Sent)
Response
(Due Date) 15 (BK)
An ISG-04 compliance matrix for the DCPP PPS system was not submitted Open RAI No further with, or referenced in, the LAR for the W/ALS platform. Instead the ISG-04 compliance section 4.8 of the LAR refers the reader to the ALS L TR for nearly all the points of ISG-04. Fig. 4.4 and 4.5 of the LAR indicate various 1 E and non-1 E communication pathways to and from ALS processor (e.g.,
Require d (RAI #
X) discussion necessa~ until Ma)l 31 1 2012.
Maintenance Work Station, plant computer, process control, port aggregator, and 4-20 rna temperature signal to Tricon processor). These are all application specific features of the PPS and the staff expects a W/CSI ALS document to be submitted, similar in scope and detail to the Invensys "PACIFIC GAS & ELECTRIC COMPANY NUCLEAR SAFETY-RELATED PROCESS PROTECTION SYSTEM REPLACEMENT DIABLO CANYON POWER PLANT DI&C-ISG-04 CONFORMANCE REPORT" Document No.
993754-1-912 Revision 0, to be submitted on the docket, which explains how the ALS portion of the PPS application conforms with the guidance of ISG
- 04.
PG&E response:
Westinghouse will provide a DCPP PPS specific ISG-4 Compliance Table by March 31,2012 and PG&E will submit the Table by May 31,2012.
April 2, 12 DCPP PPS Open Item Summary Table Page 22 of 29 No SrclRI Issue Description P&GE response:
Status RA/ No.
RA/
Comments (Date Sent)
Response
(Due Date) 16 (BK)
Section 1.4.4 (pg. 12/38) of document 993754-1-813 Diablo Canyon Triconex PPS Validation Test Plan (VTM) states "The network equipment, including media converter, NetOptics Network Aggregator Tap, and gateway hub, and the MWS will not be within the test scope of this VTP. The Nuclear Delivery (NO) group will coordinate with Pacific Gas & Electric for system staging prior to turn over to Nuclear IV&V. The Nuclear IV&V group will confirm proper operation of network communications system interfaces before beginning testing addressed in this VTP." When, where, and what procedures will be used to test the network equipment??
X)
Please indicate when this action is scheduled for completion.
PG&E response: IN PROGRESS 17 (BK)
Section 5.1.4.3, Hardware Validation Tests, (pg. 27/38) of document 993754 Open RAI Please indicate 1-813 Diablo Canyon Triconex PPS Validation Test Plan (VTM) states that the ALS equipment will not be included in the FAT. Where, when, and what procedures will be used to fully test the Integrated PPS system (both Tricon V10 and ALS platforms together) be subjected to FAT.
Require d (RAI #
X) when this action is scheduled for completion.
PG&E response: IN PROGRESS
April 2, 12 DCPP PPS Open Item Summary Table Page 23 of 29 No SrclRI Issue Description P&GE response:
Status RAI No.
RA/
Comments (Date Sent)
Response
18 (BK)
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, Open RAI Require d (RAI #
X)
(Due Date)
When will Invensys provide this information??
"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 actuation systems (ESFAS)
The Invensys PPS Replacement Software Verification and Validation Plan (SWP), 993754-1-802 does not provide a clear explanation of how the Invensys SWP complies with IEEE 1012-1998. Please provide a cross reference table that explains how the Invensys SWP implements the criteria of IEEE 1012-1998.
Also, the Westinghouse/ALS 6116-00000 Diablo Canyon PPS Management Plan, does not provide a clear explanation of how the CSI SWP complies with IEEE 1012-1998. Please provide a cross reference table that explains how the W/CSI SWP implements the criteria of IEEE 1012-1998.
April 2, 12 DCPP PPS Open Item Summary Table Page 24 of 29 No SrclRI Issue Description P&GE response:
Status RAI No.
