ML16320A484

Public Telecon Regarding LAR to Upgrade Power Range Neutron Monitoring System (Meeting Handout)

ML16320A484
Person / Time
Site:	Hope Creek
Issue date:	11/15/2016
From:	Office of Nuclear Reactor Regulation
To:
Parker C
References
DOC-0006-2118 R6
Download: ML16320A484 (49)

Text

Updated Issues List for November 15, 2016 Public Teleconference between PSEG LLC and the Nuclear Regulatory Commission Hope Creek Generating Station (HCGS)

Power Range Neutron Monitoring (PRNM) System Digital Upgrade License Amendment Request HCGS NUMAC Upgrade - Open Items DOC-0006-2118 R6

DOC-0006-2118 R6 PSEG Update 11-10-16 HCGS NUMAC Upgrade - Open Items No. Resp. Issue Description Status RAI No. PSEG Response

1. EICB System Description Close No LTR 5.3.1 first bullet discusses APRM chassis and (for large cores) LPRM Appendix R provides responses to plant chassis. NEDC-33864P Appendix A specific responses to the NUMAC LTR. refers to these two chassis as APRM-The response to LTR 2.3.4 identifies the Master and Slave.

configuration for HCGS to be 4 APRM channels with one APRM chassis and Master refers to the APRM chassis and one LPRM chassis. However the LTR Slave refers to the LPRM chassis. These and Appendix A system architecture do terms are used interchangeably.

not describe this.

Appendix A describes a master/slave NEDC-33864P Appendix A page A-11 APRM instrument, but the LTR describes shows the system level architecture.

a LPRM unit not clear how these two concepts relate, if they do.

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

2. EICB System Description Close No The LTR describes variants of PRNM system architecture, depending on Appendix A seems to describe the whether the target application (plant) has generic PRNM system architecture and a large or small core, and whether it is not the architecture for HCGS. What is BWR6 or non-BWR6. Appendix A different between this description and the provides additional details about large one provided in the LTR? core, non-BWR6, such as Hope Creek.

Also there are system differences, which are described in Appendix J. How do The differences described in Appendix J these modules work and fit in the system are not architectural differences.

architecture for HCGS?

3. EICB System Description Close No NRC update 03022016: NRC will identify the documents to be placed in the portal.

Appendix J identifies Hope Creek deviations from the approved generic a) 1

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response NUMAC PRNM system. This is required

• These are GEH references pointing to in ISG-06 Section D.8. where the support for the justification a) Table 1 lists these deviations and is stored in the GEH document provide justifications for such. system. The following two referenced Please provide additional documents can be placed in reading information for the following items: room upon request.

• Column Reference Document

• Item 2 - 001N5637 PRNM Time to

- what are these documents? Calculate Flow-biased Trip Setpoint

• Item 2 - Why the modification

• Item 5 - 001N5640 PRNM Increased for time to calculate flow- Instrument Security biased trip setpoint is a clarification? It seems that the b) total time for the Hope Creek Relay Logic Module and Relay Logic Design has changed. Card refer to the same thing. Hope

• Item 5 - What higher level of Creek will receive the new design.

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.

4. EICB Software Development Plans Close No NRC update 03022016: NRC will identify the documents to be placed in the portal.

The plans submitted describe GEH processes, but they do not include the PSEG is required to create or acquire a activities to be performed by the licensee, number of documents from vendors such as oversight. Please describe the providing safety related equipment per IT-activities and processes for which PSEG AA-101. The purpose of many of these is responsible. documents is to ensure the vendor has a 2

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response quality process in place for software and product design and that the process and design are accurately 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 Engineer determines the scope and breadth of the CDR for the particular application.

A critical digital review is a review of a vendors software QA processes and a technical review (EMI/RFI, failure analysis) of the design, documentation, 3

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response and testing of a digital device determining the software/hardwares 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 theyre 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 throughout the project.

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 4

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response 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 Close No 6/21/2016 The information has been re-classified in The proprietary markings in the 6/9/2016 Appendix B. The NEDC and NEDO appendices are inconsistent. For Since we are not versions of Appendix B with the re-example, information in Sections 4.2 and asking for classified sections will be docketed with 4.3 in Appendix B is not marked additional the PRNM Phase 2 Supplement in proprietary, but this same information is information, this September 2016. If desired the two also provided in Sections 4.2 and 4.3 of does not need Appendix B versions can be placed in the Appendix D, where is marked as to be an RAI. PRNM Reading Room portal in advance proprietary. Just reclassify of the September submittal.

the information already 4/19/2016 provided.

Please provide A complete replacement of Appendix B expected proprietary and non-proprietary with the completion date. corrected pages will be provided.

2/16/2016 Appendix B Sections 4.2 and 4.3 should be marked proprietary to match Appendix D. Updated copies of Appendix B proprietary and non-proprietary can be provided.

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DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response

6. EICB Appendix E, PRNM System Management Close EICB RAI-1 Plan a) Section 2.3 describes how project Close EICB RAI- 6/21/2016 management will be performed. 1a The System Management Plan (SyMP),

This section refers to critical-to- 6/9/2016 Appendix E of the Phase one submittal quality features to be part of the Is the HCGS NEDC-33864P, contains non-commercial management process. However, Project Work information, complementary to what is this plan does no define these Plan available contained in the Hope Creek PRNM features. Since these features are for NRC review? Upgrade PWP. The SyMP does not part of project oversight, please contain Project-specific CTQs, which are describe these features and in in Appendix C of the PWP. Those CTQs which document will they be are:

recorded?

• GEH (internal) CTQs:

o No non-compliance condition report initiate on Project. Comply with GEH policies and procedures, including the requirements described in the project planning documents specified in Section 3.

o Adhere to GEH policies of Integrity, Safety culture principles, Quality and Outputs (ISQO).

o Meet customers expectations, achieve T-NPS score greater or equal to 8.

o Utilize human performance (HU) tools.

o Execute the project in accordance with the Project schedule and meet the established Engineering 6

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response Deliverables (ED) and Customer Deliverables (CD) promise dates.

o Report or escalate to the Engineering Manager and/or PM any issues related to integrity and safety using the issue resolution process (Section 4.2). Safety means both occupational safety and the requirements that will impact the safety functions and operation of the system being design and developed.

• Customer CTQs o Meet project milestones specified in GEH-KT0-182455-005 (Reference B.2.12).

o Timely escalate issues to PM using the escalation process.

2/16/2016 A Project Work Plan (PWP) is required by GEH policies and procedures. As stated in Appendix B Section 3.1.1.5, the PWP contains personnel and commercial information, including project budgetary information that is classified as GEH Proprietary Class III (confidential). The PWP is created and maintained by the Project Manager to manage the commercial aspects of the project.

Critical to quality features are project specific and are listed in the PWP. For Hope Creek, these are listed in Appendix 7

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response C3 of the Hope Creek PRNM Upgrade PWP.

b) Section 2.4.1 describes the Close EICB RAI- A collection of administrative procedures secure development environment. 1b covers specific topics related to the This section states the control secure development environment:

employs in the system

• Asset Identification development should be in

• Secure Development Network accordance with GEH established

• Physical Security procedures, consistent with

• Malicious Code Protection guidance provided in RG 1.152.

• Patch Management Please describe the GEH

• Server and Computer Hardening procedures to be followed for

• Threat Analysis secure development environment.

