ML15134A257

5/7/15 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

ML15134A257
Person / Time
Site:	Diablo Canyon
Issue date:	05/18/2015
From:	Andrea George Plant Licensing Branch IV
To:	Halpin E Pacific Gas & Electric Co
George A
References
TAC ME7533, TAC ME7523
Download: ML15134A257 (27)

Text

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

SUMMARY

OF MAY 7, 2015, 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 May 7, 2015, 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). The meeting notice and agenda dated April 23, 2015, are available at ADAMS Accession No. ML151138278. A list of attendees is provided in Enclosure 1.

The teleconference meeting is one in a series of publicly noticed teleconference meetings to be held periodically to discuss issues associated with the NRC staff's LAR review. Preliminary issues that the NRC staff identified during the initial review, and the licensee's responses to these preliminary issues, were discussed during the teleconference meeting. The list of preliminary issues is provided in Enclosure 2.

Highlights from this meeting include the following:

• An upcoming NRC audit regarding this LAR was confirmed for the week of June 8, 2015; however, the licensee and vendor staff expressed concern at being ready for that audit given delays in the project.

• The open item summary listing was discussed and the current version is provided with this meeting summary as Enclosure 2. The NRC staff noted that it is still awaiting responses to some items that have been open for an extended period of time. The NRC staff noted that no new issues had been added to the open items list, and that no new items are able to be closed as of the date of the meeting.

• The project plan for the review of the LAR was discussed and the major upcoming milestones were confirmed. The current version is provided with this meeting summary as Enclosure 3.

• The NRC staff and the licensee agreed to wait until the audit is firmly scheduled and/or completed before scheduling 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 the Diablo Canyon Project Manager, Siva Lingam, at 301-415-1564 or at Siva.Lingam@nrc.gov.

Andrea E. George, Project 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. Staff Identified Issues That are Open

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

LIST OF ATTENDEES MAY 7. 2015. 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 K. Jentzsch Pacific Gas and Electric K. Hughes Westinghouse A. Breneman Westinghouse W. Odess-Gillet Westinghouse T. Tuite Westinghouse Rich Stattel Nuclear Regulatory Commission (NRC)

Samir Darbali NRC Rossnyev Alvarado NRC John Thorp NRC Andrea George NRC George Adams Southwest Research Institute (SwRI)

Dan Pomerening SwRI Eric Domes SwRI Gordon Clefton Nuclear Energy Institute Enclosure 1

ENCLOSURE 2 STAFF IDENTIFIED OPEN ISSUES LISTING PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT. UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323

May 14, 2015 DCPP PPS Open Item Summary Table Page 1 of 18 No Src/RI Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response (Due Date) 101 RJS Phase 2 Environmental Qualification Documentation: Open RAI 61 4/30/14 12/12/14 Hold OPEN until final Per ISG 6 Section D.5.1, the NRC staff needs to review the information qualification documents are provided to determine if the PPS equipment has been demonstrated to be received.

able to operate within the specified environment. In order to do this the staff needs to have plant specific environmental data for the plant and 12/11/13- RJS 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.

• Range of temperature and humidity conditions that are 11/1/13- RJS 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 6/26/2013: during installed. this call the following clarifications were The FRS section does specify the ranges of temp and humidity but for provided:

seismic environment, it refers to documents DCM C-17, DCM C-25, DCM - Describe specific C-30, DCM C-28, and DCM T-10. conditions for the room where the Note: The required information may also be contained in the UFSAR. The staff is system will be reviewing design basis information in the UFSAR, however specific environmental installed.

conditions applicable to the PPS equipment remain unclear to the staff. - Is there any restrictive 3/28/14 Update: requirement for this In-Equipment Response Spectra (IERS): In the seismic test report, it is room?

- What is the stated the IERS spectra will change as a result of the equipment

May 14, 2015 DCPP PPS Open Item Summary Table Page 2of18 No Src!RI Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response (Due Date) modifications. So far, the evaluation is based on comparing the ALS and relationship Tricon test data (TRS) with the RRS derived from the 140' elevation between the spectra provided in DCM No. C-25. I think that these RRS spectra will be system specification conservative in comparison to the IERS but I will need to confirm this once requirement and I see the revised IERS. environmental conditions?

