ML11136A114
ML11136A114 | |
Person / Time | |
---|---|
Site: | Watts Bar ![]() |
Issue date: | 04/29/2011 |
From: | Office of Nuclear Reactor Regulation |
To: | Division of Operating Reactor Licensing |
References | |
Download: ML11136A114 (67) | |
Text
1 WBN2Public Resource From: Poole, Justin Sent: Friday, April 29, 2011 2:27 PM To: Crouch, William D Cc: Clark, Mark Steven; Hilmes, St even A; WBN2HearingFile Resource
Subject:
FW: Open Items List Attachments:
20110429 Open Item List Master NRC Update 04-29-11.docx JustinC.PooleProjectManagerNRR/DORL/LPWBU.S.NuclearRegulatoryCommission(301)4152048email:Justin.Poole@nrc.gov From: Darbali, Samir Sent: Friday, April 29, 2011 1:49 PM To: Poole, Justin Cc: Rahn, David
Subject:
Open Items List Justin, Attached is the OI list to be sent to TVA.
- Thanks, Samir Hearing Identifier: Watts_Bar_2_Operating_LA_Public Email Number: 361 Mail Envelope Properties (19D990B45D535548840D1118C451C74D7F86E52154)
Subject:
FW: Open Items List Sent Date: 4/29/2011 2:27:23 PM Received Date: 4/29/2011 2:27:25 PM From: Poole, Justin Created By: Justin.Poole@nrc.gov Recipients: "Clark, Mark Steven" <msclark0@tva.gov> Tracking Status: None "Hilmes, Steven A" <sahilmes@tva.gov>
Tracking Status: None "WBN2HearingFile Resource" <WBN2HearingFile.Resource@nrc.gov> Tracking Status: None "Crouch, William D" <wdcrouch@tva.gov> Tracking Status: None
Post Office: HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 376 4/29/2011 2:27:25 PM 20110429 Open Item List Master NRC Update 04-29-11.docx 551106 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments 001 All All B (A The Watts Bar Nuclear Plant FSAR red-line for Unit 2 (A g enc y 12/15/2009 Presentation Slides
- 1. Y Closed Closed EICB RAI 3/12/2010 NNC 11/19/09:
The FSAR contains 002 All All B (A Are there I&C com p onents and s y stems that have chan g ed to a 12/15/2009 Presentation Slides
- 2. Y Closed Closed EICB RAI 3/12/2010 NNC 11/19/09:
The FSAR contains 003 All All B (A Because a di gital I&C p latform can be confi g ured and p ro grammed 12/15/2009 Presentation Slides
- 3. Y Closed Closed EICB RAI 3/12/2010 NNC 11/19/09:
The FSAR contains 004 All All B (APlease identif y the information that will be submitted for each Res p onder: Webb 1/13/10 Public Meetin g 4. Y Closed Closed EICB RAI Januar y 13 , 2010 NNC 11/19/09:
LIC-110 Rev. 1 Section 005 7.1.3. (G B y letter date Februar y 28 , 2008 (A g enc ywide Documents Access Res p onder: Crai g/Webb 5. Y Closed Closed EICB RAI TVA Letter dated 006 (G A mendment 95 of the FSAR
, Cha p ter 7.3 , shows that chan g e 7.3-1 B y letter dated Februar y 5 , 2010: TVA p rovided the Unit 2
- 6. Y Closed Closed EICB RAI TVA Letter dated NNC: WCAP-12096 Rev. 7 007 7.1.3. (G The set p oint methodolo gy has been reviewed and a pp roved b y the TVA Letter Dated March 12
, 2010 (Enclosure 1
, Item No. 7
- 7. Y Closed Closed EICB RAI TVA Letter dated TVA to p rovide Rev. 8 of the Unit 1 008 7.3 (G There are several staff positions that p rovide guidance on set point TVA Letter Dated March 12
, 2010 (Enclosure 1
, Item No. 8
- 8. Y Closed Closed EICB RAI TVA Letter dated 009 7.3.2 5.6 , (D a Chan g e 7.3-2 , identified in Watts Bar Nuclear Plant FSAR red-line TVA Letter Dated March 12
, 2010 (Enclosure 1
, Item No. 9
- 9. Y Closed Closed EICB RAI 3/12/10 , 010 7.3 7.3 (D a The ori g inal SER on Watts Bar (NUREG-0847
) documents that the TVA Letter Dated March 12
, 2010 (Enclosure 1
, Item No. 10
- 10. Y Closed Closed EICB RAI 3/12/10 , 011 7.3.2 5.6 , (D aNUREG-0847 Su pplement No. 2 Section 7.3.2 includes an TVA Letter Dated March 12
, 2010 (Enclosure 1
, Item No. 11
- 11. Y Closed Closed EICB RAI ML101680598
, 012 7.4 7.4 (D a The ori g inal SER on Watts Bar (NUREG-0847
) documents that the TVA Letter Dated March 12
, 2010 (Enclosure 1
, Item No. 12
- 12. Y Closed Closed EICB RAI TVA Letter dated 013 7.1.3. (G Cha p ter 7 and Cha p ter 16 of Amendment 95 to the FSAR do not TVA Letter Dated March 12
, 2010 (Enclosure 1
, Item No. 13
014 All All B (A Provide the justification for an y hardware and software chan g es Date: 4/27/10
- 14. Y Closed Closed NRC Meetin g TVA Letter dated 015 (G Verif y that the refurbishment of the p ower ran ge nuclear Date: 4/27/10
- 15. Y Closed Closed NRC Meetin g TVA Letter dated 016 (CIdentify the precedents in license amendment requests (LARs), if Date: 4/27/10
- 16. Y Closed Closed NRC Meeting TVA Letter dated 017 7.3.1 7.3.1 , (D a Identif y precedents in LARs
, if an y, for the solid state p rotection Date: 4/27/10
- 17. Y Closed Closed NRC Meetin g TVA Letter dated 018 (G Identif y an y chan g es made to an y instrumentation and control Date: 4/27/10
- 18. Y Closed Closed NRC Meetin g TVA Letter dated 019 (G Verif y that the containment p ur ge isolation radiation monitor is the Date: 4/27/10
- 19. Y Closed Closed NRC Meetin g TVA Letter dated 020 (GProvide environmental q ualification information p ursuant to Section Date: 4/27/10
- 20. Y Closed Closed NRC Meetin g TVA Letter dated NNC 4/30/10:
SRP Section 7.0 states:
021 7.3 (GFor the Foxboro S p ec 200 p latform , identif y an y chan g es in Date: 5/25/10
- 21. Y Closed Closed NRC Meetin g TVA Letter dated The resolution of this item will be 022 7.3.2 5.6 , (D a Verif y the auxiliar y feedwater control refurbishment results in a like-Date: 4/27/10
- 22. Y Closed Closed NRC Meetin g TVA Letter dated 023 (GProvide environmental q ualification (10 CFR 50.49
) information for Date: 4/27/10
- 23. Y Closed Closed NRC Meetin g TVA Letter dated NNC 4/30/10:
SRP Section 7.0 states:
024 (CProvide a schedule b y the Januar y 13 , 2010 , meetin g for providin g Durin g the Januar y 13 , 2010 meetin g, TVA p resented a
- 24. Y Closed Closed NRC Meetin g N/A - Re q uest for NNC 4/30/10:
Carte to address 025 7.5.2 7.5.1 (S i For the containment radiation hi g h radiation monitor
, verif y that the Date: 4/27/10
- 25. Y Closed Closed NRC Meetin g ML101230248
, 026 (GProvide environmental q ualification (10 CFR 50.49
) information for Date: 4/27/10
- 26. Y Closed Closed NRC Meetin g TVA Letter dated NNC 4/30/10:
SRP Section 7.0 states:
027 7.7.1. (CFor Foxboro I/A p rovide information re g ardin g safet y/non-safet y-Date: 4/27/10
- 27. Y Closed Closed NRC Meetin g TVA Letter dated 028 (GFor the turbine control AEH s ystem , verif y that the refurbishment Res p onder: Mark Scansen
- 28. Y Closed Closed NRC Meetin g TVA Letter dated 029 (CFor the rod control s y stem , verif y that the refurbishment results in a Date: 4/27/10
- 29. Y Closed Closed NRC Meetin g TVA Letter dated 030 (G Re g ardin g the refurbishment of I&C e q ui p ment , identif y an y Res p onder: Clark
- 30. Y Closed Closed NRC Meetin g TVA Letter dated 031 (C For the rod position indication s y stem (CERPI), p rovide information Date: 4/27/10
- 31. Y Closed Closed NRC Meetin g TVA Letter dated CERPI is non-safet y related. 032 (C For the process com p uter , need to consider c yber securit y issues Date: 4/27/10
- 32. Y Closed Closed NRC Meetin g TVA Letter dated EICB will no lon g er consider c yber 033 (C For the loose p arts monitorin g s y stem , provide information Date: 4/27/10
- 33. Y Closed Closed NRC Meetin g TVA Letter dated The loose p arts monitorin g s ystem is 034 (G 2/4/2010 Res ponder: TVA
- 34. Y Closed Closed N/A TVA Letter dated 034. a r g Cha p ter 7.1 - Introduction
- 35. Y Closed Closed N/A N/A 034. (G Cha pter 7.2 - Reactor Tri p S y stem 36. Y Closed Closed N/A N/A 034.7.3 7.3 (D a Cha p ter 7.3 - ESFAS 37. Y Closed Closed N/A N/A 034.7.5.1.7.5.2 (M a Cha pter 7.5 - Instrumentation S y stems Im p ortant to Safet y 38. Y Closed Closed N/A N/A Closed 034.7.5.1.7.5.2 r c u Cha p ter 7.6 -
A ll Other S ystems Re quired for Safet y 39. Y Closed Closed N/A N/A Closed 034. n g h/ Cha pter 7.7 Control S ystems 40. Y Closed Closed N/A N/A 035 (S i 2/18/2010 Res p onder: Clark
- 41. Y Closed Closed RAI No. 1 TVA Letter dated LIC-110 Section 6.2.2 states: "Desi g n 036 7.5.2 7.5.1 (CFebruar y 18 , 2010 Date: 5/25/10
- 42. Y Closed Closed NRC Meetin g NNC: Unit 2 FSAR Section 7.5.1
, "Post 037 7.5.1.7.5.2 (M a 2/18/2010 Res p onder: Clark Date: 5/25/10
- 43. Y Closed Closed N/A TVA Letter dated FSAR Amendment 100 p rovides Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments 038 7.5.1.7.5.2 (M a 2/18/2010 Res p onder: Clark Date: 5/25/10
- 44. Y Closed Closed EICB RAI TVA Letter dated The slides presented at the December 039 (G Januar y 13 , 2010 Res p onder: Clark Date: 5/25/10
- 45. Y Closed Closed EICB RAI FSAR amendment The e quation for the calculation of the 040 (G Januar y 13 , 2010 Res p onder: Clark Date: 5/25/10
- 46. Y Closed Closed EICB RAI EICB RAI FSAR amendment The e quation for the calculation of the 041 7.5.2 7.5.1 EICB (Carte) 2/19/2010
Please provide the following Westinghouse documents:
(1) WNA-DS-01617-WBT Rev. 1, "PAMS System Requirements Specification" (2) WNA-DS-01667-WBT Rev. 0, "PAMS System Design
Specification" (3) WNA-CD-00018-GEN Rev. 3, "CGD for QNX version 4.5g" Please provide the following Westinghouse documents or pointers to where the material was reviewed and approved in the CQ TR or
SPM:
(4) WNA-PT-00058-GEN Rev. 0, "Testing Process for Common Q Safety systems" (5) WNA-TP-00357-GEN Rev. 4, "Element Software Test
Procedure" Responder: WEC
Items (1) and (2) were docketed by TVA letter dated April 8, 2010. Item (3) will be addressed by Revision 2 of the Licensing
Technical Report. Due 12/3/10 Item (4) will be addressed by Westinghouse developing a WBN2 Specific Test Plan to compensate for the fact that the NRC disapproved WNA-PT-00058-GEN during the original Common Q review. Due 12/7/10 Item (5) Procedures that are listed in the SPM compliance table in the Licensing Technical Report revision 1 supersede that test procedure WNA-TP-00357-GEN.Due 10/22/10 For Item 3, Attachment 19 contains the Westinghouse document "Post-Accident Monitoring System (PAMS)
Licensing Technical Report," WNA-LI-00058-WBT, Revision 2, dated December 2010. Attachment 20 contains the Westinghouse Application for Withholding for the "Post-Accident Monitoring System (PAMS) Licensing Technical Report," WNA-LI-00058-WBT, Revision 2, dated December 2010. For Item 4, Attachment 9 contains the Westinghouse document "Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Post Accident Monitoring System Test Plan," WNA-PT-00138-WBT, Revision 0, dated November 2010. Attachment 10 contains the Westinghouse Application for Withholding for the WNA-PT-00138-WBT, Revision 0 "Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Post Accident Monitoring System Test Plan," WNA-PT-00138-WBT, Revision 0, dated November 17, 2010.
TVA Response to Follow-up NRC Request:
(1) WEC presented the results of the self assessment to the NRC on February 2, 2011.
(2) By agreement between TVA, WEC and the NRC, the Post Accident Monitoring System Test Plan, WNA-PT-00138-WBT, Revision 0 will not be revised. Instead a non-proprietary Common Q PAMS Test Summary Report will be developed and submitted to address the issues with the STP. Attachment 1 contains non-proprietary WNA-TR-02451-WBT, Revision 0, "Test Summary Report for the Post Accident Monitoring System," dated March 2011.
- 1. N Open Pending Submittal of the Test
Summary Report due 3/29/11 Final Response included in
letter dated 12/3/10
Partial Response is included in letter dated 10/5/10.
The SysRS and SRS incorporate requirements from many other documents by reference.
NNC 8/25/10: (3) An earlier version of this report was docketed for the Common Q
topical report; therefore, there
should be no problem to docket this version. (4) Per ML091560352, the testing process document does not address the test plan
requirements of the SPM. Please provide a test plan that implements the requirements of
the SPM. Open-NRC Review
Due 3/29/11 NNC 1/27/11:
Issues with the STP were discussed in the weekl y public meetings. Westinghouse to: (1) perfrom STP self assessment., and (2) Augment Test Summary report to provide missing test
plan information
NNC 2/3/11:
At next audit compare &
discuss:
(1) WNA-PT-00058-GEN Rev. 0 (2) WNA-PT-00138-WBT Rev. 0
(3) AP1000 STP NRC Meeting Summary NRC
Meeting Summary
ML093560019, Item No. 11 TVA Letter dated 6/18/10
TVA Letter dated 10/5/10 See also Open Item Nos. 226 & 270.
042 All All B (AFebruar y 25 , 2010: Telecom Date: 5/25/10
- 47. Y Closed Closed EICB RAI TVA Letter dated The drawin g provided did not have the 043 7.5.2 7.5.1 CB (C ar t 2/19/2010 Responder: WEC Date: 5/25/10
- 2. N Open Open-NRC Review EICB RAI ML102910002 TVA Letter dated 2/5/10 NNC 8/25/10:
A CQ PAMS ISG6 compliance matrix was docketed on: (1)
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments The PAMS ISG6 compliance matrix supplied as Enclosure 1 to TVA letter dated February 5, 2010 is a first draft of the information needed. The shortcomings of the firs t three lines in the matrix are:
Line 1: Section 11 of the Common Q topical report did include a commercial grade dedication program, but this program was not approved in the associated SE. Westinghouse stated that this was the program and it could now be reviewed. The NRC stated that TVA should identified what they believe was previously reviewed
and approved.
Line 2: TVA stated the D3 analysis was not applicable to PAMS, but provided no justification. The NRC asked for justification since SRP Chapter 7.5 identified SRM to SECV-93-087 Item II.Q as being SRP acceptance criteria for PAMS.
Line 3: TVA identified that the Design report for computer integrity was completed as part of the common Q topical report. The NRC noted that this report is applicable for a system in a plant, and the CQ topical report did no specifically address this PAMS system at
Watts Bar Unit 2.
NRC then concluded that TVA should go through and provide a more complete and thorough compliance matrix.
The PAMS ISG6 compliance matrix supplied as Enclosure 1 to TVA letter dated February 5, 2010 is a first draft of the information needed.
By letter dated April 8, 2010 TVA provided the PAMS Licensing Technical Report provided additional information.
contains the revised Common Q PAMS ISG-6 Compliance Matrix, dated June 11, 2010, that addresses these items (Reference 13).
By letter Dated June 18, 2010 (see Attachment 3) TVA provided a table, "Watts Bar 2 - Common Q PAMS ISG-6 Compliance Matrix."
It is TVA's understanding that this comment is focused on the fact that there are documents that NRC has requested that are currently listed as being available for audit at the Westinghouse offices. For those Common Q PAMS documents that are TVA deliverable documents from Westinghouse, TVA has agreed to provide those to NRC.
Westin ghouse documents that are not deliverable to TVA will be available for audit as stated above. Requirements Traceability Matrix issues will be tracked under NRC RAI Matrix Items 142 (Software Requirements Specification) and 145 (System Design Specification). Commercial Item Dedication issues will be tracked under NRC RAI Matrix Item 138. This item is considered closed.
TVA Response to Follow-up NRC Request:
WNA-LI-00058-WT-P, Revision 2, "Post-Accident Monitoring System (PAMS) Licensing Technical Report" submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1) contains the following changes to address the NRC requests:
(1) While RSEDs are not specifically mentioned, Section 7 has been revised to be applicable to both hardware and software which includes the RSEDs.
(2) Table 6-1 item 15 reference added for WNA-VR-00280-WBT (RESD)
TVA Response to Second Follow-up NRC Request:
The NRC audited the Westinghouse commercial item dedication process for both hardware and software during the week of February 28 to March 4, 2011. The audif found the processes acceptable. Westinghouse and TVA previously agreed to provide additional information to address this item in Revision 3 of the Licensing Technical Report.
contains WNA-LI-00058-WBT-P, "Post-Accident Monitoring System (PAMS) Licensing Technical Report," Revision 3, dated March 2011 (proprietary). contains WNA-LI-00058-WBT-NP, "Post-Accident Monitoring System (PAMS) Licensing Technical Pending Submittal of Revision 3 of the Licensing Technical Report due 3/29/11.
Revised response included in
letter dated 12/22/10.
Response is included in letter
dated 10/5/10.
Revised compliance matrix is unacceptable.
NNC 8/12/10:
It is not quite enough to provide all of the documents requested. There are two possible routes to
review that the NRC can undertake: (1) follow ISG6, and (2) follow the CQ SPM. The
TVA response that was originally pursued was to follow ISG6, but some of the compliance items for ISG6 were
addressed by referencing the SPM. The NRC approved the CQ TR and associated SPM; it may be more appropriate to review the WBN2 PAMS application to for adherence to
the SPM that to ISG6. In either path chosen, the applicant should provide documents and a justification for the acceptability of any deviation from the path chosen. For example, it appears that the Westinghouse's CDIs are
commercial grade dedication plans, but Westinghouse maintains that they are
reports; this apparent deviation should be justified or explained. Due 3/29/11 NNC 2/2/11:
Issues with Common Q TR &
SPM compliance were discussed in the weekl y public meetings. Westinghouse to perform Common Q TR
& SPM compliance self assessment; his will be discussed in detail on the next audit. Item No. 2 TVA Letter dated 5/12/10 TVA Letter dated
6/18/10 TVA Letter dated
10/5/10 February, 5 12010, (2) March 12, 2010, & (3) June 18, 2010. The staff has expressed issued with all of these compliance evaluations. The staff is still
waiting for a good compliance evaluation.
