ML14295A733

9/24/14 Summary of Meeting with Pacific Gas and Electric Company to Discuss Digital Replacement of Process Protection System at Diablo Canyon Power Plant, Units 1 and 2 (TAC Nos. ME7522 and ME7523)

ML14295A733
Person / Time
Site:	Diablo Canyon
Issue date:	11/17/2014
From:	Oesterle E R Plant Licensing Branch IV
To:
Oesterle E R
References
TAC ME7522, TAC ME7523
Download: ML14295A733 (30)

Text

LICENSEE:

FACILITY:

SUBJECT:

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

SUMMARY

OF SEPTEMBER 24, 2014, TELECONFERENCE MEETING WITH PACIFIC GAS AND ELECTRIC COMPANY ON DIGITAL REPLACEMENT OF THE PROCESS PROTECTION SYSTEM PORTION OF THE REACTOR TRIP SYSTEM AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEM AT DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 (TAC NOS. ME7522 AND ME7523) On September 24, 2014, a Category 1 teleconference public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Pacific Gas and Electric Company (PG&E, the licensee) at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland.

The purpose of the teleconference meeting was to discuss the license amendment request (LAR) submitted by PG&E on October 26, 2011, for the Digital Replacement of the Process Protection System Portion of the Reactor Trip System and Engineered Safety Features Actuation System at Diablo Canyon Power Plant, Unit Nos. 1 and 2 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 113070457).

The meeting notice and agenda dated August 7, 2014, are available in ADAMS Accession No. ML 14219A658.

A list of attendees is provided in Enclosure

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

2. Highlights from this meeting include the following:

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

2.

• The project plan for the review of the LAR was discussed and the major upcoming milestones were confirmed.

The current version is provided with this meeting summary as Enclosure

3.

• A tentative date of November 18, 2014, was established as a target for the next periodic meeting. Four members of the public were in attendance for the teleconference meeting and no public meeting feedback forms were submitted. Please direct any inquiries to me at 301-415-1014 or at Eric.Oesterle@nrc.gov.

Docket Nos. 50-275 and 50-323

Enclosures:

1 . List of Attendees

2. Staff Identified Issues That are Open 3. Project Plan cc w/encls: Distribution via Listserv Eric R. Oesterle, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation LIST OF ATTENDEES SEPTEMBER 24, 2014, TELECONFERENCE MEETING WITH PACIFIC GAS AND ELECTRIC COMPANY DIGITAL UPGRADE FOR DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-275 AND 50-323 NAME K. Schrader J. Hefler K. Durinsky A. Breneman W. Odess-Gillet T. Tuite M. Shaffer E. Matusek D. Head Rich Stattel Samir Darbali Rossnyev Alvarado Shiattin Maker Margaret Watford Gordon Clefton T. Bolian F. Ricart D. Mills ORGANIZATION Pacific Gas and Electric A It ran Westinghouse Westinghouse Westinghouse Westinghouse

Westinghouse Westinghouse lnvensys Nuclear Regulatory Commission (NRC) NRC NRC NRC NRC Nuclear Energy Institute AREVA AREVA California Energy Commission Enclosure 1

ENCLOSURE 2 STAFF IDENTIFIED OPEN ISSUES LISTING PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT. UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323 October 22, 2014 DCPP PPS Open Item Summary Table Page 1 of 21 No Src/RI Issue Description P&GE response:

Status RAJ No. RAJ Comments (Date Sent) Response (Due Date) 93 RJS (ALS Audit Item) Open 9/18/14 -Ask if new version of the The RTM for the ALS subsystem was prepared using Westinghouse ALS RTM can be document WNA-DS-02442 to trace PG&E requirements.

The IV&V team put on sharepoint now. If so then I found that Westinghouse document WNA-DS-02442 does not capture all could complete the PG&E requirements (see descriptions for Tickets #4787 and #4800). RTM evaluation Please provide a description of how this issue is being resolved.

and possibly some threads. 4/16/14 -Updated PG&E Response:

The 6116-00000 Diablo ALS Management Plan, revision 4, specifies an RTM to be made available prior to updated document structure that has all PG&E Customer Requirements ALS audit. feeding directly into the 6116-00011, which will flow down into all ALS Diablo sub-ordinate requirement and design specifications.

Westinghouse 12/12/13-RJS document WNA-DS-02442 has been removed from the document Current version of hierarchy.

6116-00000, revision 4, 6116-00011, revision 1, and the 6116-6116-00059 on 00059 RTM, revision 0, are all reflective of this new document structure.

sharepoint is "0." Documents 6116-00011, revision 1, was submitted under PGE Letter DCL-This does not establish 13-087 dated September 17, 2013. The next revision of the 6116-00059 traceability to the RTM, Revision 1, will include traceability to the Core FPGA Design Core FPGA Design Specifications, and will be submitted prior to the ALS audit. Specifications.

10/16/13-RJS New RTM still does not establish traceability to the 6116-10203, and 6116-10204 Core FPGA Design Specifications.