• Software Usage

• Electronic Access Control

• Log Management

• Personnel Security and Segregation of Duties

• Production Deployment

• 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 Close EICB RAI- 3/15/2016 Supplemental Response establish project quality metrics. 1c However, this section does not NRC Clarification identify the project quality metrics. BTP 7-14 requires the applicant identify the metrics to track progress and determine appropriateness of its software development process. The NRC staff needs a clear description on how the 8

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response licensee is using configuration reviews and technical reviews to measure success or failure of the software development process.

This item is identified in open items: 6c, 7g, 8a, and 11e

Response

The software development process includes a series of technical design reviews and baseline reviews. At the end of each of these reviews, a review report and a scorecard will be issued by the review chair. The review report summarizes the results of the review.

The scorecard evaluates the content of the review material and the performance of the design team based on pre-established criteria also known as metrics, e.g., Did the design team resolve action items assigned at previous reviews, or are acceptable plans in place? A successful review will require a passing grade of 75%. However, any grade below 90% would result in action items to correct the deficiency in the design or in the compliance with the design process. Condition reports will be issued in accordance with GEH problem reporting procedure should a design fail any of the reviews.

2/16/2016 9

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response The Design Review Summary Report and Design Review Scorecard provide a record of quality metrics applied by the Chief Engineers Office. A copy of a scorecard can be placed in the Reading Room upon request.

7. EICB Appendix B, PRNM Systems Close EICB RAI-2 Engineering Development Plan a) Section 2.4.1 of Appendix K Close EICB RAI- When the design team prepares and states the verification of the 2a releases design artifacts, GEH design documents is performed by procedures require the Design team to the design team prior to IVV perform verification of documents prior to activities. But section 2.3 seems the document release. The released to imply that these reviews are document is then provided to the IVV performed by a team independent team who conducts the independent of the design team. In addition, verification in accordance with the section 4.2 of Appendix B also SyIVVP. Conducting the IVV activities describes an independent review defined in the SyIVVP (Section 3.0) team who perform the technical constitutes the Technical Design Review, design review. Please clarify what which is performed by the IVV team and group (in the GEH organization) is supervised by the Chief Engineers performs these independent Office.

reviews.

b) Section 2.4.1 describes the Close EICB RAI- 3/15/2016 Supplemental Response technical design reviews. This 2b section states the design team is NRC Clarification responsible for resolving issues BTP 7-14 requires the applicant identify identified during these reviews. how anomalies are identified, How are these issues being documented, tracked and resolved. The recorded and tracked? Section staff needs a clear description on how 10

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response 4.5 of this appendix describes PSEG and GEH are performing these how deficiencies or discrepancies activities during the design and could be tracked, and Section 7.0 development, V&V, and testing, and then states they could use engineering after the system is installed in HCGS.

change order to handle problems This item is identified in open items: 7b, encountered during product 8a, 8b, and 11f development. But these statements are not specific. In GEH Response addition, it seems that these During design & development of the options are used after delivery of PRNM system for PSEG, the IVV Team the NUMAC system. Please would review and provide comments explain what method will be used about design artifacts at each phase. The to identify and track problems comments and resolutions are archived in identified during the technical the design records in accordance with design reviews. Also, explain the GEH procedures. The comments, process to approve the resolution resolutions and any open items are also of these problems. reported and tracked in Appendix A of the SyVV Task Report or SySA Task Report for each phase as discussed in Section 4.4 of the SyEDP, SyIVVP and SyQAP.

During IVV team testing, when anomalies are observed, they are recorded in the control copy of the test datasheets. The anomalies and the resolutions, which may include changes or corrections to the design, are discussed in the test reports.

An independent engineer is responsible to verify that the content of test report is consistent with the test data sheets. The technical design reviews and baseline reviews will confirm that the acceptance of the resolution and the closure of the 11

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response anomalies or open items. Resolution of all anomalies and closure of all open items are required before the system can be delivered to PSEG.

After GEH delivers the system to PSEG, if an anomaly is discovered it would be tracked in the GEH Corrective Action Program.

PSEG Response As discussed in the response to Open Item (OI) #4, PSEG will continue oversight and audit activities during the design, development, V&V, and testing of the PRNM system. The processes discussed in OI#4 will disposition any anomalies identified. This will include, as appropriate, resolution in the PSEG Corrective Action Program (CAP) -LS-AA-125 - and in the Engineer of Choice (EOC) corrective action program (for the vendor performing the design change package for the PRNM upgrade -

Sargent and Lundy).

During installation and acceptance testing, and after installation, both the PSEG CAP and EOC CAP will be used to identify, document, track and resolve anomalies.

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DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response 2/16/2016 Project specific issues that remain open across project phases are tracked in the task reports. See Section 4.4.2 of the NUMAC Systems Engineering Development Plan. Closure of open items is reviewed as part of subsequent Baseline reviews; open items are resolved and closed prior to completion of the final Baseline review.

c) Section 4.3 states the baseline Close EICB RAI- The SyQA Functional Configuration Audit review team would also review 2c Checklist (NUMAC System Quality and approve development tools. Assurance Plan Section 4.4.1) lists tools Was this necessary for the HCGS that were approved for the associated PRNM system? baseline. A SyQA Functional Configuration Audit Checklist is developed for each Baseline.

Tools are approved for use via the Baseline review process for application to a specific project. Tools were used for the HCGS PRNM system development.

d) Section 5.0 describes the use of Close EICB RAI- 3/15/2016 Supplemental Response development tools. BTP 7-14, 2c Section B.3.1.2.3 requires NRC Clarification licensee to provide a description BTP 7-14 requires the applicant identify of software tools to be used. the software tools used for the Please identify the software development of the system. The NRC development tools. staff needs a list and reference of the 13

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response software tools being used for the development of the HCS NUMAC. During the call, the licensee noted these tools were described in previous license amendments, if this is the case, then the staff needs the references or ML numbers for the documents that described the software tools. This item is identified in open items: 7d and 9b

Response

The Hope Creek PRNM system has similar hardware and software designs as previously approved PRNM projects, e.g.,

Grand Gulf and Columbia. Therefore, the software tools for the HCGS PRNM are the same as those previously described for Columbia in NEDC-33685P Revision 2 (ML12040A074) Section 4.4.6.

2/16/2016 Tools are selected and approved for use throughout the various phases of project.

The approved tools are documented in the SyQA Functional Configuration Audit Checklists (NUMAC System Quality Assurance Plan Section 4.4.1).

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

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DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response e) Section 6.0 describes the secure Close EICB RAI- GEH has a procedure for controlling development and operational 2d access to the NUMAC lab; see response environment. This section states to Open 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 Close EICB RAI- GEH has a procedure for access control development and operational 2d of the secure server, see response to environment. This section states Open Item 6.b.

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

g) Section B.3.1.2.2 of BTP 7-14 Close EICB RAI- 3/15/2016 Supplemental Response requires licensee to identify the 1c See open item 6.c.

indicators to determine the success or failure of the 2/16/2016 development processes. This Success or failure is indicated by the information was not provided in Design Review Summary Report and the engineering development Design Review Scorecard.