NNC 11/23/10: WNA-LI-00058-WT-P Rev. 1 Section 7 does not include the RSED documents, and it should. Table 6-1 Item No. 15 should also include the RSED RTMs.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Report," Revision 3 dated March 2011 (non-proprietary). Attachment 4 contains CWA-11-311, Application for Withholding Proprietary Information from Public Disclosure, WNA-LI-00058-WBT-P, Revision 3 "Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Post-Accident Monitoring System (PAMS) Licensing Technical Report," dated March 14, 2011.
044 7.5.2 7.5.1 (CFebruar y 25 , 2010 Date: 5/25/10
- 50. Y Closed Closed N/A - Re q uest for N/A 047 7.5.2 7.5.1 (C 4/8/2010 Res p onder: WEC/Hilmes Date: 5/25/10
- 52. Y Closed Closed EICB RAI TVA Letter dated 049 7.5.2 7.5.1 (C 4/8/2010 Res ponder: WEC Date: 5/25/10
- 53. Y Closed Closed EICB RAI TVA Letter dated 050 7.5.2 7.5.1 (C 4/8/2010 Res p onder: WEC Date: 5/25/10
S y sRS Rev. 2 contains 051 (G Ap ril 15 , 2010 Date: 5/25/10
- 55. Y Closed Closed N/A N/A Review addressed b y another O p en 052 7.5.2 7.5.1 (S i Ap ril 19 , 2010 Date: 5/25/10
- 56. Y Closed Closed RAI No. 12 053 7.5.2 7.5.1 (S i Ap ril 19 , 2010 Date: 5/25/10
- 57. Y Closed Closed RAI No. 13 054 7.5.2 7.5.1 (S i 4/19/2010 Res ponder: Slifer/Clark Date: 5/25/10
- 58. Y Closed Closed RAI No. 14 TVA Letter dated 055 7.5.2 7.5.1 (S i 4/19/2010 Res ponder: Slifer/Clark Date: 5/25/10
- 60. Y Closed Closed RAI No. 16 TVA Letter dated Sorrento Radiation Monitorin g 057 7.5.2 7.5.1 (S i 4/19/2010 Res ponder: TVA I&C Staff Date: 5/25/10
- 62. Y Closed Closed RAI No. 18 TV A Letter dated 059 7.5.2 7.5.1 (S i Ap ril 19 , 2010 Date: 63. Y Closed Closed RAI No. 19 TVA Letter dated 060 7.5.2 7.5.1 (C Ap ril 19 , 2010 Date: 5/25/10
- 64. Y Closed Closed N/A N/A A ddressed b y O p en Item No. 47 061 7.5.2 7.5.1 (C Ap ril 19 , 2010 Date: 5/25/10
- 65. Y Closed Closed N/A N/A A ddressed b y O p en Item No. 48 062 7.5.2 7.5.1 (C Ap ril 19 , 2010 Date: 5/25/10
- 66. Y Closed Closed N/A N/A A ddressed b y O p en Item No. 49 063 7.5.2 7.5.1 (C Ap ril 19 , 2010 Date: 5/25/10
- 67. Y Closed Closed N/A N/A A ddressed b y O p en Item No. 50 064 7.5.2 7.5.1 (C B y letter dated March 12
, 2010 TVA stated that the tar g et submittal Res p onder: Webb Date: 4/8/2010
- 68. Y Closed Closed N/A - No q uestion TVA Letter dated 065 7.5.2 7.5.1 (C B y letter dated March 12
, 2010 TVA stated that the tar g et submittal Res ponder: WEC Date: 5/25/10
- 69. Y Closed Closed N/A - No q uestion TVA Letter dated 066 7.5.2 7.5.1 (C B y letter dated March 12
, 2010 TVA stated that the tar g et submittal Res p onder: WEC Date: 5/25/10
- 70. Y Closed Closed N/A - No q uestion TVA Letter dated 067 7.5.2 7.5.1 EICB (Carte)
By letter dated March 12, 2010 TVA stated that the target submittal date for the "Commercial Grade Dedication Instructions for AI687, AI688, Upgraded PC node box and flat panels." was September
28, 2010.
Responder: WEC Date: 5/25/10 The following status is from the revised WB2 Common Q PAMS ISG-6 Compliance Matrix submitted in response to
Item 43:
- a. AI687, AI688 - Scheduled for September 28, 2010
- b. Upgraded PC node box and flat panel displays - Per Westinghouse letter WBT-D-2024 (Reference 7
), these items are available for audit at the Westinghouse Rockville office.
- c. Power supplies - Per Westinghouse letter WBT-D-2035 (Reference 12), these items are available for audit at the Westinghouse Rockville office.
To be addressed during 9/20-9/21 audit TVA Response to Follow-up NRC Request:
- 3. N Open Pending Submittal of Revision 3 of the Licensing Technical Report due 3/29/11.
Response included in letter
dated 12/22/10.
This item is addressed in Rev. 2 of the Licensing Technical Report Open-NRC Review Due: 3/29/11
NNC 2/2/11:
Section 7 of the WBN2 PAMS LTR should be updated to include:
(1) non-proprietary description of commercial grade dedication, and (2) Software example Commercial grade
dedication will also be
addressed at the next audit. N/A - No question was asked. Item was opened to track comm8ittment made by applicant. TVA Letter dated 6/18/10 Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments WNA-LI-00058-WT-P, Revision 2, "Post-Accident Monitoring System (PAMS) Licensing Technical Report" submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1) contains the following change to address the NRC request:
Section 7, "Commercial Grade Dedication Process," has been revised to describe the general commercial grade dedication process for both hardware and software and uses a description of the AI687 dedication process as an example of how the process is applied.
TVA Response to Follow-up NRC Request dated 2/2/11:
The non-proprietary commercial grade dedication discussion is included in Attachment 3, WNA-LI-00058-WBT-NP, "Post-Accident Monitoring System (PAMS) Licensing Technical Report," Revision 3 dated March 2011 (non-proprietary)
Section 7.
The software example is included in , WNA-LI-00058-WBT-P, "Post-Accident Monitoring System (PAMS) Licensing Technical Report," Revision 3, dated March 2011 (proprietary) Section 7.
068 7.5.2 7.5.1 EICB (Carte)
By letter dated March 12, 2010 TVA stated that the target submittal date for the "Summary Report on acceptance of AI687, AI688, Upgraded PC node box, flat panels, and power supplies." was
September 28, 2010.
Responder: WEC Date: 5/25/10 The following status is from the revised WB2 Common Q PAMS ISG-6 Compliance Matrix submitted in response to
Item 43:
- a. AI687, AI688 - Scheduled for September 28, 2010
- b. Upgraded PC node box - Per Westinghouse letter WBT-D-2024 (Reference 7), this item is available for audit at the Westinghouse Rockville office.
- c. Flat panel displays - Per Westinghouse letter WBT-D-2024 (Reference 7), this item is available for audit at the Westinghouse Rockville office.
- d. Power supplies - Per Westinghouse letter WBT-D-2035 (Reference 12), these items are available for audit at the Westinghouse Rockville office.
To be addressed during 9/20-9/21 audit
TVA Response to Follow-up NRC Request:
For the commercial grade dedication process, please see
the response to Request for Additional Information (RAI) item 3 in this letter, NRC Matrix Item 067.
The component level EQ/Seismic summary reports for the hardware listed above are available for NRC review/audit as described below:
(1) AI687 and AI688, the following documents were submitted in TVA Letter to NRC dated October 26, 2010, "Watts Bar Nuclear Plant (WBN) Unit 2 -
Instrumentation and Controls Staff Information
- 4. N Open Response included in letter
dated 12/22/10.
This item is addressed in Rev. 2 of the Licensing Technical Report Open-NRC Review NNC 2/2/11:
Commercial grade dedication will be addressed at the next audit. Summary reports for AI687 &
AI688 were docketed one month late. N/A - No question was asked. Item was opened to track comm8ittment made by applicant. TVA Letter dated 6/18/10 Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Requests," (Reference 5):
- a. EQ-EV-62-WBT, Revision 0, "Common Q PAMS Comparison of Tested Conditions for the AI687 and AI688 Common Q Modules and Supporting
Components to the Watts Bar Unit 2 (WBT)
Requirements," dated September 10, 2010
- b. EQLR-171, Revision 0, "Environmental and Seismic Test Report, Analog Input (AI)687 &
AI688 Modules for use in Common Q PAMS,"
dated September 10, 2010
- c. CN-EQT-10-44, Revision 0, "Dynamic Similarity Analysis for the Watts Bar Unit 2 Post Accident Monitoring System (PAMS)," dated September
28, 2010 (2) Upgraded PC Node Box - As stated in Westinghouse letter WBT-D-2024, dated June 9, 2010 "NRC Access to Common Q Documents at the Westinghouse Rockville Office," (Reference 6), the following documents are available for NRC audit at the Westinghouse Rockville office:
- a. CDI-3722, Revision 7, "Next Generation PC Node Box Commercial Dedication Instruction"
- b. LTR-EQ-10-50 "PC Node Box/Flat Panel Display System Components Qualification Summary"
(3) Flat Panel Displays - As stated in Westinghouse letter WBT-D-2024, dated June 9, 2010 "NRC Access to Common Q Documents at the Westinghouse Rockville Office," (Reference 6), the following documents are
available for NRC audit at the Westinghouse Rockville office: a. CDI-3803, Revision 8, "Next Generation Flat Panel Display (FPD) Commercial Dedication Instruction"
- b. LTR-EQ-10-50 "PC Node Box/Flat Panel Display System Components Qualification Summary" (4) Power supplies - As stated in Westinghouse letter WBT-D-2035 dated June 11, 2010 "NRC Access to Common Q Documents at the Westinghouse Rockville Office" (Reference 7), the following documents are
available for NRC audit at the Westinghouse Rockville office: a. CDI- 4057, Revision 4, "Commercial Dedication Instruction"
- b. EQ-TP-1 05-GEN, Revision 0, "Electromagnetic Compatibility Test Plan and Procedure for Quint Power Supplies and Safety System Line Filter"
- c. Breakers," EQ-TP-114-GEN, Revision 0, "Seismic Qualification Test Procedure For Common Q Power Supplies, Quint Power Supplies, Line Filter Assemblies, and South Texas Units 3 & 4 Circuit"
- d. EQ-TP-117-GEN, Revision 0, "Environmental Qualification Test Procedure For Common Q Pow eSupplies, Quint Power Supplies, and Line Filter Assemblies" 069 7.5.2 7.5.1 CB (C ar t By letter dated March 12, 2010 TVA stated that the target submittal date for the "Watts Bar 2 PAMS Specific FAT Report" was October Responder: WEC Date: 5/25/10
- 5. N Open Open-NRC Review Due 3/29/11 N/A - No question was asked. Item N/A Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments 2010. As agreed, the Watts Bar 2 PAMS Specific FAT Report will not be submitted. Instead a non-proprietary PAMS Test Summary Report will be submitted. Attachment 1 contains non-proprietary WNA-TR-02451-WBT, Revision 0, "Test Summary Report for the Post Accident Monitoring System," dated March 2011. Pending Submittal of the Test Summary Report due 3/29/11 Awaiting for document to be
docketed by TVA.
NNC 2/3/11: The current due dated above is 4 months later than planned. was opened to track comm8ittment made by applicant.
070 7.5.2 7.5.1 (C B y letter dated March 12
, 2010 TVA stated that the tar g et submittal Res p onder: WEC Date: 5/25/10
- 71. N Closed Closed N/A - No q uestion TVA Letter dated NNC 11/23/10:
The dues date in this 071 7.5.2 7.5.1 (C B y letter dated March 12
, 2010 TVA stated that the tar g et submittal Res ponder: WEC Date: 5/25/10
- 72. N Closed Closed N/A - No q uestion N/A NNC 11/23/10:
The dues date in this 072 7.5.2 7.5.1 (C B y letter dated March 12
, 2010 TVA stated that the tar g et submittal Res p onder: WEC Date: 5/25/10
- 73. Y Closed Closed N/A - No q uestion N/A 073 7.5.2 7.5.1 (C B y letter dated March 12
, 2010 TVA stated that the tar g et submittal Res p onder: WEC Date: 5/25/10
- 74. N Closed Closed N/A - No q uestion N/A 074 7.5.2 7.5.1 EICB (Carte)
By letter dated March 12, 2010 TVA stated that the target submittal date for the Post FAT IV&V Phase Summary Report was November 30, 2010.
Responder: WEC Date: 5/25/10 contains WNA-VR-00283-WBT-P, "
I V&V Summary Report for the Post Accident Monitoring System," Revision 4, dated March 2011 (proprietary). Attachment 2 contains WNA-VR-00283-WBT-NP, "
I V&V Summary Report for the Post Accident Monitoring System," Revision 4, dated March 2011 (non-proprietary). Attachment 3 contains CWA-11-3121, Application for Withholding Proprietary Information from Public Disclosure, WNA-VR-00283-WBT-P, Revision 4 "Nuclear Automation IV&V Summary Report for the Post Accident Monitoring System" (Proprietary)," dated March 3, 2011. 6. N Open Response in letter dated March 16, 2011 Open-NRC Review
Due TBD NNC 2/3/11:
At least 3 months later than planned. N/A - No question was asked. Item
was opened to track commitment made by applicant. N/A Rev. 4 will be available for the NRC audit on 2/28/11. This document will not be submitted. Rev. 5 will be submitted after resolution of the datastorm display issue. 075 7.5.2 7.5.1 (C B y letter dated March 12
, 2010 TVA stated that the tar g et submittal Res ponder: WEC Date: 5/25/10
- 75. N Closed Closed N/A - No q uestion N/A 076 7.5.2 7.5.1 (C B y letter dated March 12
, 2010 TVA stated that the tar g et submittal Res p onder: Clark Date: 5/25/10
- 76. Y Closed Closed N/A - No q uestion N/A 077 7.5.2 7.5.1 (C B y letter dated March 12
, 2010 TVA stated that the tar g et submittal Res p onder: WEC Date: 5/25/10
- 77. Y Closed Closed N/A - No q uestion TVA Letter dated 078 (G 4/26/2010 Res p onder: Clark Date: 5/25/10
- 79. Y Closed Closed EICB RAI TVA Letter dated Reviewed under Item 154 080 (S i 4/26/2010 Res p onder: WEC
- 80. Y Closed Closed RAI No. 2 TVA Letter dated 081 7.5.2 7.5.1 EICB (Carte) 5/6/2010 The PAMS Licensing Technical Report (WNA-LI-00058-WBT Rev. 0, Dated April 2010), in Section 7, lists codes and standards applicable to the Common Q PAMS. This list contains references to old revisions of several regulatory documents, for example:
(1) RG 1.29 - September 1978 vs. March 2007 (2) RG 1.53 - June 1973 vs. November 2003 (a) IEEE 379-1994 vs. -2000 (3) RG 1.75 - September 1975 vs. February 2005 (a) IEEE 384-1992 vs. -1992 (4) RG 1.100 - June 1988 vs. September 2009 (a) IEEE 344-1987 vs. -2004 (5) RG 1.152 - January 1996 vs. January 2006 (a) IEEE 7-4.33.2-1993 vs. -2003 (6) RG 1.168 - September 1997 vs. February 2004 (a) IEEE 1012-1986 vs. -1998 (b) IEEE 1028-1988 vs. -1997 (7) IEEE 279-1991 vs. 603-1991 (8) IEEE 323-1983 vs. -1974 (RG 1.89 Rev. 1 June 1984 endorses 323-1974)
However, LIC-110, "Watts Bar Unit 2 License Application Review,"
states: "Design features and administrative programs that are unique to Unit 2 should then be reviewed in accordance with the current staff positions." Please identify all differences between the versions referenced and the current staff positions. Please provide Responder: Merten/WEC
The codes and standards documents listed in Section 7 of the Common Q PAMS Licensing Technical Report are the documents that the Common Q platform was licensed to when the NRC approved the original topical report and issued the approved SER. The WBN Unit 2 Common Q PAMS is designed in accordance with the approved Common Q topical report and approved SER and the codes and standards on which the SER was based. Since the current versions referenced are not applicable to WBN Unit 2, there is no basis for a comparison review.
Bechtel to develop a matrix and work with Westinghouse to provide justification.
TVA Response to Follow-up NRC Request:
Attachment 4 contains the results of the TVA analysis of standards and regulatory guides applicable to the Common Q PAMS. Based on the results of the analysis, the Common
Q PAMS design meets the applicable requirements and is acceptable.
- 7. N Open ML101600092 Item No.1: There are three sets of regulatory
criteria that relate to a Common
Q application (e.g. WBN2
PAMS): (a) Common Q platform components - Common Q TR (b) Application Development Processes - Common Q SPM (c) Application Specific - current regulatory criteria The Common Q Topical Report and associated appendices primarily addressed (a) and (b). The Common Q SER states:
'-Appendix 1, "Post Accident Monitoring Systems," provides the functional requirements and conceptual design approach for
upgrading an existing PAMS
based on Common Q components (page 58, Section 4.4.1.1, "Description")-On the Open-NRC Review
Due 2/25/11 TVA to provide
requested information.
NNC 2/3/11: The above due date has
been missed by at least 2 months.
Please provide new due date.
EICB RAI ML102910002
Item No. 9 TVA Letter dated 6/18/10 NNC 1/5/11:
See Also Open Item No.
86 and 202.
NNC 4/125/2011: See Open Item No.
364.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments a justification for the acceptability PAMS with respect to these differences. basis of the above review, the staff concludes that Appendix 1 does not contain sufficient information to establish the generic acceptability of the
proposed PAMS design (page 56, Section 4.4.1.3, "PAMS Evaluation")-'
The NRC did not approve the proposed PAMS design.
Section 6, "References," and
Section 7, "Codes and
Standards Applicable to the Common Q PAMS," of the PAMS Licensing Technical
Report contain items that are
not the current regulatory criteria.
Please provide an explanation
of how the WBN2 PAMS conforms with the application specific regulatory criteria applicable to the WBN2 PAMS
design. For example IEEE Std.
603-1991 Clause 5.6.3, "Independence Between Safety Systems and Other Systems,"
and Clause 6.3, "Interaction
Between the Sense and Command Features and Other Systems," contain application
specific requirements that must
be addressed by a PAMS system.
Awaiting TVA Response.
082 7.5.2 7.5.1 (C 5/6/2010 Res p onder: WEC Date: 6/18/10
See also O p en Item No.
