ML16064A005

Summary of Teleconference with PSEG Nuclear LLC on the Upgrade of Hope Creek Generating Station'S Power Range Neutron Monitoring System to a Digital Power Range Neutron Monitoring System

ML16064A005
Person / Time
Site:	Hope Creek
Issue date:	03/22/2016
From:	Thomas Wengert Plant Licensing Branch 1
To:	Public Service Enterprise Group
Parker C, NRR/DORL/LPL1-2
References
CAC MF6768
Download: ML16064A005 (23)

Text

LICENSEE: PSEG Nuclear LLC FACILITY: Hope Creek Generating Station

SUMMARY

OF FEBRUARY 16, 2016, TELECONFERENCE WITH PSEG NUCLEAR LLC ON THE UPGRADE OF HOPE CREEK GENERATING STATION'S POWER RANGE NEUTRON MONITORING SYSTEM TO A DIGITAL POWER RANGE NEUTRON MONITORING SYSTEM (CAC NO. MF6768)

On February 16, 2016, a Category 1 public teleconference was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of PSEG Nuclear LLC (PSEG, the licensee). The purpose of the teleconference was to discuss the license amendment request (LAR) submitted by PSEG on September 21, 2015, 1 which would allow for the replacement and upgrade of the existing analog Average Power Range Monitor (APRM) sub-system of the Neutron Monitoring System with General Electric-Hitachi (GEH) digital Nuclear Measurement Analysis and Control Power Range Neutron Monitoring (PRNM) system. The PRNM upgrade also includes Oscillation Power Range Monitor capability and will allow full APRM, Rod Block Monitor, Technical Specification Improvement Program implementation, and will include application of Technical Specification Task Force Traveler-493, "Clarify Application of Setpoint Methodology for LSSS Functions," to affected PRNM functions. The teleconference notice and agenda, dated February 5, 2016, is available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML16036A154. A list of attendees is provided as Enclosure 1.

The teleconference was one in a series of publicly noticed teleconferences to be held periodically to discuss the issues associated with the NRC staff's LAR review. Preliminary issues that the NRC staff identified during the initial review, and the licensee's responses to the preliminary issues, were discussed during the teleconference. The list of preliminary issues is provided in Enclosure 2.

Highlights from the February 16, 2016, teleconference include the following:

• The NRC staff will perform an audit of GEH, PSEG's vendor for this LAR. The NRC staff is targeting spring 2016 for the audit.

• The roadmap included in the LAR was helpful for the staff, and a similar document will be provided with the Phase 2 submittal.

1 ADAMS Accession No. ML15265A223

• The NRC staff will provide audit dates and a list of documents to be placed in the reading room. In addition, the NRC staff will update the list of preliminary issues for the March meeting, including closing several items.

• The next teleconference will be on March 15, 2016.

Members of the public were in attendance. Public Meeting Feedback forms were not received.

No comments from the public were received.