Also A new revision of 6116-00059 will need to be October 22, 2014 DCPP PPS Open Item Summary Table Page 2 of 21 No Src/RI Issue Description P&GE response:

Status RA/No. RAI Comments (Date Sent) Response (Due Date) docketed due to the significance of changes made since the original document was submitted.

6116-00011, ALS SDS, revision 1 6116-00059 ALS RTM, revision 0 They are both available in the Sharepoint SDS Rev. 0 is already on docket. [ML11277A152]

RTM to be submitted on Docket. 94 RJS The ALS Topical Report Plant Specific Action Items will be made available Open RAI59 4/30/14 9/18/14 -Provide to Westinghouse.

When these are available, PG&E should prepare a status of ALS PSAI document to identify how each applicable PSAI is being addressed for the evaluations

-PPS project. This document should include references to the LAR and ongoing. Ask about September supporting documents where PSAI's are addressed.

due date for remaining PSAI PG&E Response:

responses.

The response to the ALS ASAis requires input from Westinghouse and a contract has been created to supply the required information.

The 5/16/14 Hold this response to the ASAis, except 4, 5, 6, 8, 1 0, 20, and 22, will be open until all ASAI's are ---

October 22, 2014 DCPP PPS Open Item Summary Table Page 3 of 21 No Src/RI Issue Description P&GE response:

Status RAI No. RAI Comments (Date Sent) Response (Due Date) submitted by March 24, 2014. The response for PSAis 4, 5, 6, 8, 10, addressed.

20, and 22 will be submitted by November, 2014. 4/16/14 -RAI ASAI4 response will only be partial. 16 of 23 PSAI's will be Status: Response to this ASAI when the ALS platform EO [EMC] testing is addressed.

7 will complete and the EO summary report is updated and the hardware be deferred by 90 detailed design is complete.

days. Waiting for input from WH on ASAI5 additional testing. 12/12/13-RJS A ALS Platform Application Restrictions

-An applicant or licensee referencing version of the ALS this SE should address its adherence to the manufacturer identified TR I SE is now application restrictions within the "ALS Application Guidance" (see available and being Reference 41 ). An applicant or licensee referencing this SE should identify reviewed.

the applicability of each restriction.

For each applicable restriction, the applicant or licensee should either demonstrate its adherence or provide justification for excluding the restriction.

For any exclusion, an applicant or licensee should also demonstrate the exclusion does not invalidate the ALS platform qualification in a manner adverse to the reliable performance of a safety function.

Such demonstrations should consider performance of supplemental testing, supplemental analysis, or both. PG&E Response:

Reference 41, 6002-00008, "ALS Application Guidance," Revision 4, has been updated to Revision 5. (note, 6002-00008, is expected to be revised again upon completion of additional ALS EO [EMC] testing).

The PPS ALS subsystem adherence to the ALS platform application restrictions specified in 6002-00008, Revision 5, is described in Appendix D of 6116-00011, Revision 4, "ALS Subsystem System Design Specification."

October 22, 2014 DCPP PPS Open Item Summary Table Page 4 of 21 No Src!RI Issue Description P&GE response:

Status RA/No. RAI Comments (Date Sent) Response (Due Date) ASAI6 Status: Response to this ASAI when the ALS platform EQ [EMC] testing is complete and the EQ summary report is updated and the hardware detailed design is complete.

Details for response to this ASAI are expected to be included in the document 6116-00204, Revision 0, "PPS ALS Subsystem Equipment Qualification Evaluation." ASAI8 Deterministic Performance

-As discussed within Section 3.4.2, an applicant or licensee referencing this SE should confirm the application specifications identify the board access sequence, frame time, and implementation of the design features to activate system alarms upon detection of a failure to meet timing requirements, so an operator can take corrective action. An applicant or licensee referencing this SE should also verify the application-specific logic does not introduce non-deterministic computation or non-deterministic digital data communications.

PG&E Response:

The PPS ALS subsystem design is consistent with the discussion in Section 3.4.2 of the SE. 6116-10203, Revision 2, "ALS-102 Core A FPGA Software Design Specification," Section 5.5 identifies the sequence and timing of RAB transaction (board access) assignments during each frame. Specifically, Table 5.5-1 specifies each sequencer step. 6116-10204, Revision 1, "ALS-1 02 Core B FPGA Design Specification," subsection 4.4.3 identifies the sequence and timing of RAB transaction (board access) assignments during each frame. Specifically, Table 4.4-2 specifies each sequencer step. ----

October 22, 2014 DCPP PPS Open Item Summary Table Page 5 of 21 No Src/RI Issue Description P&GE response:

Status RA/No. RAI Comments (Date Sent) Response (Due Date) 6116-00011, Revision 4, "ALS Subsystem System Design Specification," Requirement R1000, and 6116-10201, Revision 2, "ALS-102 FPGA Requirements Specification," Requirement R5000, specify the ALS subsystem frame time as 1 0 milliseconds.

ALS platform-specific self-diagnostic fault conditions are supplemented by an application-specific ALS-102 board double RAB timeout fault condition.

