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 (TAC Nos. ME7522 and ME7523)

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 M
References
TAC ME7522, TAC ME7523
Download: ML12242A256 (62)

Text

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

SUBJECT:

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. ML 113070457). 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.

-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. ML 12208A364). 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 AUGUST 22, 2012, TELECONFERENCE MEETING PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT DIGITAL DOCKET NOS. 50-275 AND NAME Ken Schrader Scott Patterson John Hefler R. Lint J. Rengepis E. Quinn J. Basso W.Odess-Gillet G. Andre Roman Shaffer Rich Stattel Bill Kemper Rossnyev Alvarado Eric Lee Darryl Parsons George Simonds Tim Harris Joe Sebrosky Shiattin Makor Gordon Clefton Craig Butler ORGANIZATION Pacific Gas and Electric Pacific Gas and Electric Altran Altran Altran Altran Westinghouse Westinghouse Westinghouse InvensyslTriconex U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Nuclear Energy Institute Areva Enclosure 1 August 20, 2012 DCPP PPS Open Item Summary Table Page 1 of 55 No I SrC/R IIssue DescripUon I P&GE response: IStatus IRAI No. I RAI (Date Sent) Comments Enclosure August 20,2012 DCPP PPS Open Item Summary Table Page 2 of 55 No I SrclR I Issue Description I P&GE response: I Status ,.' .... .... .',. \'" ",;'1 part wltCbe submitted by 12131112:-. . , ., I RAI No. I RAI (Date Sent) Comments I August 20, 2012 DCPP PPS Open Item Summary Table Page 3 of 55 ......=, Comments (Date Sent) No I SrC/R IIssue Description P&GE response: RAI No. IRAI Response (Due August 20, 2012 DCPP PPS Open Item Summary Table Page 4 of 55 No I SrC/R \ Issue Description I P&GE response: IStatus IRAI No. IRAI (Date Sent) Response (Due Comments August 20,2012 DCPP PPS Open Item Summary Table Page 5 of 55 No I SrC/R IIssue Description I P&GE response: IStatus IRAI No. IRAI (Date Sent) Response Comments (Due Date)

August 20,2012 DCPP PPS Open Item Summary Table Page 6 of 55 No I SrC/R IJssue Description CommentsP&GE response: IStatus IRAJ No. IRAJ (Date Sent) ResponseJ (Due PPS Replacement Project Management Plan (PMP), 993754 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 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 SrclR IIssue Description I P&GE response: IStatus IRAI No. IRAI (Date Sent) Response 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. (Due Comments August 20,2012 DCPP PPS Open Item Summary Table Page 8 of 55 No I Src/R IIssue Description I P&GE response: I Status IRAI No. I RAI (Date Sent) Comments August 20, 2012 DCPP PPS Open Item Summary Table Page 9 of 55 CommentsINo ISrC/R Itssue Description IP&GE response: IStatus IRAt No. IRAt t (Date Sent) Response (Due Date)

I August 20, 2012 DCPP PPS Open Item Summary Table Page 10 of 55 CommentsINo ISrclR IIssue Description ., P&GE response: IStatus IRAI No. IRAI (Date Sent) Response (Due August 20,2012 DCPP PPS Open Item Summary Table Page 11 of 55 No I SrclR IIssue Description I P&GE response: IStatus IRAI No. IRAI (Date Sent) Response (Due Date) Comments August 20, 2012 DCPP PPS Open Item Summary Table Page 12 of 55 No I SrclR IIssue Description I P&GE response: IStatus IRAI No. IRAI (Date Sent) Response (Due Date) Comments August 20, 2012 DCPP PPS Open Item Summary Table Page 13 of 55 P&GE response: IStatus IRAJ No. IRAJ CommentsNo ISrclR IIssue Description J (Date Sent)

