ML12242A256

8/22/12 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

ML12242A256
Person / Time
Site:	Diablo Canyon
Issue date:	09/25/2012
From:	Joseph Sebrosky Plant Licensing Branch IV
To:	Pacific Gas & Electric Co
Sebrosky J
References
TAC ME7522, TAC ME7523
Download: ML12242A256 (62)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 25, 2012 LICENSEE: Pacific Gas and Electric Company FACILITY: Diablo Canyon Power Plant, Unit Nos. 1 and 2

SUMMARY

OF AUGUST 22,2012, TELECONFERENCE MEETING WITH PACIFIC GAS AND ELECTRIC COMPANY ON DIGITAL REPLACEMENT OF THE PROCESS PROTECTION SYSTEM PORTION OF THE REACTOR TRIP SYSTEM AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEM AT DIABLO CANYON POWER PLANT (TAC NOS. ME7522 AND ME7523)

On August 22, 2012, a Category 1 teleconference public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Pacific Gas and Electric Company (PG&E, the licensee) at NRC Headquarters, One White Flint North, 11555 Rockville, Maryland. The purpose of the teleconference meeting was to discuss the license amendment request (LAR) submitted by PG&E on October 26, 2011, for the Digital Replacement of the Process Protection System (PPS) Portion of the Reactor Trip System and Engineered Safety Features Actuation System at Diablo Canyon Power Plant, Unit Nos. 1 and 2 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML113070457). A list of attendees is provided in Enclosure 1.

The teleconference meeting is one in a series of publicly noticed teleconference meetings to be held periodically to discuss issues associated with the NRC staff's LAR review. Preliminary issues that the NRC staff identified during 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. Enclosure 3 provides an updated status of the project plan for the review of the LAR that was discussed during the meeting and subsequently provided to the licensee.

The NRC staff and licensee confirmed that the next meeting on this topic would be held on September 19, 2012. Highlights from the meeting include the following:

• The NRC staff and PG&E discussed how changes to the LAR would be documented related to a design change for the maintenance work station (MWS).

PG&E intends to implement a design change to the MWS to install a switch that would prevent the Advanced Logic System (ALS) and the Invensys Operations Management Tricon (Tricon) portions of the PPS from interacting with each other through the MWS. It was recognized that the design change will affect several documents that were submitted to support the LAR. PG&E took an action to provide a revised version of the LAR and the affected supporting documents for the LAR with revision bars such that it will be clear to the staff what changes have been made to the respective documents as a resuit of the MWS design change. PG&E indicated that it was targeting the November 2012 time frame for providing these revised documents.

- 2

• The NRC staff took an action to update the project plan (see Enclosure 3) and to provide the updated project plan to PG&E. Enclosure 3 was provided to PG&E subsequent to the meeting. PG&E updated the staff on the status of several Phase 2 document submittals that had originally been scheduled to be provided by July 31,2012. PG&E indicated that it planned to provide the remaining ALS documents by September 15, 2012, the remaining Tricon documents by September 30, 2012, and had not yet developed a schedule for the PG&E system level failure modes and effects analysis document. The PG&E document schedule has not yet been determined because of design changes being considered for a portion of the ALS PPS design to address overheating of a logic board. PG&E indicated that it was targeting December 31, 2012, for providing the staff all Phase 1 and Phase 2 documents for both the ALS and Tricon platforms.

• The NRC staff and PG&E discussed the cyber security review and question 52 of Enclosure 2. PG&E took an action to provide a high-level response to question 52 in the September 2012, time frame, and the staff took an action to provide additional feedback to PG&E on how the cyber security review would be performed and documented. The staff considers PG&E's LAR to be a pilot project in this area and indicated that it was discussing how to perform and document the cyber security review. The NRC staff will provide feedback to PG&E in future meetings related to the LAR.

• Enclosure 2 was updated prior to the meeting to indicate those questions that had been closed based on docketed material or included in the NRC staff's request for additional information dated August 7,2012 (ADAMS Accession No. ML12208A364). The issues that have been closed have a gray background in Enclosure 2 and new issues have a white background in Enclosure 2. PG&E took an action to provide responses to the new issues in Enclosure 2 and those responses will be discussed at the next public meeting.

• PG&E took an action to update the Open Item table to provide responses to be discussed at the next meeting.

-3 Please direct any inquiries to me at 301-415-1132 or Docket Nos. 50-275 and 50-323

Enclosures:

1. List of attendees

2. Staff identified issues

3. Project Plan cc w/encls: Distribution via Listserv

LIST OF ATrENDEES AUGUST 22, 2012, TELECONFERENCE MEETING WITH PACIFIC GAS AND ELECTRIC COMPANY REGARDING DIABLO CANYON POWER PLANT DIGITAL UPGRADE DOCKET NOS. 50-275 AND 50-323 NAME ORGANIZATION Ken Schrader Pacific Gas and Electric Scott Patterson Pacific Gas and Electric John Hefler Altran R. Lint Altran J. Rengepis Altran E. Quinn Altran J. Basso Westinghouse W.Odess-Gillet Westinghouse G. Andre Westinghouse Roman Shaffer InvensyslTriconex Rich Stattel U.S. Nuclear Regulatory Commission Bill Kemper U.S. Nuclear Regulatory Commission Rossnyev Alvarado U.S. Nuclear Regulatory Commission Eric Lee U.S. Nuclear Regulatory Commission Darryl Parsons U.S. Nuclear Regulatory Commission George Simonds U.S. Nuclear Regulatory Commission Tim Harris U.S. Nuclear Regulatory Commission Joe Sebrosky U.S. Nuclear Regulatory Commission Shiattin Makor U.S. Nuclear Regulatory Commission Gordon Clefton Nuclear Energy Institute Craig Butler Areva Enclosure 1