See follow-up questions and answers in the PG&E response below.

PG&E Response: PG&E provided seismic information in the document titled "Westinghouse Seismic Test Report EQLR-2248, Rev. 1" on the Sharepoint on 12/3/13. Additional testing is required for the PPS cabinets to be used.

3/28/14 Update:

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

Based on the following criteria:

2) IEEE 344-1975, Section 6.6.3.1, states that the TRS envelops the RRS over a frequency range which includes all natural frequencies of the equipment up to 33 Hz. The guidance has been more specifically addressed in IEEE 344-1987 (Endorsed by NRC RG 1.100 Rev. 2),

Section 7 .6.3.1.10 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 TRI CON v10 Nuclear Qualification Project ,

Seismic Test Report 9600164-526, Date 04/13/07) Section 6.8,

May 14, 2015 DCPP PPS Open Item Summary Table Page 3 of 18 No Src!RI Issue Description P&GE response: Status RAJ No. RAJ Comments (Date Sent) Response (Due Date)

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

Therefore, Tricon seismic test response are acceptable.

Based on 2) and 3) above, it can be justified that the Tricon test report is acceptable for the qualification of PCS racks.

The PCS racks are identical to the PPS racks and are in the same location/elevation. Since there are no natural frequencies below 5Hz, you only need to envelop down to 3.5Hz. The resonance survey showed that the natural frequencies were all greater than 40Hz. So the TRS below 3.5Hz does not matter.

Response to follow-up questions:

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

No, EQLR-2248 is Westinghouse proprietary. We cannot revise their report. We will generate IERS at ALS mounting location to compare with TRS from the EQLR-2248. The new 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

May 14, 2015 DCPP PPS Open Item Summary Table Page 4of18 No Src/RI Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response (Due Date) same set of spectra be applied to both subsystems?

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

10/14/14 - The ALS Platform EQ report revision, 6002-00200, Revision 4 is on the sharepoint. This document is referenced by the PPS specific EQ report (EQ-QR-120-PGE, Revision 0, Diablo Canyon PPS Advanced Logic System and Line Sense Module Equipment Qualification Summary Report) that is also on the sharepoint.

109 RJS Audit Preparation: Close NoRAI 5/6/15 Confirmed Rev. 2 of 6116-In preparation for the follow-up audits at Invensys and at Westinghouse, 00050 is on the staff would like to have access to the configuration status accounting sharepoint.

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

3/18/15 Confirmed that both requested

1. 6116-00050, Diablo Canyon PPS Configuration Status Accounting, documents are on

2. Triconex Master Configuration List 993754-803 Rev. 41 sharepoint.

TheALS CSA document is old PG&E Response: The 6116-00050, Diablo Canyon PPS Configuration and does not have Status Accounting was put on the Sharepoint on 12/3/13. The Tricon MCL enough information will be placed on the Sharepoint to support the audit by 05/08/14. on configuration in it.

5/16/14 Could not find the MCL on share point. When will this be available to us?

May 14, 2015 DCPP PPS Open Item Summary Table Page 5of18 No Src/RI Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response (Due Date) 4/16/14 - PG&E agreed to add current Tricon MCL to sharepoint to support pre-audit activities. MCL will also be available during Invensys audit.

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

Tricon doc will be made available prior to second audit.

115 RJS Electro Magnetic Compatibility {Tricon): Open RAI 71 3/12/15 Request schedule for Section 4.14 -ASAl-6 of the LAR states that the equipment vendors are submittal of supplemental required to confirm equipment compliance with physical requirements in information.

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, 4/16/14 - RAI will analysis, or a combination thereof, to function without fault or error in an be required.

electromagnetic environment in accordance with the guidance of Regulatory Guide 1.180."

In contrast to this, the Tricon V10 safety evaluation determined that the Tricon V10 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 V10 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 V10 system as approved in this SE."

May 14, 2015 DCPP PPS Open Item Summary Table Page 6of18 No Src/RI Issue Description P&GE response: Status RAJ No. RAJ Comments (Date Sent) Response (Due Date)

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 V10 test levels achieved and documented in the Tricon V10 safety evaluation.