August 20, 2012 DCPP PPS Open Item Summary Table Page 14 of 55 No I SrclR IIssue Description I P&GE response: IStatus IRAI No. IRAI (Date Sent) Response (Due Comments August 20, 2012 DCPP PPS Open Item Summary Table Page 15 of 55 No I SrclR IIssue Description I P&GE response: IStatus IRAI No. I RAI (Date Sent) Comments August 20,2012 DCPP PPS Open Item Summary Table Page 16 of 55 P&GE response: IStatus IRAI No. IRAI CommentsNo ISrclR !/ssue Description I (Date Sent)

August 20,2012 DCPP PPS Open Item Summary Table Page 17 of 55 IP&GE response: IStatus IRAI No. IRAI Comments (Date Sent) Response (Due No I SrclR IIssue Description I August 20, 2012 DCPP PPS Open Item Summary Table Page 18 of 55 No I SrclR IIssue Description I P&GE response: IStatus IRAI No. I RAI (Date Sent) Comments I August 20, 2012 DCPP PPS Open Item Summary Table Page 19 of 55 P&GE response:-rStatus IRAI No. IRAI CommentsNo ISrclR IIssue Description I i (Date Sent)

August 20,2012 DCPP PPS Open Item Summary Table Page 20 of 55 P&GE response: IStatus IRAI No. IRAI CommentsNo **1 SrclR IIssue Description I (Date Sent)

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

I August 20, 2012 DCPP PPS Open Item Summary Table Page 22 of 55 P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due No I SrC/R IIssue Description August 20,2012 DCPP PPS Open Item Summary Table Page 23 of 55 No I SrC/R IIssue Description I P&GE response: IStatus IRAI No. IRAI (Date Sent) Response (Due Comments August 20,2012 DCPP PPS Open Item Summary Table Page 24 of 55 No I SrC/R IIssue Description I P&GE response: IStatus IRAJ No. (Date Sent) I RAI Comments 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 SrclR IIssue Description I P&GE response: IStatus IRAI No. IRAJ (Date Sent) Response (Due Comments 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 , P&GE response: No ISrclR IIssue Description I RAI No. I RAJ (Date Sent) Comments

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I 21 August 20, 2012 ocpp PPS Open Item Summary Table Page 29 of 55 -No SrclR Issue Description P&GE response: RA Westinghouse/CSI document 6116-00005, "Diablo Canyon PPS System Test Plan," states that the ALS-102 FPGA design is changed for the DCPPS System. Further, Section 5.3.3 states: "Test as many of the ALS-1 02 requirements as possible." Please identify what document describes the design verification test for this board. PG&E response: The documents that describe the design verification tests for the ALS-102 are 6116-70140, "Diablo Canyon PPS System Test Design Specification," submitted June 6,2012, and 6116-10216, "Diablo Canyon PPS W Simulation Environment Specification" that will be submitted by September 30, 2012. Status Open (Hold) RAI No. (Date Sent) RAI10 Not used RAI Response (Due Date) Comments 6-13-12 PG&E that they need provide an to this response. the PG&E and have provided specifications will address this These are placed on PG&E website. Doc. 6116-10740 submitted on 6, 2012, describes system test specification. No was also on June 6, which ALS system Doc. No. Specification be provided in 3/21/12 update: I August 20,2012 DCPP PPS Open Item Summary Table Page 30 of 55 No SrclR I Issue Description P&GE response: Status RAI No. (Date Sent) RAI Response (Due Date) Comments 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 P&GE response: IStatus IRAI No. I RAI CommentsNo ISrclR IIssue Description I (Date Sent)

August 20, 2012 DCPP PPS Open Item Summary Table Page 32 of P&GE response: I Status I RAI No. IRAI (Date Sent) Response No I SrC/R IIssue Description I Comments (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 '-1. IRAJ No. I RAJ CommentsNo I SrclR IIssue Description I P&GE response: (Date Sent)