6116-00011, subsection 7.2.2 and the associated tables, describe these fault conditions and specify their assignment to the plant Failure alarm (for faults that adversely affect the ability of the PPS ALS subsystem to perform its safety system function) or the plant Trouble alarm (for faults that indicate ALS subsystem degradation but do adversely affect the ability of the PPS ALS subsystem to perform its safety system function).

ALS-1 02 board FPGA application-specific logic is deterministic in all respects.

It does not introduce conditions that require the associated finite state machines (FSMs) to wait for responses from unreliable sources (e.g. look-up tables). Furthermore, Procedures 9006-00043, Revision 6, "ALS Core A FPGA Build Procedure" and 9006-00071, Revision 1, "ALS Core B FPGA Build Procedure" require use of "safe encoding" methods to ensure that undefined FSM state transitions result in reset to a valid (defined) state, thereby preventing non-deterministic behavior.

Finally, simulation testing of the Register Transfer Level (RTL) code included predictive models that are based on the interface requirements specified in 6002-00010, Revision 18, "ALS Platform Requirements Specification," and 6002-10201, Revision 4, "ALS-102 Requirements Specification," as well as the requirements specified in 6116-10201, Revision 2. The use of these models results in test failure if non-deterministic behavior is present in the design. No failures were identified in the final production code. A description of these models and the test results are presented in 6116-00500, Revision 0, "Diablo Canyon PPS VV --*-

October 22, 2014 DCPP PPS Open Item Summary Table Page 6 of 21 No Src/RI Issue Description P&GE response:

Status RA/No. RAJ Comments (Date Sent) Response (Due Date) Summary Report" and other documents specified therein. 101 RJS Phase 2 Environmental Qualification Documentation:

Open RAI61 4/30/14 Hold OPEN until final qualification Per ISG 6 Section D.5.1, the NRC staff needs to review the information documents are provided to determine if the PPS equipment has been demonstrated to be received.

Ask PG&E to provide able to operate within the specified environment.

In order to do this the estimate for staff needs to have plant specific environmental data for the plant and availability of plant specifically for the cable spreading room. The ISG 6 matrix (item 2.12} specific states that this information has been provided in the two vendor topical qualification reports, however, these reports do not contain any plant specific data. documents.

The NRC requires plant specific environmental condition data for normal 12/11/13 -RJS Seismic Reports operating conditions and the worst conditions expected during abnormal posted on and accident conditions where the PPS equipment is expected to perform sharepoint.

Further its safety function.

plant specific information

• Range of temperature and humidity conditions that are including ping tests expected in the cable spreading room. of PPS cabinets is still needed for

• Seismic data for the Diablo Canyon OBE and SSE evaluation.

earthquakes including frequencies and acceleration values.

• EMI I RFI data for areas where PPS equipment is to be 11/1/13-RJS installed.

Waiting for additional testing to The FRS section does specify the ranges of temp and humidity but for be completed.

seismic environment, it refers to documents DCM C-17, DCM C-25, DCM PG&E to provide C-30, DCM C-28, and DCM T-10. estimate of completion for next Note: The required information may also be contained in the UFSAR. The staff is call. reviewing design basis information in the UFSAR, however specific environmental conditions applicable to the PPS equipment remain unclear to the staff. 6/26/2013:

during ! this call the October 22, 2014 DCPP PPS Open Item Summary Table Page 7 of 21 No Src/RI Issue Description P&GE response:

Status RA/No. RAJ Comments (Date Sent) Response (Due Date) 3/28/14 Update: following Integrated Equipment Response Spectra(IERS):

In the seismic test report, clarifications were it is stated the IERS spectra will change as a result of the equipment provided:

modifications.

So far, the evaluation is based on comparing the ALS and -Describe specific conditions for the Tricon test data (TRS) with the RRS derived from the 140' elevation room where the spectra provided in DCM No. C-25. I think that these RRS spectra will be system will be conservative in comparison to the IERS but I will need to confirm this once installed.

I see the revised IERS. -Is there any restrictive See follow-up questions and answers in the PG&E response below. requirement for this room? -What is the relationship PG&E Response:

PG&E provided seismic information in the document between the titled 'Westinghouse Seismic Test Report EQLR-224B, Rev. 1" on the system Sharepoint on 12/3/13. Additional testing is required for the PPS cabinets specification to be used. requirement and environmental 3/28/14 Update: conditions?

Based on Patrick Huang's response:

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

Therefore use 5% damping. Based on the following criteria:

2) IEEE 344-1975, Section 6.6.3.1, states that the TRS envelops the RRS over a frequency range which includes all natural frequencies of the equipment up to 33 Hz. The guidance has been more specifically addressed in IEEE 344-1987 (Endorsed by NRC RG 1.100 Rev. 2), Section 7.6.3.1.1 0 that it can be shown by a resonance search that no resonance response phenomena exist below 5Hz, it is required to envelop the RRS only down to 3.5 Hz. Excitation must continue to be maintained in ----------

October 22, 2014 DCPP PPS Open Item Summary Table Page 8 of 21 No Src/RI Issue Description P&GE response:

Status RA/No. RAI Comments (Date Sent) Response (Due Date) the 1 Hz to 3.5 Hz range to the capability of the test facility.

