ML14157A091

Summary of 5/21/14 Meeting with Pacific Gas and Electric Company to Discuss Digital Replacement of Process Protection System at Diablo Canyon Power Plant, Units 1 and 2

ML14157A091
Person / Time
Site:	Diablo Canyon
Issue date:	06/17/2014
From:	Peter Bamford Plant Licensing Branch IV
To:	Pacific Gas & Electric Co
Bamford P
References
TAC MF7522, TAC MF7523
Download: ML14157A091 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 17, 2014 LICENSEE: Pacific Gas and Electric Company FACILITY: Diablo Canyon Power Plant, Unit Nos. 1 and 2

SUMMARY

OF MAY 21,2014, 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, UNIT NOS. 1 AND 2 (TAC NOS. ME7522 AND ME7523)

On May 21, 2014, 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 Pike, 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 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 meetings that is being held periodically to discuss issues associated with the NRC staff's LAR review. Selected open items that are being tracked for this review were discussed during the teleconference meeting. A complete list of the current open items is provided in Enclosure 2.

Highlights from this meeting on May 21, 2014, include the following:

• The open item summary listing was discussed and the current version is provided with this meeting summary as Enclosure 2.

One member of the public was in attendance for the teleconference meeting and no public meeting feedback forms were submitted.

Please direct any inquiries to me at 301-415-2833 or at Peter.Bamford@nrc.gov.

Peter Bamford, Pr Ject Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosures:

1. List of Attendees

2. Open Items Listing cc w/encls: Distribution via Listserv

LIST OF ATTENDEES MAY 21. 2014. TELECONFERENCE MEETING WITH PACIFIC GAS AND ELECTRIC COMPANY DIGITAL UPGRADE FOR DIABLO CANYON POWER PLANT. UNIT NOS. 1 AND 2 DOCKET NOS. 50-275 AND 50-323 NAME ORGANIZATION K. Schrader Pacific Gas and Electric A. Wilson Pacific Gas and Electric J. Hefler Altran E. Quinn Altran W. Odess-Gillet Westinghouse A. Breneman Westinghouse T. Tuite Westinghouse D. Head lnvensys Rich Stattel Nuclear Regulatory Commission (NRC)

Samir Darbali NRC Rossnyev Alvarado NRC Shiattin Makar NRC Jennie Rankin NRC Gordon Clefton Nuclear Energy Institute Enclosure 1

Enclosure 2 Open Item Summary Table

June 3, 2014 DCPP PPS Open Item Summary Table Page 1 of 10 No Src/RI Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due Date) 93 RJS (ALS Audit Item) Open 4/16/14 - Updated RTM to be made The RTM for the ALS subsystem was prepared using Westinghouse available prior to ALS audit.

document WNA-DS-02442 to trace PG&E requirements. The IV&V team found that Westinghouse document WNA-DS-02442 does not capture all 12/12/13- RJS PG&E requirements (see descriptions for Tickets #4787 and #4800). Current version of Please provide a description of how this issue is being resolved. 6116-00059 on sharepoint is "0."

This does not establish PG&E Response:

traceability to the The 6116-00000 Diablo ALS Management Plan, revision 4, specifies an Core FPGA Design updated document structure that has all PG&E Customer Requirements Specifications.

feeding directly into the 6116-00011, which will flow down into all ALS Diablo sub-ordinate requirement and design specifications. Westinghouse 10/16/13- RJS document WNA-DS-02442 has been removed from the document New RTM still does hierarchy. 6116-00000, revision 4, 6116-00011, revision 1, and the 6116- not establish traceability to the 00059 RTM, revision 0, are all reflective of this new document structure.

6116-10203, and Documents 6116-00011, revision 1, was submitted under PGE Letter DCL- 6116-10204 Core 13-087 dated September 17, 2013. The next revision of the 6116-00059 FPGA Design RTM, Revision 1, will include traceability to the Core FPGA Design Specifications.

Specifications, and will be submitted prior to the ALS audit.

Also A new revision of 6116-00059 will need to be docketed due to the significance of changes made since the original document was submitted.