August 20,2012 DCPP PPS Open Item Summary Table Page 34 of 55 No I SrcJR IIssue Description I P&GE response: IStatus IRAI No. IRAI (Date Sent) Response (Due Comments I August20,2012 DCPP PPS Open Item Summary Table Page 35 of No I SrclR I Issue P&GE response: -----rl-S-ta-tu-s--.IRAI No. IRAI Comments (Date Sent) Response (Due I August 20, 2012 DCPP PPS Open Item Summary Table 36 of 55 No ISrclR I Issue Description P&GE response: IStatus IRAJ No. (Date Sent) IRAJ Response (Due Comments August 20,2012 DCPP PPS Open Item Summary Table Page 37 of 55 No ISrclR IIssue Description IP&GE response: IStatus IRAI No. I RAI Comments I (Date Sent)

I 30 August20,2012 DCPP PPS Open Item Summary Table Page 38 of 55 P&GE response: IStatus IRAI No. IRAI CommentsNo I SrclR IIssue Description I (Date Sent) IRAI14RA Software Development Plan Open (Hold) 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 906, Software Development Plan, and pending review of 993754 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 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 906, describes the software development process for the Invensys scope of the PPS Replacement Project. 993754 906, has been revised to Revision 1, to include new Section 3.2.6 that discusses problem reporting and corrective action. 993754 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 SrclR IIssue Description J P&GE response: IStatus IRAJ No. IRAJ (Date Sent) Response In addition, the Invensys Software Quality Assurance Plan, 993754 900, Section 8, and the Invensys Software Configuration Management Plan, 993754 909, Section 3.2, both provide reference to procedures to follow when deviations are identified and how deviations are corrected. (Due Comments August 20,2012 DCPP PPS Open Item Summary Table Page 40 of 55 No I SrclR I Issue Description I P&GE response: I Status I RAI No. IRAI (Date Sent) Response Comments (Due August 20,2012 DCPP PPS Open Item Summary Table No ISrC/R IIssue Description I P&GE response: Status RAJ No. RAJ under load, (ALS SOAP) Software tools are used extensively during the FPGA development process. The staff therefore considers these tools to be a key component to the assurance of quality in the ALS system development process. The ALS SOAP states that "no additional tools, techniques, or methodologies have been identified" for the ALS system. The staff considers the development tools, as well as the techniques and methodologies used during system development to be relevant to the assurance of quality for the ALS system. Please provide information on the tools, and methodologies used during system development to ensure quality of the ALS system products. PG&E response: Westinghouse agrees that Section 8, Tools, Techniques, And Methodologies of the ALS OA Plan (6002-00001) should be revised to reference document 6002-00030, "ALS Design Tools." This document describes the tools used and how they are used in the design process. This document is also on the ALS docket. Westinghouse will submit a revision of the ALS OA Plan on the ALS docket.by IN PROGRESS Open (Hold) (Date Sent) Response (Due Date) 41 of 55 Comments Item initiated on 6/5/12. 6-13-12 update (Kemper): W/ALS agrees with NRC's position on tools and will revise the document (Doc. No. 6002-00001) accordingly to address this matter. Placed this item on hold pending review of revised OA plan.

August 20,2012 DCPP PPS Open Item Summary Table Page 42 of 55 response: NC:-::o-*---rI RAI CommentsNo ISrcIR IIssue Description (Date Sent) I August 20, 2012 DCPP PPS Open Item Summary Table Page 43 of 55 No ISrclR IIssue Description IP&GE response: I (Date Sent)I m IRAI Response 35 Follow up of Item 21 -Software Test Plan (Due Comments 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 I Issue Description P&GE response: Status RAI No. (Date Sent) RAI Response (Due Comments 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 1 OCFR 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 38 ---SrclR I RA Issue Description P&GE response: Software Management Plan 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 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 Status OPEN New RAI No. (Date Sent) RAI Response (Due Date) Comments 39 RA Software Management Plan 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 OPEN New I 40 RA Software Tools 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 OPEN New .