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.

119 sd (Audit Item) IOM is using laptops, one per Protection Set plus one backup, Close RAI 72 3/19/15 Hold in 01 each with TriStation 1131 installed, to develop the V10 Tricon protection list until RAI is sent.

set application code for the DCPP PPS Replacement project. PG&E bought these 5 development laptops and IOM will be delivering them to PG&E as part of the Tricon product delivery. However, during the Invensys 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: The PG&E laptops provided for development for the V10 Tricon were not designated as safety related and will not be used by PG&E in the future because they are obsolete.

129 RA ALS Topical Report Addendum: Open RAI 73 Hold Open for RAI letter.

The ALS topical report addendum identifies changes in Category 4 as those modifications that are applicable to the approved ALS topical report. 12/10/14 -The ALS

May 14, 2015 DCPP PPS Open Item Summary Table Page 7of18 No Src/RI Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response (Due Date)

Please describe how these changes affect the DC PPS replacement, in addendum is being particular description and functionality of the Halt mode. withdrawn.

However, PG&E provided PG&E Response: Additional information provided by licensee in separate clarifications about document dated 12/11/14. the HALT mode for the ALS system.

Therefore, a RAI is necessary.

135 RA ALS Project Organization 3/1/15: A new Open revision of the The Management Plan (6116-00000, Rev. 6) defines the project Management Plan organization for the DC PPS replacement project. However this plan does will address this not define the role and responsibilities for the PPS Product Manager. This team member is identified in Section 4.1.1 of the Management Plan, as well as in Section 2.1 of the Software Safety Plan (6116-10020). Please describe the roles and responsibilities for the PPS Product Manager, and his interface/relationship with the Project Manager PG&E Response: This will be addressed by an update to 6116-00000 (new Revision 7).

136 RA ALS Management Plan 3/1 /15: A new Open revision of the The Management Plan (6116-00000, Rev. 6), Section 4.1.2, states ALS Management Plan personnel required support from Global Instrumentation and Control will address this Production (GICP) to complete the project. Can you please provide information about the support provided by GICP?

PG&E Response: This will be addressed by an update to 6116-00000 (new Revision 7).

May 14, 2015 DCPP PPS Open Item Summary Table Page 8 of 18 No Src/RI Issue Description P&GE response: Status RAJ No. RAJ Comments (Date Sent) Response (Due Date) 137 RA ALS Management Plan 3/1 /15: A new Open revision of the The Management Plan (6116-00000, Rev. 6), Section 6.16, describes NA Management Plan 4.51"Fiel Programmable Gate Array Development Procedure" as the will address this procedure used for software development. Can you please provide a copy of this procedure in the Sharepoint?

PG&E Response: This will be addressed by an update to 6116-00000 (new Revision 7).

138 RA ALS Configuration Management Plan Open 3/1/15: A new revision of the The Management Plan (6002-00002, Rev. 10), Sections 1.2.5 and 2.1, Management Plan states the ALS Project Management Plan will identify the configuration and the management organizational structure. However, the ALS Project Configuration Management Plan does not provide this information. Furthermore, Section Management Plan 2.2 of the Configuration Management Plan describes allocation for will address this.

configuration management activities, but the Project Management Plan This is SE reference 72 does not define how this is applied to the DC PPS project.

PG&E Response: This will be addressed by an update to 6116-00000 (new Revision 7) that will contain an updated Section to address the project specific portions of the ALS Configuration Management Plan (6002-00002).

140 RA ALS Configuration Management Plan Open 3/1 /15: A new revision of the Section 3.1.1 refers to a Document Index (DI). This document is not Configuration identified or described in the ALS Management Plan. Please describe how Management Plan the DI is used in conjunction with the configuration items and the will address this Configuration Status Accounting. This is SE reference 72 PG&E Response: This will be addressed by an update to 6116-00000 (new Revision 7) that will contain an updated Section to address the project specific portions of the ALS Configuration Management Plan (6002-00002).