6116-00011, ALS SDS, revision 1

June 3, 2014 DCPP PPS Open Item Summary Table Page 2 of 10 No Src!RI Issue Description P&GE response: Status RAJ No. RAJ Comments (Date Sent) Response (Due Date) 6116-00059 ALS RTM, revision 0 They are both available in the Sharepoint SDS Rev. 0 is already on docket.

[ML11277A152]

RTM to be submitted on Docket.

94 RJS The ALS Topical Report Plant Specific Action Items will be made available Open RAI59 4/30/14 5/16/14 Hold this to Westinghouse. When these are available, PG&E should prepare a open until all document to identify how each applicable PSAI is being addressed for the ASAI's are addressed.

PPS project. This document should include references to the LAR and supporting documents where PSAI's are addressed. 4/16/14- RAI response will only PG&E Response: be partial. 16 of 23 The response to the ALS ASAis requires input from Westinghouse and a PSAI's will be contract has been created to supply the required information. The addressed. 7 will be deferred by 90 response to the ASAis, except 4, 5, 6, 8, 10, 20, and 22, will be days. Waiting for submitted by March 24, 2014. The response for PSAis 4, 5, 6, 8, 10, input from WH on 20, and 22 will be submitted by August 30, 2014. additional testing.

12/12/13- RJS A version of the ALS TR/ SE is now available and being L...-- ------ - - ------

reviewed.

June 3, 2014 DCPP PPS Open Item Summary Table Page 3 of 10 No Src/RI Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due Date) I 101 RJS Phase 2 Environmental Qualification Documentation: Open RAI61 4/30/14 Hold OPEN until final qualification Per ISG 6 Section D.5.1, the NRC staff needs to review the information documents are received.

provided to determine if the PPS equipment has been demonstrated to be able to operate within the specified environment. In order to do this the 12/11/13- RJS staff needs to have plant specific environmental data for the plant and Seismic Reports specifically for the cable spreading room. The ISG 6 matrix (item 2.12) posted on states that this information has been provided in the two vendor topical sharepoint. Further reports, however, these reports do not contain any plant specific data. plant specific information including ping tests The NRC requires plant specific environmental condition data for normal of PPS cabinets is operating conditions and the worst conditions expected during abnormal still needed for and accident conditions where the PPS equipment is expected to perform evaluation.

its safety function.

11/1/13-RJS Waiting for

• Range of temperature and humidity conditions that are additional testing to expected in the cable spreading room.

be completed.

• Seismic data for the Diablo Canyon OBE and SSE earthquakes including frequencies and acceleration values. PG&E to provide

• EM I/ RFI data for areas where PPS equipment is to be estimate of installed. completion for next call.

The FRS section does specify the ranges of temp and humidity but for 6/26/2013: during seismic environment, it refers to documents DCM C-17, DCM C-25, DCM this call the C-30, DCM C-28, and DCM T-10. following clarifications were Note: The required information may a/so be contained in the UFSAR. The staff is provided:

reviewing design basis information in the UFSAR, however specific environmental - Describe specific conditions applicable to the PPS equipment remain unclear to the staff. conditions for the room where the 3/28/14 Update: system will be installed.

Integrated Equipment Response Spectra(IERS): In the seismic test report,

-Is there any it is stated the IERS spectra will change as a result of the equipment

June 3, 2014 DCPP PPS Open Item Summary Table Page 4 of 10 No Src!R/ Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due Date) modifications. So far, the evaluation is based on comparing the ALS and restrictive Tricon test data (TRS) with the RRS derived from the 140' elevation requirement for this spectra provided in DCM No. C-25. I think that these RRS spectra will be room?

-What is the conservative in comparison to the IERS but I will need to confirm this once relationship I see the revised IERS. between the system See follow-up questions and answers in the PG&E response below. specification requirement and environmental PG&E Response: PG&E provided seismic information in the document conditions?

titled "Westinghouse Seismic Test Report EQLR-224B, Rev. 1" on the Sharepoint on 12/3/13. Additional testing is required for the PPS cabinets to be used that is expected to be completed in May 2014.

I 3/28/14 Update:

Based on Patrick Huang's response:

1) IEEE 344-1975, Section 3.5.3, states that If equipment damping is not known, a value of 5 percent is recommended. Therefore use 5% damping.