August 20, 2012 DCPP PPS Open Item Summary Table Page 1 of 55 No I I SrC/R Issue DescripUon P&GE response: I Status I RAI No. I RAI Comments I (Date Sent)

Enclosure 2

August 20,2012 DCPP PPS Open Item Summary Table Page 2 of 55 No I SrclR I Issue Description P&GE response: I Status I RAI No. I RAI Comments I (Date Sent)

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No I I SrC/R Issue Description P&GE response: RAI No. I RAI Comments I (Date Sent) Response (Due

August 20, 2012 DCPP PPS Open Item Summary Table Page 4 of 55 No I SrC/R \ Issue Description P&GE response: I Status I RAI No.

(Date Sent)

IRAI

Response

Comments I

(Due

August 20,2012 DCPP PPS Open Item Summary Table Page 5 of 55 No I I SrC/R Issue Description P&GE response: I Status I RAI No.

(Date Sent)

IRAI

Response

Comments I

(Due Date)

August 20,2012 DCPP PPS Open Item Summary Table Page 6 of 55 I

No I SrC/R Jssue Description P&GE response: I Status I RAJ No.

(Date Sent)

IRAJ

Response

Comments J

(Due PPS Replacement Project Management Plan (PMP), 993754-1-905. "Project Management Plan" was used to more closely match BTP 7-14 with regard to "management plans"; and PPS Replacement Software Verification and Validation Plan (SWP),

993754-1-802.

The PMP describes the PPS Replacement Project management activities within the Invensys scope of supply. The guidance documents BTP 7-14 and NUREG/CR-6101 were used as input during development of the PMP.

With regard to compliance with RG 1.168, the PPS Replacement PMP and SWP both describe the organizational structure and interfaces of the PPS Replacement Project. The documents describe the Nuclear Delivery (NO) design team structure and responsibilities, the Nuclear Independent Verification and Validation (lV&V) team structure and responsibilities, the interfaces between NO and Nuclear IV&V, lines of reporting, and degree of independence between NO and Nuclear IV&V. In addition, the PMP describes oraanizational boundaries between Invensvs and the other

August 20,2012 DCPP PPS Open Item Summary Table Page 7 of 55 No I I SrclR Issue Description P&GE response: I Status I RAI No.

(Date Sent)

IRAI

Response

Comments I

(Due external entities involved in the PPS Replacement project: PG&E, Altran, Westinghouse, and Invensys suppliers. The combination of the PMP and SWP demonstrate compliance of the Invensys organization with RG 1.168.

August 20,2012 DCPP PPS Open Item Summary Table Page 8 of 55 No I I Src/R Issue Description P&GE response: I Status I RAI No. I RAI Comments I (Date Sent)

August 20, 2012 DCPP PPS Open Item Summary Table Page 9 of 55 INo ItSrC/R Itssue Description IP&GE response: IStatus IRAt No. IRAt (Date Sent) Response Comments (Due Date)

August 20, 2012 DCPP PPS Open Item Summary Table Page 10 of 55 INo IISrclR IIssue Description ., P&GE response: IStatus IRAI No. IRAI (Date Sent) Response Comments (Due

August 20,2012 DCPP PPS Open Item Summary Table Page 11 of 55 No I

I I SrclR Issue Description P&GE response: I Status I RAI No.

(Date Sent)

IRAI

Response

Comments (Due Date)

August 20, 2012 DCPP PPS Open Item Summary Table Page 12 of 55 No I I SrclR Issue Description P&GE response: I Status I RAI No.

(Date Sent)

IRAI

Response

Comments I

(Due Date)

August 20, 2012 DCPP PPS Open Item Summary Table Page 13 of 55 No I I SrclR Issue Description P&GE response: I Status I RAJ No. I RAJ (Date Sent)

Comments J

August 20, 2012 DCPP PPS Open Item Summary Table Page 14 of 55 No I I SrclR Issue Description P&GE response: I Status I RAI No.

(Date Sent)

IRAI

Response

Comments I

(Due

August 20, 2012 DCPP PPS Open Item Summary Table Page 15 of 55 No I I SrclR Issue Description P&GE response: I Status I RAI No. I RAI Comments (Date Sent)

I

August 20,2012 DCPP PPS Open Item Summary Table Page 16 of 55 No I SrclR !/ssue Description P&GE response: I Status I RAI No. I RAI Comments I (Date Sent)

August 20,2012 DCPP PPS Open Item Summary Table Page 17 of 55 No I I SrclR Issue Description I P&GE response: I Status I RAI No. I RAI Comments I (Date Sent) Response (Due

August 20, 2012 DCPP PPS Open Item Summary Table Page 18 of 55 No I I SrclR Issue Description P&GE response: I Status I RAI No. I RAI Comments (Date Sent)

I

August 20, 2012 DCPP PPS Open Item Summary Table Page 19 of 55 No I I SrclR Issue Description i P&GE r e s p o n s e : - rStatus I RAI No. I RAI (Date Sent)

Comments I I

August 20,2012 DCPP PPS Open Item Summary Table Page 20 of 55 No **1 I SrclR Issue Description P&GE response: I Status I RAI No. I RAI Comments (Date Sent)

I

August 20, 2012 DCPP PPS Open Item Summary Table Page 21 of 55 No I I SrclR Issue Description P&GE response: I Status I RAI No. I RAI Comments I (Date Sent)

August 20, 2012 DCPP PPS Open Item Summary Table Page 22 of 55 No I I SrC/R Issue Description P&GE response: Status RAI No. RAI Comments I (Date Sent) Response (Due

August 20,2012 DCPP PPS Open Item Summary Table Page 23 of 55 No I I SrC/R Issue Description P&GE response: I Status I RAI No.