May 14, 2015 DCPP PPS Open Item Summary Table Page 9 of 18

~

No Src/RI Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response (Due Date) 141 RA ALS Configuration Management Plan Open 3/1 /15: A new revision of the Section 3.2.5 described the use of REC to manage requirement changes to Configuration Cls. Please explain the relationship of the REC and the On Time ticket Management Plan process. will address this, This is SE PG&E Response: This will be addressed by an update to 6116-00000 (new reference 72 Revision 7) that will contain an updated Section to address the project specific portions of the ALS Configuration Management Plan (6002-00002).

142 RA ALS Configuration Management Plan Open 3/1 /15: A new revision of the Section 3.2.5 states that the control points for release of Level A, B and C Configuration are described in Section 3.2.2, but the section referenced does not provide Management Plan that information. Please clarify when these points are released will address this.

This is SE PG&E Response: This will be addressed by an update to 6116-00000 (new reference 72 Revision 7) that will contain an updated Section to address the project specific portions of the ALS Configuration Management Plan (6002-00002).

143 RA ALS Configuration Management Plan Open 3/1 /15: A new revision of the Section 3.6 describes control of subcontractors and vendors. This section Configuration refers to the ALS management plan for further description of integration Management Plan and sightseeing of activities conducted by subcontractors and vendors. will address this.

However, the Management Plan does not provide any information about This is SE control of subcontractors and vendors. reference 72 Furthermore, Section 4.1.2 identifies Global Instrumentation and Control Production as a provider for this project. This section does not describe how WEC will manage and integrate the work performed by GICP.

Please provide this information.

PG&E Response: This will be addressed by an update to 6116-00000 (new Revision 7) that will contain an updated Section to address the project specific portions of the ALS Configuration Management Plan (6002-00002).

May 14, 2015 DCPP PPS Open Item Summary Table Page 10 of 18 No Src/RI I Issue Description P&GE response: Status I RA/ No. RA/ Comments (Date Sent) I Response (Due Date) 144 Rjs/ga J Environmental qualification: EMl/RFI Open Added 01 on 3/18/15 Clarify if CD-ER 993754-30 demonstrates Triconex components comply with RG 1.180 conducted emissions levels for CE101 and CE102 testing.

Basis:

Project Traceability Matrix (Document No. 993754-1-804) Item 445 identifies CD-ER 993754-30 with regard to 120VAC power module exceeding allowable levels specified in RG 1.180. This line item refers to qualified AC power line filters provided.

PG&E Response: In progress.

145 RA Remaining Document Submittals Added 01 on 3/18/15 Next Supplement: (to include)

• Removal of Printers from system

• Response to ALS ASAl's

• T.S. Implementation Commitment PG&E Documents:

DCPP Seismic Calculation I IERS (See 01 101)

ALS Documents:

The following documents were identified in ISG-06 matrix as part of Phases 1 and 2 submittals for the Diablo Canyon LAR. Several of these documents have been submitted but have been superseded. Please

May 14, 2015 DCPP PPS Open Item Summary Table Page 11of18 No Src/RI Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response (Due Date) docket the latest revision of the following documents:

6116-10020, "Diablo Canyon PPS Software Safety Plan" 6116-00003, "Diablo Canyon PPS W Plan" (Ref. 91) 6116-00000, "Diablo Canyon Management Plan" (Ref. 72) 6116-00005, "Diablo Canyon PPS System Test Plan" (Ref. 93) 6116-70140, "PPS ALS Test Design Specification" (NR) 6116-10216, "Diablo Canyon PPS W Simulation Environment Specification" (Ref. 205) DCL-15-009 6116-70140, "PPS ALS Test Design Specification" (NR) 6116-00100, "Tx81 and Tx82 Communications Protocol Specification" (NR) 6116-00054, "Diablo Canyon PPS ISG04 Matrix" (NR)

ALS Platform Documents 6002-00002, "ALS Configuration Management Plan" (Ref. 70) 6002-00006, "ALS Security Plan" Rev. 3 (Rev. 1 is docketed ML13036A380) (Samir to make call.)