Based on the following criteria:

2) IEEE 344-1975, Section 6.6.3.1, states that the TRS envelops the RRS over a frequency range which includes all natural frequencies of the equipment up to 33Hz. The guidance has been more specifically addressed in IEEE 344-1987 (Endorsed by NRC RG 1.100 Rev. 2),

Section 7.6.3.1.1 0 that it can be shown by a resonance search that no resonance response phenomena exist below 5Hz, it is required to envelop the RRS only down to 3.5 Hz. Excitation must continue to be maintained in the 1 Hz to 3.5 Hz range to the capability of the test facility.

3) According to Draft NTS Report No TR62987-07N-SEI, Revision 0 (Reference 8.9 of Draft TRIGON v1 0 Nuclear Qualification Project , -

June 3, 2014 DCPP PPS Open Item Summary Table Page 5 of 10 No Src/RI Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due Date)

Seismic Test Report 9600164-526, Date 04/13/07) Section 6.8, Resonance Survey Results shows that the ETP or Chassis has no resonance occurred below 40 Hz. The TRS did not envelop RRS below 3 Hz meet the above IEEE 344-1975 as well as IEEE 344-1987 criteria.

Therefore, Tricon seismic test response are acceptable.

Based on 2) and 3) above, it can be justified that the Tricon test report is acceptable for the qualification of PCS racks.

The PCS racks are identical to the PPS racks and are in the same location/elevation. Since there are no natural frequencies below 5Hz, you I I

only need to envelop down to 3.5Hz. The resonance survey showed that the natural frequencies were all greater than 40Hz. So the TRS below 3.5Hz does not matter.

Response to follow-up questions:  !

. Will you be submitting a revised EQLR-2248 with the new IERS or do you plan to submit the IERS information via some other I document?

I No, EQLR-2248 is Westinghouse proprietary. We cannot revise their report. We will generate IERS at ALS mounting location to compare with TRS from the EQLR-2248. The new IERS will be documented in the DCPP seismic calculation.

. Also, the EQLR-2248 document is specific to the ALS, so will there be a similar seismic test report for the Tricon?

Yes, Tricon has seismic test report for ETP and chassis per IEEE 344.

June 3, 2014 DCPP PPS Open Item Summary Table Page 6 of 10 No Src/RI Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due

. Will there be a different set of IERS for ALS and Tricon or can the Date) same set of spectra be applied to both subsystems?

Yes, the ALS and Tricon are mounted in the different PPS racks, the IERS are not the same. Since the ALS and Tricon have different seismic test reports, we will compare the TRS with the IERS separately.

108 RJS Phase 2 Document Status Assessment: Open No RAI 4/16/14- NRC will provide update to The staff performed an assessment of the phase 2 document matrix and Phase 2 matrix status following the would like to discuss several items in the table. Please address comments next DCL submittal added to the phase 2 matrix by the NRC staff. of Tricon documents.

We recognize that some of these items will not be available until after the FAT is performed, however, there are several other phase 2 documents 12/11/13- RJS that should be available now. We have identified the following documents Tricon Reliability that should not require completion of the design or FAT that have not yet Analysis document is on sharepoint.

been submitted. We will need a revised schedule for submittal of these Schedule for documents in order for us to proceed with the safety evaluation. submittal of all documents still WSR's for phases of development beyond Planning/Req. (Both Vendors) needs to be Tricon 993754-1-819, Reliability Analysis provided.

Tricon 993754-1-811, Project specific platform FMEA (IEEE 352)

PG&E System level FMEA Tricon 993754-1-812, Validation Test Specification (Integrated System)

Tricon 993754-1-868, Software Verification Test Plan Westinghouse 6116-10020 "ALS PPS Software Safety Plan"

June 3, 2014 DCPP PPS Open Item Summary Table Page 7 of 10 No Src/RI Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due Date)

PG&E Response:

PG&E is working with each Vendor to determine the submittal dates for the remaining Phase 2 documents not related to FAT testing that still need to be submitted. The schedule for the outstanding lnvensys documents was provided on the Sharepoint on 12/17/13. A revised schedule for the outstanding ALS documents will be provided on the Sharepoint by 05/19/14.