3) According to Draft NTS Report No TR62987-07N-SEI, Revision 0 (Reference 8.9 of Draft TRIGON v1 0 Nuclear Qualification Project , Seismic Test Report 9600164-526, Date 04/13/07)

Section 6.8, Resonance Survey Results shows that the ETP or Chassis has no resonance occurred below 40 Hz. The TRS did not envelop RRS below 3 Hz meet the above IEEE 344-1975 as well as IEEE 344-1987 criteria.

Therefore, Tricon seismic test response are acceptable.

Based on 2) and 3) above, it can be justified that the Tricon test report is acceptable for the qualification of PCS racks. The PCS racks are identical to the PPS racks and are in the same location/elevation.

Since there are no natural frequencies below 5Hz, you only need to envelop down to 3.5Hz. The resonance survey showed that the natural frequencies were all greater than 40Hz. So the TRS below 3.5Hz does not matter. Response to follow-up questions:

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

No, EQLR-2248 is Westinghouse proprietary.

We cannot revise their report. We will generate IERS at ALS mounting location to compare with TRS from the EQLR-2248.

The new I ERS will be documented in the DCPP seismic calculation.

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

October 22, 2014 DCPP PPS Open Item Summary Table Page 9 of 21 No Src!RI Issue Description P&GE response:

Status RA/No. RAJ Comments I (Date Sent) Response (Due Date) Yes, Tricon has seismic test report for ETP and chassis per IEEE 344.

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

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

I 10/14/14 -The ALS Platform EQ report revision, 6002-00200, Revision 4 is on the sharepoint.

This document is referenced by the PPS specific EQ report (EQ-QR-120-PGE, Revision 0, Diablo Canyon PPS Advanced Logic System and Line Sense Module Equipment Qualification Summary Report) that is also on the sharepoint.

108 RJS Phase 2 Document Status Assessment:

Open No RAI 9/15/14-the following The staff performed an assessment of the phase 2 document matrix and documents have would like to discuss several items in the table.

Please address comments been placed in the added to the phase 2 matrix by the NRC staff. share point: -Tricon 993754-1-812 We recognize that some of these items will not be available until after the -Tricon 993754-1-FAT is performed, however, there are several other phase 2 documents 868 that should be available now. We have identified the following documents

-Westinghouse that should not require completion of the design or FAT that have not yet 6116-10020 been submitted.

We will need a revised schedule for submittal of these documents in order for us to proceed with the safety evaluation.

4/16/14 -NRC will provide update to VVSR's for phases of development beyond Planning/Req. (Both Vendors) Phase 2 matrix Tricon 993754-1-819, Reliability Analysis status following the -**---

October 22, 2014 DCPP PPS Open Item Summary Table Page 10 of 21 No Src/RI Issue Description P&GE response:

Status RA/No. RAI Comments (Date Sent) Response (Due Date) Tricon 993754-1-811, Project specific platform FMEA (IEEE 352) next DCL submittal PG&E System level FMEA of Tricon Tricon 993754-1-812, Validation Test Specification (Integrated System) documents.

Tricon 993754-1-868, Software Verification Test Plan 12/11/13 -RJS Westinghouse 6116-10020 "ALS PPS Software Safety Plan" Tricon Reliability Analysis document is on sharepoint.

PG&E Response:

Schedule for submittal of all PG&E is working with each Vendor to determine the submittal dates for the documents still remaining Phase 2 documents not related to FAT testing that still need to needs to be I be submitted.

The schedule for the outstanding lnvensys documents was provided.

provided on the Sharepoint on 12/17/13.A revised schedule for the outstanding ALS documents will be provided on the Sharepoint by 05/19/14.

October 22, 2014 DCPP PPS Open Item Summary Table Page 11 of 21 No Src/RI Issue Description P&GE response:

Status RA/No. RAJ Comments (Date Sent) Response (Due Date) 115 RJS Electro Magnetic Compatibility (Tricon):

Open RAI 4/16/14-RAI will be required.

Section 4.14 -ASAI-6 of the LAR states that the equipment vendors are required to confirm equipment compliance with physical requirements in the DCPP FRS. These requirements include the EMC requirements from Section 3.1.6 of the FRS which states: "the PPS shall be qualified by test, analysis, or a combination thereof, to function without fault or error in an electromagnetic environment in accordance with the guidance of Regulatory Guide 1.180." In contrast to this, the Tricon V1 0 safety evaluation determined that the Tricon V1 0 PLC system did not fully meet the guidance of RG 1.180, Revision 1, for conducted or radiated emissions or susceptibility.

As a result, the SE states: "before using the Tricon V1 0 system equipment in SR systems in a nuclear power plant, licensees must determine that the plant-specific EMI requirements are enveloped by the capabilities of the Tricon V1 0 system as approved in this SE." To complete its safety evaluation, the NRC requires the licensee to provide documentation to show the DCPP specific EMI requirements to be enveloped by the Tricon V1 0 test levels achieved and documented in the Tricon V1 0 safety evaluation.

October 22, 2014 DCPP PPS Open Item Summary Table Page 12 of 21 No Src/RI Issue Description P&GE response:

Status RA/No. RAJ Comments (Date Sent) Response (Due Date) PG&E Response:

Additional electromagnetic environment testing has been performed for the Tricon that improve meeting the RG 1.180 guidance.