(Date Sent)

IRAI

Response

Comments I

(Due

August 20,2012 DCPP PPS Open Item Summary Table Page 24 of 55 No I I SrC/R Issue Description P&GE response: I Status I RAJ No. I RAI Comments I (Date Sent)

DCPP PPS Open Item Summary Table Page 25 of 55 Issue Description P&GE response: Status RAI No. Comments (Date Sent)

August 20,2012 DCPP PPS Open Item Summary Table Page 26 of 55 No I I SrclR Issue Description P&GE response: I Status I RAI No.

(Date Sent)

IRAJ

Response

Comments I

(Due

August 20,2012 DCPP PPS Open Item Summary Table Page 27 of 55 No I SrclR I Issue Description P&GE response: I Status I RAI No. I RAI Comments I (Date Sent)

August 20,2012 DCPP PPS Open Item Summary Table Page 28 of 55 No I SrclR I Issue Description , P&GE response: RAI No. I RAJ Comments I (Date Sent)

August 20, 2012 ocpp PPS Open Item Summary Table ---

Page 29 of 55

~~~-

No SrclR Issue Description P&GE response: Status RAI No. RAI Comments I (Date Sent) Response (Due Date) 21 RA Westinghouse/CSI document 6116-00005, "Diablo Canyon PPS System Test Open RAI10 6-13-12 update Plan," states that the ALS-102 FPGA design is changed for the DCPPS (Hold) Not used (Kemper):

System. Further, Section 5.3.3 states: "Test as many of the ALS-1 02 PG&E understands requirements as possible." that they need to provide an update Please identify what document describes the design verification test for this to this response. In board. the meantime, PG&E and ALS have provided 2 PG&E response: The documents that describe the design verification tests design for the ALS-102 are 6116-70140, "Diablo Canyon PPS System Test Design specifications that Specification," submitted June 6,2012, and 6116-10216, "Diablo Canyon will address this 01.

PPS W Simulation Environment Specification" that will be submitted by These documents September 30, 2012. are placed on the PG&E sharepoint website. Doc. No 6116-10740 was submitted on June 6, 2012, which describes ALS system test design specification. Doc.

No 6116-00005 was also submitted on June 6, 2012, which describes ALS system test plan.

Doc. No. 6116 10216ALSW Simulation Environment Specification will be provided in the future.

3/21/12 update: I

August 20,2012 DCPP PPS Open Item Summary Table Page 30 of 55 No SrclR Issue Description P&GE response: Status RAI No. RAI Comments I (Date Sent) Response (Due Date)

PG&E has created a share point website for NRC to review PPS design drawings that will address this issue.

NRC staff will determine if they are needed to be submitted on the docket. PG&E will ensure the website is information is only applicable to this licensing action.

NRC- the response provided does not address the question.

7/13/12 rjs Deleted RAI 10 pending review of revised response.

Also decided to hold item open.

August 20, 2012 DCPP PPS Open Item Summary Table Page 31 of 55 No I I SrclR Issue Description P&GE response: I Status IRAI No. I RAI Comments I (Date Sent)

August 20, 2012 DCPP PPS Open Item Summary Table Page 32 of 55 No I I SrC/R Issue Description P&GE response: I Status I RAI No. I RAI Comments I (Date Sent) Response (Due Date) 1 The NetOptics Model PAO-CU has two one-way output ports but is otherwise identical in function to the PA-CU.

August20,2012 DCPP PPS Open Item Summary Table Page 33 of 55 No I I SrclR Issue Description P&GE response: . S~tC-at""'us

'-1 I RAJ No. I RAJ Comments (Date Sent)

I

August 20,2012 DCPP PPS Open Item Summary Table Page 34 of 55 I

No I SrcJR Issue Description P&GE response: I Status I RAI No. I RAI Comments I (Date Sent) Response (Due

August20,2012 DCPP PPS Open Item Summary Table Page 35 of 55 No I SrclR I Issue Description P&GE response: -----rl-S-ta-tu-s--.IRAI No. I RAI Comments I (Date Sent) Response (Due

August 20, 2012 DCPP PPS Open Item Summary Table 36 of 55 No ISrclR I Issue Description P&GE response: I Status I RAJ No. I RAJ Comments I (Date Sent) Response (Due

August 20,2012 DCPP PPS Open Item Summary Table Page 37 of 55 No ISrclR I

I Issue Description I P&GE response: I Status IRAI No.

(Date Sent)

I RAI Comments

August20,2012 DCPP PPS Open Item Summary Table Page 38 of 55 No I I SrclR Issue Description P&GE response: I Status IRAI No. I RAI Comments I (Date Sent)

I 30 RA Software Development Plan Open (Hold)

IRAI14 Not used 7/13/12 - rjs:

Section 7 of the Invensys Nuclear System Integration Program Manual Decided to not use (NSIPM) requires that non-conforming procedures shall be used to control the RAI and hold parts, components, or systems which do not conform to requirements. this item open Invensys documents 993754-1-906, Software Development Plan, and pending review of 993754-1-905, PPS Replacement DCPP Project Management Plan, do not updated phase 2 identify non-confirming procedures to be followed when deviations are submittals.

identified and how deviations should be corrected.

Please provide this information.

PG&E response:

The Project Management Plan (PMP), 993754-1-905, is the overarching project management document for the Invensys scope of the PPS Replacement Project. It references other Invensys planning documents that discuss procedures to follow when deviations are identified and how they are corrected. The Software Development Plan, 993754-1-906, describes the software development process for the Invensys scope of the PPS Replacement Project. 993754-1-906, has been revised to Revision 1, to include new Section 3.2.6 that discusses problem reporting and corrective action. 993754-1-906, Revision 1, was submitted by PG&E on August 2, 2012.