083 7.5.2 7.5.1 (C Ma y 6 , 2010 Date: 6/18/10
- 84. N Closed Closed EICB RAI 086 7.5.2 7.5.1 EICB (Carte) 5/6/2010 The PAMS Licensing Technical Report (WNA-LI-00058-WBT Rev. 0, Dated April 2010), in Section 6, lists references applicable to the Common Q PAMS. This list contains references to old revisions of several regulatory documents, for example:
(1) DI&C-ISG04 - Rev. 0 (ML072540138) vs. Rev. 1 (ML083310185) However, LIC-110, "Watts Bar Unit 2 License Application Review,"
states: "Design features and administrative programs that are unique to Unit 2 should then be reviewed in accordance with the Responder: WEC Date: 5/24/10
The regulatory documents listed in the Common Q PAMS Licensing Technical Report are the documents that the Common Q platform was licensed to when the NRC approved the original topical report and issued the approved SER. The WBN Unit 2 Common Q PAMS is designed in accordance with the approved Common Q topical report and approved SER and the regulatory documents on which the
SER was based. Since the current versions referenced are not applicable to WBN Unit 2, there is no basis for a
- 81. Open-NRC Review
Due 2/25/11 NNC 2/3/11: The above due date has
been missed by at least 2 months.
Please provide new
due date.
EICB RAI ML102910002
Item No. 14 TVA Letter dated 6/18/10 NNC 1/6/11:
See Also Open Item No.81
& 202 Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments current staff positions." Please identify all differences between the versions referenced and the current staff positions. Please provide a justification for the acceptability PAMS with respect to these differences.
comparison review.
Rev 0 of the Licensin g Technical Report references Rev. 1 of ISG4 TVA Response to Follow-up NRC Request:
The analysis for compliance with DI&C-ISG04, Revision 0 to Revision 1 was previously submitted as part of the Common Q PAMS Licensing Technical Report Revision 2 on December 22, 2010. Attachment 4 contains the results of
the TVA analysis of standards and regulatory guides applicable to the Common Q PAMS. Based on the results of the analysis, the Common Q PAMS design is acceptable.
087 7.5.2 7.5.1 (S i Ma y 6 , 2010 Date: 5/24/10
- 87. Y Closed Closed EICB RAI TVA Letter dated NNC: Docketed res p onse states that 090 (C 5/6/2010 Res p onder: Clark Date: 5/25/10
- 89. Y Closed Closed EICB RAI No.1 TVA Letter dated 092 DORL (Poole) 5/20/2010 TVA to review Licensee Open Item list and determine which items are proprietary.
Responder: Hilmes This item will close when we are no longer using this document as a communications tool.
- 1. Y Open Due SER Issue Open-TVA/Oversight Due: SER Issue Continuous review as items are added 093 (G Ma y 20 , 2010 Date: 5/25/10
- 90. Y Closed Closed N/A N/A Will be reviewed under item 154 094 (G 5/20/2010 Res p onder: Clark Date: 5/25/10
- 91. Y Closed Closed N/A N/A Information was found in FSAR 095 7.8.1 , XX (D a Ma y 20 , 2010 Date: 92. Y Closed Closed EICB RAI No. 2 TVA Letter dated 096 7.7.5 XX (D a 5/20/2010 Res p onder: 93. Y Closed Closed EICB RAI No.3 TVA Letter dated 097 7.4.2 7.4 (D a Ma y 20 , 2010 Date: 94. Y Closed Closed EICB RAI No.4 TVA Letter dated 098 7.4.2 7.4 (D a Ma y 25 , 2010 Date: 95. Y Closed Closed EICB RAI No.5 TVA Letter dated 099 (B a April 12, 2010 Date: 96. Y Closed Closed Closed to Item 129 100 (C 5/20/2010 Res p onder: WEC
- 97. Y Closed Closed N/A - No q uestion N/A 101 DORL (Poole) 4/12/2010 The non-proprietary versions of the following RM-1000, Containment High Range Post Accident Radiation Monitor documents will be provided by June 30, 2010.
- 1. V&V Report 04508006A 2. System Description 04508100-1TM 3. Qualification Reports 04508905-QR, 04508905-1 SP, 04508905-
2SP, 04508905-3SP
- 4. Functional Testing Report 04507007-1TR Responder: Slifer The documents, and affidavits for withholding for the listed documents were submitted to the NRC on TVA letter to the
NRC dated July 15, 2010.
- 9. Y Open Documents provided in letter dated 07/15/10 Open-NRC Review Due 10/14/10
Confirm receipt. N/A TVA is working with the vendor to meet the 6/30 date, however there is the potential this will slip to 7/14.
102 (C Ma y 24 , 2010 Date: 5/24/10
- 98. Y Closed Closed N/A TVA Letter dated Re q uest for schedule not information.
103 7.4 7.4 (D a 5/27/2010 Res p onder: A y ala Date: 5/27/10
- 99. Y Closed Closed EICB RAI No.1 TVA Letter dated Submittal date is based on current 104 7.4 7.4 (D a 5/27/2010 Res ponder: Merten Date: 5/27/10 100. Y Closed Closed EICB RAI No.1 TVA Letter dated Submittal date is based on current 105 (G Ap ril 29 , 2010 Date: 101. Y Closed Closed N/A N/A Will be reviewed under item 154.
106 (S i May 6, 2010 Date: 5/25/10 102. Y Closed Closed RAI No. 9 TVA Letter dated 107 (S i May 6, 2010 Date: 5/28/10 103. Y Closed Closed RAI No. 22 TVA Letter dated 108 (G Ma y 6 , 2010 Date: 5/25/10 104. Y Closed Closed N/A N/A Will be reviewed under OI#154
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments 109.7.8 XX (D a 5/6/2010 Res ponder: N/A 105. Y Closed Closed N/A N/A 109. (C 5/6/2010 Res ponder: N/A 106. Y Closed Closed N/A N/A Du plicate of another o p en Item. 110 (G Ma y 6 , 2010 Date: 107. Y Closed Closed N/A N/A Information was found.
111 (C May 6, 2010 Date: 5/28/10 108. Y Closed Closed N/A TVA Letter dated Request to help find, not a request for 112 (G June 1, 2010 Date: 109. Y Closed Closed N/A N/A Information was received 113 (G 6/1/2010 Res p onder: Clark 110. Y Closed Closed EICB RAI TVA Letter dated 114 7.2 7.2 (G 6/1/2010 Res p onder: WEC 111. Y Close Closed EICB RAI TVA Letter dated 115 (C 2/25/2010 Res p onder: Clark 112. Y Closed Closed EICB RAI TVA Letter dated 116 (G 6/3/2010 Res p onder: WEC 113. Y Closed Closed EICB RAI TVA Letter dated Letter sent to Westin g house re q uestin g 117 7.1 7.1 (G 6/3/2010 Res p onder: Hilmes 114. Y Closed Closed EICB RAI TVA Letter dated 118 7.4 7.4 (D a 6/8/2010 Res ponder: Merten 115. Y Closed Closed EICB RAI No.1 TVA Letter dated Submittal date is based on current 119 (S i June 10 , 2010 Date: 116. Y Closed Closed RAI No. 23 TVA Letter dated 120 (C 5/6/2010 Res p onder: Hilmes/Merten/Costle y 117. Y Closed Closed EICB RAI TVA Letter dated 121 (C 5/6/2010 Res p onder: Webb/Webber 118. Y Closed Closed EICB RAI TVA Letter dated 122 (C June 14 , 2010 Date: 119. Y Closed Closed N/A - Re quest for N/A 123 7.7.3 7.4.1 , (D a 6/14/2010 Res p onder: 120. Y Closed Closed ML101720589
, TVA Letter dated 124 7.7.5 XX (D a 6/14/2010 Res p onder: 121. Y Closed Closed ML101720589
, Item TVA Letter dated 125 7.7.8 7.7.1.12 (D a 6/14/2010 Res p onder: 122. Y Closed Closed ML101720589
, Item TVA Letter dated 126 7.8 7.8 (D a June 14 , 2010 Date: 123. Y Closed Closed ML101720589
, Item TVA Letter dated 127 7.2 7.2 (G 6/16/2010 Res p onder: WEC/Clar k 124. Y Closed Closed EICB RAI TVA Letter dated 128 7.2 7.2 (G 6/18/2010 Res p onder: WEC Drake /TVA Crai g 125. Y Closed Closed EICB RAI TVA Letter dated Track throu gh SE o p en item 129 (P 6/12/2010 Res p onder: WEC 126. Y Closed Closed N/A TVA Letter dated 130 (P 6/28/2010 Res p onder: Clark 127. Y Closed Closed N/A TVA Letter dated 131 (P 6/28/2010 Res p onder: Clark 128. Y Closed Closed N/A TVA Letter dated 132 (P 6/28/2010 Res p onder: Clark 129. Y Closed Closed N/A TVA Letter dated 133 (P 6/28/2010 Res p onder: Clark 130. Y Closed Closed TVA Letter dated 134 (P 6/28/2010 Res p onder: Clark 131. Y Closed Closed TVA Letter dated 135 7.3.1 7.3.1 (D a 6/30/2010 Res p onder: Clark 132. Y Closed Closed RAI not necessar y TVA Letter dated 136 7.3.2 , 7.4 , 5.6 , (D a 6/30/2010 Res p onder: Clark 133. Y Closed Closed RAI not necessar y TVA Letter dated 137 (CSeveral WBN2 PAMS documents contain a table titled
, "Document Res p onder: WEC 134. Y Closed Closed ML101650255
, Item TVA Letter dated 138 EICB (Carte) By letter dated February 3, 2010, Westinghouse informed TVA that certain PAMS documentation has been completed.
(a) The draft ISG6 states that a commercial grade dedication plan should be provided with an application for a Tier 2 review.
By letter dated February 5, 2010, TVA stated that the commercial grade dedication plan was included in the Common Q Topical Report Section 11, "Commercial Grade Dedication Program."
Section 11 includes a description of the Common Q Commercial Grade Dedication Program, and states: "A detailed review plan is developed for each Common Q hardware or software component that requires commercial grade dedication."
Please provide the commercial grade dedication plans for each Common Q hardware or software component that has not been previously reviewed and approved by the NRC.
Responder: WEC This item is used to track all Commercial Grade Dedication issues.
- a. WNA-LI-00058-WT-P, Revision 2, "Post-Accident Monitorin g S ystem (PAMS) Licensin g Technical Report" submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1) contains the following changes to address the NRC request:
Section 7, "Commercial Grade Dedication Process" has been revised to describe the general commercial grade dedication process for both hardware and software and uses a description of the AI687 dedication process as an example of how the process is applied.
- 10. N Open Pending Submittal of Revision 3 of the Licensing Technical Report due 3/29/11.
Revised response included in letter dated 12/22/10
TVA agreed to include a description of the generic Westinghouse hardware commercial grade dedication process in the PAMS licensing
technical report. (see ML102920031 Item No 1)
Open-NRC Review NNC 2/2/11:
Commercial grade dedication will be
addressed at the next audit.
NNC 2/17/11:
The description of the commercial grade dedication process in
the CQ PAMS LTR Rev. 2 should be updated to include a non-proprietary description and to ML101650255, Item No. 2 See also No. 82.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments (b) The draft ISG6 states that a commercial grade dedication report should be provided within 12 months of requested approval for a Tier 2 review.
(i) Please provide 00000-ICE-37722 Rev. 0, "Commercial Grade Dedication Report for the QNX Operating System for Common Q Applications."
(ii) Please provide WNA-CD-00018-GEN Rev. 3, "Commercial Dedication Report for QNX 4.25G for Common Q Applications."
As listed in Table 6-3. "Westinghouse Watts Bar 2 Common Q PAMS Documents at Westinghouse Rockville Office, the following commercial grade dedication documents are available for NRC audit at the Westinghouse Rockville office: (list included in letter)
- b. It is TVA's understanding that the submittal of the documents listed in (b.i) and (b.ii) is no longer required. Rather, it was agreed, that the inclusion of a description
of the commercial grade dedication process in revision 2 of the Post-Accident Monitoring System (PAMS) Licensing Technical Report, WNA-LI-00058-WT-P, would be sufficient to address this request.
TVA Response to Follow-up NRC Request:
The non-proprietary commercial grade dedication discussion is included in Attachment 3, WNA-LI-00058-WBT-NP, "Post-Accident Monitoring System (PAMS) Licensing Technical Report," Revision 3 dated March 2011 (non-proprietary)
Section 7.
The software example is included in , WNA-LI-00058-WBT-P, "Post-Accident Monitoring System (PAMS) Licensing Technical Report," Revision 3, dated March 2011 (proprietary) Section 7.
TVA agreed to include (in the PAMS licensin g technical report) an evaluation of WBN2 critical characteristics for commercial Westinghouse hardware components against the generic critical characteristics. (see ML102920031 Item No 2)
TVA agreed to include a description of the generic Westinghouse software commercial grade dedication process in the PAMS licensing technical report. (see ML102920031 Item No 3)
TVA agreed to include (in the PAMS licensin g technical report) an evaluation of WBN2 critical characteristics for commercial
software components against the generic critical characteristics. (see
ML102920031 Item No 4) include a software example. 139 (C The WBN2 PAMS S y stem Re q uirements S p ecification (WBN2 Res p onder: WEC 135. Y Closed Closed ML101650255
, Item TVA Letter dated WBN2 PAMS S y stem Re q uirements 140 (C The first re quirement in the WBN2 PAMS S y sRS (i.e., R2.2-1) Res p onder: Clark 136. N Closed Closed ML101650255
, Item TVA Letter dated WBN2 PAMS S y stem Re q uirements 141 (C Deleted b y DORL Date: 137. Y Closed Closed ML101650255
, Item WBN2 PAMS S y stem Re q uirements 142 EICB (Carte) The applicable regulatory guidance for reviewing the WBN2 PAMS SysRS would be IEEE 830 as endorsed by Re g ulator y Guide 1.172 and BTP 7-14 Section B.3.3.1, Requirements Activities - Software Requirements Specifications." IEEE 830-1994 Section 4.3.8, "Traceable," states: "A [requirements specification] is traceable of the origin of each of its requirements is clear-"
- 1. How did TVA ensure the traceability of each requirement in the WBN2 PAMS SysRS.
- 2. Explain the source(s) of the requirements present in the Post Responder: WEC
This item is used to track all traceability issues with the Software Requirements Specification (SRS).
TVA Response to 1:
Traceability of requirements for the WBN Unit 2 Common Q PAMS is ensured by:
- a. Preparation of the TVA Contract Compliance Matrix contained in WNA-LI-00058-WBT-P, Revision 2, "Post-Accident Monitoring System (PAMS) Licensing Technical Report" submitted in TVA Letter to NRC dated December 3, 2010 (Reference 1).
- b. Engineering review/comment/status of each revision of: i. WNA-DS-01617-WBT, "Post Accident Monitoring System - System Requirements
Specification" ii. WNA-DS-01667-WBT, "Post Accident Monitoring System - System Design Specification" (hardware) iii. WNA-SD-00239-WBT, "Software Requirements Specification for the Post Accident Monitoring System" (software)
TVA Response to 2:
As documented in the RTM, some software requirements
- 11. N Open
Revised response included in letter dated 02/25/11
Response included in letter
dated 12/22/10 TVA/Westinghouse agreed to include the V&V evaluation of
their reusable software element
development process in the V&V design phase summary report. This evaluation would include an evaluation against the development process requirements. This evaluation would also include an evaluation
of how the WBN2 specific requirements were addressed by the reusable software elements. (see ML102920031
Item No 5)
Open-NRC Review
Due 2/25/11 (document
submittals)
NNC 2/2/11: Updated Specifications and RTMs to be provided b y TVA
Tracability to be
addressed during the next audit.
ML101650255, Item No. 6 WBN2 PAMS System Requirements Specification
TVA docketed WNA-DS-01617-WBT Rev. 1, "RRAS Watts Bar 2 NSSS Completion Program I&C Projects Post Accident Monitoring System- System Requirements Specification," dated December 2009.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Accident Monitoring System's Software Requirements Specification. To clarify, many documents have requirements that are incorporated by reference into the SRS, but what served to direct the author to include those various documents in the SRS or, if the requirement is based on the System Requirements Specification, what directed the author to include the requirement there?
- 3. Clarify whether the unnumbered paragraphs in the Post Accident Monitoring System's Software Requirements Specification, such as in the section headings, or are all such sections simply considered to be informative?
Does the same apply to documents referenced by the SRS?
Such as WCAP-16096-NP-A, Rev. 1A, "Software Program Manual for Common Q Systems," which is incorporated by reference in requirement R2.3-2 in the SRS.
R2.3-2 [The PAMS software shall comply with the requirements and guidelines defined in WCAP-16096-NP-A, "Software Program Manual for Common Q Systems" (reference 5).]
If any requirements are expressed in such unnumbered paragraph form instead of individually identified requirements, please list them, describe why they satisfy the fundamental requirement of unambiguity, and describe how they were verified.
- 4. Are there any sources of requirements in parallel with the Post Accident Monitoring System's Software Requirements Specification? Meaning does the SRS contain, explicitly or by reference, all the requirements that were used in the design phase for the application specific software, or do software design phase activities use requirements found in
any other source or document? If so, what are these sources or documents?
- 5. References 12, 27, 29, and 31-44 in the Post Accident Monitoring System's Software Requirements Specification are various types of "-Reusable Software Element-".
These references are used in the body of the SRS, for
example:"
R5.3.14-2 [The Addressable Constants CRC error si g nal shall be TRUE when any CAL CRC's respective ERROR terminal
= TRUE (WNA-DS-00315-GEN, "Reusable Software Element Document CRC for Calibration Data" [Reference 12]).] are taken from generic documents. The decision to include generic software requirements was to reduce the overall scope for Common Q features that are unchanged across projects. Westinghouse reviewed the generic PAMS requirements and included those requirements that were applicable to WBN Unit 2 PAMS.
Source: E-mail from Westinghouse (Matthew A.
Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)
TVA Response to 3:
Unnumbered paragraphs in the Post Accident Monitoring System's Software Requirements Specification, such as in the section headings, are informative and are not to be interpreted as requirements. All requirements are explicitly
numbered. It depends on the document type. The statement would be true for requirements documents (such as the SysRS or SDS) if they were incorporated by reference. However, for the specific item cited, WCAP-16096-NP-A, Rev. 1A, it does not contain numbered requirements. The requirements contained in this document are contained within the text of the various sections.
Source: E-mail from Westinghouse (Matthew A. Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)
TVA Response to 4:
The Westinghouse SRS, WNA-SD-00239-WBT, Revision 3 contains references to other Westinghouse software requirements documents. Specifically,
00000-ICE-3238, Revision 5, "Software Requirements Specification Post Accident Monitoring System" 00000-ICE-3239, Revision 13, "Software Requirements Specification for the Common Q Generic Flat Panel Display
Software" Source: E-mail from Westinghouse (Matthew A. Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)
TVA Response to 5:
Requirements for the reusable software elements (RSEDs) are evaluated in WNA-VR-00283-WBT-P, Revision 3, "IV&V Summary Report for the Post Accident Monitoring System,"
dated December 2010 (Attachment 10).