(Date Sent)
Response
(Due Date)
Comments PG&E response:
Westinghouse will provide an IEEE-1012 compliance map by May 4,2012 to PG&E and PG&E will submit the matrix to the staff by May 31, 2012.
19 RS Section 4.1.1 of the LAR states that;
'The SSPS evaluates the Signals and performs RTS and ESFAS functions to mitigate Abnormal Operational Occurrences and Design Basis Events described in FSAR [26J Chapter 15."
- however, Chapter 15 of the DCPP FSAR does not use the terms Abnormal Operational Occurrence (AOO) or Design Basis Accident (DBE). Instead, the accident analysis in chapter 15 identifies conditions as follows; CONDITION I - NORMAL OPERATION AND OPERATIONAL TRANSIENTS CONDITION 11-FAULTS OF MODERATE FREQUENCY CONDITION III - INFREQUENT FAULTS CONDITION IV - LIMITING FAULTS Open RAI will eventual Iy be required (RAI#
X) 3/21/12 update:
PG&E has created a share point website for NRC to review PPS design drawings that will address this issue as well as 01 20 and 21.
NRC staff will determine if they are needed to be submitted on the docket. PG&E will ensure the website is information is only applicable to this licensing action.
April 2, 12 No SrclRI DCPP PPS Open Item Summary Table Issue Description P&GE response:
As such, the statement that AOO's and DBE's are described in the FSAR appears to be inaccurate. Please explain the correlation between the Conditions described in FSAR chapter 15 and the Abnormal Operational Occurrences, and Design Basis Events described in the LAR.
PG&E response: The AOO's are referred to as ANS Condition I "Operational Transients" in FSAR Chapter 15 and are addressed in FSAR Chapter 15.1. The design basis accidents are referred to as ANS Condition II "faults of moderate frequency," ANS Condition III "infrequent faults," and ANS Condition IV "limiting faults" and are addressed in FSAR Chapter 15.2, 15.3, and 15.4 respectively.
Status RAINo.
(Date Sent)
Response
(Due Date)
Page 25 of 29 Comments
20 April 2, 12 DCPP PPS Open Item Summary Table Page 26 of 29 P&GE response:
No Issue Description SrclRI The system description provided in Section 4 of the LAR includes "functions performed by other protective systems at DCPP in addition to the PPS functions". In many cases, there is no explanation of what system is performing the functions described nor is there a clarification of whether the described functions are being performed by the PPS system.
RS As an example, Section 4.1.16 describes a bypass function to support testing of the high-high containment pressure channel to meet requirements of IEEE 279 and IEEE 603. The description of this function does not however, state whether this latch feature is being implemented within the PPS system or in the SSPS.
The staff needs to have a clear understanding of the functional scope of the PPS system being modified in order to make its regulatory compliance determinations. Please provide additional information such as PPS function diagrams to help the staff distinguish PPS functions from functions performed by other external systems.
PG&E Response: PPS design drawings have been provided to the staff on the Sharepoint site.
Status Open RAI No.
(Date Sent)
RAlwili eventual Iy be required (RAI #
X)
Response
(Due Date)
Comments 3/21/12 update:
PG&E has created a share point website for NRC to review PPS design drawings that will address this issue. NRC staff will determine if they are needed to be submitted on the docket. PG&E will ensure the website is information is only applicable to this licensing action.
21 RA Westinghouse/CSI document 6116-00005, "Diablo Canyon PPS System Test Open RAI will 3/21/12 update:
Plan," states that the ALS-1 02 FPGA design is changed for the DCPPS eventual PG&E has created System. Further, Section 5.3.3 states: "Test as many of the ALS-102 Iy be a share point requirements as possible."
required website for NRC (RAI#
to review PPS Please identify what document describes the design verification test for this X) design drawings
April 2, 12 DCPP PPS Open Item Summary Table Page 27 of29 P&GE response:
No Status RAI No.
SrclRI Issue Description RAI Comments (Date Sent)
Response
(Due Date) board.