August 20, 2012 DCPP PPS Open Item Summary Table Page 39 of 55 No I I SrclR Issue Description P&GE response: I Status I RAJ No.

(Date Sent)

IRAJ

Response

Comments J

(Due In addition, the Invensys Software Quality Assurance Plan, 993754-1-900, Section 8, and the Invensys Software Configuration Management Plan, 993754-1-909, Section 3.2, both provide reference to procedures to follow when deviations are identified and how deviations are corrected.

August 20,2012 DCPP PPS Open Item Summary Table Page 40 of 55 No I SrclR I Issue Description P&GE response: I Status I RAI No. I RAI Comments I (Date Sent) Response (Due

August 20,2012 DCPP PPS Open Item Summary Table 41 of 55 No I I SrC/R Issue Description P&GE response: Status RAJ No.

(Date Sent)

RAJ

Response

Comments I

(Due Date) under load, (ALS SOAP) Software tools are used extensively during the FPGA Open Item initiated on development process. The staff therefore considers these tools to be a key (Hold) 6/5/12.

component to the assurance of quality in the ALS system development process. The ALS SOAP states that "no additional tools, techniques, or 6-13-12 update methodologies have been identified" for the ALS system. The staff considers (Kemper): W/ALS the development tools, as well as the techniques and methodologies used agrees with NRC's during system development to be relevant to the assurance of quality for the position on tools ALS system. Please provide information on the tools, and methodologies and will revise the used during system development to ensure quality of the ALS system document (Doc.

products. No. 6002-00001) accordingly to address this matter.

PG&E response: Westinghouse agrees that Section 8, Tools, Techniques, And Methodologies of the ALS OA Plan (6002-00001) should be revised to Placed this item on reference document 6002-00030, "ALS Design Tools." This document hold pending describes the tools used and how they are used in the design process. This review of revised document is also on the ALS docket. Westinghouse will submit a revision of OA plan.

the ALS OA Plan on the ALS docket.by IN PROGRESS

August 20,2012 DCPP PPS Open Item Summary Table Page 42 of 55 No I SrcIR I Issue Description response: T-::S~ta--;-tu-s--'I--=R::-:A-:-INC:-::o-*---rI RAI Comments I (Date Sent)

August 20, 2012 DCPP PPS Open Item Summary Table Page 43 of 55 No I I SrclR Issue Description m I P&GE response: ~~~~~~~~~--'------'-R=-A~/~N:~~~o~. IRAI Comments I I (Date Sent) Response (Due 35 Follow up of Item 21 - Software Test Plan In the response provided for Item 21, PG&E explained that a new revision I New (Rev. 1) of ALS document No. 6116-00005 was provided. The scope of Revision 1 is slightly different from the scope described in Rev. O. For example, Section 1.2 in both revisions states that test coverage includes all ALS modules, backplane, license sense modules (LSM), and ALS service unit (ATU). However Section 2, Test Items, for these revisions are different.

Revision 1 only focuses on ALS-1 02 and backplane assemblies. This section does not include other ALS modules, LSM and ATU. Please explain why these other ALS modules are not included in section 2 of the new revision.

Further, Table 1-2 identifies "Diablo Canyon PPS Test Plan" as document No. 6116-00005, which is the same number than "Diablo Canyon PPS System Test Plan". Please clarify if this is referring to a different document.

PG&E Response: IN PROGRESS 36 RA Software Test Plan OPEN New Section 5.3.6 of ALS Document No. 6116-00005 refers to a "Test Team" to perform system level testing. However, the "Test Team" is not defined in ALS Document No. 6116-00000, "Diablo Canyon PPS Management Plan," which defines roles and responsibilities for the PPS Replacement Project.

Please clarifv who is the Test Team and where their roles and responsibilities

August 20, 2012 DCPP PPS Open Item Summary Table Page 44 of 55 No SrcIR Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response I

(Due Date) are defined.

PG&E Response: IN PROGRESS 37 RA Software Management Plan OPEN New PG&E "PPS Replacement Concept, Requirements, and Licensing Phase 1 Project Plan" does not address reporting mechanisms and controlling changes to the system. The only reference is that PG&E states that they will follow the activities describe before for software modifications. After reviewing the of PG&E's SyWP, we found that Section 6 states that Anomaly Resolution and Reporting shall be performed per the respective PG&E and 10CFR 50 Appendix B supplier control procedures. However, this statement does not identify the document to follow to report anomalies.

Please identify and describe the process that PG&E will follow for reporting mechanisms.

PG&E Response: PG&E administrative procedure X11.ID2, "Regulatory Reporting Requirements and Reporting Process," provides the instructions for reporting facility events and conditions to the NRC. This procedure applies to plant problems, including software anomalies, and provides a list of regulatory reporting requirements applicable to the DCPP, including those contained in the NRC regulations- (including 10 CFR), the plant operating license (including associated Technical Specifications), license amendments, and regulatory correspondence. The procedure summarizes the types of reporting requirements and references the source of the requirement, time-frame for reporting, reporting method, lead responsible organization, primary regulatory agency recipient, and implementing procedures.