Please direct any inquiries to me at 301-415-4037 or Thomas.Wengert@nrc.gov.

~~~~

Thomas Wengert, Senior Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-354

Enclosures:

1. List of Attendees

2. Staff Identified Issues cc w/enclosures: Distribution via Listserv

LIST OF ATTENDEES FEBRUARY 16. 2016 TELECONFERENCE WITH PSEG NUCLEAR LLC DIGITAL UPGRADE FOR HOPE CREEK GENERATING STATION DOCKET NO. 50-354 NAME ORGANIZATION C. Parker NRC R. Alvarado NRC V. Huckabay NRC M. Lewis Public P. Duke PSEG B. Thomas PSEG R. Hoffman PSEG E. Scott PSEG R. Gallaher PSEG C. Lukacsy PSEG K. Swing PSEG M. Parrish PSEG T. Rogers GEH F. Novak GEH K. Miller GEH R. Hayes GEH R. Merante GEH T. Vikara GEH D. Heinig Sargent and Lundy Enclosure 1

DOC-0006-2118 RO HCGS NUMAC Upgrade - Open Items No. Resp. Issue Description Status RAI No. PSEG Response

1. EICB System Description new LTR 5.3.1 first bullet discusses APRM chassis and (for large cores) LPRM chassis.

Appendix R provides responses to plant NEDC-33864P Appendix A refers to these specific responses to the NU MAC LTR. The two chassis as APRM-Master and Slave.

response to LTR 2.3.4 identifies the configuration tor HCGS to be 4 APRM Master refers to the APRM chassis and Slave channels with one APRM chassis and one refers to the LPRM chassis. These terms are LPRM chassis. However the LTR and used interchangeably.

Appendix A system architecture do not describe this. NEDC-33864P Appendix A page A-11 shows Appendix A describes a master/slave APRM the system level architecture.

instrument, but the LTR describes a LPRM unit not clear how these two concepts relate, if they do.

Provide a figure showing the system architecture tor the HCGS PRNMS.

2. EICB System Description new The LTR describes variants of PRNM system architecture, depending on whether the target Appendix A seems to describe the generic application (plant) has a large or small core, PRNM system architecture and not the and whether it is BWR6 or non-BWR6.

architecture tor HCGS. What is different Appendix A provides additional details about between this description and the one large core, non-BWR6, such as Hope Creek.

provided in the LTR?

Also there are system differences, which are The differences described in Appendix J are described in Appendix J. How do these not architectural differences.

modules work and fit in the system architecture tor HCGS?

Enclosure 2

DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response

3. EICB System Description new a)

• These are GEH references pointing to Appendix J identifies Hope Creek deviations where the support for the justification is from the approved generic NUMAC PRNM stored in the GEH document system. The system. This is required in ISG-06 Section following two referenced documents can D.8. be placed in reading room upon request.

a) Table 1 lists these deviations and

• Item 2 - 001 N5637 PRNM Time to provide justifications for such. Calculate Flow-biased Trip Setpoint Please provide additional information

• Item 5 - 001 N5640 PRNM Increased for the following items: Instrument Security

• Column Reference Document -

what are these documents? b)

• Item 2 - Why the modification for "Relay Logic Module" and "Relay Logic Card" time to calculate flow-biased trip refer to the same thing. Hope Creek will setpoint is a clarification? It receive the new design.

seems that the total time for the Hope Creek Design has changed.

• Item 5 - What higher level of security was applied and to what activities?

b) Section 4.2 describes the relay logic for HCGS. Please clarify how the improved relay logic module relates to the new relay logic card to be included in the Hope Creek PRNM system.

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DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response

4. EICB Software Development Plans new PSEG is required to create or acquire a number of documents from vendors providing The plans submitted describe GEH safety related equipment per IT-AA-101. The processes, but they do not include the purpose of many of these documents is to activities to be performed by the licensee, ensure the vendor has a quality process in such as oversight. Please describe the place for software and product design and activities and processes for which PSEG is that the process and design are accurately responsible. documented and tested. The required documents include a configuration management plan, a problem management and reporting process, a disaster recovery process, documented functional requirements, a documented technical design, a verification and validation plan, testing reports, user documentation, code review process and documentation and a traceability matrix to ensure all requirements are tested.

In addition, CC-AA-103-1007 responsibilities state:

Lead Responsible Engineers (LREs) are responsible for ensuring DCPs with digital devices are provided to DTS Design Engineer for review. DTS Design Engineers are responsible for reviewing Design Change Packages (DCP) with digital devices ensuring an adequate Critical Digital Review (CDR) is performed and documented. The DTS 3

DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response Engineer determines the scope and breadth of the CDR for the particular application.

A critical digital review is a review of a vendor's software QA processes and a technical review (EMl/RFI, failure analysis) of the design, documentation, and testing of a digital device determining the software/hardware's suitability for purchase and installation at PSEG Nuclear facilities.