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 Close EICB RAI-3 Assurance Plan 15

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response a) General comment: This plan does Close EICB RAI- 3/15/2016 Supplemental Response not cover all the activities 3a and see See open item 6.c and open item 7.b.

identified in section B.3.1.3 of the EICB RAI-BTP 7-14. Specifically, this plan 1c 2/16/2016 does not describe the corrective The NUMAC plans augment and action program, description of QA supplement the GEH QA Program. As procedures, and indicators to stated in Section 1.0 of the NUMAC determine software quality. Systems Quality Assurance Plan, the GEH Quality Assurance Program encompasses quality assurance related activities such as audits, supplier control, and archiving of quality records. Although not explicitly mentioned, the corrective action program is a component of the GEH Quality Assurance Program.

b) Section 3.0 states unresolved Close EICB RAI- 3/15/2016 Supplemental Response configuration items is grounds for 3b See open item 7.b.

failure. How are these issues identified, recorded and tracked? 2/16/2016 Who is responsible for approving Open items are listed in the System resolution of these issues? (see Quality Assurance Configuration Audit open item 7.b) Checklist and tracked in the System Configuration Management Task report (SyEDP 4.4.2). The checklist and task report are part of the Baseline Review Records. These records are approved by the baseline review team, which is chaired by the Chief Consulting Engineer.

c) Section 4.4.1 describes the Close No As discussed in response to Question oversight activity associated with 8.a, the GEH Quality Assurance Program 16

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response quality assurance. Is the activity See EICB has other activities. Problems are tracked described in this section the only RAI-3a in accordance with GEH procedures.

oversight 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 (SIntP) Close EICB RAI-4 GEH did not submit a separate plan for 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 Close EICB RAI-4 6/21/2016 implementation characteristics of As discussed in NEDC-33864P Appendix the SIntP. His section requires 6/9/2016 A, the microprocessor-based NUMAC description of the software This response instruments consist of a chassis and a integration activities. GEH does not complement of modules, which may references SyEDp for this, but address the lack include embedded software. Software SyEDP does not provide enough of integration integration is accomplished by compiling information about the software activity detailed individual software components into integration process. Please in the SyEDP. executable applications that are specific provide this information. to each programmable entity in the modules, integrating those modules into the instruments in which they run, and finally integrating the instruments within the system to perform the system functions. For GEH, software integration 17

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response is performed by the design team and their activities are described in the SyEDP. At completion of design team activities, software and hardware are provided to the Independent Verification and Validation Team who perform independent integration and system testing in a phased approach as detailed in the SyIVVP.

Management Characteristics of the SIntP:

• Purpose - Objectives and scope of a software Integration plan are included within the SyEDP lifecycle process. As part of the Design Phase of the SyEDP, planning is performed and software design specifications are developed which describe major modules, their functions and how the software tasks fit together. In the Implementation Phase, code is assembled into modules and tested as described in Section 3.4.5.2.2, Software Module Testing. After module testing, software is integrated with the hardware and tested as described in Section 3.4.5.2.4, Integration Testing.

• Organization - design team organization is discussed in SyEDP Section 2.2. Scheduling and resource allocation is described in 18

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response SyEDP Section 3.1.1, Project Planning.

• Responsibilities - design team responsibilities are discussed in SyEDP Section 2.1 Implementation Characteristics of the SIntP:

• Measurement - The software development process includes a series of technical design reviews and baseline reviews. At the end of each of these reviews, a review report and a scorecard will be issued by the review chair. The review report summarizes the results of the review. The scorecard evaluates the content of the review material and the performance of the design team based on pre-established criteria also known as metrics. Per SyEDP Section 3.4, integration testing is part of the Implementation Phase (Baseline 4) baseline and technical review.

• Procedures - as indicated in SyEDP Sections 3.4.5.2.2 and 3.4.5.2.4, results, methods, and extent of testing are recorded during the testing and are included in a test item transmittal report.

Resource Characteristics of the SIntP:

• Methods/tools - SyEDP Section 3.4.5.2.2 and 3.4.5.2.4 discusses the 19

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response general methods employed for testing and types of tools used.

Section 5.0 of the SyEDP describes the use of tool evaluation reports and method for approval of development tools which includes tools used for module and integration testing.

2/16/2016 GEH does not have a separate software integration team, rather software integration is performed by the design team. Therefore, the characteristics described in the SyEDP for design team activities apply to integration activities as well. For explanation of how measurement is performed, see response to 6.c.

b) Section B.3.1.4.3 identifies Close No 3/15/2016 Supplemental Response software tools. As mentioned in See open item 7.d.

open item 7.d, these GEH See EICB document do not identify the RAI-2c. 2/16/2016 software tools to be used. Please See response to open item 7.d.

provide this information. Already covered in Open Item No. 7.

10. EICB Software Safety Plan (SSP) Close No The PRNM upgrade is a retrofit system.

GEH did to submit a separate plan for As a retrofit system, the GEH approach to this. However, GEH (Appendix K) software safety planning for PRNM is to identified the NUMAC documents that ensure that the safety significance of the cover the requirements for this plan (BTP PRNM retrofit is consistent with the 20

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response 7-14, Section B.3.1.9). Based on this design basis of the replaced system and information, the staff identified the of the plant. GEH provided details on following question: software safety approach during previous Appendix K refers to the IVVP and SyMP (Grand Gulf and Columbia) projects. See for the information required in BTP 7-14. RAI #1 and 2 in GNRO-2011/00039 However, the information identified in (ML111460590) and Section 4.4.1.9 in these sources seem to address the NEDC-33685 (ML12040A074).

hazard 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 Close EICB RAI-5 Independent Verification and Validation a) Section 2.1 describes the GEH Close No The Chief Consulting Engineer reports to organization. This section states the Chief Engineers Office.

the GEH Chief Engineers 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 Close No 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 21

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response cover evaluation of the documentation.

c) Is the safety analyses described in Close No Hazard analysis is performed during each lifecycle phase considered various lifecycle phases as indicated in to be the hazard analysis Appendix K, Table 5 for cross-reference identified in IEEE Std. 1012? If so, of IEEE Std 1012 to NUMAC process.

will this also include the risk Project risk management is performed analysis identified in IEEE Std. during all system life cycle development 1012? phases in accordance with the GEH Quality Assurance Program d) Appendix K refers to the IVVP Close EICB RAI-5 Project risk management is performed Section 4.0 to confirm item during all system life cycle development B.3.1.10.1, risks. Section 4.0 phases in accordance with the GEH describes the baseline process. Quality Assurance Program. SyIVVP So it is not clear how the baseline Section 4.2 describes Technical Reviews.

process will be used to identify Although not stated in the SyIVVP, the and manage risks associated with GEH procedure for Technical Design the V&V process. Reviews requires risks management.

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

e) Appendix K refers to several Close No 3/15/2016 Supplemental Response sections in the IVVP to confirm See open item 6.c.

item B.3.1.10.2, measurement. See However, the information provided EICB RAI- 2/16/2016 does not clearly define the 1c See response to open item 6.c.

indicators that will be used.

f) Section B.3.1.10.2, procedures Close No 3/15/2016 Supplemental Response requires applicants to describe See open item 7.b.

how anomalies are identified and See reported. This information is not EICB RAI- 2/16/2016 2b 22

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response provide in the plan (See item 11.b Per section 2.2.2 and 2.2.3 of the SyIVV, above) the System Verification Engineer and System Safety Analysis Engineer are responsible for documenting results of reviews including anomalies in their respective tasks reports. The task reports are discussed in sections 4.4.1 and 4.4.2.