August 20, 2012 DCPP PPS Open Item Summary Table Page 45 of 55 No SrclR Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response I

(Due Date) --

38 RA Software Management Plan OPEN New Section 2 of the PG&E "PPS Replacement Concept, Requirements, and Licensing Phase 1 Project Plan" does not describe the activities to be performed by the Engineering of Choice Design Change Package Team.

It is also not clear what the roles and responsibilities of this team are. Please i clarify and provide the applicable PG&E control document that describes PG&E roles and responsibilities specifically for the Engineering of Choice Design Change Package Team.

PG&E Response: IN PROGRESS I

39 RA Software Management Plan OPEN New Figure 2-1 of the PG&E "PPS Replacement Concept, Requirements, and Licensing Phase 1 Project Plan" and Figure 3-1 of the SyQAP identify Altran under the PG&E Project Engineering box. However, Figure 4-1 of the SyWP identifies PG&E project team under the PG&E Project Engineering box.

Please explain the role and responsibilities for Altran during the PPS Replacement Project.

PG&E Response: IN PROGRESS 40 RA Software Tools OPEN New In the ALS Progress Update 2012-08-01 provided to the staff, Westinghouse/CSI described that they are replacing Automated Test Environment (ATE) from IW credited tools with a LabView based ALS Board Test System (ABTS). Also, in this presentation, Westinghouse/CSI noted that they are performing additionallV&V and equipment qualification tools.

Since this information needs to be reflected in the software planning .

August 20. 2012 DCPP PPS Open Item Summary Table Page 46 of 55 No SrclR Issue Description P&GE response: Status RAI No.

(Date Sent)

RA/

Response

Comments I

/

(Due Date) documents, please identify how these items will affect Westinghouse/ALS documents related to PPS replacement project. Also, identify what document will be revised to include description of these modifications.

---

~

PG&E Response: IN PROGRESS 41 RA Software V&V and Test Plan OPEN New I Westinghouse/ALS document 6116-0005, section 8.2 identifies the software tools to be used in the PPS replacement project. However, this list is not consistent with the list of IV&V tools identified in Section 3.6 of ALS W Plan 6002-00003. Specifically, the test tools identified in 6002-00003 are not listed in 6116-00005 and vice versa. For example, the W Plan (6002-00003) identifies ATE tool for IV&V, but this tool is not listed in 6116-0005 Rev. 1.

Furthermore, the staff reviewed 6116-0005 Rev. 0, and found that the ATE tool was listed in this version. Please clarify what software tools will be used and what document describes them.

PG&E Response: IN PROGRESS

~ --

42 RA Software V&V OPEN New PG&E "PPS System Replacement System Verification and Validation Plan (SyWP)" does not describe the V&V activities to be performed during the Operation Phase and Maintenance Phase. This document states that these activities are covered by approved DCPP procedures. Please identify these DCPP procedures.

PG&E Response: IN PROGRESS

August 20. 2012 DCPP PPS Open Item Summary Table Page 47 of 55 No SrC/R Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response I

(Due Date) 43 RA Software V&V OPEN New PG&E "PPS System Replacement System Verification and Validation Plan (SyWP)", Section 5.1.1, explains that during the Concept Phase, PG&E will verify system requirements in accordance with PG&E procedure CF2.ID9, "Software Quality Assurance for Software Development." However, Procedure CF2.ID9 is for in-house development of software applications.

Please explain how this procedure is going to be used for the PPS replacement project.

Further, Section 5.1.2 of the CF2.ID9 states that and independent review of the functional requirements prepared during the concept phase would be performed. The PG&E SyWP does not identify this review, and thus there is no specific V&V product for this phase. Please identify who will perform this review and if this is considered a V&V product.

PG&E Response: IN PROGRESS 44 RA Software V&V OPEN New Invensys prepared Document No. 993754-1-813, "DCPP PPS Validation Test Plan". It states that the Test Review Board and PG&E will review all validation testing documents. Please describe the composition of the Test I Review Board, since its role/responsibility is not described in the Invensys V&V Plan or in the Validation Test Plan (Section 4.4)

PG&E Response: IN PROGRESS

August 20, 2012 DCPP PPS Open Item Summary Table Page 48 of 55 No SrclR Issue Description P&GE response: Status RAINo RAI Comments I (Date Sen t) I Response (Due Date) 45 RA Follow up of item 18 - Software V&V OPEN New RG 1.168 identifies five of the activities in IEEE Std. 1012-1998, Annex G, "Optional V&V Tasks," as being considered by the NRC staff to be necessary components of acceptable methods for meeting the requirements of Appendices A and B to 10 CFR Part 50 as applied to software. These tasks are:

1. Audits

2. Regression Analysis and Testing

3. Security Assessment

4. Test Evaluation

5. Evaluation of User Documentation Westinghouse/ ALS Document No. 6002-00003, "ALS W Plan" describes the following techniques for V&V: reviews, testing, traceability analysis, inspection/analysis, and IV&V regreSSion (change) analysis. This plan does not include any of the optional V&Vactivities identified in IEEE Std.1012 1998, Annex G. Please explain if these activities are performed.