6002-00030, "ALS Design Tools" Rev. 12 (Ref. 150 Rev. 9)

Tricon Documents:

993754-11-854-1 Revision 1 Protection Set I Factory Acceptance Report (filled out test paperwork does not need to be included) 993754-11-854-0 Revision 1 Protection Set I HVT Report 993754-11-861 Revision 2 VnV Design Phase Summary Report PPS I 993754-11-862 Revision 1 VnV Implementation Phase Summary Report PPS I

May 14, 2015 DCPP PPS Open Item Summary Table Page 12of18 No Src/RI I Issue Description P&GE response: Status j RA/ No. I RA/ Comments (Date Sent) Response (Due Date) 993754-12-818 Revision O Protection Set II System Time Response Confirmation Report 993754-12-854-0 Revision 0 Protection Set II HVT Report 993754-12-854-1 Revision 0 Protection Set II Factory Acceptance Report 993754-12-862 Revision 0 VnV Implementation Phase Summary Report PPS II-IV 993754-13-818 Revision 0 Protection Set Ill System Time Response Confirmation Report 993754-13-854-0 Revision 0 Protection Set Ill HVT Report 993754-13-854-1 Revision 0 Protection Set Ill Factory Acceptance Report 993754-14-818 Revision 0 Protection Set IV System Time Response Confirmation Report 993754-14-854-0 Revision 0 Protection Set IV HVT Report 993754-14-854-1 Revision 0 Protection Set IV Factory Acceptance Report 993754-1-915 Revision 9 Safety Analysis PG&E Response: The ALS documents have been uploaded to the Share Point Site and will all be docketed, except for the NA 4.50 and NA 4.51 procedures which are quality assurance procedures that are part of the Westinghouse Quality Management System (QMS) and can be made available for audit purposes. (Staff agrees that these two documents can be removed from docketing list) 146 I Rjs/ga I Environmental Qualification: I Open I I I Added on 4/8/15 In the response to 0194 (ASAl-04), PG&E referred to document 6116-00204, Revision 1, "ALS Subsystem Equipment Qualification Evaluation." The NRC staff needs to review this document. Please place on sharepoint or provide on docket.

PG&E Response: 6116-00204-R1 was placed on the Sharepoint site in the ALS directory on 4/14/15.

May 14, 2015 DCPP PPS Open Item Summary Table Page 13 of 18 No Src/RI Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response (Due Date) 147 Rjs/ga Environmental Qualification: Temperature and Humidity Open Added on 4/8/15 Clarify if FRS Section 3.1.4.1 specifies the temperature and relative humidity worst case conditions expected in the cable spreading room (i.e., mild environment) for normal, abnormal, and accident conditions.

Has an evaluation been performed for the plant-specific configuration of Tricon and ALS components to determine:

a. Maximum temperature rise in each cabinet,

b. Maximum ambient temperature in the cable spreading room, and

c. Design basis temperature margin has not been affected?

Provide DCM T-20, Environmental Qualification including Appendix A titled "Environmental Conditions for EQ of Electric Equipment." This reference is cited in Section 3.11.2.1 of the UFSAR under Accident Environments. This reference is cited in Section 3.11.2.1 of the UFSAR under Accident Environments PG&E Response. DCM T-20 has been put on the sharepoint site in the DCM directory. It lists CSR Normal Operation humidity level range as 20%

to 90% on page 31 in Table A4.2-1. It also seems to list the same area humidity range as 0% to 95% on page 32 and this includes a note identifying a basis for this range and states it is an abnormal, non-condensing relative humidity specification.

May 14, 2015 DCPP PPS Open Item Summary Table ~

Page 14 of 18 No Src/RI Issue Description P&GE response: Status RAJ No. RAJ Comments (Date Sent) Response (Due Date) 148 Rjs/ga Environmental Qualification: EMl/RFI Open Added on 4/8/15

1. Clarify if EMl/RFI levels in the cable spreading room are within the tested operating envelopes for Tricon and ALS components. Was the plant-specific electromagnetic environment confirmed to be similar to that identified in EPRI TR-102323? Note: This is a follow-up to 01 101 which also asks for plant specific environmental conditions.