12. EICB Software Configuration Management Close EICB RAI-6 SyEDP - section 3.4 specifies Plan (SCMP) configuration management of source code and section 5 specifies configuration GEH did to submit a separate plan for management of firmware. Tools are this. However, GEH (Appendix K) controlled at the baseline in which they identified the NUMAC documents that are introduced. Configuration Status cover the requirements for this plan (BTP Accounting includes all the configurable 7-14, Section B.3.1.11). Based on this items.

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 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 Close No 4/19/2016 The Qualification Summary Report has The system equipment qualification (EQ) been uploaded to the PRNM Reading test plan was not submitted with the LAR. Room portal (Phase 2 folder):

Instead the licensee submitted an EQ 002N9894-PRNM System Qualification program in Appendix H. This program Summary Report_Rev0.pdf states the EQ plans will provide the 23

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response details on the system to be qualified. NRC update 03022016: The qualification Also, that the EQ program provides summary report will provide the guidance to prepare EQ plans, if they are information requested.

necessary. For this amendment, GEH described design changes for the HVPS, These items are encompassed by Relay Logic Card, and UFP Display. Appendix H. They are specifically Therefore, a qualification plan for these identified in Section 3.3 and qualification components should be submitted. ISG- approach is discussed in Section 5.

06, Section D.5.2 describes the information to be provided for the staff to evaluate EQ of I&C systems. Section D.5.2 requires submittal of the EQ plan.

14. EICB EQ Testing Requirements Close No 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:

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].

24

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response 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 Open No 6/21/2016 DI&C-ISG-06, Subsection D.9.4.2.14, The PRNM HFE Assessment (Revision 0)

IEEE Std. 603, Clause 5.14, Human and the PRNM 18-A Assessment Factors Considerations, states, in part, (Revision 0) were placed in the PRNM that the information provided should be Reading Room portal (Phase 2 folder) sufficient to demonstrate that the June 8, 2016, for NRC review and guidance contained in Standard Review feedback prior to docketing with the Plan, Appendix 18-A, has been met. Phase 2 supplement in September 2016:

NUREG-0800, Standard Review Plan,

• PRNM Human Factors Assessment Appendix 18-A, Crediting Manual Rev 0.pdf Operator Actions in Diversity and

• PRNM Appendix 18-A Assessment Defense-in-Depth (D3) Analyses, Rev 0.pdf Revision 0, states, in part, that a diversity and defense-in-depth analysis should 2/16/2016 include the justification of any operator An analysis, consistent with NUREG-actions that are credited for response to 0800, Appendix 18-A, will be provided an Anticipated Operational demonstrating that the manual operator Occurrence/Postulated Accident actions remain both feasible and reliable, concurrent with software Common Cause and the ability to perform the actions Failure (CCF). It further states that reliably within the time available is credited manual operator actions and maintained.

their associated interfaces (controls, displays, and alarms) should be 25

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response specifically addressed in the The analysis will be provided in the vendor/licensee/applicants Human HCGS PRNM Electronic Reading Room Factors Engineering (HFE) portal, in the second quarter of 2016.

Program. The vendor/licensee/applicant should commit, in the defense-in-depth PSEG would like to discuss some submittal, to include the proposed clarifications concerning Appendix 18-A:

defense-in-depth coping actions in an HFE Program consistent with that described in NUREG-0711 and to provide a. Phase 3 vs Phase 1 required time: If the results of the HFE Program to the the required time (and margin to time staff prior to implementation of the available) has been verified via Phase 3 proposed action(s). ISV, is it still necessary to perform the Phase 1 time required estimate?

As stated in NUREG-0800, Appendix 18-A, to credit operator actions, an b. For the two manual operator action acceptable method would be to items from the D3 report the HCGS demonstrate that the manual actions in Operators have multiple existing response to a BTP 7-19 software CCF indications available. Consequently, are both feasible and reliable, given the PSEG does not need the simulator PRNM time available, and that the ability of digital modification to support the18-A operators to perform credited actions Phase 3 ISV; the existing plant/simulator reliably will be maintained for as long as configuration supports the ISV. The ISV the manual actions are necessary to is scheduled to be completed in satisfy the defense-in-depth March/April 2016. (Note: if simulator analysis. Changes in plant design, modifications were required before timing including those that do not add, change, operator actions that could not be done or delete the credited manual operator until couple of months before modification actions, may affect the ability of operators implementation, ie 2018) to correctly and reliably perform manual actions due to performance shaping factors (e.g., workload, time pressure) or other causes.

26

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response 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 available to perform the required manual actions and the time required to perform such actions will not be adversely affected by the proposed modification).

16. EICB System Requirements Close EICB RAI-7 3/15/2016 The Hope Creek System Requirements Appendix F defines the system Specification (Appendix F) is plant requirements for the NUMAC PRNM specific. The following discussion system. It is not clear if these elaborates on how the topics from requirements reflect the system to be 27

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response installed in HCGS. Specifically, does Appendix J are addressed in the Hope appendix F include the requirements for Creek specifications.

the modified components described in Appendix J? LTR Deviations

1. APRM Upscale / OPRM Upscale /

APRM Inop. Appendix F1, Section 6.1 reflects this LTR deviation.

NOTE: Appendix J Reference document 001N5636 can be provided in the reading room portal, if desired. This topic was discussed during previous PRNM projects. Please see, Enclosure 1 (Section 1.5 and Appendix A) of ML12040A073, submitted for Columbia.

2. Time to Calculate Flow-biased Trip Setpoint. This clarifies a statement in the LTR but does not affect the NUMAC PRNM design.

NOTE: Appendix J Reference document 001N5637 can be provided in the reading room portal, if desired. This topic was discussed during a previous PRNM project. Please see, Enclosure 1 of ML12040A073, submitted for Columbia.

3. Abnormal Conditions Leading to Inoperative Status. Appendix F2, Section 4.3.4.9 reflects this LTR deviation.

NOTE: Appendix J Reference document 001N5635 can be provided in the reading room portal, if desired. This topic was 28

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response discussed during a previous PRNM project. Please see Enclosure 1 of ML12040A073, submitted for Columbia.

4. OPRM Pre-Trip Alarms. Appendix F1, Section 4.3.1.2 reflects this LTR deviation.

NOTE: Appendix J Reference document 001N5641 can be provided in the reading room portal, if desired. This topic was discussed during a previous PRNM project. Please see Appendix A (page A-

5) of ML101790437, submitted for Grand Gulf (DSS-CD Plant like HCGS).

5. Increased Instrument Security.

Appendix F1 Section 4.1 (traceable item 436R) provides the higher level requirement that the system provides a means to adjust user-configurable parameters, and Appendix F2 Section 4.4.14 (traceable item 2345R) incorporates the same feature at the instrument level. That the Hope Creek design implements increased security relative to previous applications may be seen by comparing it to a previous application. Please see Section 4.4.8 of 25A5916, APRM Performance Specification for CGS (Reference 64 and included in Appendix A) - ML12040A074 submitted for Columbia. That design includes an OPER-SET function, a 29

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response function that enables the user to adjust a small number of select parameters after entering a password but without placing the instrument in INOP. PSEG elected to not include this feature at Hope Creek.

NOTE: Appendix J Reference document 001N5640 can be provided in the reading room portal, if desired.