RSED traceability is contained in WNA-VR-00280-WBT, Revision 2, "Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceabili ty Matrix for the Reactor Vessel Level Indication System (RVLIS) Custom PC Elements." This document can be made available for audit Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments They are also included via tables such as found in requirement R7.1.2-1
[The Watts Bar 2 PAMS shall use the application-specific type circuits and custom PC elements listed in Table 7.1-1.]
Do the referenced reusable software element documents include requirements not explicitly stated in the SRS? If so what is their
origin? at the Westinghouse Rockville office.
At the September 15 public meeting in Rockville, the following actions were agreed to. These items address the traceability concerns with the Software Requirements Specification.
- 1. Westinghouse will perform a review of the Requirements Traceability Matrix(RTM), using the issues identified at the 9/15 public meeting as a guide (documented below) and update the RTM as required.
TVA Response:
See response to letter Item 13 (NRC Matrix Item 145).
- 2. The next issue of the IV&V report will include the Requirements phase review of the RTM and a partial review for the Design phase.
TVA Response:
See response to letter Item 13 (NRC Matrix Item 145).
- 3. Westinghouse will add a comments column in the Requirements Traceability Matrix (RTM) to address items not in the SRS or SysRS.
TVA Response:
A comments column has been added to WNA-VR-00279-WBT, Revision 3, "Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System." Source: E-mail from Westinghouse (Matthew A.
Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)
- 4. IEEE 830 says you shouldn't have planning information in the SRS. Westinghouse has agreed to remove this information.
TVA Response:
Westin ghouse has confirmed that process requirements have been removed from the SRS.
Source: E-mail from Westi nghouse (Andrew P. Drake) to Bechtel (Mark S. Clark), RE: Common Q RAI concerns, dated December 8, 2010 (Reference 17)
- 5. IEEE 830 says you shouldn't have process requirements in the SRS. Westinghouse has agreed to remove these requirements.
TVA Response:
Westinghouse confirmed that process requirements
have been removed from the SRS.
Source: E-mail from Westi nghouse (Andrew P. Drake) to Bechtel (Mark S. Clark), RE: Common Q RAI concerns, dated December 8, 2010 (Reference 17)
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments
- 6. Westinghouse will perform and document an evaluation of the SRS to ensure compliance with Reg. Guide 1.172 and justify any deviations.
TVA Response:
WNA-LI-00058-WBT-P, Revision 2, "Post-Accident Monitorin g S ystem (PAMS) Licensin g Technical Report" submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1):
Section 9, "Compliance Evaluation Of The Watts Bar 2 PAMS Software Requirements Specification To IEEE Standard 830-1998 And Regulatory Guide 1.172" has been added.
- 7. 25 issues identified by V&V where some requirements have not been included in the System Design Specification (SDS) (14) and SRS (11) at the revisions reviewed by V&V. Have these been addressed?
TVA Response:
The twenty-five (25) issues are captured in Exception Reports (ERs): V&V-769 and V&V-770. These ERs have all been addressed and the ERs have been closed satisfactorily by Westinghouse IV&V.
Source: E-mail from Westinghouse (Matthew A. Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)
- 8. Some hardware requirements are contained in the SRS instead of the System Design Specification (SDS). These will be removed from the SRS and incorporated into the next revision of the SDS.
TVA Response:
The hardware requirements in the Software Requirements Specification have been deleted and moved to System Design Specification.
Source: E-mail from Westinghouse (Matthew A.
Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 16, 2010 (Reference 15)
- 9. RTM item R4.2-2 protection class software set to 0. Needs to be fixed internally. Write CAPs to revise the application restrictions document on AC160.
TVA Response:
Westinghouse CAPs IR# 10-259-M034 has been issued. This item will be addressed in revision 4 of the RTM. Source: E-mail from Westinghouse (Matthew A. Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)
- 10. Westinghouse to improve the traceability of the tests Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments that are performed with the function enable (FE) switch in the "ENABLE" position.
TVA Response:
The tests that are performed with the FE keyswitch in the ENABLE position are defined in the SRS Sections:
6.2 "Manually Initiated Testing," 7.2.23 "Annunciator Test Display," 7.2.25 "Saturation Margin Test Display,"
and 7.2.26 "Analog Output Test Display."
- 11. Westinghouse to revise documents to be consistent with referring to the FE switch in the "ENABLE" position.
TVA Response:
Westinghouse has elected to standardize on the terms "FE keyswitch" and "ENABLE." A review of recent documents for compliance with this comment and commitment was performed with the following results:
- a. Revision 3 of the SysRS, and SDS have been revised to use the terms "FE keyswitch." Revision 3 of the SDS is consistent in use of the term "ENABLE." b. SysRS Revision 3 is not consistent in use of the term "ENABLE" as noted below:
- i. R2.5.2.1-2 uses the term "ENABLED" instead of "ENABLE" ii. R2.5.2.1.3-3, R2.6.3.3-1, R2.6.3.3-2, R2.6.3.3-3, and R2.6.3.3-7, use the term "Enable"
instead of "ENABLE"
- c. Revision 3 of the SRS is not consistent in use of the terms "FE keyswitch" and "ENABLE" as noted below: i. Tables 7.2-1 "Train A PAMS Data Transmitted to the Plant Computer" and 7.2-2 "Train B PAMS Data Transmitted to the Plant Computer" items 101 and 102 in the SRS refer to the FE switch.
All other items in the SRS refer to the FE
keyswitch.
ii. Section 2.1, page 2-4, uses the term "Enable" instead of "ENABLE" iii. Requirements R7.2.14-6 and R7.2.16-7 use the term "active" instead of "ENABLE" iv. Requirements R7.2.23-2, R7.2.25-2, R7.2.26-2, R7.2.31-4, 7.2.56 FPDS Availability, and
R7.2.57-4 use the term "enabled" instead of
"ENABLE" d. WNA-AR-00180-WBT-P, Revision 0, "Failure Modes and Effects Analysis (FMEA) for the Post Accident Monitoring System," dated October 2010, submitted in TVA letter to NRC dated (Reference 12) is not consistent in use of the term "FE keyswitch" as noted below:
ii. Table 3-1 describes the switch as the "Functional Enable (FE) switch" and the "FE key-switch"
- e. Revision 2 of the Licensing Technical Report is not Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments consistent in use of the term "FE keyswitch" as noted below:
- i. Sections 2.2, 5.3 use the term (FE) keylock switch on pages 2-3 (2 places), page 5-3, page
5-6 (4 places)
The identified discrepancies in the use of the terms "FE keyswitch" and "ENABLE" in the SysRS, SRS, FMEA and Licensing Technical Report, will be corrected in the next revision of the documents.
- 12. The flow of information is from the SysRS to the SDS (hardware) and SRS (software). Describe how the documents are used. Describe in 1.1 of the SysRS. Need a good write up of how the process works.
TVA Response:
See response to letter item 13 (NRC Matrix Item 145).
- 13. Westinghouse and TVA will develop a revised schedule for document submittals and provide it to the NRC no later than 9/30/10 TVA Response:
The revised document submittal schedule was included
as item 3 NRC Request (Matrix Item Number 142, TVA Commitments Nos. 10 and 17) in TVA letter to NRC dated October 26, 2010 (Reference 5).
- 14. TVA will update the Procurement Requisition Resolution Matrix and submit it to show how the Common Q PAMS design meets the contract requirements.
TVA Response:
The Procurement Requisition Resolution Matrix has been updated and is included in WNA-LI-00058-WBT-P, Revision 2, "Post-Accident Monitoring System (PAMS)
Licensing Technical Report" submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1), as Section 11, "TVA Contract Compliance Matrix."
- 15. Westinghouse to add the Software Design Descriptions to the RTM
TVA Response:
The Software Design Description documents were added to the RTM in WNA-VR-00279-WBT, Rev 2.
Source: E-mail from Westinghouse (Matthew A.
Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)
- 16. Westinghouse to clarify how requirements or documents are incorporated by reference into the Common Q PAMS requirements.
TVA Response:
When a Common Q PAMS requirements document Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments references a section of another document, all requirements in that section are applicable.
Source: E-mail from Westinghouse (Matthew A.
Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)
- 17. Westinghouse to review the use of "shall" outside of numbered paragraphs in requirements documents to
ensure that all requirements are captured and clearly identified.
TVA Response:
See response in letter dated December 22, 2010, item 2 (NRC Matrix Item 050).
- 18. Westinghouse to resolve the following questions concerning Software Design Descriptions (SDDs)
- a. Is the SDD a standalone document or will it incorporate the generic SDD by reference?
- b. What are the SDDs?
- c. PAMS is a delta document so how do we capture all the generic requirements for traceability.
TVA Response:
- a. There are three SDDs prepared specifically for the Watts Bar 2 PAMS project. These are listed below in Item b. These documents and superior requirements documents refer to other generic SDDs also listed in Item b.
- b. The SDDs developed for this project are:
Projects Software Design Description for the Post Accident Monitoring System Flat Panel Display" ii. WNA-SD-00250-WBT, Revision 1, "Watts Bar 2 NSSS Completion Program I&C
Projects Software Design Description for the Post Accident Monitoring System AC160 Software" iii. WNA-SD-00277-WBT, Revision 2, "Watts Bar 2 NSSS Completion Program I&C Projects Software Design Description for the Post Accident Monitoring System Flat Panel Display System Screen Design Details"
iv. Other generic SDDs referenced by the PAMS project are:
(a) 00000-ICE-20157, Revision 18, "Software Design Description for the Common Q Generic Flat-Panel Software"
(b) 00000-ICE-30152, Revision 5, Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments "Software Design Description Post Accident Monitoring System AC160" (c) 00000-ICE-30140, Revision 4, "Software Design Description for the Common Q Core Protection Calculator System Database and Utility Functions"
- c. Refer to WNA-VR-00279-WBT, Revision 3.
Source: E-mail from Westinghouse (Matthew A. Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)
- 19. For Reusable Software Elements, Westinghouse to describe as qualified libraries by following the SPM and qualified using the Software Elements Test procedure under Appendix B program. Provide a summary of RSEDs generic WCAP. Westinghouse to determine if the WCAP was docketed under the AP1000. RSED concept is not in the SPM. WCAP-15927 AP-1000 does not discuss RCEDs. WCAP process was
acceptable. RSEDs are listed in the SDD References.
TVA Response:
Section 3.2.4.1 of WCAP-15927 describes the RSED design process for custom PC elements and type circuits. The Glossary of Terms in the SPM defines custom PC elements and type circuits as modules. Therefore, the relationship between WCAP-15927 describing the RSED process as circuits, is defined in
the SPM requirements for software module development.
WCAP-15927 is on the AP1000 docket.
Source: E-mail from Westinghouse (Matthew A. Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)
TVA Response to Follow-up NRC Request:
WNA-VR-00279-WBT, Revision 4, "Watts Bar 2 NSSS
Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System" is scheduled to be available for audit at the Westinghouse Rockville office February 21, 2011. The document will be available at the Westinghouse Cranberry offices to support the NRC Common Q PAMS audit.
contains the proprietary version of WNA-DS-01617-WBT-P, Revision 4, "Post Accident Monitoring System - System Requirements Specification," dated February 2011. Attachment 10 contains the non-proprietary
version WNA-DS-01617-WBT-NP, Revision 4, "Post Accident Monitoring System - System Requirements Specification," dated February, 2011. Attachment 11 contains the Application for Withholding Proprietary Information from Public Disclosure, WNA-DS-01617-WBT-P, Revision 4, "Nuclear Automation Watts Bar 2 NSSS Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Completion Program I&C Projects, Post Accident Monitoring System - System Requirements Specification" (Proprietary), dated February 10, 2011.
2 contains the proprietary version of WNA-DS-01667-WBT-P, Revision 4, "Post Accident Monitoring System - System Design Specification," dated February 2011. Attachment 13 contains the non-proprietary version WNA-DS-01667-WBT-NP, Revision 4, "Post Accident Monitoring System - System Design Specification," dated February 2011. Attachment 14 contains the Application for Withholding Proprietary Information from Public Disclosure, WNA-DS-01667-WBT-P, Revision 4, "Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects Post Accident Monitoring System - System Design Specification" (Proprietary), dated February 11, 2011.
5 contains the proprietary version of WNA-SD-00239-WBT-P, Revision 4, "Software Requirements Specification for the Post Accident Monitoring System,"
dated February 2011. Attachment 16 contains the non-proprietary version WNA-SD-00239-WBT-NP, Revision 4, "Software Requirements Specification for the Post Accident Monitoring System," dated February 2011. Attachment 17 contains the Application for Withholding Proprietary Information from Public Disclosure, WNA-SD-00239-WBT-P, Revision 4, "Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Software Requirements Specification for the Post Accident Monitoring System" (Proprietary), dated February 10, 2011.
143 EICB (Carte) The WBN2 PAMS Software Requirements Specification (WBN2 PAMS SRS - ML101050202) contains a table (see page iii) titled, "Document Traceability & Compliance," which states that the
WBN2 PAMS SRS was created to support the three documents identified (one of which is the WBN2 PAMS SysRS). Section 1.1, "Overview," of the WBN2 PAMS SRS states: "This document describes requirements for the major software components -"
(a) Please list and describe each of the "major software components". Please include a description of any NRC review for each of these components.
(b) Please list and describe each of the other software components. Please include a description of any NRC review for each of these components.
(c) What other documents contain the requirements for the other
software components?
The WBN2 PAMS System Design Specification (WBN2 PAMS SDS) contains a table (see page iii) titled, "Document Traceability
& Compliance," which states that the WBN2 PAMS SysRS was created to support the WBN2 PAMS SysRS. Section 1.1, "Purpose," of the WBN2 PAMS SDS states: "The purpose of this document is to define the hardware design requirements -"
(c) Do the WBN2 PAMS SRS and SDS, together, implement all of the requirements in the WBN2 PAMS SysRS?
Responder: WEC Addressed in the 9/15 public meeting and 9/20 - 9/21 audit.
A detailed explanation will be provided.
TVA Response:
(a) and (b) The requested information is provided in the following documents:
- i. WNA-LI-00058-WBT-P, Revision 2, "Post-Accident Monitoring System (PAMS) Licensing Technical Report," Table 6-1, "Document Requirements" which lists the software
documentation requirements for the Common Q PAMS and Section 11 "TVA Contract Compliance Matrix" submitted in TVA Letter to NRC, dated December 3, 2010 (Reference 1).
ii. WNA-DS-01617-WBT-P, Revision 3, "Post Accident Monitoring System- System Requirements Specification," dated December
2010 (Attachment 1) iii. WNA-SD-00239-WBT-P, Revision 3, "Software Requirements Specification for the Post Accident Monitoring System," dated December 2010 (Attachment 7) iv. WNA-VR-00279-WBT, Revision 3, "Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post
- 12. N Open Response included in letter
dated 12/22/10 Open-NRC Review Due 2/25/11 (document submittals)
To be addressed by Revision of the RTM, SRS, SysRS, and SysDS.
NNC 2/2/11: Updated Specifications and RTMs to be provided b y TVA NNC 2/3/11: The above due date has
been missed by at least 2 months.
Please provide new
due date. ML101650255, Item No. 7 WBN2 PAMS System Requirements Specification
TVA docketed WNA-DS-01617-WBT Rev. 1, "RRAS Watts Bar 2 NSSS Completion Program I&C Projects Post Accident Monitoring System- System Requirements Specification," dated December 2009.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments (e) Please briefly describe all of the documents that implement the WBN2 PAMS SysRS. Accident Monitoring System" (available for NRC audit at the Westinghouse Rockville office) To the best of TVA's knowledge, no prior NRC review of the software components has been performed. (c) WNA-VR-00280-WBT, Revision 2, "Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Reactor Vessel Level Indication System (RVLIS) Custom PC Elements" (available for NRC audit at the Westinghouse Rockville office) (d) No. Please see Item (e) below. (e) The documents that describe the requirements that implement the WBN Unit 2 SysRS are:
- i. WNA-VR-00279-WBT, Revision 3, "Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System" (available for NRC audit at the Westinghouse Rockville office) ii. WNA-VR-00280-WBT, Revision 2, "Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Reactor Vessel Level Indication System (RVLIS) Custom PC Elements" (available for NRC audit at the Westinghouse Rockville office)
Source: E-mail from Westinghouse (Matthew A. Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)
TVA Response to Follow-up NRC Request:
See Response to item 3 (Item number 142)
144 EICB (Carte) The WBN2 PAMS Software Requirements Specification (WBN2 PAMS SRS) contains a table (see page iii) titled, "Document Traceability & Compliance," which states that the WBN2 PAMS
SRS was created to support the three documents identified (two of these documents have been provided on the docket).
(a) Please describe the third document (i.e., NABU-DP-00014-GEN Revision 2, "Design Process for Common Q Safety Systems").
(b) Please describe the flow of information between these three documents.
(c) Does the PAMS SRS implement the requirements in these three documents?
(d) Please describe if and how these three documents are used in the development of the PAMS Software Design Description.
(e) Do the WBN2 V&V activities include verification that the requirements of these three documents have been incorporated
into the WBN2 PAMS SRS.
Responder: WEC
(a) The purpose of NABU-DP-00014-GEN document is to define the process for system level design, software design
and implementation, and hardware design and implementation for Common Q safety system development. This document supplements the Common Q SPM, WCAP-16096-NP-A. The scope of NABU-DP-00014-GEN includes
the design and implementation processes for the application development. For a fuller description of the design process described in NABU-DP-00014-GEN please refer to the Design Process for AP1000 Common Q Safety Systems, WCAP-15927 on the AP1000 docket. Since this is a Westinghouse process document that is not specifically referenced in the SRS, it will be removed in the next revision
of the document.
(b) - Closed to items 142 and 145 (c) - Closed 142 (d) - Closed to Item 142
- 13. N Open Pending Submittal of Revision 3 of the Licensing Technical Report due 3/29/11.
Revised response included in
letter dated 12/22/10 Response provided in letter
dated 10/5/10
NRC Review and WEC to complete response.
b-d to be addressed at public meeting and audit. Will require information to be docketed.
Open-NRC Review
Due 3/29/11
Responses to items a and e provided.
NNC 11/18/10:
(1) Items b-d closed to other Open Item nos. (2) The point of these questions was to
understand how the origin of the requirements in the
requirements specifications were documented. TVA stated that the origin of the requirements would
be demonstrated in Rev. 2 of the CQ PAMS LTR. ML101650255, Item No. 8 TVA Letter dated 10/5/10 WBN2 PAMS Software Requirements Specification
By letter dated April 8, 2010 (ML10101050203), TVA docketed WNA-SD-00239-WBT, Revision 1, ""RRAS Watts Bar 2 NSSS Completion Program I&C Projects, Software Requirements Specification for the Post Accident Monitoring System," dated February 2010 (ML101050202).
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments (e) WBN2 PAMS Software Requirements Specification (WNA-SD-00239-WBT, Rev. 1) refers to Document Traceability & Compliance table on page iii. This table has three entries; Design Process for Common Q Safety Systems (NABU-DP-00014-GEN, Rev. 2), RRAS Watts Bar 2 NSSS Completion Program I&C Projects Post Accident Monitoring System - System Requirements Specification (WNA-DS-01617-WBT, Rev. 1), and RRAS Watts Bar 2 NSSS Completion Program I&C Projects Post Accident Monitoring System - System Design Specification (WNA-DS-01667-WBT, Rev. 1).
