ML14197A352

7/9/14 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

ML14197A352
Person / Time
Site:	Diablo Canyon
Issue date:	07/22/2014
From:	Peter Bamford Plant Licensing Branch IV
To:	Pacific Gas & Electric Co
Bamford P
References
TAC ME7522, TAC ME7523
Download: ML14197A352 (22)

Text

LICENSEE: Pacific Gas and Electric Company FACILITY: Diablo Canyon Power Plant, Unit Nos. 1 and 2

SUMMARY

OF JULY 9, 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 July 9, 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. ML113070457). A list of attendees is provided in Enclosure 1.

The teleconference meeting is one in a series of publicly noticed meetings that is being held periodically to discuss issues associated with the NRC staff's LAR review. Selected open items that are being tracked for this review were discussed during the teleconference meeting. A complete list of the current open items is provided in Enclosure 2.

Highlights from this meeting on July 9, 2014, 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 will be updated by the NRC staff, with input from PG&E, to support the next periodic teleconference meeting, as several target dates will need to be shifted to account for licensee project scheduling delays.

• A tentative date of September 24, 2014, was established as a target for the next periodic meeting.

One member of the public was in attendance for the teleconference meeting and no public meeting feedback forms were submitted.

Please direct any inquiries to me at 301-415-2833 or at Peter.Bamford@nrc.gov.

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Peter Bamford, P ject Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosures:

1. List of Attendees

2. Open Items Listing cc w/encls: Distribution via Listserv

LIST OF ATTENDEES JULY 9. 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 ORGANIZATION K. Schrader Pacific Gas and Electric A. Wilson Pacific Gas and Electric W. Ginter Pacific Gas and Electric A. Breneman Westinghouse T. Tuite Westinghouse M. Shaffer Westinghouse K. Durinsky Westinghouse M. Shakun Westinghouse J. Perock Westinghouse D. Head lnvensys J. McKay lnvensys Rich Stattel Nuclear Regulatory Commission (NRC)

Samir Darbali NRC Rossnyev Alvarado NRC Peter Bamford NRC Gordon Clefton Nuclear Energy Institute Enclosure 1

Enclosure 2 Open Item Summary Table

July 16, 2014Jt~ly 7, ~G~ 4 DCPP PPS Open Item Summary Table Page 1 of 17 No Src/RI Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due Date) 93 RJS (ALS Audit Item) Open 4/16/14- Updated RTM to be made The RTM for the ALS subsystem was prepared using Westinghouse available prior to ALS audit.

document WNA-DS-02442 to trace PG&E requirements. The IV&V team found that Westinghouse document WNA-DS-02442 does not capture all 12/12/13-RJS PG&E requirements (see descriptions for Tickets #4787 and #4800). Current version of Please provide a description of how this issue is being resolved. 6116-00059 on sharepoint is "0."

This does not PG&E Response: establish traceability to the The 6116-00000 Diablo ALS Management Plan, revision 4, specifies an Core FPGA Design updated document structure that has all PG&E Customer Requirements Specifications.

feeding directly into the 6116-00011, which will flow down into all ALS Diablo sub-ordinate requirement and design specifications. Westinghouse 10/16/13- RJS document WNA-DS-02442 has been removed from the document New RTM still does hierarchy. 6116-00000, revision 4, 6116-00011, revision 1, and the 6116- not establish 00059 RTM, revision 0, are all reflective of this new document structure. traceability to the 6116-10203, and Documents 6116-00011, revision 1, was submitted under PGE Letter DCL- 6116-10204 Core 13-087 dated September 17, 2013. The next revision of the 6116-00059 FPGA Design RTM, Revision 1, will include traceability to the Core FPGA Design Specifications.

Specifications, and will be submitted prior to the ALS audit.

Also A new revision of 6116-00059 will need to be docketed due to the significance of changes made since the original document was submitted.

6116-00011, ALS L____ ----

SDS, revision 1

July 16, 2014JtJiy 7, ~Q~ 4 DCPP PPS Open Item Summary Table Page 2 of 17 No Src/RI Issue Description P&GE response: Status RAJ No. RAJ Comments (Date Sent) Response (Due Date) 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 5/16/14 Hold this to Westinghouse. When these are available, PG&E should prepare a open until all document to identify how each applicable PSAI is being addressed for the ASAI's are addressed.