August 20. 2012 DCPP PPS Open Item Summary Table Page 46 of 55 -No SrclR / Issue Description P&GE response: 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 Status RAI No. (Date Sent) RA/ Response (Due Date) Comments I 41 RA Software V&V and Test Plan 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 OPEN New I 42 RA Software V&V 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 OPEN New August 20. 2012 DCPP PPS Open Item Summary Table Page 47 of 55 No SrC/R I Issue Description P&GE response: Status RA/ No. (Date Sent) RA/ Response (Due Date) Comments 43 RA Software V&V 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. OPEN New PG&E Response: IN PROGRESS 44 RA Software V&V Invensys prepared Document No. 993754 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 Review Board, since its role/responsibility is not described in the Invensys V&V Plan or in the Validation Test Plan (Section 4.4) OPEN New I PG&E Response: IN PROGRESS August 20, 2012 DCPP PPS Open Item Summary Table P&GE response: Issue Description No SrclR I Follow up of item 18 -Software V&V 45 RA RG 1.168 identifies five of the activities in IEEE Std. 1 012-1998, 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 1998, Annex G. Please explain if these activities are performed. PG&E Response: IN PROGRESS 46 RA Software V&V 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. Status Page 48 of 55 RAINo RAI Comments (Date Sen t) I Response (Due Date)

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I August 20. 2012 DCPP PPS Open Item Summary Table Page 49 of 55 -RAIRAI No. CommentsStatusP&GE response: Issue Description No SrclR (Date Sent) Response (Due Date) PG&E Response: IN PROGRESS 47 RA Software V&V Invensys Document No. 993754 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 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. OPEN New OPEN New

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I August 20. 2012 DCPP PPS Open Item Summary Table Page 50 of 55 -RAI No. RAI CommentsStatusP&GE response: SrclR Issue Description No (Date Sent) Response (Due Date) PG&E Response: IN PROGRESS 49 RA Software V&V Invensys Document No. 993754 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 The Invensys Validation test plan, Section 8.2, states that the Narrative Test 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)? --OPEN New OPEN New

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August 20, 2012 DCPP PPS Open Item Summary Table Page 51 of 55 -P&GE response: Issue Description No SrclR I PG&E Response: IN PROGRESS 51 Software Configuration See Attachment RA PG&E Response: IN PROGRESS 52 RJS 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 Status RAI No. (Date Sent) RAI Comments Response (Due Date)

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.