I Information on the additional testing and evaluation to the PG&E requirements will be submitted.

Determination of the submittal date is in progress.

I I I 118 rjs (Audit Item) The NRC requests resolution of the following SIDR's be placed CLOSE No RAI These documents on sharepoint for follow-up review. The NRC is particularly interested in were posted in the reviewing the extent of condition analysis performed for each of these and Sharepoint on 9/9 process deficiencies identified.

SIDR-1057 CAR-2531 PG&E Response:

SIDR-1057 and CAR-2531 were placed on the Sharepoint on 9/9/14. 119 sd (Audit Item) 10M is using laptops, one per Protection Set plus one backup, New each with TriStation 1131 installed, to develop the V1 0 Tricon protection set application code for the DCPP PPS Replacement project. PG&E bought these 5 development laptops and 10M will be delivering them to --

October 22, 2014 DCPP PPS Open Item Summary Table Page 13 of 21 No Src/RI Issue Description P&GE response:

Status RA/No. RAI Comments I (Date Sent) Response (Due Date) PG&E as part of the Tricon product delivery.

However, during the lnvensys audit on June 3-5, 2014, PG&E informed the staff that it does not plan to I use these laptops, and only plans use the TriStation installed on the MWS's. Please clarify what PG&E will do with the 5 development laptops once they are delivered to them. Also, please clarify what controls will be placed on the TriStation software installed on these laptop computers.

I PG&E Response:

In progress.

121 rs Implementation Phase V&V Summary Report-The NRC staff reviewed Close No RAI Reviewed and the V&V tasks summarized in this report and confirmed correlation to accepted response.

several of the activities prescribed in the SVVP Section 5.2.4. There were two prescribed activities in the SVVP that did not have corresponding activities in Section 3.2 of the Implementation phase V&V activity summary report. These were: (2) Verify that the Input/Output

{I/O) List is correct and ensure implementation requirements are adequately incorporated, and (9) Nuclear IV&V shall be responsible for system test equipment staging to perform the Validation Test. It is noted that the Protection set one 1/0 list is listed as an Implementation phase input document {993754-11-806), however, the summary report makes no mention of a specific V&V activity to ensure correctness of this list. It can be inferred that performance of test equipment staging for the Validation test was completed prior to performance of the informal dry-run of the FAT as described in task number 13, however, there is no specific activity listed to ensure accomplishment of this task.

October 22, 2014 DCPP PPS Open Item Summary Table Page 14 of 21 No Src/RI Issue Description P&GE response:

Status RA/No. RAI Comments (Date Sent) Response (Due Date) PG&E Response:

Specified in IPSR, Section 2, Item 2, that the "tagnames" being verified are the "Input/Output (1/0) List" tagnames.

Added Item 14 for stating test equipment activity.

122 rs Implementation Phase V&V Summary Report-Several of the input Close No RAI Reviewed and documents pertain only to protection set I, however, the summary report accepted response.

scope is intended to include all four protection sets. Section 2.0 of the summary report provides a reference to a project conditional release (CR 993754-06), but this does not describe a reduction in scope to only protection set one. Please explain how V&V activities for the entire scope of the PPS Tricon system (i.e. all four protection sets) will be reported.

PG&E Response:

Specified in IPSR Section 2.0 summary scope and throughout the document (Sections 3.1, 3.2, and 4.1) where applicable, that the report is intended only for Protection Set I (PPS I). In addition, document numbering scheme and title of phase summary reports and test reports were changed to indicate specific protection set, i.e, 993754-11-xxx for -

October 22, 2014 DCPP PPS Open Item Summary Table Page 15 of 21 No Src/RI Issue Description P&GE response:

Status RA/No. RAI Comments I (Date Sent) Response (Due Date) PPS I and 993754-12-xxx for PPS 11-IV. 123 rs Implementation Phase V&V Summary Report-One of the Deficiency Close No RAI Reviewed and Reports remained unresolved at the completion of the Implementation accepted response.

phase. This was CAR 2507 which is an issue with the Emulation Test Driver used for system verification tests. No evaluation of risks associated with this unresolved issue was provided in the Technical and Management Risks section of the summary report and the report recommended exiting the implementation phase with this condition present. Additionally, the report states that "all deficiencies are resolved", and that "all output documents are issued." These statements seem to conflict with the information in Table 5-3, and with the conditions of the provisional release in that only protection set I implementation is complete.

PG&E Response:

Added in IPSA Section 8.0, the justification for exiting PPS I Implementation Phase with CAR 2507 open. 124 RA Software and System Quality Assurance Open In the table for compliance with ISG-06, PG&E identified 6002-00001, "ALS Quality Assurance Plan", as the document to describe software quality assurance.