PPS project. This document should include references to the LAR and supporting documents where PSAI's are addressed. 4/16/14- RAI response will only PG&E Response: be partial. 16 of 23 The response to the ALS ASAisrequires input from Westinghouse and a PSAI's will be contract has been created to supply the required information. The addressed. 7 will be deferred by 90 response to the ASAis, except 4, 5, 6, 8, 10, 20, and 22, will be days. Waiting for submitted by March 24, 2014. The response for PSAis 4, 5, 6, 8, 10, input from WH on 20, and 22 will be submitted by August 30, 2014. additional testing.

ASAI4 12/12/13- RJS A version of the ALS TR/ SE is now Status: Response to this ASAI when the ALS platform EO [EMC] testing is available and being complete and the EQ summary report is updated and the hardware reviewed.

detailed design is complete.

July 16, 2014dl:.lly 7, ~Q~ 4 DCPP PPS Open Item Summary Table Page 3 of 17 No Src!RI Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due Date)

ASAI5 ALS Platform Application Restrictions - An applicant or licensee referencing this SE should address its adherence to the manufacturer identified application restrictions within the "ALS Application Guidance" (see Reference 41 ). An applicant or licensee referencing this SE should identify 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 EQ [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."

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

July 16, 2014dblly 7, ~Q~ 4 DCPP PPS Open Item Summary Table Page 4 of 17 No Src/RI Issue Description P&GE response: Status RAJ No. RAJ Comments (Date Sent) Response (Due Date)

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 I 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.

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 10 milliseconds.

ALS platform-specific self-diagnostic fault conditions are supplemented by an application-specific ALS-1 02 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

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July 16, 2014J~;;~Iy 7, ~Q~ 4 DCPP PPS Open Item Summary Table Page 5 of 17 No Src!RI Issue Description P&GE response: Status RAJ No. RAJ Comments (Date Sent) Response (Due Date) 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-102 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 W 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 received.

provided to determine if the PPS equipment has been demonstrated to be able to operate within the specified environment. In order to do this the 12/11/13-RJS staff needs to have plant specific environmental data for the plant and

July 16, 2014J!:jly 7, 2Q~ 4 DCPP PPS Open Item Summary Table Page 6 of 17 No Src/RI Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due Date) specifically for the cable spreading room. The ISG 6 matrix (item 2.12) Seismic Reports states that this information has been provided in the two vendor topical posted on reports, however, these reports do not contain any plant specific data. sharepoint. Further plant specific information The NRC requires plant specific environmental condition data for normal including ping tests operating conditions and the worst conditions expected during abnormal of PPS cabinets is and accident conditions where the PPS equipment is expected to perform still needed for its safety function. evaluation.

11/1/13-RJS

• Range of temperature and humidity conditions that are Waiting for expected in the cable spreading room.

additional testing to

• Seismic data for the Diablo Canyon OBE and SSE be completed.

earthquakes including frequencies and acceleration values.

• EMI I RFI data for areas where PPS equipment is to be PG&E to provide installed. estimate of completion for next call.

The FRS section does specify the ranges of temp and humidity but for seismic environment, it refers to documents DCM C-17, DCM C-25, DCM 6/26/2013: during C-30, DCM C-28, and DCM T-10. this call the following Note: The required information may also be contained in the UFSAR. The staff is clarifications were reviewing design basis information in the UFSAR, however specific environmental provided:

conditions applicable to the PPS equipment remain unclear to the staff. - Describe specific conditions for the 3/28/14 Update: room where the system will be Integrated Equipment Response Spectra(IERS): In the seismic test report, installed.

it is stated the IERS spectra will change as a result of the equipment - Is there any modifications. So far, the evaluation is based on comparing the ALS and restrictive Tricon test data (TRS) with the RRS derived from the 140' elevation requirement for this spectra provided in DCM No. C-25. I think that these RRS spectra will be room?

conservative in comparison to the IERS but I will need to confirm this once -What is the relationship I see the revised IERS.

between the

July 16, 2014J~Iy 7, 2G~ 4 DCPP PPS Open Item Summary Table Page 7 of 17 No Src/RI Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due Date)

See follow-up questions and answers in the PG&E response below. system specification requirement and environmental conditions?