2. Clarify how EMC requirements are met with regard to power sources including those cases where the plant-specific system differs from the Tricon and ALS tested subsystems.

a. Clarify how the PPS AC and DC power sources are deployed to accomplish the isolation features that can affect EMl/RFI test results.

b. Clarify how the PPS AC and DC power sources have been qualified for EMC.

c. Clarify how the installation limitation for the safety power supply is met as described in Section 7 .2 of the ALS Platform EQ Summary Report.

3. Identify the qualification test documentation for the rack power supplies specified in Section 4.6.3 of the LAR (Ancillary Safety-Related Equipment Utilized in the PPS Replacement Project) to show testing was done in accordance with EPRI TR-107330 and RG 1.180.

4. For the ALS subsystem components, identify the LAR section and supporting documentation that explains how the plant design basis criteria for PPS power quality are maintained to meet the requirements for exemption to CE101 testing.

May 14, 2015 DCPP PPS Open Item Summary Table Page 15of18 No Src/R/ Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response (Due Date)

PG&E Response. In Progress.

149 Rjs/ga Environmental Qualification: Seismic Open Added on 4/8/15

1. Provide the response spectra for Attachments C and H to DCM C-17

a. The contents for Attachment H to DCM C-17 reference several response spectra that are not included in the document. In particular, horizontal and torsional spectra are identified in the contents of the document but were not actually shown as figures in the document.

b. DCM C-17 also includes ground response spectra for the Auxiliary Building in Attachment C.

2. Provide supporting documentation to show how the DCM C-17 and DCM C-25 node-specific floor response spectra were used to develop the IERS for both Tricon and ALS subsystems. For the ALS subsystem, provide SAP No 9000040848-000-00 (Legacy Cale No. IS-0228) which is referenced in the Review of EQLR-2248.

a. DCM C-25 provides node-specific response spectra for Node #2 at the 140' elevation

b. DCM C-17 provides node-specific response spectra in attachment H at the 128' and 140' elevations

c. The review of EQLR-2248, Revision 1 shows IERS for the OBEA/SSEA and OBEB/SSEB versus the RRS for the ALS subsystem.

d. No documentation was found showing the development of the IERS from the node -specific floor response spectra.

3. Provide DCM T-24 for the seismic qualification of plant instrumentation and controls. DCM T-24 is referenced by DCM T-

May 14, 2015 DCPP PPS Open Item Summary Table Page 16of18 No Src/RI Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response (Due Date) 10 is identified in FRS Section 3.1.5.2. Clarify what category the ALS and Tricon subsystems fall under in DCM T-24 and how they meet the specific seismic qualification requirements in DCM T-24.

4. Provide documentation to clarify what Phase A and Phase B RRS are representing for the ALS subsystem. From the information we have reviewed, it is not clear how Figures 5-1 and 5-2 in the ALS EQ Plan were developed. For example, were they developed from the information in DCM C-17 and DCM C-25 or were they developed from some other basis?

5. Clarify the following information from the Seismic Test Report (Document No. 9600164-526) because this report only provides a discussion of results.

a. Provide comparison plots of the TRS and RRS to show the RRS levels were enveloped.

b. Clarify the resonance search results. The executive summary states that there were no resonances below 100 Hz. Section 7.3 states that there was amplification between 20 and 70 Hz up to about 20 times.

C. Provide data to show statistical independence and stationarity of seismic time histories.

d. Reference 9.14 of the Tricon Seismic Test Report may contain this information (National Technical Systems Test Report No. TR62987-07N-SEI, "Test Report for Seismic Qualification of TR ICON v 10 Nuclear Qualification Project TRICON-Under-Test,"Rev. 0)

May 14, 2015 DCPP PPS Open Item Summary Table Page 17of18 No Src/RI Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response (Due Date)

PG&E Response: Part 1. PG&E previously provided the applicable Auxiliary Building horizontal and torsional spectra at the 115 foot and 140 foot locations that bound the location of the PPS Replacement equipment on the Sharepoint site in the "Spectra" subdirectory in the NRC directory on 02/12/14 as part of the response to Open Item 101.

Requested following spectra be added to shared drive for SWRI access.

Aux Bldg. E-W Horizontal 115ft.

Aux Bldg N-S Horizontal 115ft.