However, the Westinghouse/ALS Document 6116-10020, "Diablo Canyon PPS Software Safety Plan," states: "Software quality assurance activities for PPS software are described in the Diablo Canyon Process Protection System Quality Assurance Plan (6116-00001) and Verification and Validation activities are described in 6002-00001." Based on that information please address the following:

-Submit Diablo Canyon Process Protection System Quality L_ -*---*--

October 22, 2014 DCPP PPS Open Item Summary Table Page 16 of 21 No Src/RI Issue Description P&GE response:

Status RAJ No. RAJ Comments (Date Sent) Response (Due Date) Assurance Plan (6116-00001

). -Explain the relationship between 6002-00001, "ALS Quality Assurance Plan" and 6116-00001, "Diablo Canyon Process Protection System Quality Assurance Plan". -Is it correct that this document refers to the ALS quality assurance plan for V&V activities, instead of referring to the DC PPS Verification and Validation Plan (6116-00003)?

PG&E Response:

In progress.

125 RA Software Safety Plan Open The Westinghouse/ALS software safety plan (6116-1 0020) contains a lot of information in Section 2 related to software design, V&V activities, and configuration management.

However, the information in section 2 does not specify the relationship among specific software safety tasks and the software activities described.

Please provide this information.

PG&E Response:

In progress.

I 126 RA Project Management Plan Open Westinghouse has modified its ALS Configuration Management Plan (CMP), now identified as document No. 6002-00002.

This CMP will be used for both the approved ALS platform, as well as the new ALS-11 platform.

In addition, Westinghouse indicated that several QA procedures were replaced after CSI was completely absorbed by WEC. For example, NA 3.18 was used for ALS projects, but it has been replaced by NA 3.19.

October 22, 2014 DCPP PPS Open Item Summary Table Page 17 of 21 No Src!RI Issue Description P&GE response:

Status RAJ No. RAJ Comments (Date Sent) Response (Due Date) Please explain how this new CMP and QA procedures impact the DC PPS replacement project. PG&E Response:

In progress.

127 RA FPGA Design Specification:

Open The ALS-1 02 Core B FPGA Design Specification (6116-1 0204) references Rev. 18 of 6002-00010, "ALS Platform Requirements Specification." However, this was not the revision evaluated with the ALS topical report. Please place a copy of Rev 18 in the Sharepoint.

PG&E Response:

In progress.

128 RA ALS revised documents:

Close Please place the latest revision of the following documents in the sharepoint:

• 6116-10201, "Pacific Gas & Electric Diablo Canyon Process Protection System ALS-1 02 FPGA Requirements Specification,"

• 6116-00100, "Pacific Gas & Electric Diablo Canyon Process October 22, 2014 DCPP PPS Open Item Summary Table Page 18 of 21 No Src/RI Issue Description P&GE response:

Status RAJ No. RAJ Comments (Date Sent) Response (Due Date) Protection System TxB1 & TxB2 Communications Protocol Specification " PG&E Response:

The following Westinghouse Documents are on the Sharepoint.

The documents are Westinghouse proprietary documents.

"6116-001 00, Revision 2, Diablo Canyon PPS TxB1 & TxB2 Communications Protocol" "6116-1 0201, Revision 3, Diablo Canyon PPS ALS-1 02 FPGA Requirements Specification" "6116-00011, Revision 4, Diablo Canyon PPS ALS System Design Specification" 129 RA ALS Topical Report Addendum:

Open The ALS topical report addendum identifies changes in Category 4 as those modifications that are applicable to the approved ALS topical report. Please describe how these changes affect the DC PPS replacement, in particular description and functionality of the Halt mode PG&E Response:

In progress.

October 22, 2014 DCPP PPS Open Item Summary Table Page 19 of 21 No Src/RI Issue Description P&GE response:

Status RA/No. RAJ Comments (Date Sent) Response (Due Date) 130 RA Tricon FAT Open The FAT references the following revisions for these documents:

• Validation Test Specification (VTS), 993754-1-813, Rev 3

• Validation Test Plan (VTP), 993754-1-813, Rev 3 Please place copies of these documents in the sharepoint for information only. PG&E Response:

The VTS Rev 3 and VTP Rev 3 will be put on the sharepoint by 9/29/14. I lnvensys document 993754-1-812 Revision 3, Validation Test Specification (VTS) and 993754-1-813 Revision 3, Validation Test Plan I (VTP) are now on sharepoint.

These documents are lnvensys proprietary documents created to support the FAT. 131 RA RAis follow up communication items to be tested during Tricon FAT Open RAis # 6, 11, and 46, as well as Section 4.2.13.1 of the LAR, describe items to be tested during the lnvensys FAT associated with communication with the MWS and the operation of the port tap aggregrator.

Specifically, activities to verify bidirectional communication to the MWS and one-way communication from Port 1 (to the PPC gateway).

In addition, RAI #48 states that testing of the KVM switch would be performed during FAT. Please confirm that these activities were performed and the results obtained.

PG&E Response:

These items were not tested during Protection Set I FAT and instead will be included as part of the Protection Set II to IV portions of the FAT. -**------------

October 22, 2014 DCPP PPS Open Item Summary Table Page 20 of 21 No Src/RI Issue Description P&GE response:

Status RAJ No. RAJ Comments I (Date Sent) Response I (Due Date) I 132 RA lnvensys Safety Analysis:

Open I I The safety analysis Rev. 7, Table 4 shows the interface type between the MWS to be the TCM interface. However, the Tricon communicates with the I MWS via the port tap aggregrator, as described in the LAR, section 4.2.13.1.