PG&E Response: IN PROGRESS 46 RA Software V&V OPEN New Several sections in the Invensys Software Verification and Validation Plan (SWP) reference "applicable Project Procedure Manual (PPM)" to perform certain activities. The reference section in this plan identifies PPM (Reference 2.4.4). It is not clear if the PPM is constituted by several procedures or if it is only one procedure. For example, Section 1.1, states the SWP was prepared in accordance with PPM 7.0 (Ref. 2.4.4), and then Section 4 states that V&V activities will be planned and scheduled in accordance with the applicable PPM. Please describe what the PPM is, and explain how this is going to be used in the PPS replacement project.

August 20. 2012 DCPP PPS Open Item Summary Table Page 49 of 55 No SrclR Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response I

(Due Date)

PG&E Response: IN PROGRESS 47 RA Software V&V OPEN New Invensys Document No. 993754-1-802, "Software Verification and Validation Plan" requires the use of V&V metrics to evaluate software development process and products. This section does not explain what methods and criteria will be used for software safety metrics. This information is required by section B.3.1 of BTP 7-14, RG 1.152, RG 1.173 and IEEE Stds. 1061 and 1074. Also BTP 7-14 Section B.3.1.1.2. Please provide this information.

~-

PG&E Response: IN PROGESS 48 RA Software V&V OPEN New PG&E SyWP, Section 6. requires that anomalies detected are identified, documented, and resolved during the V&V activities. This section states that anomaly reporting and resolution requirements are defined in the respective PG&E control procedures. Section 2 "Control Procedures does not include a reference for an anomaly reporting procedure. Please identify the PG&E control procedure used for anomaly reporting.

Further, Section 7 of the SyWP states that the PG&E authority responsible for approving deviations from SyWP is the PG&E Project Manager, who will document his/her approval a Change Notice or equivalent formal PG&E document. Please identify where the responsible PG&E authority will document its approval.

August 20. 2012 DCPP PPS Open Item Summary Table Page 50 of 55 No SrclR Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response I

(Due Date)

-- PG&E Response: IN PROGRESS

-- r--

49 RA Software V&V OPEN New Invensys Document No. 993754-1-802, "Software Verification and Validation Plan", Section 6.3 states that the Invensys personnel prepared System Deficiency Integration Report (SDlR) to document non-conformances and corrective actions during testing; the SDIR is prepared in accordance with PPM 10.0. Please explain what PPM this is.

Further, the Invensys "Validation Test Plan", Section 5.4.2 states that the Test Review Board and PG&E shall review SDIRs, but this is not indicated in the Invensys V&V plan. Please explain why this review activity is not identified as a V&V task in the V&V Plan ..

PG&E Response: IN PROGRESS 50 RA Software V&V OPEN The Invensys Validation test plan, Section 8.2, states that the Narrative Test New Logs are used to document conduct of testing and any anomalies that occur.

Please explain if this is only used during validation, and why this is not mentioned in the Invensys SWP. Further, please explain how is this used in conjunction with Document Review Comment Sheet (DRCS) and System Deficiency Integration Report (SDIR)?

August 20, 2012 DCPP PPS Open Item Summary Table - --

Page 51 of 55 No SrclR Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response I

(Due Date)

PG&E Response: IN PROGRESS 51 RA Software Configuration Management OPEN See Attachment 2. New PG&E Response: IN PROGRESS 52 RJS Security:

NSIR PG&E stated in its letters DCL-11-123 and DCL-11-104 that the PPS replacement will be fully compliant with the 10 CFR 73.54 cyber security requirements, including RG 5.71, Revision 0, "Cyber Security Programs for Nuclear Facilities," dated January 2010, and is being reviewed to comply with 10 CFR 50.73, the DCPP Cyber Security Plan, and NEI 08-09, "Cyber Security Plan for Nuclear Power Reactors," Revision 6, dated April 2010.

The cyber security program that PG&E is implementing per its NRC approved cyber security plan includes provisions applicable to all phases of a systems' life cycle, including the digital upgrade or modification of critical digital assets.

Please explain how the provisions outlined in the PG&E's NRC-approved cyber security plan were considered, and/or implemented, as part of the PPS replacement. The provided explanations should include how all of the management, operational, and technical security controls contained within the plan, especially security controls associated with Configuration Management and System and Service Acquisition, are being addressed.

The provided explanations should also include any issues associated with partial implementation of the PPS replacement and full implementation of the cyber security plan for the site, and processes to identify and resolve any

August 20,2012 DCPP PPS Open Item Summary Table Page 52 of 55 No SrclR Issue Description P&GE response: Status RAI No. RAI Comments I (Date Sent) Response (Due Date) such issues.

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,....--~~-~

August 20,2012 DCPP PPS Open Item Summary Table Page 53 of 55 Figure 1 DCPP 120 Volt Vital Instrument AC System (Simplified) 480V BUS 1F

-l SD11 (21) S013 (23)

UPS UPS UPS IY11 IY12 IY13 (21 ) (22) (23)

AC AC AC DC NIA Transfer Switch DC Transfer Switch Transfer SWitch N Transfer Switch fRY 13