Aux Bldg. T ortional 115ft.

Aux Bldg. E-W Horizontal 140ft.

Aux Bldg N-S Horizontal 140ft.

Aux Bldg. Tortional 140ft.

Part 2. In progress.

Part 3. DCM T-24 has been put on the sharepoint site in the DCM directory.

Part 4. SSE-A was developed in LTR-EQ-12-23 (and was derived from previous Eagle 21 seismic levels. Several limitations to the seismic spectra are noted in the letter, with the understanding that Oiablo Canyon had the responsibility to confirm the final levels that are applicable to the ALS installation in their PGE cabinets.

SSE-B was developed in EQ-EV-48 and was designed to envelop all locations within a Corry cabinet under representative loading. These levels were originally developed for Common Q generic applications, specifically for the HSL modems, and were therefore decided to be applied to generic

May 14, 2015 DCPP PPS Open Item Summary Table Page 18 of 18 No Src/RI Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response (Due Date)

ALS applications.

Part 5. In progress.

150 Rjs/ga Environmental Qualification: Radiation Open Added on 4/8/15 Clarify if the mild environment within the Auxiliary Building Cable Spreading Room specified in FRS Section 3.1.4 meets the requirements of EPRI TR 107330 Section 4.3.6.1 D and 4.3.6.2D for Radiation. Section 3.1.4 states, "N/A (mild environment)"

Provide justification for excluding radiation testing for ALS and Tricon components.

PG&E Response. Licensee provided sharepoint access to Generic l&C design specification documents DCM T-20 and DCM T-24. T-20 lists Cable Spreading Room radiation levels at 176 rad. T-24 states that CSR radiation levels are under 0.5 X 10-3 .

ENCLOSURE 3 PROJECT PLAN PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323

Project Plan for Diablo Canyon Replacement of Digital RPS and ESFAS (PPS) - LAR Review Step Planned Date Task Actual Date 1 Oct. 26, PG&E LAR Submittal for NRC approval. Submittal includes Oct. 26, 2011 all Phase 1 documents needed to be docketed prior to 2011 acceptance for review per ISG-06, "Digital Licensing."

2 Jan. 12, 2012 Acceptance Review complete. LAR accepted for detailed Jan. 12, technical review. Several issues identified that could 2012 present challenges for the staff to complete its review.

Scheduled public meeting with PG&E to discuss the results of the acceptance review.

3 Jan. 13, 2012 Acceptance letter sent to licensee. Jan. 13, 2012 4 Jan. 18, 2012 Conduct Public Meeting to discuss staff's findings during Jan. 18, the LAR acceptance review. Staff proceeds with LAR 2012 technical review.

5 March 18, PG&E provides information requested in acceptance letter. April 2, 2012 Initiate bi-weekly telecoms with PG&E and its contractors to 2012 discuss potential RAI issues. Open Items spreadsheet will be maintained by NRC to document staff issues and planned licensee responses.

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

• PG&E provided a subset of the Phase 2 documents on June 61h See step 14 which is a milestone for submittal of all remaininq Phase 2 documents.

7 July First RAI sent to PG&E on Phase 1 documentation (e.g., August 7, 2012 specifications, plans, and equipment qualification). 2012 Continue review of the application. Request 45 day response. (ML12208A364) 8 June SER for Tricon V10 Platform issued final. This platform May 15, 2012 becomes a Tier 1 review of the LAR. (ML12146A010) 2012 8.1 June SER for Westinghouse ALS Platform issued final. This 2013 platform becomes a Tier 1 review of the LAR.

9 September Receive answers to first RAI. (ML12256A308) Sept. 11, 2012 2012 10 November Audit trip to Invensys facility for thread audit; audit the life Nov. 13-2012 cycle planning documents and outputs, with particular 16, 2012 emphases on verification and validation, configuration management, quality Assurance, software safety, the Invensys application software development procedures, and application software program design.

10.1 December Audit report provided to PG&E. February 2012 21, 2013 11 February Audit trip to Westinghouse/CS I facility for thread audit; audit February 2013 the life cycle planning documents and outputs, with 21, 2013 Page 1 of 3

Project Plan for Diablo Canyon Replacement of Digital RPS and ESFAS (PPS) - LAR Review particular emphases on verification and validation, configuration management, quality Assurance, software safety, the W/ALS application software development procedures, and PPS ALS application software program design.