6. PRNM System Input Power Source.

The deviation does not affect the PRNM design. Appendix F1 Section 7.5 reflects the type of input power as described in the Hope Creek LAR Attachment 1 Section 4.1.1 page 28 of 46, which deviates from what is described in the LTR.

NOTE: Appendix J Reference document 002N3909 can be provided in the reading room portal, if desired.

Differences from Columbia Generating Station PRNM

1. OPRM Solution. Appendix F1 Section 4.1 (traceable item 225) and 4.3 reflect this difference.

2. Relay Logic Module. The new part is incorporated in schematics and bills of material, which may be placed in the reading room portal if desired. The 30

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response design function is not changed and therefore does not affect Appendix F.

3. APRM High voltage Power Supply.

Appendix F2 Section 4.4.2 (traceable item 2322) reflects this difference (note that Appendix F2 Table 4.3-1 erroneously points to Section 3.3.1 vs 4.4.2 for Manual LPRM I/V curve request).

4. Display of Calibration Constants for LPRM Detector and Flow Signals.

Appendix F2 Section 4.4.5 (traceable item 2287) reflects this difference.

5. Instrument Front Panel Display. The new part is incorporated in schematics and bills of material, which may be placed in the reading room portal if desired. The design function is not changed and therefore does not affect Appendix F.

17. EICB System Requirements Close No 3/15/2016 The requirements marked with brackets in Appendix F defines the system Appendix F are identified for traceability requirements for the NUMAC PRNM purposes. Appendix F also includes system. There are requirements identified several sections that are written in (use of the word SHALL) that do not support of the requirements marked with include identifiers in brackets (e.g., brackets for traceability. Section 4 of Section 5.6). Then there are statements Appendix F1 states The primary system that seems more description than functions of the integrated NUMAC requirements (e.g., Sections 5.4 and 5.5). PRNM replacement system are summarized below, followed by a specific 31

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response Clarify if all sections are requirements for identification of the safety functions of the the system. system. See Sections 5 and 6 for more details on the input and output requirements discussed in this section.

Therefore, Sections 5 and 6 are also considered as requirements although these requirements would not be explicitly traced in downstream documents. For example, it would be cumbersome to establish traceability for the LPRM assignments in Section 5.1. However, each LPRM assignment will be verified and validated in the V&V activities. The bases for the V&V would be Section 5.1 of Appendix F.

18. SRXB HCGS is changing the existing ABB Close No 6/21/2016 OPRM with the BWROG Option III A representative power/flow map was stability solution to the GEH-OPRM with 7/6/2016 placed in the PRNM Reading Room portal the Detect and Suppress Solution- May 18, 2016:

Confirmation Density (DSS-CD) stability SRXB reviewed solution. the

• 003N5661r0_HCGS_OI18_PF representative Map.pdf Submit the HCGS power/flow map power/flow map identifying Scram (Region I) and in the reading 4/19/2016 Controlled Entry (Region II). A plant- portal. PSEG can supply a representative specific power/flow map is required for power/flow map with BSP regions the review of DSS-CD setpoint evaluation 6/9/2016 identified. However, PSEG would like given in Appendix T, HCGS Thermal NRC staff will clarification on the purpose/value of Hydraulic Stability, DSS-CD Evaluation review the providing such a map. The Amplitude of NEDC-33864P. representative Discriminator Setpoint (SAD) and power/flow map minimum time period limit (Tmin) are not dependent on the BSP regions as 32

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response in the reading described in Section 2.1 of NEDC-room portal. 33864P, Appendix T. The ABSP setpoints are developed based on the BSP Region I; however, the methodology described in the DSS-CD LTR is applied to establish or validate the ABSP setpoints (NEDC-33075P, Section 7.4 details ABSP region generation, Section 7.5.4 details ABSP implementation). This methodology will be applied on a cycle specific basis as required by Section 7.5.3 of the DSS-CD LTR. Section 7.2 of the DSS-CD LTR describes the methodology for the generation of the manual BSP regions. With the implementation of DSS-CD there are no changes to the process to determine the cycle-specific manual BSP regions and the existing BSP methodology.

19. SRXB TS Change 8a, Table 3.3.6-2, Page 3/4 Close No 4/19/2016 3-59, Control Rod Block Instrumentation The values provided in TS 3.1.4.3 are for set points: determination of the operating region where the RBM is required to be The proposed new notes a, b, c, and d operable. The 30% and 90% values are identify a low power set point of 28% not associated with the power setpoints.

rated thermal power and a high power The RBM is required to be operable set point of 83% rated thermal power. In above 30% RTP if the MCPR value is the proposed addition to the Applicability below the MCPR value provided in the section for Rod Block Monitor in TS COLR. There will be two MCPR values 3.1.4.3 (Page 3/4 1-18), 30% and 90% provided in the COLR; one that is are proposed. Provide a justification for applicable with power less than 90% RTP and one applicable at or above 90% RTP.

33

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response the margins of 2% for the low set point Unlike the power setpoints described and 7% for the high set point. below, the operability requirements are administrative. The operability requirements were determined by the analysis detailed in Section 3.5 of NEDC-33864P, Appendix S.

TS Table 3.3.6-2 has the added notes a, b, c, and d which identify the LPSP, IPSP, and HPSP. These setpoints are used to distinguish rated thermal power ranges that apply to the power trip setpoints.

Section 3.3.1 of NEDC-33864P, Appendix S details the analysis completed for the determination of these values. Analytical Limits for the LPSP, IPSP, and HPSP are provided in Tables 5 and 6 of Appendix S while the Allowable Values and Nominal Trip Setpoints are provided in Section 3 of Appendix P2. Allowable Values are used in TS for the power setpoints; the analytical limit for the LPSP is 30%.

The RBM is automatically bypassed below the LPSP in accordance with the 30% operability criteria described above.

The HPSP does not represent an automatic bypass and is not associated with the 90% operability criteria.

20. SRXB (a) TS 6.9.1.9, Page 6-20, Core (a) Close No 6/21/2016 Operating Limits Report: (b) The proposed revisions to TS 6.9.1.9 (b) Close are consistent and appropriate for the existing HCGS (non-improved standard) 6/9/2016 TS.

34

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response Add or provide justification for not The Columbia As noted in the previous response, including the following staff-approved LAR is not Appendix A of NEDC-33075P-A provides LTRs as references: exactly like the DSS-CD changes to the GE improved Hope Creek standard TS and Bases. PSEG does not

• NEDC-33075P-A, Revision 8, GE LAR - Columbia have improved standard TS/Bases; the Hitachi Boiling Water Reactor Detect was not putting language in TS 6.9.1.9 is different than and Suppress Solution-Confirmation in DSS-CD. It is the language in improved standard TS Density, November 2013. not clear how 5.6.3. Specifically, Hope Creeks the proposed language is: Core operating limits shall

• NEDC-32410P-A, Supplement 1, addition of be established and documented in the Nuclear Measurement Analysis and 3/4.3.1 and PSEG Nuclear LLC generated Core Control Power Range Neutron 3/4.3.6 will Operating Limits Report before each Monitor (NUMAC PRNM) Retrofit Plus satisfy Item 1 of reload cycle, or any remaining part of a Option Ill Stability Trip Function, Appendix A, reload cycle for the following Technical November 1997. 5.6.3(a). DSS- Specifications:. The difference is Hope CD LTR NEDC- Creeks language points to the specific

• NEDC-32410P-A, Nuclear 33075P-A, Technical Specifications; whereas, the Measurement Analysis and Control Appendix A improved TS 5.6.3 (and CGS and NMP)

Power Range Neutron Monitor states that For language uses the phrase for the (NUMAC PRNM) Retrofit Plus Option DSS-CD, the following:; i.e., it is not pointing to the Ill Stability Trip Function, October following is specific Technical Specifications but 1995. required in leaving it open to what is described in the addition to the following. Therefore, consistent with the (b) TS 6.9.1.9, Page 6-20, Core normal list of HCGS language and the current listing of Operating Limits Report: limits. TS in TS 6.9.1.9, the specific TS affected by the PRNM/DSS-CD upgrade have The following is provided in the DSS-CD been added to the list.