PG&E Response: PG&E provided seismic information in the document titled "Westinghouse Seismic Test Report EQLR-224B, Rev. 1" on the Sharepoint on 12/3/13. Additional testing is required for the PPS cabinets to be used that is expected to be completed in May 2014.

3/28/14 Update:

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 33Hz. 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 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. ---------

July 16, 2014d~;;~ly 7, ~Q~ 4 DCPP PPS Open Item Summary Table Page 8 of 17 No Src/RI Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due Date)

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 IERS 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?

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 -

July 16, 2014d~:Jiy 7, ~Q~ 4 DCPP PPS Open Item Summary Table Page 9 of 17 No Src!RI Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due Date) are not the same. Since the ALS and Tricon have different seismic test reports, we will compare the TRS with the IERS separately.

108 RJS Phase 2 Document Status Assessment: Open NoRAI 4/16/14- NRC will provide update to The staff performed an assessment of the phase 2 document matrix and Phase 2 matrix would like to discuss several items in the table. Please address comments status following the next DCL submittal added to the phase 2 matrix by the NRC staff.

of Tricon documents.

We recognize that some of these items will not be available until after the FAT is performed, however, there are several other phase 2 documents 12/11/13- RJS that should be available now. We have identified the following documents Tricon Reliability that should not require completion of the design or FAT that have not yet Analysis document is on sharepoint.

been submitted. We will need a revised schedule for submittal of these Schedule for documents in order for us to proceed with the safety evaluation. submittal of all documents still WSR's for phases of development beyond Planning/Req. (Both Vendors) needs to be Tricon 993754-1-819, Reliability Analysis provided. I Tricon 993754-1-811, Project specific platform FMEA (IEEE 352)

PG&E System level FMEA Tricon 993754-1-812, Validation Test Specification (Integrated System)

Tricon 993754-1-868, Software Verification Test Plan Westinghouse 6116-10020 "ALS PPS Software Safety Plan"

July 16, 2014d~:Jiy 7, ~G~4 DCPP PPS Open Item Summary Table Page 10 of 17 No Src/RI Issue Description P&GE response: Status RAJ No. RAJ Comments (Date Sent) Response (Due Date)

PG&E Response:

PG&E is working with each Vendor to determine the submittal dates for the remaining Phase 2 documents not related to FAT testing that still need to be submitted. The schedule for the outstanding lnvensys documents was 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.

109 RJS Audit Preparation: Open NoRAI 5/16/14 Could not find the MCL on In preparation for the follow-up audits at lnvensys and at Westinghouse, share point. When will thisbe available the staff would like to have access to the configuration status accounting to us?

documents. Can the following documents be put onto the share point site?

4/16/14- PG&E

1. 6116-00050, Diablo Canyon PPS Configuration Status Accounting, agreed to add

2. Triconex Master Configuration List current Tricon MCL to sharepoint to support pre-audit activities. MCL will PG&E Response: The 6116-00050, Diablo Canyon PPS Configuration also be available Status Accounting was put on the Sharepoint on 12/3/13. The Tricon MCL during lnvensys will be placed on the Sharepoint to support the audit by 05/08/14. audit.

11/1/13-RJS 6116-00050 to be put on sharepoint.

Tricon doc will be made available prior to second

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audit.

July 16, 2014J~:Jiy 7, 2G~ 4 DCPP PPS Open Item Summary Table Page 11 of 17 No Src/RI Issue Description P&GE response: Status RA/No. RAI 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.

July 16, 2014Jt~ly 7, ~Q~ 4 DCPP PPS Open Item Summary Table Page 12 of 17 No Src/RI Issue Description P&GE response: Status RAJ 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.

Information on the additional testing and evaluation to the PG&E requirements will be submitted. Determination of the submittal date is in progress.

116 lnvensys Audit Close The Project Traceability Matrix {PTM) Rev 5 does not identify the test cases for functional verification of the requirements identified.

PG&E Response: PTM Rev. 7 was available during the audit and is now on sharepoint. It includes traceability to the Software Verification Test Specification (SVTS). Revision ?a will include traceability to Validation Test Spec. Rev. ?a was not available to the NRC during the audit because it has not been approved for issuance.