PSEG personnel participated in critical digital review that was led by ProDesCon on the GEH Power Range Neutron Monitoring System (also refer to LAR Attachment 1 Section 3). The CDR report pointed out that GEH has an established regulatory approved Appendix B quality program and that they're processes are suitable to ensure the quality of the design, configuration control, Part 21 reportability and the system maintenance throughout the life cycle. The CDR included a high-level review of the overall system design, focusing on the safety functions of the system and how digital design principles indicative of highly reliable digital systems were applied to the PRNM system.

PSEG has reviewed and commented on software lifecycle documentation produced by GEH throuqhout the project.

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DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response In addition PSEG has performed two audits (reference Survey numbers NOV2116-014 and NOD-15-038) thus far on GEH to help ensure product reliability. These audits focused on GEH audits performed on subcontractor Gavial, the GEH actions and process to correct identified issues, QA hold points placed on the purchase order, overall test plans and completed testing, restrictions placed on the Gavial subcontractor, cyber security aspects of the project and the GEH engineering change process.

PSEG also plans to witness continued factory testing with the quality assurance department.

5. EICB Software Development Plans new Appendix B Sections 4.2 and 4.3 should be marked proprietary to match Appendix D.

The proprietary markings in the appendices Updated copies of Appendix B proprietary are inconsistent. For example, information in and non-proprietary can be provided.

Sections 4.2 and 4.3 in Appendix B is not marked proprietary, but this same information is also provided in Sections 4.2 and 4.3 of Appendix D, where is marked as proprietary.

6. EICB Appendix E, PRNM System Management new Plan 5

DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response a) Section 2.3 describes how project A Project Work Plan (PWP) is required by management will be performed. This GEH policies and procedures. As stated in section refers to critical-to-quality Appendix B Section 3.1.1.5, the PWP features to be part of the contains personnel and commercial management process. However, this information, including project budgetary plan does no define these features. information that is classified as GEH Since these features are part of Proprietary Class Ill (confidential). The PWP project oversight, please describe is created and maintained by the Project these features and in which Manager to manage the commercial aspects document will they be recorded? of the project. Critical to quality features are project specific and are listed in the PWP.

For Hope Creek, these are listed in Appendix C3 of the Hope Creek PRNM Upgrade PWP.

b) Section 2.4.1 describes the secure A collection of administrative procedures development environment. This covers specific topics related to the secure section states the control employs in development environment:

the system development should be

• Asset Identification in accordance with GEH established

• Secure Development Network procedures, consistent with

• Physical Security guidance provided in RG 1.152.

• Malicious Code Protection Please describe the GEH

• Patch Management procedures to be followed for secure

• Server and Computer Hardening development environment.

• Threat Analysis

• Software Usage

• Electronic Access Control

• Log Management

• Personnel Security and Segregation of Duties

• Production Deployment 6

DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response

• Product Handling and Delivery

• Incident Response

• Contingency Planning

• Security Control Review

• Changes to Physical, Logical, or Programmatic Controls c) Section 3.1 describes the need to The Design Review Summary Report and establish project quality metrics. Design Review Scorecard provide a record of However, this section does not quality metrics applied by the Chief identify the project quality metrics. Engineer's Office. A copy of a scorecard can be placed in the Reading Room upon request.

7. EICB Appendix B, PRNM Systems Engineering new Development Plan a) Section 2.4.1 of Appendix K states When the design team prepares and releases the verification of the design design artifacts, GEH procedures require the documents is performed by the Design team to perform verification of design team prior to IVV activities. documents prior to the document release.

But section 2.3 seems to imply that The released document is then provided to these reviews are performed by a the IVV team who conducts the independent team independent of the design verification in accordance with the SylVVP.

team. In addition, section 4.2 of Conducting the IVV activities defined in the Appendix B also describes an SylVVP (Section 3.0) constitutes the independent review team who Technical Design Review, which is performed perform the technical design review. by the IVV team and is supervised by the Please clarify what group (in the Chief Engineers Office.

GEH organization) performs these independent reviews.

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DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response b) Section 2.4.1 describes the technical Project specific issues that remain open design reviews. This section states across project phases are tracked in the task the design team is responsible for reports. See Section 4.4.2 of the NUMAC resolving issues identified during Systems Engineering Development Plan.

these reviews. How are these issues Closure of open items is reviewed as part of being recorded and tracked? Section subsequent Baseline reviews; open items are 4.5 of this appendix describes how resolved and closed prior to completion of the deficiencies or discrepancies could final Baseline review.