LTR NEDC-33075P-A, Revision 8, Appendix A, Example of Changes to 4/19/2016 BWR/4 Standard Technical Specifications, TS Section 5.6.3, which is (a) NEDC-33075P-A, Revision 8 (DSS-not included in the proposed CD LTR) is incorporated by reference:

Administrative Controls section of the Section 3.2 of Appendix T (NEDC-35

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response technical specifications, Page 6-20, 33864P) includes the disposition of 6.9.1.9, Core Operating Limit Report: Limitation and Condition 5.2 which indicates that GESTAR (Global Nuclear

[For DSS-CD, the following is required in Fuel, General Electric Standard addition to the normal list of limits.] Application for Reactor Fuel, NEDE-24011-P-A-22 and NEDE-24011-P-A 1. The Manual Backup Stability US.), which includes reference to the Protection (BSP) Scram Region (Region DSS-CD LTR, is referenced in TS 6.9.1.9.

I), the Manual BSP Controlled Entry NEDC-32410P-A (PRNM LTR) is not Region (Region II), the modified APRM required, or appropriate, to include in the flow-biased set point used in the OPRM, COLR list of references. The PRNM LTR Automatic BSP Scram Region, and the does not provide any analytical BSP Boundary) for Specification 3.3.1.1. methodology for determining operating limits contained in the COLR. The PRNM Explain in detail why the above LTR references were also not included in requirements given in the DSS-CD LTR the approved changes to TS 5.6.3 are not in the proposed TSs. The NRC (COLR) for the Columbia Generating staff acknowledges that HCGS is not Station PRNM upgrade (ADAMS using BSP Boundary, but justification is ML13317B623).

needed as to why the other regions are not applicable. (b) Appendix A of NEDC-33075P-A provides DSS-CD changes to the GE improved standard TS and Bases; PSEG has included appropriate language for the HCGS TS Bases. The limits in question are applicable to HCGS and are provided in the proposed changes to TS 6.9.1.9.

This is indicated in mark-up of TS 6.9.1.9 by the addition of TS 2.2 (Reactor Protection System Instrumentation Setpoints) and TS 3/4.3.1 (Reactor Protection System Instrumentation) to the list of applicable TS. The proposed 36

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response changes to TS 2.2 and 3/4 3.1 indicate COLR provided values for the indicated limits. The proposed changes to HCGS TS 6.9.1.9 are similar to the approved changes to TS 5.6.3 (COLR) for the Columbia Generating Station PRNM upgrade.

21. SRXB TS Bases Insert 1, Page 3 of 5, 2.f. (a) Close No 4/19/2016 OPRM Upscale:

(b) Close No (a) The TS Bases will be revised in (a) Add GDCs 10 and 12 and revise the accordance with the Open Item.

first sentence as follows to be consistent with Appendix A of NEDC-33075P-A: (b) Note (m) does not reflect a need, rather it describes an option (to prevent The OPRM Upscale Function provides spurious scrams) that that plant may or compliance with GDC 10 and 12, thereby may not choose to implement, consistent providing protection from exceeding the with NEDC-33075P-A, Section 3.2.6.

fuel safety limit (SL) MCPR due to Information on Note (m) is included in the anticipated thermal-hydraulic oscillations. TS Bases consistent with the level of (b) Add the following to be consistent detail in the existing HCGS TS Bases, with Appendix A (page A-20) of NEDC- and consistent for a one-time note. Also 33075P-A: refer to the response to OI#23.

Note (m) in TS page 3/4 3-5 reflects the need for plant need for data collection in order to test the DSS-CD equipment.

Testing the DSS-CD equipment ensures its proper operation and prevents spurious reactor trips. Entry into the DSS-CD Armed Region without automatic arming of DSS-CD during this initial testing phase allows for changes in 37

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response plant operations to address maintenance or other operational needs.

22. SRXB Enclosure 3, NEDC-33864P, Appendix I, 6/9/2016 6/21/2016 Diversity and Defense in Depth (D3) (a), (d) As discussed during the April 19th Analysis: (a) Close No call: PSEG stated that it could not place the EPRI report in the project reading (a) Section 1.2, Background 6/9/2016 room (PSEG does not own the report, it The NRC staff must be obtained directly from EPRI).

PRNM LTR NEDC-32410P, Section 6.4, requests PSEG However the NRC could view Table F-1 in provides a D3 assessment using EPRI to place EPRI the CGS PRNM submittal - it was Report No. NP-2230, Part 3, ATWS Report NP-2230 understood that the NRC staff would look Frequency of Anticipated Transients. in the reading at the CGS document. This was further Section 6.4.1 refers to Table F-1. NRC room for review. discussed and agreed to in the response staff review of this table is required to to OI#26. To further facilitate the review, No verify that for each event for which the (b) Close a copy of the table has been placed in the PRNM may be called upon to initiate PRNM Reading Room portal (refer to SRXB RAI-scram, there is at least one other (c) Close updated OI#26 response).

1 parameter processed by a different type of I&C equipment that provides a diverse 6/9/2016 4/19/2016 means of detecting the event and Staff will review initiating a scram. This table is required the document in (a) The table NEDC-32410P-A Section for the review of Table 4.1, Assessment the reading 6.4 refers to is in NEDC-30851P-A, which of HCGS AOOs. Please submit the room. No references the EPRI report. NEDC-EPRI report. 30851P-A was reviewed and approved (b) Section 4.1.2, Instability, page I-9, (d) Close previously, so it does not seem necessary states: to submit the EPRI report.

6/9/2016 The table from NEDC-30851P-A was also The postulated CCF in the PRNM Table 4.1 does reproduced in the Columbia PRNM LAR.

system results in the system providing not provide See NEDO-33694 (ML12040A076),

valid indications of plant conditions until sufficient containing the D3 analysis for the the stability transient occurs information. Columbia PRNM. The Hope Creek LAR Assuming the failure of PRNM due to The staff will supplemented this analysis with NEDC-review the EPRI 33864 Appendix I, which includes an 38

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response CCF, which system will provide the valid Report in an evaluation of each event in the Hope indications during instability events? effort to resolve Creek UFSAR against the criteria in BTP the issue. 7-19.

(c) Section 4.1.2, Instability, pages I-9 and I-10: (b) The diverse systems that provide valid indications are described in Appendix I Provide the TRACG transient results Section 4.1.2, starting with the last plots for the limiting cases to demonstrate paragraph on page I-9 (2RPT scenario) that the SLMCPR is not exceeded for and the last paragraph on page I-10 these events. (LFWH scenario).