11.1 April Audit report provided to PG&E and its contractor. April 11, 2013 2013 12 March Second RAI Letter to PG&E on Phase 1 documentation March 2013 20, 2013 12.1 April Receive responses to Second set of RAl's May 9, 2013 2013 13 April LAR revision and all supporting documentation associated April 30, 2013 with the change in ALS and Tricon V10 workstation designs 2013 for the PPS are submitted.

14 August NSIR Cyber Security audit at Diablo Canyon site. August 8, 2013 2013 14.1 February Cyber Security Audit Report provided to licensee April 28, 2014 EICB Letter sent to PM 9/2/13 - ML13242A078 2014 NSIR Report- ML13339A428, ML13339A438 and ML13339A442 15 See Revised PG&E provides remaining set of Phase 2 documentation Document per commitments made in LAR. To include ALS PSAI Submittal related documents. See step 6 for initial submittal of Phase Schedules 2 documents.

16 See Revised All Documentation for DCPP W/CSI ALS and IOM/Triconex Document V10 processors applicable to the DCPP PPS LAR are Submittal submitted.

Schedules 17 June 2014 Follow-up audit trip to Invensys facility for thread audit; June 13, audit the life cycle planning documents and outputs, with 2014 particular emphases on verification and validation, configuration management, quality assurance, software safety, the Invensys application software development procedures, and application software program design.

17.1 July 2014 Second Invensys audit report provided to PG&E. April 30, Report sent to DORL 8/14. ML14216A398 2015 Final report 4/30/15. ML15103A011/ML15103A010 18 February Third RAI Letter to PG&E on Phase 2 documentation February 2014 (e.g., FMEA, safety analysis, RTM, EQ test results, setpoint 27, calculations.) ML14055A058 2014 Page 2 of 3

Project Plan for Diablo Canyon Replacement of Digital RPS and ESFAS (PPS) - LAR Review 18.1 April Receive responses to third set of RAl's. April 30, 2014 DCL-14-036 - ML14121A002 2014 19 June 2015 Audit trip to W/ALS facilities for additional thread audit items; audit hardware and software installation plans, configuration management reports, detailed system and hardware design, completed test procedures, V&V activities, summary test results (including FAT) and incident reports, and application code listings.

Audit Plan - ML15090A716 19.1 July 2015 Audit report provided to PG&E.

22 February 18 I Presentation to ACRS Subcommittee/Full ACRS Committee February March on DCPP PPS LAR Safety Evaluation. 18; 2014 March 6, 2014 February 10, Presentation to ACRS Subcommittee/Full ACRS Committee 22.1 2016 on DCPP PPS LAR Safety Evaluation.

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

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

26 December Receive comments from PG&E and its contractors on draft 2015 SER proprietary review.

27 March Approved License Amendment issued to PG&E 2016 28 TBD Inspection trip to DCPP for PPS Site Acceptance Testing (SAT), training and other preparation for installing the new system. To be coordinated with regional visit.

29 TBD Inspection trip to DCPP for PPS installation tests, training and other system installation activities for the new system.

To be coordinated with region visit.

Page 3 of 3

• The project plan for the review of the LAR was discussed and the major upcoming milestones were confirmed. The current version is provided with this meeting summary as Enclosure 3.

• The NRC staff and the licensee agreed to wait until the audit is firmly scheduled and/or completed before scheduling 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 the Diablo Canyon Project Manager, Siva Lingam, at 301-415-1564 or at Siva.Lingam@nrc.gov.

IRA!

Andrea E. George, Project 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. Staff Identified Issues That are Open

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

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DATE 5/14/15 5/14/15 5/14/15 OFFICE NRR/DE/EICB NRR/DORL/LPL4-1 /BC NRR/DORL/LPL4-1 /PM NAME JThorp (DRahn for) MMarkley A George DATE 5/18/15 5/18/15 5/18/15 OFFICIAL RECORD COPY