109 RJS Audit Preparation: Open NoRAI 5/16/14 Could not find the MCL on In preparation for the follow-up audits at lnvensys and at Westinghouse, share point. When will thisbe available the staff would like to have access to the configuration status accounting to us?

documents. Can the following documents be put onto the share point site?

4/16/14- PG&E

1. 6116-00050, Diablo Canyon PPS Configuration Status Accounting, agreed to add

2. Triconex Master Configuration List current Tricon MCL to sharepoint to support pre-audit activities. MCL will PG&E Response: The 6116-00050, Diablo Canyon PPS Configuration also be available Status Accounting was put on the Sharepoint on 12/3/13. The Tricon MCL during lnvensys will be placed on the Sharepoint to support the audit by 05/08/14. audit.

11/1/13- RJS 6116-00050 to be put on sharepoint.

Tricon doc will be made available prior to second

,_ audit.

June 3, 2014 DCPP PPS Open Item Summary Table Page 8 of 10 No Src/RI Issue Description P&GE response: Status RAJ No. RAJ Comments (Date Sent) Response (Due Date) 115 RJS Electro Magnetic Compatibility (Tricon): New RAI 4/16/14- RAI will be required.

Section 4.14- ASAI-6 of the LAR states that the equipment vendors are required to confirm equipment compliance with physical requirements in the DCPP FRS. These requirements include the EMC requirements from Section 3.1.6 of the FRS which states: "the PPS shall be qualified by test, analysis, or a combination thereof, to function without fault or error in an electromagnetic environment in accordance with the guidance of Regulatory Guide 1.180."

In contrast to this, the Tricon V1 0 safety evaluation determined that the Tricon V1 0 PLC system did not fully meet the guidance of RG 1.180, Revision 1, for conducted or radiated emissions or susceptibility. As a result, theSE states: "before using the Tricon V10 system equipment in SR systems in a nuclear power plant, licensees must determine that the plant-specific EMI requirements are enveloped by the capabilities of the Tricon V10 system as approved in this SE."

To complete its safety evaluation, the NRC requires the licensee to provide documentation to show the DCPP specific EMI requirements to be enveloped by the Tricon V1 0 test levels achieved and documented in the Tricon V1 0 safety evaluation.

- '---------- - - - - - - L__ - - - - - -

June 3, 2014 DCPP PPS Open Item Summary Table Page 9 of 10 No Src/RI Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due Date)

PG&E Response: Additional electromagnetic environment testing has been performed for the Tricon that improve meeting the RG 1.180 guidance.

Information on the additional testing and evaluation to the PG&E requirements will be submitted. Determination of the submittal date is in progress.

116 lnvensys Audit NEW The Project Traceability Matrix (PTM) Rev 5 does not identify the test cases for functional verification of the requirements identified.

PG&E Response:

117 Tricon conformance with ISG-06 position 1, point 10 NEW The Safety Evaluation for the Tricon platform, Section 3.7.3.1.10 STAFF POSITION 1, POINT 10, states "The application can be programmed to perform any required action on a change of the keyswitch position.

However, this would be an application specific feature that is beyond the scope of this review."

PG&E response to RAI #17 states the Operating System running on the MP application processor would monitor the position of the keyswitch, and used this parameter to allow modifications to the control program when a

June 3, 2014 DCPP PPS Open Item Summary Table Page 10 of 10 No Src/RI Issue Description P&GE response: Status RAI No. RAI Comments .

(Date Sent) Response (Due Date) command from an external device is received. Furthermore, the response to RAI #17 implies that an application can call any of four function blocks to perform certain activities.

The lnvensys SRS identifies a requirement to indicate the position of the keyswitch. However, when this requirement is traced down to the SOD level, the requirement is only used to indicate an alarm when the keyswitch is not in the RUN position.

Besides the alarm to indicate the keyswitch is not in the RUN position, please describe what actions are programmed in the application software on a change of the keyswitch position?

PG&E Response:

One member of the public was in attendance for the teleconference meeting and no public meeting feedback forms were submitted.

Please direct any inquiries to me at301-415-2833 or at Peter.Bamford@nrc.gov.

/RAJ Peter Bamford, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosures:

1. List of Attendees

2. Open Items Listing cc w/encls: Distribution via Listserv DISTRIBUTION:

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