(d) On page I-14, the response to BTP 7-19 Criterion 7 states: (c) The requested plots for the limiting cases are provided in GEH Document instability is the only AOO requiring a 003N5152, Revision 0. This document diverse protection method. Please has been placed in the PRNM Reading provide justification for this conclusion. Room portal.

Revise Table 4-2 to show that this conclusion is valid. (d) The quoted section refers to Section 4.1, which includes Table 4.1 (not Table 4.2). Generic and plant-specific discussions are provided in Table 4.1 for each event except instability justifying that there is no threat to the applicable limits (BTP 7-19 Criterion (1)) posed by a CCF in PRNM in conjunction with the event.

23. SRXB Enclosure 3, NEDC-33864P, Appendix Close No 4/19/2016 R, Plant Responses Required by PRNM The response is provided in GEH LTR: 6/9/2016 Document 003N5152, Revision 0, which The NRC staff has been placed in the PRNM Reading On page R-21, the licensee provided the will review the Room portal.

following response: document in the reading room.

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DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response Regarding the initial monitoring period, the GEH NUMAC OPRM system can be installed and activated immediately without an initial monitoring period because: 1) The operating experience of the GEH NUMAC OPRM system in general is sufficient, 2) The GEH NUMAC OPRM system is replacing the current Option III OPRM system, 3) (( )). The DSS-CD LTR does not require an additional monitoring period.

Every plant PRNMS is unique and, therefore, a monitoring period is required.

Because only a few BWRs have implemented DSS-CD, there is insufficient operating data to justify a deviation from the staff position discussed in the approved LTR (SER Section 3.2.6, First Cycle Implementation). Please provide justification for not requiring an additional monitoring period.

24. SRXB Enclosure 3, NEDC-33864P, Appendix S, Close No 6/21/2016 Supplemental Information for ARTS for As stated below, there is no approved HCGS. 6/9/2016 ARTS LTR; also note that Appendix S The generic Section 3.3.1 does not refer to GESTAR The Section 3.3.1 analyses refer to a statistical for the generic statistical analysis. The generic statistical analysis for application analyses refer to information provided in Appendix S is to all BWRs, including HCGS. Identify GESTAR consistent with the level of information the staff-approved LTR section that NEDE-24011-P- that was provided for Columbia which approved the generic statistical analyses. A. During the 40

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response staffs review of implemented full ARTS (NRC SE:

this document, it ADAMS ML13317B623).

was unable to identify the 4/19/2016 source for Table There is no NRC approved ARTS LTR; 2 of Appendix S ARTS are individually analyzed and and the approved for each plant. ARTS applicability of (concurrent with MELLLA) for HCGS was Table 2 to Hope approved by Amendment 163 (ADAMS Creek. ML060620500). A HCGS-specific Typically, there ARTS/MELLLA safety analysis report will be a generic (A/MSAR), NEDC-33066P, was submitted LTR approved to support the change. As discussed in by the staff for NEDC-33864P Appendix S, the the approval of implementation of the NUMAC PRNM the statistical allows for the hardware portion of ARTS analyses. The to be installed thus allowing the transition staff needs to to full ARTS.

see this generic analyses for rod withdrawal error (RWE).

25. SRXB Enclosure 3, NEDC-33864P, Appendix T, (a) Close No 6/21/2016 HCGS Thermal Hydraulic Stability, DSS- (e) Hope Creek has never experienced CD Evaluation: (b) Close No feedwater temperature reduction greater than 102 °F.

(a) Section 2.1 DSS-CD Set points:

(c) Close No As a part of DSS-CD implementation, 4/19/2016 the applicability checklist is incorporated into the reload evaluation process and is (a) The DSS-CD implementation at documented in the Supplemental Reload (d) Close No HCGS is based on GE14 fuel and is done Licensing Report (SRLR). Submit the per the DSS-CD LTR (NEDC-33075P-A, SRLR for GNF2 fuel to verify the DSS-CD (e) Close No Revision 8).

41

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response implementation process. (Confirmatory The DSS-CD stability section of the SRLR item) 6/9/2016 is of a standard format, which includes Some plants the confirmation checklist. If required, (b) HCGS plans to transition from GE-14 have GEH can provide the reference of a to GNF2 during the implementation of experienced representative DSS-CD SRLR already PRNMS. Resubmit Appendix T, HCGS larger feedwater issued for another plant.

Thermal Hydraulic Stability DSS-CD temperature Evaluation and Appendix S, reduction than (b) The PRNM license amendment Supplemental Information for ARTS for the reduction request is based on the GE14 fuel design HCGS, for the GNF2. RWE analysis was value assumed that is currently in operation at Hope done for Cycle 13. RWE analyses are in the analyses. Creek.

required with the GNF2 fuel. Have there been The DSS-CD implementation at HCGS is (Confirmatory item) any instances at per the DSS-CD LTR (NEDC-33075P-A, Hope Creek Revision 8). Any future implementation of (c) HCGS plant-specific LPRM/APRM when the a new fuel design at HCGS, such as data was gathered during Cycle 18 and feedwater GNF2, will be addressed through the Cycle 19 at lower power/flow conditions, temperature approved DSS-CD process described in rather than at full power/flow conditions. decreased more Section 6.1of the LTR. Plant-specific Please justify why it was not necessary to than 102 review and approval is not required for collect data at full power/flow conditions. degrees F? fuel transition as stated in Items 7 and 9 (d) In Table 2-1, a Checklist in Section 6.0 of the Safety Evaluation of Confirmation is provided. The NRC staff (f) Close SRXB RAI- the DSS-CD LTR (NEDC-33075P-A, may perform an audit to verify the 2 Revision 8).

confirmations done for all the 6/9/2016 As stated in the first paragraph of Section parameters. 3.3.1 of Appendix S, A generic statistical The staff will analysis for application to all BWRs (e) The rated feedwater temperature review the including HCGS has been performed and reduction is provided in Table 2-1. information in is summarized in Table 2. The Historically, what has been the maximum the reading application of these results is validated for feedwater heater temperature reduction room portal. GE and GNF fuel and core design for experienced at HCGS? each reload analysis in accordance with (g) Close No Reference 2. (Reference 2 being GESTAR-II). Consequently, the 42

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response (f) The TRACG confirmatory best- application of the generic statistical estimate MCPR margins to the SLMCPR analysis is not dependent on plant type, were calculated and are summarized in specific core design, or specific GE / GNF Table 2-2. Submit the detailed plots that fuel design. The application of these include the important parameters for the results will be validated on a cycle most limiting case. specific bases including consideration of any future new fuel designs, such as (g) Table 3-1, Disposition of Limitations GNF2, as described in Section 1.2.6 B of and Conditions: GESTAR-II.

In the table, only Condition 9.18 is (c) Thermal-Hydraulic instabilities are not addressed. Please address all (except of concern at rated conditions and the for MELLLA+ items) conditions and DSS-CD system is not armed at rated limitations identified in the SER for conditions. Therefore, data collected at NEDC-33173P, Applicability of GE rated conditions is not of interest for DSS-Methods to Expanded Operating CD applications.

Domains.

(d) No response required.