Please explain why this table does not consider the port tap aggregrator as the interface with the MWS. PG&E Response:

As a third-party hardware device and the port aggregator switch position being controlled by a plant procedure, the port aggregator is considered in the PPS FAT scope. The TCM interface is considered a primary interface between MWS and Tricon and the focal point in the interface analysis because it is a lnvensys product within the scope of project development.

133 RA Tricon FAT Open FAT Appendix 1-18 summarizes the FAT procedures tested. This appendix identifies the test cases from the Validation Test Specification (993754 812) tested. This appendix does not identify the TIC test cases FAT-11-TIC-22 to FAT-11-TIC-35, which are described in the Validation Test Specification (993754-1-812).

Please explain if these test cases were tested during the FAT and where the results are summarized.

PG&E Response:

Please see the test ID FAT-11-TIC-22 to FAT-11-TIC-35 that were covered in the FAT test cases below: FAT Appendix 1-18: Test ID FAT-11-TIC-22 was covered in test case #27, 28. FAT Appendix 1-28: Test ID FAT-11-TIC-23 was covered in test case #17. Test ID FAT-11-TIC-24 was covered in test case #6. Test ID FAT-11-TIC-25 was covered in test case #2, 3, 4, 6, 20, 24. Test ID FAT-11-TIC-26 was covered in test case #7, 21, 22, 25.

Test ID FAT-11-TIC-27 was covered in test case #7. -----*------

October 22, 2014 DCPP PPS Open Item Summary Table Page 21 of 21 No Src/RI Issue Description P&GE response:

Status RA/No. RAI Comments (Date Sent) Response (Due Date) Test 10 FAT-11-TIC-28 was covered in test case #3. Test 10 FAT-11-TIC-29 was covered in test case #8, 9, 19, 20, 21, 22, 23, 24, 25. Test 10 FAT-11-TIC-30 was covered in test case #12. Test 10 FAT-11-TIC-31 was covered in test case #13, 25. Test 10 FAT-11-TIC-32 was covered in test case #11. Test I 0 FAT TIC-33 was covered in test case #4, 6, 9, 1 0, 17, 18. Test 10 FAT-11-TIC-34 was covered in test case #5. Test I 0 FAT TIC-35 was covered in test case #11 . lnvensys document 993754-11-902-1 FAT-Appendix 1-28 is on the I sharepoint.

This document has the executed test cases for the test cases referred to above. I --------------------

ENCLOSURE 3 PROJECT PLAN PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323 Project Plan for Diablo Canyon Replacement of Digital RPS and ESFAS (PPS) -LAR Review (Rev. 22) Step Planned Date Task Actual Date 1 Oct. 26, PG&E LAR Submittal for NRC approval.

Submittal Oct. 26, 2011 includes all Phase 1 documents needed to be docketed 2011 prior to acceptance for review per ISG-06, "Digital Licensing." 2 Jan. 12, 2012 Acceptance Review complete.

LAR accepted for detailed Jan. 12, technical review. Several issues identified that could 2012 present challenges for the staff to complete its review. Scheduled public meeting with PG&E to discuss the results of the acceptance review. 3 Jan. 13, 2012 Acceptance letter sent to licensee.

Jan. 13, 2012 4 Jan. 18, 2012 Conduct Public Meeting to discuss staff's findings during Jan. 18, the LAR acceptance review. Staff proceeds with LAR 2012 technical review. 5 March 18, PG&E provides information requested in acceptance letter. April2, 2012 Initiate bi-weekly telecoms with PG&E and its contractors 2012 to discuss potential RAI issues. Open Items spreadsheet will be maintained by NRC to document staff issues and planned licensee responses.

6 May 30, 2012 PG&E provides partial set of Phase 2 documentation per June 6, commitments made in LAR. 2012* *PG&E provided a subset of the Phase 2 documents on June 6 1 h See step 14 which is a milestone for submittal of all remaining Phase 2 documents.

7 July First RAI sent to PG&E on Phase 1 documentation (e.g., August 2012 specifications, plans, and equipment qualification).

07, 2012 Continue review of the application.

Request 45 day response. (ML 12208A364) 8 June SER for Tricon V1 0 Platform issued final. This platform May 15, 2012 becomes a Tier 1 review of the LAR. (ML 12146A010) 2012 8.1 June SER for Westinghouse ALS Platform issued final. This 2013 platform becomes a Tier 1 review of the LAR. 9 September Receive answers to first RAI. (ML 12256A308)

Sept. 11, 2012 2012 10 November Audit trip to lnvensys facility for thread audit; audit the life Nov. 13-2012 cycle planning documents and outputs, with particular 16, 2012 emphases on verification and validation, configuration management, quality Assurance, software safety, the lnvensys application software development procedures, and application software program design. 10.1 December Audit report provided to PG&E. February 2012 21,2013 Page 1 of 3 Project Plan for Diablo Canyon Replacement of Digital RPS and ESFAS {PPS) -LAR Review {Rev. 22) 11 February 2013 Audit trip to Westinghouse/CSI facility for thread audit; February audit the life cycle planning documents and outputs, with 21,2013 particular emphases on verification and validation, configuration management, quality Assurance, software safety, the W/ALS application software development procedures, and PPS ALS application software program design. 11.1 April Audit report provided to PG&E and its contractor.