. (23)

~

To Protection Set I To Protection Set 1/ To Protection Set IV To Protedlon Set III Legend:

IY: UPS and DC-AC Inverter PY: 120 VAC Distribution Panel SO: 125 VOC Distribution Panel TRY: 480 VAC/120 VAC Transformer and Regulator Normal Power Flow (N)

Bypass (120 VAC)/Backup (125 VDC) Power Flow Alternate Bypass Power Flow (A)

Unit 1 Component 10's are shown; Unit 2 Component 10's are in parentheses. For example, PY11 is Unit 1 Vital Instrument AC Distribution Panel 1 ; PY21 is Unit 2 Vital Instrument AC Distribution Panel 1.

August 20,2012 DCPP PPS Open Item Summary Table Open Items Related to Software Configuration Management Plan

1) Configuration process a) In open item 4, the staff requested description of the software configuration management activities for configurable boards (e.g., ALS FPGA-102 board). Since the ALS FPGA-102 board is customer specific, its configuration management activities are not covered by "ALS Configuration Management Plan."

Even though item 4 is closed, this request was not addressed in the response for item 4.

b) The PG&E SCM 36-01, item 1.2.8, states that ALS board has two sets of NVRAM. Further, it explains that the configuration of the NVRAM can be changed only by removing the subject board from the ALS chassis and inserting it into a special test fixture. It is not clear who will control this process and configuration of the NVRAM. Please explain.

c) Section 1.2 of the Invensys Document No. 993754-1-909, "Software Configuration Management Plan,"

states that this plan controls operating system of the computers used to run TriStation 1131 and the signal simulation software used for testing purpose. However, the description provided throughout the plan only focuses on the configuration activities for the TSAP (e.g., Section 2.3 states that the SCM procedures are for the TSAP). Further, this same section (later on) identifies the software configuration to be managed, and this list does not include operating system of the computers used to run TriStation 1131 and the signal simulation software used for testing purpose. Please clarify the scope of this plan.

2) Organization a) The organization and responsibilities described in Section 4 of CF2.ID2 is not consistent with the information presented in Section 2 of SCMP 36-01. For example, Section 2 of SCMP 36-01 identifies system coordinator, application sponsor, and system team, who are not identified in Section 4 of Cf2.ID2. Further these descriptions are not identified in the project organization described in PG&E PPS Replacement Plan (Attachment 3 of the LAR). Please clarify the roles and responsibilities for SCM, and provide a cross reference of the PG&E organizations described in these documents.

3) Changes and Problems Identification a) PG&E SCMP36-01 states that software, hardware, and configuration problems are reported in accordance with PG&E OM7.ID1 and that software and/or configuration problems are reported via a PROG PDCM Notification. Please clarify when and how these are used. For example, for software problems does one have to report the problem using both PG&E OM7.ID1 and PROG PDCM Notification. Note that PG&E CF2.1D2 states that all problems associated with plant computer system should be reported and document per OM7.ID1 (See section 5.11 and 5.16.10 (b) of CF2.ID2)

Further, Section 3.2.1 states that all PPS modifications should be initiated and tracked per plant procedures or CF4.ID1. Section 3.2.2 states that the implementation of the change is documented in the associated Change Package and a SAP notification and order. And Section 3.2.10 states that all identified problems and corrective actions using a notification, which is not specified.

So should software modifications require reporting and tracking using OM7.1D1, CF4.ID1, PROG PDCM Notification, Change Package, and SAP Order?

Please explain PG&E procedures for different changes and the documenting and tracking system used for all types of modification.

b) Please clarify the means to track changes. Section 3.2.4.7 of the SCM 36-01 states that this is done using a SAP order, but Section 3.2.4.7 states that Change Package and SAP order are entered in the

August 20,2012 DCPP PPS Open Item Summary Table Record Management System, and Section 3.3 describes a Configuration Status Account, which is used to track changes of configuration items.

4) Document Repository a) SCM 36-01, Section 2.3.3 identifies the Digital Systems Engineering SourceSafe as the repository, but Section 3.2.5.5 identifies http://dcpp142/idmws/home/asp, and Section 3.29 states that the files necessary for recovery of the baseline are maintained in the PPS database in SC-I-36M, Eagle 21 Tunable Constants." It is not clear if these two sections are referring to the same document reporsitory or if it is the same. Please clarify b) PG&E has implemented restrictions to access files and documents associated with PPS replacement project. Further, PG&E requires user authentication and access to edit configuration, software, and data. It is not clear if these restrictions apply for access to the Digital Systems Engineering SourceSafe or the repository in http://dcpp142/idmws/home/asp.

Project Plan for Diablo Canyon Replacement of Digital RPS and ESFAS (PPS) - LAR Review (Rev. 3)

Step Planned Task Actual Date Date 1 Oct. PG&E LAR Submittal for NRC approval. Submittal includes all Oct. 26, 26,2011 Phase 1 documents needed to be docketed prior to acceptance for 2011 review per ISG-06, "Digital Licensing."