be tracked, and Section 7.0 states they could use engineering change order to handle problems encountered during product development. But these statements are not specific. In addition, it seems that these options are used after delivery of the NUMAC system.

Please explain what method will be used to identify and track problems identified during the technical design reviews. Also, explain the process to approve the resolution of these problems.

c) Section 4.3 states the baseline The SyQA Functional Configuration Audit review team would also review and Checklist (NUMAC System Quality approve development tools. Was this Assurance Plan Section 4.4.1) lists tools that necessary for the HCGS PRNM were approved for the associated baseline. A system? SyQA Functional Configuration Audit Checklist is developed for each Baseline.

T cols are approved for use via the Baseline review process for application to a specific 8

DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response project. Tools were used for the HCGS PRNM system development.

d) Section 5.0 describes the use of Tools are selected and approved for use development tools. BTP 7-14, throughout the various phases of project. The Section B.3.1.2.3 requires licensee approved tools are documented in the SyQA to provide a description of software Functional Configuration Audit Checklists tools to be used. Please identify the (NUMAC System Quality Assurance Plan software development tools. Section 4.4.1 ).

GEH provided details on software tools during previous (Grand Gulf and Columbia) projects. See RAI #3 in GNR0-2011/00038 (ML111370259) and Section 4.4.6 in NEDC-33685 {ML12040A074).

e) Section 6.0 describes the secure GEH has a procedure for controlling access development and operational to the NUMAC lab; see response to Open environment. This section states Item 6.b.

access to the NUMAC lab is controlled and monitored. But it does not provide details on how these are perform. Please provide detail explanation.

f) Section 6.0 describes the secure GEH has a procedure for access control of development and operational the secure server, see response to Open environment. This section states the Item 6.b.

code is maintained in the secure server. How is access granted to this server?

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DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response g) Section B.3.1.2.2 of BTP 7-14 Success or failure is indicated by the Design requires licensee to identify the Review Summary Report and Design Review indicators to determine the success Scorecard.

or failure of the development processes. This information was not provided in the engineering development plan. In addition, Appendix A in Appendix K identifies the alignment to NUMAC documents. This table identifies that this information in SyMP (See open item 6.c). Please provide this information.

8. EICB Appendix C, NUMAC Systems Quality new Assurance Plan a) General comment: This plan does The NUMAC plans augment and supplement not cover all the activities identified the GEH QA Program. As stated in Section in section B.3.1.3 of the BTP 7-14. 1.0 of the NUMAC Systems Quality Specifically, this plan does not Assurance Plan, the GEH Quality Assurance describe the corrective action Program encompasses quality assurance program, description of QA related activities such as audits, supplier procedures, and indicators to control, and archiving of quality records.

determine software quality. Although not explicitly mentioned, the corrective action program is a component of the GEH Quality Assurance Prooram.

b) Section 3.0 states unresolved Open items are listed in the System Quality configuration items is grounds for Assurance Configuration Audit Checklist and failure. How are these issues tracked in the System Configuration identified, recorded and tracked? Management Task report (SyEDP 4.4.2).

Who is responsible for approving The checklist and task report are part of the 10

DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response resolution of these issues? (see Baseline Review Records. These records open item 7.b) are approved by the baseline review team, which is chaired by the Chief Consulting Engineer.

c) Section 4.4.1 describes the oversight As discussed in response to Question 8.a, activity associated with quality the GEH Quality Assurance Program has assurance. Is the activity described other activities. Problems are tracked in in this section the only oversight accordance with GEH procedures.

activity to be performed? (This section is marked proprietary so the specific activity is not identified in the question). What happens if problems are identified during this oversight activity?

9. EICB Software Integration Plan (SlntP) new GEH did not submit a separate plan tor this.

However, GEH (Appendix K) identified the NUMAC documents that cover the requirements for this plan (BTP 7-14, Section B.3.1.4). Based on this information, the staff identified the following questions:

a) Section B.3.1.4.2 identifies the GEH does not have a separate software implementation characteristics of the integration team, rather software integration SlntP. His section requires is performed by the design team. Therefore, description of the software the characteristics described in the SyEDP integration activities. GEH for design team activities apply to integration references SyEDp for this, but activities as well. For explanation of how SvEDP does not provide enouqh 11

DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response information about the software measurement is performed, see response to integration process. Please provide 6.c.

this information.

b) Section B.3.1.4.3 identifies software See response to open item 7.d.

tools. As mentioned in open item 7.d, these GEH document do not identify the software tools to be used. Please provide this information.

10. EICB Software Safety Plan (SSP) new The PRNM upgrade is a retrofit system. As a GEH did to submit a separate plan for this. retrofit system, the GEH approach to software However, GEH (Appendix K) identified the safety planning for PRNM is to ensure that NU MAC documents that cover the the safety significance of the PRNM retrofit is requirements for this plan (BTP 7-14, consistent with the design basis of the Section B.3.1.9). Based on this information, replaced system and of the plant. GEH the staff identified the following question: provided details on software safety approach Appendix K refers to the IVVP and SyMP for during previous (Grand Gulf and Columbia) the information required in BTP 7-14. projects. See RAI #1 and 2 in GNRO-However, the information identified in these 2011/00039(ML111460590) and Section sources seem to address the hazard 4.4.1.9 in NEDC-33685(ML12040A074).

analysis required by IEEE 102, and not what is required in BTP 7-14.

The SSP should provide a general description of the software safety effort, and the intended interactions between the software safety organization and the general system safety organization.

11. Appendix D, NUMAC Systems Independent new Verification and Validation 12

DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response a) Section 2.1 describes the GEH The Chief Consulting Engineer reports to the organization. This section states the Chief Engineer's Office.

GEH Chief Engineer's office supervises independent V& V activities. However, Appendix D, Figure 2-1 identifies the Chief Consulting Engineer as the person responsible for V&V activities.

b) Section 3.1.2 describes the safety See response to open item 10.

analysis for the concept phase. It is not clear if this activity will include the preliminary hazard analysis, since it seems to only cover evaluation of the documentation.

c) Is the safety analyses described in Hazard analysis is performed during various each lifecycle phase considered to lifecycle phases as indicated in Appendix K, be the hazard analysis identified in Table 5 for cross-reference of IEEE Std 1012 IEEE Std. 1012? If so, will this also to NUMAC process.

include the risk analysis identified in Project risk management is performed during IEEE Std. 1012? all system life cycle development phases in accordance with the GEH Quality Assurance Program d) Appendix K refers to the IVVP Project risk management is performed during Section 4.0 to confirm item all system life cycle development phases in 8.3.1.10.1, risks. Section 4.0 accordance with the GEH Quality Assurance describes the baseline process. So it Program. SylVVP Section 4.2 describes is not clear how the baseline process Technical Reviews. Although not stated in will be used to identify and manage the SylVVP, the GEH procedure for Technical 13

DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response risks associated with the V & V Design Reviews requires risks management.

process. SylVVP Section 4.3 describes Baseline Reviews, which are a process check to ensure the project plans are beinq followed.

e) Appendix K refers to several See response to open item 6.c.

sections in the IVVP to confirm item B.3.1.10.2, measurement. However, the information provided does not clearly define the indicators that will be used.

f) Section B.3.1.10.2, procedures Per section 2.2.2 and 2.2.3 of the SylVV, the requires applicants to describe how System Verification Engineer and System anomalies are identified and Safety Analysis Engineer are responsible for reported. This information is not documenting results of reviews including provide in the plan (See item 11.b anomalies in their respective tasks reports.

above) The task reports are discussed in sections 4.4.1 and 4.4.2.

12. EICB Software Configuration Management Plan new SyEDP - section 3.4 specifies configuration (SCMP) management of source code and section 5 specifies configuration management of GEH did to submit a separate plan for this. firmware. Tools are controlled at the baseline However, GEH (Appendix K) identified the in which they are introduced. Configuration NU MAC documents that cover the Status Accounting includes all the requirements for this plan (BTP 7-14, configurable items.

Section B.3.1.11 ). Based on this information, the staff identified the following question:

Appendix K refers to the SyEDP for the information required in section B.3.1.11.2, procedures. However, the information 14

DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response identified in these sources seem to address only configuration of documents, and not all configuration items (e.g., software tools, source code, etc.). How will GEH control these items?

13. EICB EQ Testing new These items are encompassed by Appendix H. They are specifically identified in Section The system equipment qualification (EQ) 3.3 and qualification approach is discussed in test plan was not submitted with the LAR. Section 5.

Instead the licensee submitted an EQ program in Appendix H. This program states the EQ plans will provide the details on the system to be qualified. Also, that the EQ program provides guidance to prepare EQ plans, if they are necessary. For this amendment, GEH described design changes for the HVPS, Relay Logic Card, and UFP Display. Therefore, a qualification plan for these components should be submitted. ISG-06, Section 0.5.2 describes the information to be provided for the staff to evaluate EQ of l&C systems. Section 0.5.2 requires submittal of the EQ plan.