PG&E response: PPS design drawings have been provided to the staff on the Sharepoint site.
22 BK Follow-on 01 # 5 question pertaining to the PPS VTP:
Open RAlwili Section 1.4.4 (pg. 12/38) states 'The network equipment, including media be converter, NetOptics Network Aggregator Tap, and gateway hub, and the required MWS will not be within the test scope of this VTP. The Nuclear Delivery (RAI#
(NO) group will coordinate with Pacific Gas & Electric for system staging prior X) to turn over to Nuclear IV&V. The Nuclear IV&V group will confirm proper operation of network communications system interfaces before beginning testing addressed in this VTP." When, where, and what procedures will be used to test the network equipment??
Also, section 5.1.4 (3) Hardware Validation Tests states that the ALS equipment will not be included in the FAT (pg. 27/38). Where, when, and what procedures will be used to fully test the Integrated PPS system (both Tricon V10 and ALS platforms together) be subjected to FAT.
PG&E response: IN PROGRESS that will address this issue. NRC staff will determine if they are needed to be submitted on the docket. PG&E will ensure the website is information is only applicable to this licensing action.
23 April 2, 12 ocpp PPS Open Item Summary Table Page 28 of 29 No SrclRI IssueDescription P&GE response:
Status RAINo.
RAI Comments (Date Sent)
Response
(Due Date)
Sel tion 4 2.13.1 of the LAR (page 85) states; "Figure 4-13 only shows one TCM ins lied in the Tricon Main Chassis (Slot 7L), the PPS replacement will util zetw TCM cards in each main chassis (Slots 7L and 7 -R). This will pre vide two non-safety-related communication paths to the MWS and the PPCGa way Computer from each Protection Set to ensure continued cor mun ations if a single TCM fails.
Tht NetO )tics Model PA-CUIPAD-CU1 PA-CU port aggregator network tap wa app ved previously by NRC for a similar application in the Oconee RPS SERSec on 3.1.1.4.3 [18]. The NRC staff determined that due to the ele trica solation provided by use of fiber optic cables and the data isolation previded 'y the Port Tap and the Maintenance and Service Interface (MSI) in the Ocon e RPS, there was reasonable assurance that a fault or failure wit in th Oconee Gateway computer or the Operator Aid Computer will not ad' ersel affect the ability of the Oconee RPS to accomplish its safety fun ctions Du ng th SAT PG&E will test the Protection Set communications paths illu: trate in Figure 4-13 to verify that there is no inbound communications pal ass ;iated with port aggregator network tap Port 1. That is, PG&E will vel fy tha communications from Port 1 to either the TCM on Port A or the MV Son 'ort B of the port aggregator network tap are not permitted.
Re ults this test will be documented in final System Verification and Val datio Report. Port aggregator dual in-line package (DIP) switch pO! tions viii be controlled by DCPP configuration management processes."
BK In ( rder r the Staff to approve the integrated configuration of the PPS, prior to l hipm 1t of the PPS equipment to DCPP site, all communications paths will requ
~ testing on or before FAT, and before completion of the SER. This tes ngis vpically completed during or before the PPS FAT, otherwise, the SER ot be completed until after the SAT. Please provide a test sct eme/, 'ocedures that satisfies all regulatory requirements prior to or dur ng th FAT. Otherwise, if this testing will be completed during the SAT, as tated n the LAR, please provide a detailed schedule for this testing so the NRC an revise its PPS LAR Review Plan accordingly.
Open RAlwill be required (RAI#
X) 1 The NetOptics Model PAO-CU has two one-way output ports but is otherwise identical in function to the PA-CU.
April 2, 12 DCPP PPS Open Item Summary Table Page 29 of 29 No SrclRI Issue Description P&GE response:
Status RAI No.
RAI Comments I
(Date Sent)
Response
I (Due Date)
PG&E response: IN PROGRESS
- 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
Enclosures:
- 1. List of Attendees
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