August 20,2012 DCPP PPS Open Item Summary Table Page 53 of 55 Attachment 1 Figure 1 DCPP 120 Volt Vital Instrument AC System (Simplified) AC DC To Protection Set I To Protection Set 1/ Legend: UPS IY12 (22) -l AC Transfer SWitch UPS IY13 (23) N Transfer 480V BUS 1F S013 (23)SD11 (21) (21 ) AC TransferDC TransferNIA$ Switch SwitchSwitch fRY 13 . (23) To Protection Set IV To Protedlon Set III 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 Bypass (120 VAC)/Backup (125 VDC) Power Alternate Bypass Power Flow 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 Attachment 2 Open Items Related to Software Configuration Management Plan 1) Configuration process 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. 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. Section 1.2 of the Invensys Document No. 993754 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 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 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 ESFAS (PPS) -LAR Review (Rev. Step Planned Date Task Actual Date 1 Oct. 26,2011 PG&E LAR Submittal for NRC approval. Submittal includes all Phase 1 documents needed to be docketed prior to acceptance for review per ISG-06, "Digital Licensing." Oct. 26, 2011 2 Jan. 12, 2012 Acceptance Review complete. LAR accepted for detailed technical review. Several issues identified that could present challenges for the staff to complete its review. Scheduled public meeting with PG&E to discuss the results of the acceptance review. Jan. 12, 2012 3 Jan. 13, 2012 Acceptance letter sent to licensee. Jan. 13, 2012 4 Jan. 1B, 2012 Conduct Public Meeting to discuss staff's findings during the LAR acceptance review. Staff proceeds with LAR technical review. Jan. 1B, 2012 5 March 18, 2012 PG&E provides information requested in acceptance letter. Initiate bi-weekly telecoms with PG&E and its contractors to discuss potential RAI issues. Open Items spreadsheet will be maintained by NRC to document staff issues and planned licensee responses. April 2, 2012 6 May 30, 2012 PG&E provides partial set of Phase 2 documentation per commitments made in LAR. *PG&E provided a subset of the Phase 2 documents on June fJh and committed to send the rest by July 31, 2012. June 6, 2012* 7 July 2012 First RAI sent to PG&E on Phase 1 documentation (e.g., specifications, plans, and equipment qualification). Continue review of the application. Request 45 day response. (ML 1220BA364) August 07, 2012 B June 2012 SER for Tricon V1 0 Platform issued final. This platform becomes a Tier 1 review of the LAR. (ML 12146A01Q) May 15, 2012 B.1 March 2013 SER for Westinghouse ALS Platform issued final. This platform becomes a Tier 1 review of the LAR. 9 September 2012 Receive answers to first RAI. 10 November 2012 Audit trip to Invensys facility for thread audit; audit the life cycle 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 2012 Audit report provided to PG&E and its contractor. 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 2012 PG&E provides remaining set of Phase 2 documentation per commitments made in LAR. 12.1 December 2012 All Documentation for DCPP W/CSI ALS and IOMlTriconex V1 0 processors applicable to the DCPP PPS LAR are submitted. 13 January 2013 Second RAI to PG&E on Phase 2 documentation (e.g., FEMA, 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 ESFAS (PPS) -LAR Review (Rev. i 14 15 15.1 February 2013 February 2013 March 2013 +IiQ analysis reports, and any incomplete or un-satisfactory response to first RAI. Continue review -hardware and program design and V& V activities Receive answers to second RAI. Continue review -V&V program, security requirements (RG 1.152, Rev.2) 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 application code listings. 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. QGj;!j;! feuilililies S88iti8Rsi sI;I8it items; I sI;I8it RSI'8'aI,ISFe SR8 s8ft¥,sFe iRstsIIsti8R 88Rfi!ll;lFsti8R SR8 RSF8¥,sFe 8esi!;JR, test V&V s&tivities, sl;lmmsry test reswlts ,,:_ C' 1\ T\ '.J. .... _" ,I:' .J. I' . 16 17 18 19 20 21 22 23 April 2013 July 2013 July 2013 August 2013 August 2013 September 2013 -November 2013 -January 2014 I Audit reports provided to PG&E and its contractors. Presentation to ACRS Subcommittee/Full ACRS Committee on DCPP PPS LAR Safety Evaluation. Complete draft technical SER for management review and approval. Issue completed draft technical SER to DORL Draft SER sent it to PG&E, Invensys, and W/CSI to perform technical review and ensure no proprietary information was included. Receive comments from PG&E and its contractors on draft SER proprietary review. Approved License Amendment issued to PG&E Inspection trip to DCPP for PPS SAT and installation test, training 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

-Please direct any inquiries to me at 301-415-1132 or at Joseph.Sebrosky@nrc.gov. 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 LPLIV Reading RidsAcrsAcnw _MaiICTR Resource RidsNrrDeEicb Resource RidsNrrDorl Resource RidsNrrDorlLpl4 Resource RidsNrrLAJBurkhardt Resource RidsNrrPMDiabloCanyon Resource RidsNsirDsp Resource RidsOgcRp Resource RidsRgn4MailCenter Resource SKennedy, EDO RIV IRA! Joseph M. Sebrosky, Senior Project Manager Plant licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation lWertz, WKemper, RStattel, RAlvarado, WMaier, SMakor, SAchen, ELee, DParsons, GSimonds, THarris, 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