(e) Hope Creek is licensed to operate at rated thermal power with feedwater at a minimum temperature of 329.6 °F (HCGS FOL 2.C.11). This corresponds to a 102

°F reduction from the rated feedwater temperature of 431.6 °F. PSEG would like clarification on why the maximum historical feedwater temperature reduction value is required in support of the value indicated in Table 2-1.

(f) The requested plot for the cases listed in Table 2-2 is provided in GEH Document 003N5152, Revision 0, which 43

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response has been placed in the PSEG Reading Room portal.

(g) The DSS-CD methodology is used for the detection and suppression of thermal-hydraulic instability. Only NEDC-33173P limitation and condition 9.18 is associated with stability and therefore is the only limitation and condition discussed in Section 2.1(Page T-5) and addressed in Table 3-1 of Appendix T.

26. EICB Appendix R, Section 6.6 of Reference 1, Close No 6/21/2016 System failure Analysis, item 1, states a A copy of the table has been placed in the similar Table to F-1 provided in 6/9/2016 PRNM Reading Room portal:

Reference 11 (NEDC-30851P-A) of the The table from PRNM LTR is included in the HCGS NEDC-30851P-

• NEDC-30851P-A_Table F-1.pdf defense-in-depth and diversity analysis. A was also However, Appendix I of the LAR does not reproduced in Also see OI#22a response.

include this table. PRNM LTR Section the Columbia 6.4.1 requires identification the diverse PRNM LAR. 4/19/2016 parameter monitored to detect symptoms See NEDO- The reference to Appendix I Table F-1 is of each event. This table should include 33694 an editorial error. During the preparation each event in Chapter 15 of HCGSs SAR (ML12040A076), and review of the content that became where an APRM-based scram trip is containing the Appendix I, it was decided to not credited in the analysis. D3 analysis for reproduce Table F-1 from NEDC-30851P-the Columbia A, as was done during a previous LAR.

PRNM. (See response to Open Item #22a.)

If a copy of the table is necessary to complete the Hope Creek PRNM review, the table was provided previously, as discussed in response to Open Item 44

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response

1. 22a. It can be provided again in the reading room portal.

Note that each event from Hope Creek UFSAR Chapter 15 was evaluated, and those that could be affected by a CCF in PRNM are discussed in Appendix I Section 4.1 and 4.2.

27. EICB Appendix I provides the defense-in-depth Close No 4/19/2016 and diversity analysis for HCGS. This Each of the BTP 7-19 criteria are appendix does not include analysis for addressed in Appendix I. The criteria that the potential of the PRNMS to adversely directly address the potential of the affect other echelons of defense (e.g. the PRNMS to adversely affect other control echelon). Please describe how echelons of defense may be found in other echelons of defense could not be Table 4.2. For example, The discussion adversely influenced by interfaces with about the potential for PRNMS to the PRNMS. adversely affect the control echelon is addressed in Criterion (3).

A similar discussion has been provided in previous submittals:

Refer to RAI #9 in GNRO-2011/00039 (ML111460590) for GGNS, NEDC-33694P (ML12040A076) for Columbia.

28. EICB LAR Section 4.1.1 states, in part, that: Close EICB RAI-8 6/21/2016 The statement was not meant to imply All interfaces with external systems are that any of the PRNM system interfaces maintained electrically equivalent using do not maintain electrical compatibility.

interface subassemblies with exception of This statement indicates that all interfaces the interface to the plant computer and other than those mentioned are plant operator's panel. electrically equivalent to the existing system, as discussed in the PRNM LTR Section 2.1.2.

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DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response As written, this statement implies that plant computer and operators panel The plant computer interface is modified interfaces do not maintain electrical by deleting the existing physical I/O and compatibility between the PRNMS and implementing a data link.

these systems. The NRC staff needs to understand the nature of this exception in The plant operators panel interface is order to determine if these interfaces are modified by the addition of Operator compliant with independence criteria of Display Assemblies.

IEEE 603. Please provide additional information describing this exception as Hope Creeks proposed design conforms well as a justification for why this to descriptions of these interfaces in the exception is acceptable from a functional PRNM LTR. The system compliance with and system independence perspective. electrical independence is addressed in Appendix L of NEDC-33864P.

29. EICB The NUMAC Systems Independent Close No 7/19/2016 Verification and Validation Plan As stated in the SyIVVP (NEDC-33864P, (Appendix D) identifies two members of Appendix D, Section 2.2.1), the the NUMAC IVV team as; the System responsibilities of the IVV team include:

Verification and Validation Engineer and the System Safety Analysis Engineer and

• Prepare equipment qualification defines roles and responsibilities for test plans and procedures these positions in Sections 2.2.2 & 2.2.3

• Perform equipment qualification respectively. The Hope Creek NUMAC testing/analysis and document the System Management Plan however, results identifies a third position of System Test

• Summarize equipment and Qualification Engineer as a member qualification results in a of the IVV team (See Figure 2-1 and qualification summary report Section 2.2.4 of Appendix E). The responsibilities for this third position are The SyIVVP also states that the IVV team not defined in either Appendix D or reports to the Chief Engineers Office E. The NRC staff requests information of (CEO) and that the CEO may draw upon the roles and responsibilities for the Test subject matter experts from anywhere 46

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response and Qualification Engineer be provided to within the GEH engineering support the staffs determination of population. GEH Engineering has a team NUMAC V&V effectiveness. of Test and Qualification Engineers who are responsible for the testing and qualification of all types of equipment, including mechanical and analog devices. Members of this team are logical candidates for performing the test and qualification of the PRNM equipment for Hope Creek. However, the candidate must be approved by the CEO. Therefore, the role and responsibilities of the Test and Qualification Engineer are as stated in the three bullets above from the SyIVVP.

30. EICB Regulatory Audit Request for Documents New 11/10/2016 to be put on Portal. The following The requested documents were placed in documents were requested: 11/02/2016 - rjs the electronic portal.

Confirmed

• PRNM System Validation Test requested Procedure 002N5897 documents are

• APRM IVV Module Test on portal and Procedure 002N7588 are accessible.

• APRM Integration Test Cases and Procedures (ITCP) 002N5941

• Licensing Oversight Audit Reports (2); Gavial, and FAT.

• Condition Report 13702 (Self Identification of Traceability Issue)

• Functional Software Code Review Report 002N6392 47

DOC-0006-2118 R6 PSEG Update 11-10-16 No. Resp. Issue Description Status RAI No. PSEG Response

• Hope Creek APRM Functional Test Item Transmittal Report 002N6397

• Engineering Change Order 0021902

• DBR 0013981

• Quality Control Work Instructions:

o 23-303-10 o 23-310-11 23-310-11(G01)

31. EICB Traceability of Design Constraints. The New 11/10/2016 NRC staff notes that Traceability Design constraints for the HC PRNM Guidance requires objects identified to be project were linked using DOORs. The design constraints (DC) to be out-linked guide (procedure) was developed very to IPS requirements. During the audit early in the project. Actual implementation however, the NRC was unable to follow was to link from design constraints to such a thread for a selected DC. We lower level documents but not the other would like to understand how this way around. Also, design constraints procedural requirement is being met if not were not included in the embedded tables through the imbedded requirements to limit the size of the tables. The design tables of the SDS and IPS documents. team review scope of the SDSs included specific direction to confirm that IPS design constraints and requirements were implemented in the SDS. Additionally, both requirements and design constraints were part of the IVV scope for independent verification and validation activities.

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