IV&V performed a Requirements Traceability Assessment
during which it reviewed Software Requirements Specification (WBN2 PAMS SRS, WNA-SD-00239-WBT, Rev. 1) against System Requirements Specification (WNA-DS-01617-WBT, Rev. 1) and System Design Specification (WNA-DS-01667-WBT, Rev. 1). Requirements within Software Requirements Specification that are referring to NABU-DP-00014-GEN, Rev 2, Design Process for Common Q Safety Systems, have also been reviewed for traceability and compliance. During IV&V's RTA effort the anomaly reports V&V-769 and V&V- 770 have been initiated and reported in the IV&V Phase Summary Report for the System Definition Phase, WNA-VR-00283-WBT, Rev. 0.
IV&V has verified that the requirements in SRS are derived from the specified documents listed in the Document Traceability and Compliance Table of WBN2 PAMS SRS.
TVA Response to Follow-up NRC Request:
(1) Item (a) in the original list, NABU-DP-00014-GEN Revision 2, "Design Process for Common Q Safety Systems," is available for NRC audit at the Westinghouse Rockville office.
(2) WNA-LI-00058-WT-P, Revision 2, "Post-Accident Monitorin g S ystem (PAMS) Licensin g Technical Report" submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1) contains the following change to address the NRC request:
Section 11, "TVA Contract Compliance Matrix" showing the origin of the requirements was added.
TVA Response to Second Follow-up NRC Request:
Section 13, Origin Tracing of WBN2 PAMS System Requirements Specification was added to the Licensing Technical Report Revision 3 to address this concern. Attachment 2 contains WNA-LI-00058-WBT-P, "Post-Accident Monitoring System (PAMS) Licensing Technical Report," Revision 3, dated March 2011 (proprietary).
NNC 2/3/11:
CQ PAMS LTR Rev. 2 Section 11 & 12 do not
adequately
demonstrate the origin of requirements in SysRS. TVA to
describe how to
address concern.
145 EICB (Carte) The WBN2 PAMS System Design Specification (WBN2 PAMS SDS) contains a table (see page iii) titled, "Document Traceability & Compliance," which states that the WBN2 PAMS SDS was created to support the WBN2 PAMS SysRS.
Responder: WEC (1) The review and update of the RTM is complete. The revised RTM can be made available for NRC audit at
- 14. N Open Response included in letter dated 12/22/10 Open-NRC Review Due 2/25/11 ML101650255, Item No. 9 WBN2 PAMS System Design Specification TVA docketed WNA-DS-01667-WBT Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments (a) Does the WBN2 PAMS SDS implement all of the hardware requirements in the WBN2 PAMS SysRS?
(b) Please briefly describe all of the documents that implement the hardware requirements of the WBN2 PAMS SysRS.
This item is used to track all traceability issues with the System Design Specification (SDS).
At the September 15 public meeting in Rockville, the following actions were agreed to. These items partially address the traceability concerns with the System Design Specification. This item will be updated with the results of the September 20 and 21 Commercial Grade Dedication and SDS RTM audit.
- 1. Westinghouse will perform completed a review of the Requirements Traceability Matrix(RT), using the issues identified at the 9/15 public meeting as a guide (documented below) and update the RTM as required.
- 2. Some hardware requirements are contained in the SRS instead of the System Design Specification (SDS). These will be removed from the SRS and incorporated into the next
revision of the SDS.
- 3. 25 issues identified by V&V where some requirements have not been included in the SDS (14) and SRS (11) at the revisions reviewed by V&V. Have these been addressed?
Yes. The next revisions of the SDS and SRS address these issues. 4. TVA will update the Procurement Requisition Resolution Matrix and submit it to show how the Common Q PAMS design meets the contract requirements.
- 5. The next issue of the IV&V report will include the Requirements phase review of the RTM and a partial review
for the Design phase.
- 6. Westinghouse to provide the generic AC160 and flat panel specifications.
- 7. Westinghouse and TVA to develop a schedule of licensing document submittals that can be met by the project team.
- 8. The flow of information is from the SysRS to the SDS (hardware) and SRS (software). Describe how the documents are used. Describe in 1.1 of the SysRS. Need a
good write up of how the process works. the Westinghouse office in Rockville.
(2) Please see letter Item 10 (NRC Matrix Item 142, sub item 13).
(3) Please see letter Item 10 (NRC Matrix Item 142, sub item 12).
(4) Section 11 "TVA Contract Compliance Matrix" was added to WNA-LI-00058-WBT-P, Revision 2, "Post-Accident Monitoring System (PAMS) Licensing Technical Report" submitted in TVA Letter to NRC
dated December 3, 2010, (Reference 1).
(5) WNA-VR-00283-WBT, Revision 1, "IV&V Summary Report for the Post Accident Monitoring System,"
submitted in TVA to NRC letter dated December 3, 2010 (Reference 1) includes the Requirements and Design phase reviews.
(6) Per Westinghouse letter WBT-D-2268 "NRC Access to Common Q Documents at the Westinghouse Rockville Office" dated August 16, 2010 (Reference 9) "System Requirements Specification for the Common Q Generic Flat Panel Display," 00000-ICE-30155, Revision 9 is available for audit at the Westin ghouse Rockville office.
The generic AC160 specifications are contained in the documents listed below. The documents are available for NRC audit at the Westinghouse Rockville office in accordance with the letter number referenced. List is contained in letter.
(7) A schedule was developed and is reviewed weekly by Westinghouse and TVA project management.
(8) The revised document submittal schedule was included as item 3 NRC Request (Matrix Item Number 142, TVA Commitments Nos. 10 and 17) in TVA letter to NRC dated October 26, 2010.
(9) The flow of documentation information was provided to the NRC inspector during the Common Q PAMS audit.
Source: E-mail from Westinghous e (Andrew P. Drake) to Bechtel (Mark S. Clark), RE: RAI on SysRS, dated December 8, 2010 TVA Response to Follow-up NRC Request:
See Response to item 3 (Item number 142)
During the September 20-21, 2010 audit at Westinghouse, it was acknowledged that TVA/Westinghouse had previously (in September 15, 2010 public meeting) stated:
TVA would provide the RSED RTM. (see ML102920031 Item No 6)
TVA would revise and resubmit the PAMS RTM to address all types of issues identified in the public meeting. (see
ML102920031 Item No 7)
TVA would revise and resubmit the Software Verification and Validation phase summary report for the requirements phase to document the completion of the requirements
phase review. (see
ML102920031 Item No 8)
To be addressed by Revision of the RTM, SRS, SysRS, and SysDS. Rev. 1, "RRAS Watts Bar 2 NSSS Completion Program I&C Projects Post Accident Monitoring System- System Design Specification," dated December
2009. 146 (C 6/17/2010 Res p onder: 138. Y Closed Closed ML101650255
, Item PAMS S ystem Re q uirements 147 (C 6/17/2010 Res p onder: 139. Y Closed Closed ML101650255
, Item PAMS S ystem Re q uirements 148 (C 6/17/2010 Res p onder: 140. Y Closed Closed ML101650255
, Item PAMS S ystem Re q uirements 149 7.2 7.2 (G FSAR Section 7.1.1.2 (2), Overtem perature delta T and Res ponder: Tindell 141. Y Close Closed ML101720589
, Item TVA Letter dated 150 7.2 7.2 (G Man y of the chan g es were based on the Westin ghouse document Res p onder: Clark 142. Y Close Closed ML101720589
, Item TVA Letter dated
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments 151 7.2 7.2 (G Provide the EDCR 52378 and 54504 which discusses the basis for Res p onder: Clark 143. Y Close Closed ML101720589
, Item TVA Letter dated 152 7.2 7.2 (G Deleted portion of FSAR section 7.2.3.3.4 and moved to FSAR Res ponder: Merten/Clark 144. Y Close Closed ML101720589
, Item TVA Letter dated 153 7.2 7.2 (GFSAR section 7.2.1.1.7 added the reference to FSAR section Res p onder: Crai g/Webb 145. Y Close Closed ML101720589
, Item TVA Letter dated 154 7.2 7.2 (GFSAR section 7.2.1.1.10
, set p oints: NRC staff has issued RIS Res p onder: Crai g/Webb 146. Y Closed Closed ML101720589
, Item TVA Letter dated EICB RAI ML102861885 sent to DORL 155 7.2 7.2 (G Summar y of FSAR chan ge document section 7.2 states that Date: 147. Y Closed Closed ML101720589
, Item 156 7.2 7.2 (GFSAR section 7.2.2.1.1 states that dashed lines in Fi g ure 15.1-Res p onder: WEC 148. Y Closed Closed ML101720589
, Item TVA Letter dated Res p onse on hold p endin g 157 7.2 7.2 (GFSAR section 7.2.2.1.1
, fifth p ara g ra p h was deleted exce p t for the Res ponder: Tindell 149. Y Close Closed ML101720589
, Item TVA Letter dated 158 7.2 7.2 (GFSAR section 7.2.2.1.1
, p ara g ra p h six was chan g ed to state that Res ponder: Tindell 150. Y Closed Closed ML101720589
, Item TVA Letter dated 159 7.2 7.2 (GFSAR section 7.2.2.1.2 discusses reactor coolant flow Res p onder: Crai g 151. Y Close Closed ML101720589
, Item TVA Letter dated 160 7.2 7.2 (GFSAR section 7.2.2.2 (7) deleted text which has references 12 and Res ponder: Tindell 152. Y Close Closed ML101720589
, Item TVA Letter dated 161 7.2 7.2 (GFSAR section 7.2.2.3 states that chan g es to the control function Res p onder: Clark 153. Y Closed Closed ML101720589
, Item TVA Letter dated 162 7.2 7.2 (GFSAR section 7.2.2.2 (14) states that b yp ass of a p rotection Res ponder: Tindell 154. Y Closed Closed ML101720589
, Item TVA Letter dated 163 7.2 7.2 (G Deleted b y DORL Date: 155. Y Closed Closed ML101720589
, Item 164 7.2 7.2 a r glFSAR section 7.2.2.2 (20) has been revised to include the p lant Res p onder: Perkins 156. Y Closed Closed ML101720589
, Item TVA Letter dated Item No. 8 sent to DORL 165 7.2 7.2 (GFSAR section 7.2.2.3.2
, last p ara g ra p h of this section has been Res p onder: Clark 157. Y Closed Closed ML101720589
, Item TVA Letter dated 166 7.2 7.2 (G Chan ges to FSAR section 7.2.2.2 (20) are justified based on the Res p onder: Clark 158. Y Closed Closed ML101720589
, Item TVA Letter dated 167 7.2 7.2 (GFSAR section 7.2.2.4
, p rovide an anal y sis or reference to cha p ter Res p onder: Clark 159. Y Close Closed ML101720589
, Item TVA Letter dated 168 7.2 7.2 (G FSAR table 7.2-4
, item 9 deleted loss of offsite p ower to station Res p onder: Clark 160. Y Close Closed ML101720589
, Item TVA Letter dated 169 (G 6/18/2010 Res p onder: Clark 161. Y Closed Closed 170 (G 6/17/2010 Res p onder: Clark 162. Y Closed Closed 171 7.2 7.2 (G 6/17/2010 Res p onder: Crai g 163. Y Closed Closed EICB RAI TVA Letter dated Closed to SE O p en Item 172 (G 6/17/2010 Res p onder: Crai g 164. Y Closed Closed EICB RAI 173 7.1 7.1 (G 6/17/2010 Res p onder: Crai g/Webb/Powers 165. Y Closed Closed EICB RAI 174 (G 6/28/2010 Res p onder: Hilmes/Crai g 166. Y Closed Closed EICB RAI 175 (G June 28 , 2010 Res p onder: 167. Y Closed Closed EICB RAI 176 7.1 7.1 (G 6/28/2010 Res p onder: Crai g/Webb 168. Y Closed Closed EICB RAI 177 7.5.2.7.5.1 (M a 7/15/2010 Res p onder: Clark 169. Y Closed Closed N/A TVA Letter dated RAI not re q uired 178 7.5.2.7.5.1 (M a 7/15/2010 Res p onder: Clark 170. Y Closed Closed N/A TVA Letter dated RAI not re q uired 179 (C A n em p hasis is placed on traceabilit y in S ystem Re q uirements Res p onder: WEC 171. Y Closed Closed N/A - Closed to NA 180 (C The SRP , BTP 7-14 , Section B.3.3.1 states that Re g ulator y Guide Res p onder: WEC 172. Y Closed Closed N/A - Closed to NA 181 (C A n em p hasis is placed on traceabilit y in S ystem Re q uirements Res p onder: WEC 173. Y Closed Closed N/A - Closed to NA 182 (CCharacteristics that the SRP states that a Software Re quirements Res p onder: WEC 174. Y Closed Closed N/A - Closed to NA 183 EICB (Carte) 7/15/2010 An emphasis is placed on traceability in System Requirements Specifications in the SRP, in the unmodified IEEE std 830-1993, and even more so given the modifications to the standard listed in Regulatory Guide 1.172, which breaks with typical NRC use of the word "should" to sa y "Each identifiable requirement in an SRS must be traceable backwards to the s ystem requirements and the desi g n bases or regulatory requirements that is satisfies" On page 1-2 of the Post Accident Monitoring System's Software Requirements Specification in the background section, is the sentence "Those sections of the above references that require modification from the generic PAMS are defined in the document" Responder: WEC The generic Software Requirements Specification applies except as modified b y the WBN Unit 2 S y stem Requirements Specification.
TVA Response to Follow-up NRC Request:
Please see the response to RAI item 12 in letter dated 12/22/10, NRC Matrix Item 144.
TVA Response to Second Follow-up NRC Request:
This item was addressed by updating the Contract
- 15. Y Open Pending Submittal of Revision 3 of the Licensing Technical Report due 3/29/11.
Revised response included in
letter dated 12/22/10.
Response provided in letter
dated 10/21/10 Open-NRC Review Due 3/29/11
NNC 11/18/10: The point behind this open item was that TVA must
demonstrate that the
origin of each requirement in the WEC requirements specification is known
and documented. TVA stated that this EICB RAI ML102980066 Item No. 9 TVA Letter dated 10/21/10 Enclosure 1 Item
No. 4 Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments referring purely to the changes from WNA-DS-01617-WBT "Post Accident Monitoring System-System Requirements Specification" or is it saying that there are additional changes beyond those and that the SRS defines them?
If there are additional changes, what is their origin?
Compliance Matrix and adding Section 13, Origin Tracing of WBN2 PAMS System Requirements Specification to the Licensing Technical Report Revision 3 to address this concern. Attachment 2 contains WNA-LI-00058-WBT-P, "Post-Accident Monitoring System (PAMS) Licensing Technical Report," Revision 3, dated March 2011 (proprietary).
information would be in CQ PAMS LTR Rev. 2.
NNC 2/3/11:
& 12 do not prove this information. TVA to proive a plan to
address requested
information.
184 (C 7/15/2010 Res p onder: WEC 175. Y Closed Closed N/A - Closed to N/A 185 EICB (Carte) 7/15/2010
An emphasis is placed on the traceability of requirements in Software Requirements Specifications in the SRP, in the unmodified IEEE std 830-1993, and even more so given the modifications to the standard listed in Regulatory Guide 1.172, which breaks with typical NRC use of the word "should" to say
"Each identifiable requirement in an SRS must be traceable backwards to the system requirements and the design bases or regulatory requirements that is satisfies" Also the NRC considers that the SRS is the complete set of requirements used for the
desi gn of the software, whether it is contained within one document or many. In order to evaluate an SRS against the guidance in the SRP the staff needs access to all the requirements.
References 12, 27, 29, and 31-44 in the Post Accident Monitoring
S ystem's Software Requirements Specification are various t ypes of "-Reusable Software Element-".
These references are used in the body of the SRS, for example:"
R5.3.14-2 [The Addressable Constants CRC error signal shall be TRUE when any CAL CRC's respective ERROR terminal = TRUE (WNA-DS-00315-GEN, "Reusable Software Element Document CRC for Calibration Data" [Reference 12]).]
They are also included via tables such as found in requirement R7.1.2-1
[The Watts Bar 2 PAMS shall use the application-specific type circuits and custom PC elements listed in Table 7.1-1.]
Do the referenced reusable software element documents include requirements not explicitly stated in the SRS? If so what is their origin? Responder: WEC
Steve Clark to look at how to combine traceability items.
Was addressed to during the 9/15 meeting and 9/20 - 9/21 audit.
TVA Response to Follow-up NRC Request:
(1) See NRC Matrix Item 144 (2) There is no RTM for development of the individual reusable software elements. As listed in item 15 of Table 6-1 "Document Requirements" of WNA-LI-00058-WT-P, Revision 2, "Post-Accident Monitoring System (PAMS) Licensing Technical Report" submitted in TVA Letter to NRC, dated December 3, 2010, a RTM for implementation of the RSEDs (WNA-VR-00280-WBT) for the WBN Unit 2 Common Q PAMS has been developed. This document is available for NRC audit at the Westinghouse Rockville office.
- 16. N Open Response included in letter
dated 12/22/10.
Open-NRC Review
NNC 11/18/10
- (1)The point behind this open item was that TVA must demonstrate that the
origin of each
requirement in the WEC requirements specification is known
and documented. TVA
stated that this information would be in CQ PAMS LTR Rev. 2.
(2) TVA also said it would provide a RTM
for the RSED NNC 2/3/11: To be addressed during next
audit. EICB RAI ML102980066 Item
No. 17 186 7.7.8 7.7.1.12 (D a 7/15/2010 Res p onder: Perkins/Clark 176. Y Closed Closed EICB RAI No.6 TVA Letter dated 187 (C B y letter dated June 18
, 2010 , TVA docketed res p onses to NRC Res ponder: Merten 177. N Closed Closed ML101970033
, Item TVA Letter dated A re these connections alread y 188 (C B y letter dated June 30
, 2010 , TVA docketed
, "Tennessee Valle y Res p onder: Clark 178. Y Closed Closed ML101970033
, Item TVA Letter dated 189 7.6.7 (S i 7/20/2010 Res p onder: Clark 179. Y Closed Closed RAI No. 3 TVA Letter dated 190 7.9 (S i FSAR Table 7.1-1 states: "Re g ulator y Guide 1.133
, Ma y 1981 Res p onder: Clark 180. Y Closed Closed RAI No. 4 TVA Letter dated Closed to OI-331.