April11, 2013 2013 12 March Second RAI Letter to PG&E on Phase 1 documentation March 20, 2013 2013 12.1 April Receive responses to Second set of RAI's May9, 2013 2013 13 April LAR revision and all supporting documentation associated April30, 2013 with the change in ALS and Tricon V1 0 workstation 2013 designs for the PPS are submitted.

14 August NSIR Cyber Security audit at Diablo Canyon site. August 8 2013 2013 14.1 February 2014 Cyber Security Audit Report provided to licensee April28, EICB Letter sent to PM 9/2/13 -ML 13242A078 2014 NSIR Report-ML 13339A428, ML 13339A438 and ML 13339A442 15 See Revised PG&E provides remaining set of Phase 2 documentation Document per commitments made in LAR. To include ALS PSAI Submittal related documents.

See step 6 for initial submittal of Schedules Phase 2 documents.

16 See Revised All Documentation for DCPP W/CSI ALS and Document IOM/Triconex V1 0 processors applicable to the DCPP Submittal PPS LAR are submitted.

Schedules 17 June 2014 Follow-up audit trip to lnvensys facility for thread audit; June 13, audit the life cycle planning documents and outputs, with 2014 particular emphases on verification and validation, configuration management, quality assurance, software safety, the lnvensys application software development procedures, and application software program design. 17.1 July 2014 Second lnvensys audit report provided to PG&E. ?? Report sent to DORL 8/14. ML 14216A398 Page 2 of 3 Project Plan for Diablo Canyon Replacement of Digital RPS and ESFAS (PPS) -LAR Review (Rev. 22) 18 February Third RAI Letter to PG&E on Phase 2 documentation February 2014 (e.g., FMEA, safety analysis, RTM, EO test results, 27 setpoint calculationsl ML 14055A058 2014 18.1 April Receive responses to third set of RAI's. April30, 2014 DCL-14-036-ML14121A002 2014 19 May 2015 Audit trip to W/ALS facilities for additional thread audit items; audit hardware and software installation plans, configuration management reports, detailed system and hardware design, completed test procedures, V&V activities, summary test results (including FAT) and incident reports, and apQiication code listings.

19.1 June 2015 Audit report provided to PG&E. 20 Deleted 21 Deleted 22 February 18 I Presentation to ACRS Subcommittee/Full ACRS Committee February March 18 2014 on DCPP PPS LAR Safety Evaluation.

March 6 August 19, Presentation to ACRS Subcommittee/Full ACRS 22.1 September 10, 2015 Committee on DCPP PPS LAR Safety Evaluation.

23 July 2015 Complete draft technical SER for management review and approval.

24 July 2015 Issue completed draft technical SER to DORL 25 September Draft SER sent it to PG&E, lnvensys, and W/CSI to 2015 perform technical review and ensure no proprietary information was included.

26 October 2015 Receive comments from PG&E and its contractors on draft SER proprietary review. 27 December Approved License Amendment issued to PG&E 2015 28 TBD Inspection trip to DCPP for PPS Site Acceptance Testing (SAT), training and other preparation for installing the new system. To be coordinated with regional visit. 29 TBD Inspection trip to DCPP for PPS installation tests, training and other system installation activities for the new system. To be coordinated with region visit. Page 3 of 3 Please direct any inquiries to me at 301-415-1014 or at Eric.Oesterle@nrc.gov.

Docket Nos. 50-275 and 50-323

Enclosures:

1. List of Attendees IRA/ Eric R. Oesterle, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

2. Staff Identified Issues That are Open 3. Project Plan cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC LPL4-2 Reading RidsAcrsAcnw_MaiiCTR Resource RidsNrrDeEicb Resource RidsNrrDorl Resource RidsNrrDorllpl4-2 Resource RidsNrrLAJBurkhardt Resource RidsNrrPMDiabloCanyon Resource RidsNsirDsp Resource RidsRgn4MaiiCenter Resource TWertz, NRR JJandovitz, EDO RIV RStattel, NRR/DE/EICB SDarbali, NRR/DE/EICB RAivarado, NRR/DE/EICB SMakor, RIV/DRS/EB2 ADAMS Accession Nos. Meeting Notice ML 14219A658; Summary ML 14295A733 OFFICE NRR/DORL/LPL4-1

/PM NRRIDORLILPL4-1

/PM NRR/DORLILPL4-1

/LA NAME MWatford EOesterle JBurkhardt DATE 10/30/14 10/31/14 10/29/14 OFFICE NRR/DE/EICB NRR/DORLILPL4-1

/BC NRR/DORLILPL4-1

/PM NAME RStattel MMarkley EOesterle DATE 11/5/14 11/6/14 11/17/14 OFFICIAL RECORD COPY