117 Tricon conformance with ISG-06 position 1, point 10 Open The Safety Evaluation for the Tricon platform, Section 3. 7.3.1.1 0 STAFF POSITION 1, POINT 10, states 'The application can be programmed to perform any required action on a change of the keyswitch position.

However, this would be an application specific feature that is beyond the

July 16, 2014d~:~ly 7, ~Q~ 4 DCPP PPS Open Item Summary Table Page 13 of 17 No Src/RI Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due Date) scope of this review."

PG&E response to RAI #17 states the Operating System running on the MP application processor would monitor the position of the keyswitch, and used this parameter to allow modifications to the control program when a command from an external device is received. Furthermore, the response to RAI #17 implies that an application can call any of four function blocks to perform certain activities.

The lnvensys SRS identifies a requirement to indicate the position of the keyswitch. However, when this requirement is traced down to the SOD level, the requirement is only used to indicate an alarm when the keyswitch is not in the RUN position.

Besides the alarm to indicate the keyswitch is not in the RUN position, please describe what actions are programmed in the application software on a change of the keyswitch position?

PG&E Response:

118 rjs (Audit Item) The NRC requests resolution of the following SIDR's be placed New on sharepoint for follow-up review. The NRC is particularly interested in reviewing the extent of condition analysis performed for each of these and process deficiencies identified.

SIDR-1057 CAR-2531 PG&E Response:

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

July 16, 2014Jllly 7, 2Q~ 4 DCPP PPS Open Item Summary Table Page 14 of 17 No Src/RI Issue Description P&GE response: Status RAJ No. RAJ Comments (Date Sent) Response (Due Date) set application code for the DCPP PPS Replacement project. PG&E bought these 5 development laptops and 10M will be delivering them to 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 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.

PG&E Response:

120 Ra/rs (Audit Item) Document Review Requests. The NRC requests the following New documents be placed on sharepoint when available.

• Completed FAT Test Case for tests relating to Turbine lmpule Pressure, Time Response Verification, and SG Trip Time Delay TTD function.

993754-11-902-1, FAT Procedure, Appendix 1-18, TICP

• Current version of the Hardware Design Description (HOD)

• Updated Safety Analysis Report

• PTM Revision 8.0 Including traceability to Validation Test Cases

• Design of Controller Transfer Function Design Input Specification SAP Specification No. 110000000552 Revision 4

July 16, 2014dl:lly 7, 2G~4 DCPP PPS Open Item Summary Table Page 15 of 17 No Src/RI Issue Description P&GE response: Status RA/No. RAI Comments (Date Sent) Response (Due Date)

PG&E Response:

121 rs Implementation Phase V&V Summary Report- The NRC staff reviewed New the V&V tasks summarized in this report and confirmed correlation to several of the activities prescribed in the SWP Section 5.2.4. There were two prescribed activities in the SWP 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 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.

July 16, 2014dl::lly 7-, ~G~ 4 DCPP PPS Open Item Summary Table Page 16 of 17 No Src/RI Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due Date)

PG&E Response:

I I

i 122 rs Implementation Phase V&V Summary Report- Several of the input New I documents pertain only to protection set I, however, the summary report scope is intended to include all four protection sets. Section 2.0 of the I summary report provides a reference to a project conditional release (CR 993754-06), but this does not describe a reduction in scope to only I 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:

July 16, 2014J~Iy 7, ~Q~ 4 DCPP PPS Open Item Summary Table Page 17 of 17 No Src/RI Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due Date) 123 rs Implementation Phase V&V Summary Report- One of the Deficiency New Reports remained unresolved at the completion of the Implementation 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:

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M eeting N ot1ce . ML14170A011 Mee f mg 5 ummary ML14197A352 OFFICE NRRIDORULPL4-1/PM NRRIDORULPL4-1/LA NRRIDE/EICB NRRIDORULPL4-1/BC NRRIDORULPL4-1/PM NAME PBamford JBurkhardt RStattel MMarkley (DPelton for) PBamford DATE 7/22/14 7/22/14 7/22/14 7/22/14 7/22/14