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

3 Jan. 13, Acceptance letter sent to licensee. Jan. 13, 2012 2012 4 Jan. 1B, Conduct Public Meeting to discuss staff's findings during the LAR Jan. 1B, 2012 acceptance review. Staff proceeds with LAR technical review. 2012 5 March 18, PG&E provides information requested in acceptance letter. Initiate April 2, 2012 bi-weekly telecoms with PG&E and its contractors to discuss 2012 potential RAI issues. Open Items spreadsheet will be maintained by NRC to document staff issues and planned licensee responses.

6 May 30, PG&E provides partial set of Phase 2 documentation per June 6, 2012 commitments made in LAR. 2012*

• PG&E provided a subset of the Phase 2 documents on June fJh and committed to send the rest by July 31, 2012.

7 July First RAI sent to PG&E on Phase 1 documentation (e.g., August 07, 2012 specifications, plans, and equipment qualification). Continue 2012 review of the application. Request 45 day response.

(ML 1220BA364)

B June SER for Tricon V1 0 Platform issued final. This platform becomes a May 15, 2012 Tier 1 review of the LAR. (ML 12146A01Q) 2012 B.1 March 2013 SER for Westinghouse ALS Platform issued final. This platform becomes a Tier 1 review of the LAR.

9 September Receive answers to first RAI.

2012 10 November Audit trip to Invensys facility for thread audit; audit the life cycle 2012 planning documents and outputs, with particular emphases on verification and validation, configuration management, quality Assurance, software safety, the Invensys application software development procedures, and application software program design.

11 December Audit report provided to PG&E and its contractor.

2012 11.1 TSD LAR revision and all supporting documentation associated with the change in ALS and Tricon V1 0 workstation designs for the PPS are submitted.

12 December PG&E provides remaining set of Phase 2 documentation per 2012 commitments made in LAR.

12.1 December All Documentation for DCPP W/CSI ALS and IOMlTriconex V1 0 2012 processors applicable to the DCPP PPS LAR are submitted.

13 January Second RAI to PG&E on Phase 2 documentation (e.g., FEMA, 2013 safety analysis, RTM, EQ Tests results, setpoint calcs, SW Tool Page 1 of 2 Enclosure 3

Project Plan for Diablo Canyon Replacement of Digital RPS and ESFAS (PPS) - LAR Review (Rev. 3) i analysis reports, and any incomplete or un-satisfactory response to I first RAI. Continue review - hardware and program design and V& V activities 14 February Receive answers to second RAI.

2013 Continue review - V&V program, security requirements (RG 1.152, Rev.2) 15 February Audit trip to W/ALS facilities for additional thread audit items; audit 2013 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 application code listings.

15.1 March 2013 Audit trip to Invensys facilities for additional thread audit items; audit hardware and software installation plans, configuration management reports, detailed system and hardware design, completed test procedures, V&Vactivities, summary test results (including FAT) and incident reports, and application code listings.

~ +IiQ A1;I8i~ b;i~ ~8 QGj;!j;! ~est feuilililies ~el' S88iti8Rsi U~l'eS8 sI;I8it items; sI;I8it RSI'8'aI,ISFe SR8 s8ft¥,sFe iRstsIIsti8R ~ISR8, 88Rfi!ll;lFsti8R mSRs!l9m9R~ Fe~8Rs, 8e~sile8 s~stem SR8 RSF8¥,sFe 8esi!;JR, 88m~lete8 test ~F88e8wres, V&V s&tivities, sl;lmmsry test reswlts 1i~~I, ,,:_ C' 1\ T\ .~". '.J. .... _" ,I:' .J. I' .

I 16 April Audit reports provided to PG&E and its contractors.

2013 17 July Presentation to ACRS Subcommittee/Full ACRS Committee on 2013 DCPP PPS LAR Safety Evaluation.

18 July 2013 Complete draft technical SER for management review and approval.

19 August Issue completed draft technical SER to DORL 2013 20 August Draft SER sent it to PG&E, Invensys, and W/CSI to perform 2013 technical review and ensure no proprietary information was included.

21 September Receive comments from PG&E and its contractors on draft SER 2013 proprietary review.

22 -November Approved License Amendment issued to PG&E 2013 23 -January Inspection trip to DCPP for PPS SAT and installation test, training 2014 and other preparation for new system. To be coordinated with regional visit. Date based on October 2014 Unit 1 Refueling Outage (1 R18).

I Page 2 of 2

- 3 Please direct any inquiries to me at 301-415-1132 or at Joseph.Sebrosky@nrc.gov.

IRA!

Joseph M. Sebrosky, Senior Project Manager Plant licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosures:

1. List of attendees

2. Staff identified issues

3. Project Plan cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC lWertz, NRR LPLIV Reading WKemper, NRRIDE/EICB RidsAcrsAcnw_MaiICTR Resource RStattel, NRR/DE/EICB RidsNrrDeEicb Resource RAlvarado, NRR/DE/EICB RidsNrrDorl Resource WMaier, RIV RidsNrrDorlLpl4 Resource SMakor, RIV/DRS/EB2 RidsNrrLAJBurkhardt Resource SAchen, RIVlDRS/EB2 RidsNrrPMDiabloCanyon Resource ELee, NSIR/DSP/CSIRB RidsNsirDsp Resource DParsons, NSIR/DSP/CSIRB RidsOgcRp Resource GSimonds, NSIRIDSP/CSIRB RidsRgn4MailCenter Resource THarris, NSIRIDSP/FCTSB SKennedy, EDO RIV ADAMS------_

A .. _- Nos. Meetina Notice ML12195A173; Meetina S _..... -_.. ML12242A256 OFFICE NRR/DORLlLPL4/PM NRR/DORLlLPL4/LA NRR/DE/EICB NAME JSebrosky JBurkhardt RStattel DATE 9/24/12 9/17/12 9/17/12 I OFFICE NSIR/DSP/CSIRB NRR/DORLlLPL4/BC NRR/DORLlLPL4/PM NAME DParsons MMarkley JSebrosky DATE 9/24/12 9/25/12 9/25/12 OFFICIAL RECORD COpy