191 7.9 (CNUREG-0800 Cha p ter 7 , Section 7.9
, "Data Communication Res p onder: Jimmie Perkins 181. Y Closed Closed ML10197016
, Item TVA Letter dated 192 7.5.1.7.5.2 (M a The NRC Staff is usin g SRP (NUREG-0800
) Cha p ter 7 Section Res p onder: Clark 182. Y Closed Closed Item No. 1 sent to TVA Letter dated EICB RAI ML1028618855 sent to 193 7.5.1.7.5.2 (M aThe WBU2 FSAR
, Section 7.5.2
, "Plant Com p uter S y stem ," Res p onder: Clark 183. Y Closed Closed Item No. 2 sent to TVA Letter dated EICB RAI ML1028618855 sent to Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments 194 7.5.1.7.5.2.1 (M aThe WBU2 FSAR Section 7.5.2.1
, "Safet y Parameter Dis p la y Res p onder: Costle y/Norman 184. Y Closed Closed Item No. 3 sent to TVA Letter dated EICB RAI ML1028618855 sent to 195 7.5.1.7.5.2.2 (M a B ypassed and Ino p erable Status Indication (BISI) Res p onder: Costle y/Norman 185. Y Closed Closed Item No. 4 sent to TVA Letter dated EICB RAI ML1028618855 sent to 196 7.5.1.7.5.2.2 (M a B ypassed and Ino p erable Status Indication (BISI) Res p onder: Costle y/Norman 186. Y Closed Closed Item No. 5 sent to TVA Letter dated EICB RAI ML1028618855 sent to 197 X O pen Item 197 was never issued.
187. Y Closed Closed 198 7.5.1.7.5.2.2 (M a SRP Section 7.5
, Subsection III
, "Review Procedures" states:
Res p onder: Costle y/Norman 188. Y Closed Closed Item No. 6 sent to TVA Letter dated EICB RAI ML1028618855 sent to 199 7.5.1.7.5.2.3 (M aThe WBU2 FSAR Section 7.5.2.3
, "Technical Su pport Center and Res p onder: Costle y/Norman 189. Y Closed Closed Item No. 7 sent to TVA Letter dated Related SE Section 7.5.5.3 EICB RAI 200 7.2 7/21/2010 Res p onder: Clark 190. Y Closed Closed EICB RAI TVA Letter dated 201 7.7.1.7.7.11 (C 7/21/2010 Res p onder: Webb 191. Y Closed Closed EICB RAI TVA Letter dated 202 7.5.2 EICB (Carte) 7/22/2010 The letter (ML0003740165) which transmitted the Safety Evaluation for the Common Q topical report to Westinghouse stated: "Should our criteria or regulations change so that our conclusions as to the acceptability of the report are invalidated, CE Nuclear Power and/or the applicant referencing the topical report will be expected to revise and resubmit their respective documentation, or submit justification for continued applicability of the topical report without revision of the respective documentation." Question No 81 identified many criteria changes; please revise the respective documentation or submit justification for continued applicability of the topical report.
Responder: WEC Revision 1 of the Licensing Technical Report will provide more detailed information on the changes to the platform.
Rev. 2 of the Licensing Technical Report will include the applicability of guidance.
TVA Response to Follow-up NRC Request:
WNA-LI-00058-WBT-P, Revision 2, "Post-Accident Monitoring System (PAMS) Licensing Technical Report" (LTR) submitted in TVA Letter to NRC dated December 3, 2010, contains the following change to address the NRC request:
Section 9, "Compliance Evaluation of the Watts Bar 2 PAMS Software Requirements Specification to IEEE Standard 830-1998 and Regulatory Guide 1.172" to show the origin of the
requirements has been added.
The descriptions and commitments in the Topical Report (TR) still apply. The LTR provides compliance evidence to the new ISG-04 criteria. The statement in the SE means that the TR can be evaluated against later NRC criteria when it appears.
Source: E-mail from Westinghouse (Matthew A. Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010
Partial TVA Response to Follow-up NRC Request:
Attachment 4 contains the results of the TVA analysis of standards and regulatory guides applicable to the Common Q PAMS. Based on the results of the analysis, the Common Q PAMS design is acceptable.
The final response is pending submittal of the Licensing Technical Report Revision 3 scheduled for March 29, 2011.
TVA Response to Follow-up NRC Request:
(1) As discussed on page 9-1 of the Licensing Technical Report (Attachment 2) a comparison of IEEE 830-1993
and IEEE 830-1998 was performed and it was determined that the 1998 version enveloped all the
- 17. N Open Pending Submittal of Revision 3 of the Licensing Technical Report due 3/29/11.
Response included in letter
dated 12/22/10
Partial Response provided in letter dated 10/5/10
NNC 1/5/11:
Summary provided in Licensing Technical Report R2 has been reviewed and found to be unacceptable.
LTR Section 9 evaluates the compliance of the SRS to IEEE
830-1998. There are two issues with this evaluation: (1) IEEE 830-1998 is not the current SRP acceptance criteria.
IEEE 830-1998 has not been
formally endorsed by a regulatory guide.
(2) Westinghouse committed to evaluate the SRS against 830 when the NRC identified several inconsistencies.
Yes ISG-4 is one new criteria, and an evaluation against it has been provided.
In addition, LTR Rev. 2 Section
13 states: "The applicable NRC
regulatory guides, IEEE and EPRI industry standards fo the common Q PAMS are shown
below. Compliance to these codes and standards are stated in Section 4 of Reference 1."
Reference 1 is the common Q
topical report.
Open-NRC Review Due 2/25/11 &
3/29/11 to provide information requested.
Due TBD EICB RAI ML102980066 Item No. 4 TVA Letter dated 10/5/10 NNC 1/5/11:
See Also Open Item No.
81 and 86.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments requirements of the 1993 version which is endorsed by Regulatory Guide 1.172. Therefore the use of IEEE 830-1998 is acceptable.
(2) Table 9.1 "IEEE Std 830-1998 Compliance" of the Licensing Technical Report (Attachment 2) evaluates the Software Requirements Specification against the requirements of IEEE 830-1998.
(3) See TVA to NRC letter "Watts Bar Nuclear Plant (WBN)
Unit 2 - Instrumentation And Controls Staff Information Requests," dated February 25, 2011 Attachment 4 "Common Q PAMS Regulatory Guide and IEEE Standard Analysis
." (4) This section of the Licensing Technical Report (Attachment 2) has been relocated to section 15. The
comment has been addressed by adding Reference 40 to TVA to NRC letter dated February 25, 2011, Attachment 4 which is the "
Common Q PAMS Regulatory Guide and IEEE Standard Analysis." 203 7.5.1.7.5.2 (M a 7/26/2010 Res p onder: Clark 192. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 204 7.5.1.7.5.2 (M a 7/26/2010 Res p onder: Costle y/Norman 193. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 205 (G 7/26/2010 Res p onder: Clark 194. Y Closed Closed EICB RAI TVA Letter dated Question B related to prior NRC 206 7.5.1.7.5.2 (M a 7/27/2010 Res p onder: Clark 195. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 207 (C Jul y 27 , 2010 Date: 196. Y Closed Closed 208 7.5.2.7.5.1 (M a 7/27/2010 Res p onder: Clark 197. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 209 7.5.2.7.5.1 (M a 7/27/2010 Res p onder: Clark 198. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 210 7.5.2.7.5.1 (M a 7/27/2010 Res p onder: Clark 199. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 211 7.5.1. (C 7/27/2010 Res p onder: Clark 200. Y Closed Closed EICB RAI TVA Letter dated Relates to SE Sections:
212 7.5.2 EICB (Carte) 7/27/2010
By letter dated June 18, 2010 (ML101940236) TVA stated (Enclosure 1, Attachment 3, Item No. 3) that the PAMS system design specification and software requirements specification contain information to address the "Design Report on Computer
Integrity, Test and Calibration..." The staff has reviewed these documents, and it is not clear how this is the case.
(1) Please describe how the information provided demonstrates compliance with IEEE 603-1991 Clauses 5.5, 5.7, 5.10, & 6.5.
(2) Please describe how the information provided demonstrates conformance with IEEE 7-4.3.2-2003 Clauses 5.5 & 57.
Responder: WEC
Application specific requirements for testing. This cannot be addressed in a topical report. Evaluation of how the hardware meets the regulatory requirements.
WEC to provide the information and determine where the information will be located.
IEEE-603 1991:
5.5 System Integrity. The safety systems shall be designed to accomplish their safety functions under the full range of applicable conditions enumerated in the design basis.
TVA Response: The applicable conditions and Common Q PAMS s ystem compliance are contained in WNA-LI-00058-WBT-P, Rev. 2, "Post-Accident Monitoring System (PAMS) Licensing Technical Report" submitted in TVA Letter to NRC dated December 3, 2010, Section 11, "Contract Compliance
Matrix" items: 87 and 88 Seismic 89, 90, 91, 92 and 185 EMI/RFI
- 18. N Open Partial Response included in
letter dated 03/16/11 Final response due 3/29/11 Open-NRC Review
NNC 2/17/2011:
IEEE 603 Clause 5.5 basically states that conditions identified in
IEEE 603 Clauses 4.7
& 4.8 must be addressed in the design. Energy supply conditions have not been identified, or
explicitly addressed.
EICB RAI ML102980066 Item
No. 10 Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments 300, 301 and 302 Environmental Seismic qualification of the equipment to meet the design basis requirements 5.7 Capability for Test and Calibration. Capability for testing and calibration of safety system equipment shall be provided while retaining the capability of the safety systems to accomplish their safety functions.
The capability for testing and calibration of safety system equipment shall be provided during power operation and shall duplicate, as closel y as practicable, performance of the safety function. Testing of Class 1E systems shall be in accordance with the requirements of IEEE Std 338-1987. Exceptions to testing and calibration during power operation are allowed where this capability cannot be provided without adversely affecting the safety or operability of the generating station. In this case:
(1) appropriate justification shall be provided (for example, demonstration that no practical design exists), (2) acceptable reliability of equipment operation shall be otherwise demonstrated, and (3) the capability shall be provided while the generating station is shut down.
TVA Response: The requirements for test and calibration and Common Q PAMS system compliance, are contained in WNA-LI-00058-WBT-P, Rev. 2, "Post-Accident Monitoring System (PAMS) Licensing Technical Report" Section 11, "TVA Contract
Compliance Matrix" items: 202 self test 350 Maintenance Bypass 351 Loop Tuning Parameters, 400 and 401 3.7.2 Testing, Calibration, and Verification 402, 403 and 404, 3.7.3 Channel Bypass or Removal from Operation 5.10 Repair. The safety systems shall be designed to facilitate timely recognition, location, replacement, repair, and adjustment of malfunctioning equipment.
TVA Response: The requirements for repair and Common Q PAMS s ystem compliance are contained in WNA-LI-00058-WBT-P, Rev. 2, "Post-Accident Monitoring System (PAMS) Licensing Technical Report" Section 11, "TVA Contract Compliance Matrix" items: 179 Mean time to repair 202 self test 398 3.7 Maintenance 399 3.7.1 Troubleshooting 6.5 Capability for Testing and Calibration NNC 2/18/11: Clause 5.7 is acceptably
addressed.
NNC 2/18/2011:
WNA-AR-00189-WBT Rev. 0 Table 5-2 shows a
MTTR of 7.2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br />. It is not clear how this satisfies the contractual item No.
179.
The Contract Compliance Matrix Item 179 in Revision 3 of the LTR has been revised to show this item as a deviaition and to reflect TVA's acceptance of
the 7.2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> MTTR value. Attachment 2 contains WNA-LI-00058-WBT-P, "Post-Accident Monitoring System (PAMS) Licensing Technical Report," Revision 3, dated March 2011 Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments 6.5.1 Means shall be provided for checking, with a high degree of confidence, the operational availability of each sense and command feature input sensor required for a safety function during reactor operation.
This may be accomplished in various ways; for example: (1) by perturbing the monitored variable, (2) within the constraints of 6.6, by introducing and varying, as appropriate, a substitute input to the sensor of the same nature as the measured variable, or (3) by cross-checking between channels that bear a known relationship to each other and that have readouts available.
6.5.2 One of the following means shall be provided for assuring the operational availability of each sense and command feature required during the post-accident period: (1) Checkin g the operational availabilit y of sensors b y use of the methods described in 6.5.1.
(2) Specifying equipment that is stable and retains its calibration during the post-accident time period.
TVA Response: The requirements for sense and command feature testing and Common Q PAMS system compliance are contained in WNA-LI-00058-WBT-P, Revision 2, "Post-Accident Monitoring System (PAMS) Licensing Technical Report" Section 11 "TVA
Contract Compliance Matrix" items: 10, display of sensor diagnostic information 202 self test 205 self diagnostics and watchdog timer 264 through 271, system self checks 311 system status displays, 341 alarms, 344 on-line diagnostics IEEE 7-4.3.2-2003 5.5 System integrity In addition to the system integrity criteria provided by IEEE Std 603-1998, the following are necessary to achieve system integrity in digital equipment for use in safety systems:
- Design for computer integrity
- Design for test and calibration
- Fault detection and self-diagnostics 5.5.1 Design for computer integrity The computer shall be designed to perform its safety function when subjected to conditions, external or internal, that have significant potential for defeating the safety function. For example, input and output
processing failures, precis ion or round off problems, improper recovery actions, electrical input voltage and frequency fluctuations, and maximum credible number of coincident signal changes.
(proprietary).
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments If the system requirements identify a safety system preferred failure mode, failures of the computer shall not preclude the safety system from being placed in that mode. Performance of computer system restart operations shall not result in the safety system being
inhibited from performing its function.
TVA Response: Common Q PAMS system reliability and failure modes are described in: WNA-AR-00180-WBT, Revision 0, "Failure Modes and Effects Anal y sis (FMEA) for the Post Accident Monitoring System" WNA-AR-00189-WBT, Revision 0 "Post Accident Monitoring System Reliability Analysis" The requirements for mean time between failure and Common Q PAMS s ystem compliance are contained in WNA-LI-00058-WBT-P, Revision 2, "Post-Accident Monitoring System (PAMS) Licensing Technical Report," Section 11 "TVA Contract Compliance Matrix" item 178.
5.5.2 Design for test and calibration Test and calibration functions shall not adversely affect the ability of the computer to perform its safety function. Appropriate bypass of one redundant channel is not considered an adverse effect in this context. It shall be verified that the test and calibration functions do not affect computer functions that are not included in a calibration change (e.g., setpoint
change). V&V, configuration management, and QA shall be required for test and calibration functions on separate computers (e.g., test and calibration computer) that provide the sole verification of test and calibration data. V&V, configuration management, and QA shall be required when the test and calibration function is
inherent to the computer that is part of the safety system. V&V, configuration management, and QA are not required when the test and calibration function is resident on a separate computer and does not provide the sole verification of test and calibration data for the computer that is part of the safety system.
TVA Response: The requirements for test and calibration and Common Q PAMS system compliance are contained in WNA-LI-00058-WBT-P, Revision 2, "Post-Accident Monitoring System (PAMS) Licensing
Technical Report" Section 11 "TVA Contract Compliance Matrix" items: 202 self test 350 Maintenance Bypass 351 Loop Tuning Parameters, 400 and 401 3.7.2 Testing, Calibration, and Verification Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments 402, 403 and 404, 3.7.3 Channel Bypass or Removal from Operation 5.5.3 Fault detection and self-diagnostics Computer systems can experience partial failures that can degrade the capabilities of the computer system, but may not be immediately detectable by the system.
Self-diagnostics are one means that can be used to assist in detecting these failures. Fault detection and self-diagnostics requirements are addressed in this sub-clause.
The reliability requirements of the safety system shall be used to establish the need for self-diagnostics. Self diagnostics are not required for systems in which failures can be detected by alternate means in a timely manner. If self-diagnostics are incorporated into the system requirements, these functions shall be subject to the same V&V processes as the safety system functions.
If reliability requirements warrant self-diagnostics, then computer programs shall incorporate functions to detect and report computer system faults and failures in a timely manner. Conversely, self-diagnostic functions shall not adversely affect the ability of the computer system to perform its safety function, or cause spurious actuations of the safety function. A typical set of self-diagnostic functions includes the following:
- Memory functionality and integrity tests (e.g., PROM checksum and RAM tests)
- Computer system instruction set (e.g., calculation tests) - Computer peripheral hardware tests (e.g., watchdog timers and keyboards)
- Computer architecture support hardware (e.g., address lines and shared memory interfaces)
- Communication link diagnostics (e.g., CRC checks) Infrequent communication link failures that do not result in a system failure or a lack of system functionality do not require reporting.
When self-diagnostics are applied, the following self-diagnostic features shall be incorporated into the system design:
a) Self-diagnostics during computer system startup b) Periodic self-diagnostics while the computer system is operating c) Self-diagnostic test failure reporting TVA Response: The requirements for fault detection and self diagnostics and Common Q PAMS system compliance are contained in WNA-LI-00058-WBT-P, Rev. 2, "Post-Accident Monitoring System (PAMS)
Licensing Technical Report" Section 11 "TVA Contract Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Compliance Matrix" items: 107 error free download 202 self test 205 self diagnostics and watchdog timer 263 primary and backup communication 264 through 271, continuous on-line self checks 311 system status displays, 341 alarms, 344 on-line diagnostics 5.7 Capability for test and calibration No requirements beyond IEEE Std 603-1998 are necessary.
TVA Response: No response required.
Concurrence: E-mail from Westinghouse (Andrew P. Drake) to Bechtel (Mark S. Clark), RE: RAI 212 Response - Errors in the Contract Compliance Matrix, dated December 17, 2010
(a) Energy Supply conditions are specified in WNA-DS-01617-WBT-P, S ystem Requirements Specification Rev.
4, Requirement 4.1-1 which requires 120Vac +/-10% and 60+/-3Hz. Power to the Common Q PAMS is provided from the 120Vac vital power system. Per WBN Unit 2 FSAR section 8.3.1.1 the vital 120 volt ac system specifications are 120Vac +/-2% and 60+/-0.5Hz. Based on this, the power provided meets the system
requirements.
Electromagnetic compatibility, seismic and environmental qualification of the equipment to meet the
design basis requirements is documented in EQ-QR WBT-P, Revision 0 "Qualification Summary Report for Post-Accident Monitoring System (PAMS)" (Proprietary) (Attachment 4). Attachment 5 contains EQ-QR WBT-NP, Revision 0 "Qualification Summary Report for Post-Accident Monitoring System (PAMS)" (non-proprietary). Attachment 6 contains CWA-11-3118, Application for Withholding Proprietary Information from Public Disclosure, EQ-QR-68-WBT-P, Revision 0 "Qualification Summary Report for Post-Accident Monitoring System (PAMS)," (Proprietary), dated February 28, 2011.
(b) The Contract Compliance Matrix Item 179 in Revision 3 of the Licensing Technical Report will be revised to show this item as a deviation and to reflect TVA's acceptance of the 7.2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> MTTR value. WNA-LI-00058-WBT-P, "Post-Accident Monitoring System (PAMS) Licensing Technical Report," Revision 3, (proprietary) dated March 2011, will be submitted no later than March 29, 2011.
213 7.5.2 EICB (Carte) 7/27/2010 By letter dated June 18, 2010 (ML101940236) TVA stated (Enclosure 1, Attachment 3, Item No. 3) that the PAMS system design specification and software requirements specification Responder: WEC Conformance with IEEE 603 is documented in the revised Common Q PAMS Licensing Technical Report and the Common Q PAMS System Design Specification.