14. EICB EQ Testing Requirements new The EQ requirements are based on plant conditions:

Are the EQ requirements based on the plant conditions? From NEDC-33864P Appendix H Section 1.1:

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DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response The replacement NUMAC PRNM system is designed to maintain functional operability under conditions specified in the PSEG Hope Creek Generating Station Power Range Neutron Monitoring System (PRNM) Upgrade Project H-1-SE-KDS-0494 [Reference 7.1 ].

The qualification requirements, the subject of this system qualification program, are further delineated in the NUMAC PRNM System Requirements Specification [Reference 7.2].

Reference 7.2 is provided as NEDC-33864P Appendix F Part 1 (NUMAC PRNM System Requirements Specification). Section 2.5 references Hope Creek specification H-1-SE-KDS-0494; the qualification requirements in Appendix F Part 1 Section 9 are obtained directly from the Hope Creek specification.

15. APHB Section D.9.4, Technical Evaluation," of new An analysis, consistent with NUREG-0800, Dl&C-ISG-06, Subsection D.9.4.2.14, "IEEE Appendix 18-A, will be provided Std. 603, Clause 5.14, Human Factors demonstrating that the manual operator Considerations, states, in part, that actions remain both feasible and reliable, and the information provided should be sufficient the ability to perform the actions reliably to demonstrate that the guidance contained within the time available is maintained.

in Standard Review Plan, Appendix 18-A, The analysis will be provided in the HCGS has been met. PRNM Electronic Reading Room portal, in the second quarter of 2016.

NUREG-0800, Standard Review Plan, Appendix 18-A, "Crediting Manual Operator PSEG would like to discuss some Actions in Diversity and Defense-in-Deoth clarifications concernina Aooendix 18-A:

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OOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response (03) Analyses," Revision 0, states, in part, that a diversity and defense-in-depth analysis should include the justification of a. Phase 3 vs Phase 1 required time: If the any operator actions that are credited for required time (and margin to time available) response to an Anticipated Operational has been verified via Phase 3 ISV, is it still Occurrence/Postulated Accident concurrent necessary to perform the Phase 1 time with software Common Cause Failure required estimate?

(CCF). It further states that credited manual operator actions and their associated b. For the two manual operator action items interfaces (controls, displays, and alarms) from the 03 report the HCGS Operators have should be specifically addressed in the multiple existing indications available.

vendor/licensee/applicant's Human Factors Consequently, PSEG does not need the Engineering (HFE) Program. The simulator PRNM digital modification to vendor/licensee/applicant should commit, in support the18-A Phase 3 ISV; the existing the defense-in-depth submittal, to include plant/simulator configuration supports the the proposed defense-in-depth coping ISV. The ISV is scheduled to be completed actions in an HFE Program consistent with in March/April 2016. (Note: if simulator that described in NUREG-0711 and to modifications were required before timing provide the results of the HFE Program to operator actions that could not be done until the staff prior to implementation of the couple of months before modification proposed action(s). implementation, ie 2018)

As stated in NUREG-0800, Appendix 18-A, to credit operator actions, an acceptable method would be to demonstrate that the manual actions in response to a BTP 7-19 software CCF are both feasible and reliable, given the time available, and that the ability of operators to perform credited actions reliably will be maintained for as lonq as the 17

DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response manual actions are necessary to satisfy the defense-in-depth analysis. Changes in plant design, including those that do not add, change, or delete the credited manual operator actions, may affect the ability of operators to correctly and reliably perform manual actions due to performance shaping factors (e.g., workload, time pressure) or other causes.

Provide information regarding the analysis, consistent with NUREG-0800, Appendix A, that was used to demonstrate that the manual actions remain both feasible and reliable, and the ability to perform the actions reliably within the time available is maintained. The analysis should demonstrate that (1) the time available to perform the required manual actions is greater than the time required for the operator(s) to perform the actions, and (2) the operator(s) can perform the actions correctly and reliably in the time available. PSEG should provide sufficient information to demonstrate that the conclusions reached in the previously performed analysis regarding the feasibility and reliability of credited manual operator actions will remain valid in the post-modification environment (i.e., that the time 18

DOC-0006-2118 RO No. Resp. Issue Description Status RAI No. PSEG Response available to perform the required manual actions and the time required to perform such actions will not be adversely affected by the proposed modification).

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ML16064A005 OFFICE DORL/LPL 1-2/PM DORL/LPL 1-2/LA DORL/LPL 1-2/BC DORL/LPL 1-2/PM NAME CParker LRonewicz DBroaddus TWengert DATE 3/04/2016 3/08/2016 3/18/2016 3/22/2016