- 19. N Open Pending Submittal of Revision 3 of the Licensing Technical Report due 3/29/11.
Open-NRC Review Due 3/29/11
NNC 2/3/11: The EICB RAI ML102980066 Item No. 18 Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments contain information to address the "Theory of Operation Description." The staff has reviewed these documents, and it is not clear how this is the case. The docketed material does not appear to contain the design basis information that is required to evaluate compliance with the Clause of IEEE 603.
(1) Please provide the design basis (as described in IEEE 604 Clause 4) of the Common Q PAMS. (2) Please provide a regulatory evaluation of how the PAMs complies with the applicable regulatory requirements for the theory
of operation. For example: Regarding IEEE 603 Clause 5.8.4 (1) What are the manually controlled protective actions? (2) How do the documents identified demonstrate compliance with this clause?
Attachment 1 contains the proprietary version of Westinghouse document "Tennessee Valley Authority (TVA), Watts Bar Unit 2 (WBN2), Post-Accident Monitoring System (PAMS), Licensing Technical Report, Revision 1, WNA-LI-00058-WBT-P, Dated October 2010" Attachment 8 contains the proprietary version of Westinghouse document "Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects Post Accident Monitoring System - System Design Specification", WNA-DS-01667-WBT, Rev. 2 dated September 2010.
TVA Response to Follow-up NRC Request:
The Regulatory Guide 1.97 classification of the Common Q PAMS variables is documented in TVA Design Criteria WB-DC-30-7 "Post Accident Monitoring Instrumentation" which was submitted as Attachment 5 on TVA to NRC letter "
Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests" dated June 18, 2010 (Reference 1)
The hardware design bases for the Common Q PAMS is described in the WBN Unit 2 FSAR section 7.5.1.8 "Post Accident Monitoring System (PAMS)."
The Common Q PAMS indications are used to support operator response to events described in chapter 15 of the WBN Unit 2 FSAR such as:
RCCA/RCCA Bank dropped/misaligned Steam Generator Tube Rupture Inadvertent Loading of a Fuel Assembly Into an Improper Position Loss of Shutdown Power Major Reactor Coolant System Pipe Ruptures (Loss Of Coolant Accident) Major Secondary System Pipe Rupture Response is included in letter dated 10/25/10
NNC to review and revise this
question after LTR R2 is received.
identified documentation does not include the design bases. Please provide
schedule for providing
the requested information.
214 (C 7/27/2010 Res p onder: WEC 201. Y Closed Closed EICB RAI TVA Letter dated 215 (P 7/29/2010 Res p onder: WEC 202. Y Closed Closed 216 7.5.1.7.5.2 (M a 7/29/2010 Res p onder: Clark 203. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 217 (G 7/6/2010 Res p onder: Clark 204. Y Close Closed EICB RAI TVA Letter dated 218 (G 7/6/2010 Res p onder: Clark 205. Y Closed Closed EICB RAI TVA Letter dated 219 (G 8/4/2010 Res ponder: TVA Licensin g 206. Y Closed Closed EICB RAI 220 (G 8/4/2010 Res p onder: A y ala 207. Y Closed Closed EICB RAI TVA Letter dated 221 7.7.1.7.7.1.3 (M a 8/4/2010 Res ponder: Trelease 208. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 222 (G 8/4/2010 Res p onder: Clark 209. Y Close Closed EICB RAI TVA Letter dated 223 (G 8/4/2010 Res p onder: Clark 210. Y Closed Closed EICB RAI 224 7.5.1.7.5.2 (M a 8/4/2010 Res p onder: Norman (TVA CEG) 211. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 225 (G 8/4/2010 Res p onder: Scansen 212. Y Close Closed EICB RAI TVA Letter dated 226 (C 8/4/2010 Res ponder: TVA Licensin g 213. Y Closed Closed N/A - Information TVA Letter dated See also O p en Item Nos. 41 & 270.
227 (G 8/4/2010 Res p onder: Clark 214. Y Close Closed EICB RAI TVA Letter dated
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments 228 (C 8/4/2010 Res p onder: Clark 215. Y Closed Closed EICB RAI TVA Letter dated 229 (C 8/4/2010 Res p onder: Clark 216. Y Closed Closed EICB RAI TVA Letter dated 230 (C 8/4/2010 Res p onder: Webb 217. Y Closed Closed EICB RAI TVA Letter dated 231 (G 8/4/2010 Res p onder: Clark 218. Y Closed Closed EICB RAI TVA Letter dated 232 (S i 8/4/2010 Res p onder: Clark 219. Y Closed Closed RAI No. 5 TVA Letter dated 233 (C 8/4/2010 Res p onder: Clark 220. Y Closed Closed EICB RAI TVA Letter dated 234 (C 8/4/2010 Res p onder: 221. Y Closed Closed N/A - Du p licate N/A 235 (G 8/4/2010 Res ponder: TVA Licensin g 222. Y Closed Closed N/A N/A 236 (G 8/4/2010 Res p onder: Clark 223. Y Close Closed EICB RAI TVA Letter dated 237 (C 8/4/2010 Res p onder: Clark 224. Y Closed Closed EICB RAI TVA Letter dated 238 (C 8/4/2010 Res p onder: Webb/Hilmes 225. Y Closed Closed N/A - Du p licate N/A 239 (C 8/4/2010 Res p onder: Hilmes 226. Y Closed Closed N/A - Meetin g N/A 240 (G 8/4/2010 Res p onder: Clark 227. Y Close Closed Ml102910008 TVA Letter dated 241 (S i 8/4/2010 Res p onder: Davies 228. Y Closed Closed RAI No. 10 TVA Letter dated 242 (G 8/4/2010 Res p onder: Hilmes 229. Y Close Closed EICB RAI TVA Letter dated 243 (C 8/3/2010 Res p onder: WEC 230. Y Closed Closed N/A - Closed to N/A 244 EICB (Carte) 8/3/2010 Section 8.2.2 of the Common Q SPM (ML050350234) states that the Software Requirements Specification (SRS) shall be developed using IEEE 830 and RE 1.172. Clause 4.8, "Embedding project requirements in the SRS," of the IEEE 830 states that an SRS should address the software product, not the process of producing the software. In addition Section 4.3.2.1 of the SPM states "Any alternatives to the SPM processe s or additional project specific information for the ...SCMP...shall be specified in the PQP.
Contrary to these two statements in the SPM, the WBN2 PAMS SRS (ML101050202) contains many process related requirements, for example all seventeen requirements in Section 2.3.2, "Configuration Control," address process requirements for configuration control.
Please explain how the above meets the intent of the approved
SPM. Responder: WEC
The process related requirements have been removed from revision 2 of the Software Requirements Specification (SRS).
Attachment 3 of letter dated 10/25/10 contains the proprietary version of Westinghouse document "Nuclear
Automation, Watts Bar 2 NSSS Completion Program, I&C Projects, Software Requirements Specification for the Post Accident Monitoring System", WNA-SD-00239-WBT, Revision 2, Dated September 2010.
TVA Response to Follow-up NRC Request:
As shown is the listed documents, process related requirements have been deleted from the SRS and S y sRS in Revision 3:
contains proprietary version of WNA-DS-01617-WBT-P, Revision 3, "Post Accident Monitoring System-System Requirements Specification," dated December 2010.
contains the proprietary version of WNA-SD-00239-WBT-P, Revision 3, "Software Requirements Specification for the Post Accident Monitoring System,"
dated December 2010.
Source: E-mail from Westinghous e (Andrew P. Drake) to Bechtel (Mark S. Clark), RE: Common Q RAI concerns, dated December 8, 2010 (Reference 17)
TVA Response to Follow-up NRC Request:
The documents discussed in Item 3 have been revised to address compliance with the Topical Report (TR) and the
- 20. N Open Revised response is included in letter dated 12/22/10
Response is provided in letter
dated 10/25/10.
NNC 11/18/10: SysRS Rev. 2 also contains process
requirements that are more
appropriately incorporated into process documentation.
Open-NRC Review
Due 2/25/11 Document revisions NNC 2/2/11:
Issues with Common Q TR &
SPM compliance were discussed in the weekl y public meetings.
Westinghouse to perform Common Q TR & SPM compliance self assessment; this will be discussed in detail on the next audit.
EICB RAI ML102980066 Item
No. 14 Response is provided in letter
dated 10/25/10. LIC-101 Rev. 3 Appendix B Section 4, "Safety Evaluation" states: "the
information relied upon in the SE must be docketed correspondence."
LIC-101 Rev. 3 states: "The safety analysis that supports the change requested should include technical information in sufficient detail to enable the NRC staff to make an independent assessment regarding the acceptability
of the proposal in terms of regulatory requirements and the protection of public health and safety."
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Software Program Manual (SPM).
245 EICB (Carte) 8/3/2010 Section 5.8 of the Common Q SPM (ML050350234) identifies the required test documentation for systems developed using the Common Q SPM. Please provide sufficient information for the
NRC staff to independently assess whether the test plan for WBN2 PAMS, is as described in the SPM (e.g., Section 5.8.1).
Responder: WEC Relates to the commitment to provide the test plan and the SPM compliance matrix
Attachment 9 contains the Westinghouse document "Post Accident Monitoring System Test Plan," WNA-PT-00138-WBT, Revision 0, dated November 2010. Attachment 10 contains the Westinghouse Application for Withholding for the "Post Accident Monitoring System Test Plan," WNA-PT-00138-WBT, Revision 0, dated November 2010.
TVA Response to Follow-up NRC Request:
The results of the self assessment were reviewed by Westinghouse with the NRC on February 2, 2011 and were further reviewed by TVA during the NRC Common Q PAMS
audit during the week of February 28 to March 4, 2011. Corrections to WNA-TR-02451-WBT, "Test Summary Report for the Post Accident Monitoring System
" and the self assessment were made as a result of the TVA review to ensure this comment was fully addressed.
By agreement between TVA, WEC and the NRC, the Post Accident Monitoring System Test Plan, WNA-PT-00138-WBT, Revision 0 will not be revised.
Instead a non-proprietary Common Q PAMS Test Summary Report will be developed and submitted to address the issues with TR and
SPM compliance. contains non-proprietary WNA-TR-02451-WBT, Revision 0, "Test Summar y Report for the Post Accident Monitoring System," dated March 2011.
- 21. N Open Pending Submittal of the Test Summary Report due 3/29/11
Response included in letter dated 12/3/10
Common Q PAMS Test
Summary Report scheduled to be submitted March 29, 2011.
Open-NRC Review Due 3/29/11
NNC 2/2/11:
Issues with the Common Q TR
& SPM were discussed in the weekly public
meetings.
Westinghouse to perform Common Q TR & SPM compliance self assessment EICB RAI ML102980066 Item No. 119 LIC-101 Rev. 3 Appendix B Section 4, "Safety Evaluation" states: "the information relied upon in the SE must be docketed correspondence."
LIC-101 Rev. 3 states: "The safety analysis that supports the change requested should include technical information in sufficient detail to enable the NRC staff to make an independent assessment regarding the acceptability of the proposal in terms of regulatory
requirements and the protection of public health and safety." 246 EICB (Carte) 8/3/2010 Section 4.3.2.1, "Initiation Phase" of the Common Q SPM (ML050350234) requires that a Project Quality Plan (PQP) be developed. Many other section of the SPM identify that this PQP should contain information required by ISG6. Please provide the PQP. If "PQP" is not the name of the documentation produced, please describe the documentation produced and provide the information that the SPM states should be in the PQP.
Responder: WEC
As agreed ISG6 does not apply to the Common Q PAMS
platform. The information required to address this question concerning the PQP and SPM has been added to compliance matrix in revision 1 of the Licensing Technical Report.
Attachment 1 of letter dated 10/25/10 contains the proprietary version of Westinghouse document "Tennessee Valley Authority (TVA), Watts Bar Unit 2 (WBN2), Post-Accident Monitoring System (PAMS), Licensing Technical Report, Revision 1, WNA-LI-00058-WBT-P, Dated October 2010"
TVA Response to Follow-up NRC Request:
The results of the Common Q TR and SPM self assessment were reviewed by Westinghouse with the NRC on February
2, 2011.
The Westinghouse Watts Bar Unit 2 NSSS Completion I&C Projects Project Quality Plan, WNA-PQ-00220-WBT, Revision 1 is available for NRC audit at the Westinghouse Rockville Office and was available for review during the NRC Common Q PAMS audit during the week of February 28 to
- 22. N Open Pending Submittal of Revision 3 of the Licensing Technical Report due 3/29/11. PQP provided for audit the week of
2/28/11.
Response is provided in letter dated 10/25/10
NNC 11/18/10: PQP has not been provided and CQ PAMS LTR Rev. 1 does not contain
comparable information.
Open-NRC Review
Due 3/29/11
NNC 2/2/11:
Issues with the Common Q TR
& SPM implementation
were discussed in the weekl y public meetin g s. Westinghouse to perform Common Q TR
& SPM compliance self assessment EICB RAI ML102980066 Item
No. 15 Response is provided in letter
dated 10/25/10 LIC-101 Rev. 3 Appendix B Section 4, "Safety Evaluation" states: "the
information relied upon in the SE must
be docketed correspondence." LIC-101 Rev. 3 states: "The safety analysis that supports the change requested should include technical information in sufficient detail to enable the NRC staff to make an independent assessment regarding the acceptability
of the proposal in terms of regulatory requirements and the protection of public health and safety."
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments March 4, 2011. During the audit, the Westinghouse Quality Assurance in process audit of the Common Q PAMS project was reviewed by the NRC inspector with no issues identified.
247 (C 8/8/2010 Res p onder: WEC 231. Y Closed Closed EICB RAI Res p onse is LIC-101 Rev. 3 A ppendix B Section 4
, 248 (C 8/8/2010 Res p onder: WEC 232. Y Closed Closed Res p onse is LIC-101 Rev. 3 A ppendix B Section 4
, 249 (C 8/8/2010 Res p onder: WEC 233. Y Closed Closed LIC-101 Rev. 3 A ppendix B Section 4
, 250 EICB (Carte) 8/8/2010 The SPM describes the software and documents that will be created and placed under configuration control. The SCMP (e.g.,
SPM Section 6, "Software Configuration Management Plan")
describes the implementation tasks that are to be carried out. The acceptance criterion for software CM implementation is that the tasks in the SCMP have been carried out in their entirety.
Documentation should exist that shows that the configuration management tasks for that activity group have been successfully accomplished. Please provide information that shows that the CM tasks have been successfully accomplished for each life cycle activity group.
Responder: WEC Westinghouse develops Software Release Reports/Records and a Configuration Management Release Report. Describe the documents and when they will be produced. Summarize guidance on how to produce these records, focus on project specific requirements in SPM etc.
TVA Response to Follow-up NRC Request:
The following documentation shows that the configuration management tasks for that activity group have been successfully accomplished.
- 1. WNA-LI-00058-WT-P, Revision 2, "Post-Accident Monitorin g S ystem (PAMS) Licensin g Technical Report" submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1) contains the following changes to address the NRC requests:
- a. Section 2.2.1 Hardware/Software Change Process has been added to describe the process of how changes are evaluated.
- b. Section 2.2.2, "Software" has been expanded to include a table detailing evolutionary software changes that have occurred since the initial submittal and the change evaluation of the life cycle. 2. WNA-PT-00138-WBT, Revision 0, "Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Post Accident Monitoring System Test Plan,"
(Proprietary), dated November 2010 submitted in TVA Letter to NRC, dated December 3, 2010 (Reference 1).
- 23. N Open Revised response included in letter dated 12/22/10
Response included in letter dated 10/25/10.
Open-NRC Review NNC 2/2/11: To be addressed during the next audit. LIC-101 Rev. 3 Appendix B Section 4, "Safety Evaluation" states: "the information relied upon in the SE must be docketed correspondence."
LIC-101 Rev. 3 states: "The safety analysis that supports the change requested should include technical information in sufficient detail to enable the NRC staff to make an independent assessment regarding the acceptability of the proposal in terms of regulatory
requirements and the protection of public health and safety." 251 EICB (Carte) 8/8/2010 The SPM describes the software testin g and documents that will be created. The SPM also describes the testing tasks that are to be carried out. The acceptance criterion for software test implementation is that the tasks in the SPM have been carried out in their entirety. Please provide information that shows that testing been successfully accomplished.
Responder: WEC
The software testing performed and documents created are addressed by the SPM Compliance matrix contained in Revision 1 of the Licensing Technical Report.
Attachment 1 of the letter dated 10/25/10 contains the Proprietary version of Westinghouse's document titled:
"Tennessee Valley Authority (TVA), Watts Bar Unit 2 (WBN2), Post-Accident Monitoring System (PAMS),
Licensing Technical Report, Revision 1, WNA-LI-00058-WBT-P, Dated October 2010"
TVA Response to Follow-up NRC Request:
Please see the response to RAI item 21 in letter dated
- 24. N Open Pending Submittal of the Test
Summary Report due 3/29/11 Revised response included in
letter dated 12/22/10
Partial response is provided in letter dated 10/25/10 Open-NRC Review
Due 3/29/11
NNC 2/2/11:
Issues with the Common Q TR
& SPM were discussed in the weekly public meetings. Westinghouse to perform Common Q TR
& SPM compliance self assessment LIC-101 Rev. 3 Appendix B Section 4, "Safety Evaluation" states: "the
information relied upon in the SE must
be docketed correspondence." LIC-101 Rev. 3 states: "The safety analysis that supports the change requested should include technical information in sufficient detail to enable the NRC staff to make an independent assessment regarding the acceptability
of the proposal in terms of regulatory
requirements and the protection of public health and safety."
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments 12/22/10, NRC Matrix Item 250.
TVA Response to second Follow-up NRC Request:
The results of the Common Q TR and SPM self assessment were reviewed by Westinghouse with the NRC on February 2, 2011.
By agreement between TVA, WEC and the NRC, the Post Accident Monitoring System Test Plan, WNA-PT-00138-WBT, Revision 0 will not be revised.
Instead a non-proprietary Common Q PAMS Test Summary Report will be developed and submitted to address the issues with TR and
SPM compliance. contains non-proprietary WNA-TR-02451-WBT, Revision 0, "Test Summar y Report for the Post Accident Monitoring System," dated March 2011.
252 EICB (Carte) 8/8/2010 The SPM contain requirements for software requirements traceability analysis and associated documentation (see Section 5.4.5.3, "Requirements Traceability Analysis"). Please provide information that demonstrates that requirements traceability analysis has been successfully accomplished.
Responder: WEC
Explain response to AP1000 audit report. RTM docketed NRC awaiting V&V evaluation of RTM.
The following responses are based on WBN Unit 2 Common Q PAMS traceability:
Software requirements traceability analysis is described in the following documents:
- 1. WNA-LI-00058-WBT-P, Revision 2, "Post-Accident Monitoring System (PAMS) Licensing Technical Report" submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1) Section 11, "TVA Contract Compliance Matrix"
- 2. WNA-VR-00279-WBT, "Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System" (available for NRC audit at the Westinghouse Rockville
office)
- 3. WNA-VR-00280-WBT, "Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Reactor Vessel Level Indication System (RVLIS) Custom PC Elements" (available for NRC audit at the Westinghouse Rockville office) This document addresses the RSEDs used in the WBN Unit 2 Common Q PAMS.
The V&V evaluation of the RTM is documented in section 2.2.2 of the following documents:
- 1. The Independent Verification & Validation (IV&V) report covering the Concept and Definition phases
("Nuclear Automation Watts Bar Unit 2 NSSS Completion Program I&C Projects, IV&V Summary Report for the Post Accident Monitoring System,"
(Proprietary), WNA-VR-00283-WBT, Revision 1, dated November 2010), submitted in TVA Letter to NRC dated December 3, 2010 (Reference 1).
- 25. N Open Response included in letter dated 12/22/10
Read ML091560352 Open-NRC Review
Due 2/25/11 (document submittals)
NNC 2/2/11: Updated RTMs and specifications to be provided.
Requirements traceability to be addressed during he next audit. LIC-101 Rev. 3 Appendix B Section 4, "Safety Evaluation" states: "the
information relied upon in the SE must be docketed correspondence."
LIC-101 Rev. 3 states: "The safety analysis that supports the change requested should include technical information in sufficient detail to enable the NRC staff to make an independent assessment regarding the acceptability of the proposal in terms of regulatory requirements and the protection of public health and safety."
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments
- 2. The Independent Verification &Validation (IV&V) report covering the Design and Implementation phases
("Nuclear Automation Watts Bar Unit 2 NSSS
Completion Program I&C Projects, IV&V Summary Report for the Post Accident Monitoring System," (Proprietary), WNA-VR-00283-WBT, Revision 2, dated November 2010), submitted in TVA Letter to NRC dated December 3, 2010 (Reference 1).
- 3. The integration phase is covered in Attachment 10, the proprietary version of "IV&V Summary Report for the Post Accident Monitoring System," WNA-VR-00283-
WBT-P, Revision 3, dated December 2010. 1 contains the non-proprietary version of "IV&V Summary Report for the Post Accident Monitoring System," WNA-VR-00283-WBT-NP, Revision 3, dated December 2010. Attachment 12 contains the "Application For Withholding Proprietary Information From Public Disclosure WNA-VR-00283-WBT-P, Revision 3, "IV &V Summary Report for the Post Accident Monitoring System" (Proprietary)," dated December 2010.
TVA Response to Follow-up NRC Request:
See Response to item 3 (Matrix Item Number 142) 253 (C 8/8/2010 Res p onder: Clark 234. Y Closed Closed TVA Letter dated Related to O pen Item no. 83.
254 (C 8/10/2010 Res p onder: WEC 235. Y Closed Closed N/A - Re quest to TVA Letter dated 255 (C 8/10/2010 Res p onder: WEC 236. Y Closed Closed N/A - Re quest to TVA Letter dated 256 (C 8/10/2010 Res p onder: WEC 237. Y Closed Closed N/A - Re quest to TVA Letter dated 257 (C 8/10/2010 Res p onder: WEC 238. Y Closed Closed N/A - Re quest to N/A 258 (C 8/10/2010 Res p onder: WEC 239. Y Closed Closed N/A - Re quest to N/A 259 (C 8/10/2010 Res p onder: WEC 240. Y Closed Closed N/A - Re quest to TVA Letter dated 260 (C 8/10/2010 Res p onder: WEC 241. Y Closed Closed N/A - Re quest to N/A 261 (C 8/10/2010 Res p onder: WEC 242. Y Closed Closed N/A - Closed to TVA Letter dated LIC-110 Rev. 1 Section 6.2.2 states:
262 (C 8/10/2010 Res p onder: WEC 243. Y Closed Closed N/A - Re quest to N/A 263 (C 8/11/2010 Res p onder: WEC 244. Y Closed Closed ML101650255
, Item 264 (C 8/11/2010 Res p onder: WEC 245. Y Closed Closed ML101650255
, Item 265 (C 8/11/2010 Res p onder: WEC 246. Y Closed Closed ML101650255
, Item 266 (C 8/11/2010 Res p onder: Webb/Webber 247. Y Closed Closed TVA Letter dated 267 (C 8/11/2010 Res p onder: WEC 248. Y Closed Closed 268 (C 8/19/2010 Res p onder: WEC 249. N Closed Closed 269 (P 8/20/2010 Res p onder: NRC 250. Y Closed Closed N/A N/A 270 (C 8/23/2010 Res p onder: Clark 251. Y Closed Closed See also O p en Item Nod. 41 & 245.
271 (C 8/23/2010 Res p onder: WEC 252. Y Closed Closed N/A - Closed to NA 272 7.5.2.7.5.1 (M a 8/26/2010 Res p onder: Clark 253. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 273 7.5.2.7.5.1 (M a 8/26/2010 Res p onder: Clark 254. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 274. (S i 8/26/2010 Res p onder: Stockton 255. Y Closed Closed RAI No. 6 TVA Letter dated Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments 274.7.5.2.7.5.1 (M a 8/26/2010 Res p onder: Clark 256. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 275 (S i 8/27/2010 Res p onder: Clark 257. Y Closed Closed Not Re q uired N/A 276 7.6 7.6 (G 8/27/2010 Res p onder: Webb 258. Y Closed Closed EICB RAI TVA Letter dated 277 7.6 7.6.3 (G 8/27/2010 Res p onder: Clark 259. Y Close Closed EICB RAI TVA Letter dated 278 7.6 7.6.6 (G 8/27/2010 Res ponder: Trelease 260. Y Close Closed EICB RAI TVA Letter dated 279 7.6 7.6.6 (G 8/27/2010 Res ponder: Mather 261. Y Close Closed EICB RAI TVA Letter dated 280 7.6 7.6.6 (G 8/27/2010 Res ponder: Trelease 262. Y Closed Closed EICB RAI TVA Letter dated 281 7.6 7.6.8 (G 8/27/2010 Res p onder: Webb 263. Closed Closed EICB RAI TVA Letter dated 282 7.6 7.6.9 (G 8/27/2010 Res ponder: Trelease 264. Y Close Closed EICB RAI TVA Letter dated 283 7.7.5 XX (D a 8/27/2010 Res p onder: Clark 265. Y Closed Closed EICB RAI No.13 TVA Letter dated This item is a follow-u p q uestion to item 284 7.7.3 7.4.1 (D a 8/27/2010 Res p onder: Webber 266. Y Closed Closed EICB RAI No.14 TVA Letter dated This item is a follow-u p q uestion to item 285 7.3.3 7.3 (D a 8/27/2010 Res p onder: McNeil 267. Y Closed Closed EICB RAI No.15 TVA Letter dated This item is a follow-u p q uestion to item 286 7.7.3 9.3.4.2.4 (D a 8/27/2010 Res p onder: Webber 268. Y Closed Closed EICB RAI No.16 TVA Letter dated 287 7.3 7.3-1 (D a 8/27/2010 Res p onder: Elton 269. Y Closed Closed ML102390538
, Item Res p onse 288 7.3 (G 9/2/2010 Res p onder: McNeil 270. Y Closed Closed EICB RAI 289 (S i 9/2/2010 Res ponder: Faulkner 271. Y Closed Closed RAI No. 24 TVA Letter dated 290 7.7 (C 9/7/2010 Res p onder: Clark 272. Y Closed Closed N/A N/A This item is a du plicate of item 291.
291 7.7 (C 9/7/2010 Res p onder: Clark 273. Y Closed Closed TVA Letter dated 292 7.2.5 7.2 (G 9/7/2010 Res p onder: Crai g 274. Y Closed Closed EICB RAI TVA Letter dated 293 7.7.4 7.2.2.3.5 (M a 9/8/2010 Res p onder: Crai g 275. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 294 7.3 7.3.1.1.1 (D a 9/9/2010 Res p onder: Elton 276. Y Closed Closed ML102390538
, Item Res p onse 295 7.3 7.3.1.1.2 (D a 9/9/2010 Res p onder: Elton 277. Y Closed Closed ML102390538
, Item Res p onse 296 7.3 7.3.1.2.1 (D a 9/9/2010 Res p onder: Elton 278. Y Closed Closed ML102390538
, Item Res p onse 297 7.3 7.3.1.2.2 (D a 9/9/2010 Res p onder: Elton 279. Y Closed Closed ML102390538
, Item Res p onse 298 7.3 XX (D a 9/9/2010 Res p onder: Clark 280.Y Closed Closed ML102390538
, Item Res p onse 299 (CProvide Common Q Software Re q uirements S pecification Post A ttachment 41 of the 10/5 letter contains the Common Q 281. Y Closed Closed TVA Letter dated 300 (S i Need Radiation Monitorin g S ystem Descri p tion/Desi g n Criteria Res p onder: Tem p les/Mather 282. Y Closed Closed RAI No. 25 TVA Letter 301 (S i 1.TVA is re q uested to address the conse q uences of software Res ponder: WEC/Davies/Clark 283. Y Closed Closed RAI No. 11 TVA Letter dated Note 1: 302 7.5.2.7.5.1 (M a 09/17/2010 Res ponder: Tindell 284. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 303 7.5.2.7.5.1 (M a 09/17/2010 Res ponder: Tindell 285. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 304 7.5.2.7.5.1 (M a 09/17/2010 Res ponder: Tindell 286. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 305 7.5.2.7.5.1 (M a 09/17/2010 Res ponder: Tindell 287. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 306 7.1 7.1 (GFSAR amendment 100
, p a g e 7.1-12 p rovides the definition of Res p onder: Hilmes 288. Y Closed Closed EICB RAI TVA Letter dated 307 7.1 7.1 (G (1) FSAR amendment 100
, Section 7.1
, p a g e 7.1-12 , definition of Res p onder: Hilmes 289. Y Closed Closed EICB RAI TVA Letter dated 308 7.1 7.1 (G (1) FSAR Amendment 100
, Section 7.1
, p a g e 7.1-13 , definition of Res p onder: Hilmes 290. Y Closed Closed EICB RAI TVA Letter dated 309 7.1 7.1.2.1.9 (G (1) FSAR amendment 100
, Pa g e 7.1-14 , Westin g house set p oint Res p onder: Hilmes 291. Y Closed Closed EICB RAI TVA Letter dated 310 7.1 7.1.2.1.9 (G (1) FSAR amendment 100
, Pa g e 7.1-14 , TVA set p oint Res p onder: Hilmes 292. Y Closed Closed EICB RAI TVA Letter dated 311 7.1 7.1 (G Both Westin ghouse and TVA set p oint methodolo gy do not have Res p onder: Hilmes 293. Y Closed Closed EICB RAI TVA Letter dated 312 7.0 (G B y letter dated Se p tember 10 ,2010 , TVA p rovided the summar y Res p onder: Stockton 294. Y Close Closed EICB RAI TVA Letter dated 313 7.7.8 7.7.1.12 (D a EDCR 52408 (installation of AMSAC in Unit 2
) states that Desi g n Res p onder: A y ala 295. Y Closed Closed EICB RAI No.18 TVA Letter dated 314 7.3 7.3 (D a The followin g 50.59 chan ges were listed in the March 12 RAI Res p onder: Stockton 296. Y Closed Closed EICB RAI No. 19 TVA Letter dated Related to OI 10 315 7.5.3 7.5.3 (GIE Bulletin 79-27 re quired that emer g enc y o p eratin g p rocedures to Res p onder: S. Smith (TVA O perations) 297. Y Close Closed EICB RAI TVA Letter dated 316 7.5.2.7.5 (S i TVA has provided various documents in su pport of RM-1000 hi g h Res p onder: Tem p les/Mather 298. Y Closed Closed RAI No. 26
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments 317 7.5.2.7.5 (S i TVA has p rovided a p ro p rietar y and a non-p ro prietar y version of Res p onder: Tem ples 299. Y Closed Closed RAI No. 27 TVA Letter dated 318 7.5.2.3 7.5 EICB (Singh) TVA has provided the following documents for RM-1000 equipment qualification:
(i) Qualification Test Report for RM-1000 Processor Module and Current-To-Frequency Converter 04508905-QR (January 2001) (ii) Qualification Test Report Supplement, RM-1000 Upgrades 04508905-1SP (June 2006) (iii) Qualification Test Report Supplement, RM-1000 Upgrades 04508905-2SP (June 2008) (iv) Qualification Test Report Supplement, RM-1000 Upgrades 04508905-3SP (May 2008)
Please clarify whether all of thes e are fully applicable to WBN2 or are they applicable with exceptions? If with exceptions, then please clarify what those are.
Supplement 3 was issued one month prior to supplement 2. Please explain the reason for the same. Responder: Temples (i) Applicable to WBN Unit 2.
04508905-1QR is applicable only in regards to the RM-1000, with the exception of re-qualification of certain RM-1000 equipment differences covered in the -1SP report.
The Current-to-Frequency (I-F) converter module qualifications in the base report and the -1SP report are not applicable to the RM-1000s, and will be used later as references in the WBN Unit 2 specific qualification reports.
(ii) Applicable to WBN Unit 2. (iii) Not applicable to WBN Unit 2 (iv) Not applicable to WBN Unit 2 The 04508905-3SP report was prepared for another TVA plant, as a monitor system-level report, where the system included equipment mostly based on the base report equipment items. These two -2SP and -3SP supplement reports were essentially worked concurrently, but the -2SP document review/release process resulted in the release time difference. TVA Response to Follow-up NRC Request:
NOTE: The response for the current to frequency (I to F) converter in item 1 below is a reversal of the response previously provided in TVA to NRC letter dated October 29, 2010 (Reference 22). General Atomics Electronic Systems Inc. (GA-ESI) notified TVA of this change on December 8, 2010 (Reference 20).
(1) The applicability of the qualification reports from GA-ESI e-mail dated December 10, 2010 (Reference 19
) is as follows:
- a. 04508905-QR "Qualification Test Report for RM-1000 Processor Module and Current-to-Frequency Converter" is applicable to the WBN Unit 2 RM-1000 and I to F converter modules.
- b. 04508905-1SP "Supplement to Qualification Test Report for RM-1000 Processor Module and Current-to-Frequency Converter" is applicable to the WBN Unit 2 RM-1000 module.
- c. 04508905-1SP is not applicable to the WBN Unit 2 I to F converter module.
- d. 04508905-2SP "Qualification Test Report Supplement, I-F Converter Upgrades" is applicable to the WBN Unit 2 I to F converter
- 26. Y Open Revised response is included in
letter dated 12/22/10.
Note check 04508905-1QR or QR. Staff version is QR only.
Response is included in letter dated 10/29/10 Open-NRC Review Due 2/25/11
Response update required. It is clear that 04508903-2SP and -
3SP are not applicable.
The response for applicability of 04508905-QR and -
1SP to RM-1000 and IF
converter is not clear.
Check pa g e numbers of Appendix F (missing/duplicate
pages). Check applicability of Appendix C to RM1000
instead of RM2300?
See items 336 and 337.
All equipment qualification reports including supplements 2SP and 3SP have been reviewed as
vendor drawings for
WBN-2. Please explain the reason for applicability of one report and not the
other. Further all TVA/Bechtel reviews seems to be dispositioned as Code 4, "Review not required.
Work may proceed."
The applicable reports should have been reviewed prior to dispositioning them.
Please explain the apparent lack of review of WBN-2 applicable documents. Was
appropriate review guidance used?
Further update required
Provide model number/part number for the RM-1000 and I/F converter used for RAI No. 28 ML102980005 10/26/2010 TVA Letter dated 10/29/10, Encl 1 Item 34, and TVA
letter 11/24/10, Att. 2.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments module.
GA-ESI provided two other reports required to support qualification of the containment high range radiation monitors. The report descriptions are from GA-ESI e-mail on December 8, 2010 (Reference 20). The reports are:
- e. GA-ESI report 04038903-QSR, "Qualification Summary Report for Watts Bar Nuclear Plant Unit 2 Replacement Radiation Monitors:" The report is the principle report and the starting point for all the radiation monitors provided as part of the replacement contract. The report describes each monitor; referenced to the technical manual for the physical and functional description and lists the major components of the monitor system.
Report section 3 identifies the TVA Watts Bar Unit 2 Environmental, Seismic, Electromagnetic Compatibility (EMC), and software requirements for each monitor. In section 4 a brief description of GA-ESI generic qualification programs for all radiation monitoring equipment in each of the four above areas is provided. The qualification basis for each monitor is provided in a separate supplement to the principle report and is identified in section 5.
- f. GA-ESI report 04038903-7SP, "Qualification Basis for 04034101-001 (2-RE-90-271, -272, -273, & -274) [TVA Note: These are the containment post accident high range radiation monitors.]:" GA-ESI report 04038903-7SP is divided into subsections to address the Environmental, Seismic, EMC, and Software qualification basis for the High Range Area Monitors. Within each subsection, the HRAM is compared to a tested or analyzed article to demonstrate similarity and/or evaluate differences, the tests that were performed, and evaluation to demonstrate qualification. In most
cases, the qualification basis references other documents. In addition to qualification, a section is provided that lists the life of those replaceable components that have life expectancy less than 40 years.
(2) This is addressed by response to RAI Question 336 in TVA to NRC letter dated November 24, 2010 (Reference 8)
(3) This is addressed by response to RAI Question 337 in TVA to NRC letter dated November 24, 2010 (Reference 8)
(4) The 04508905-3SP Qualification Test Report Supplement, RM-1000 Upgrades" is not applicable to WBN Unit 2 (Reference 19).
WBN-2. This information is needed to verify that the model or part number used is
the equipment that has been qualified for WBN-
- 2.
Provide qualification reports 04038903-QSR and 04038903-7SP by the dues date of
1/22/11.
Submit a copy of any other relevant reviewed
versions of the qualification reports.
Submit copies of the reviewed reports for
04508905-QR, 04508905-1SP, 04508905-2SP.
Clarification of applicability of existing reports is acceptable.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Please see Item 1, above, for applicability of the other reports.
(5) TVA provided the proprietary versions of the reports by letter dated March 12, 2010 (Reference 10). By letter dated July 15, 2010 (Reference 23), TVA provided the non-proprietary version of the reports and included a copy of the proprietary report which had been erroneously marked as having not been reviewed. 04508905-QR report has been reviewed by TVA. The review of the remaining reports is ongoing.
(6) See item 5. TVA Response to Follow-up NRC Request:
The following documents are the qualification documents associated with the RM-1000 radiation monitors: Attachment 5 contains the approved proprietary version of General Atomics Electronic Systems 04508905-1SP, "Qualification Test Report Supplement, RM-1000 Upgrade." Attachment 6 contains the approved proprietary version of General Atomics Electronic Systems 04508905-2SP, "Qualification Test Report Supplement, I-F Converter Upgrades." Attachment 7 contains the approved proprietary version of General Atomics Electronic Systems 04038903-7SP, "Qualification Basis for 04034101 (2-RE-90-271, 272, 273 & 274)." Attachment 8 contains the proprietary version of General Atomics Electronic Systems 04038903-QSR, "Qualification Summary Report for Watts Bar Nuclear
Plant Unit 2 Replacement Radiation Monitors." In order to meet the NRC submittal schedule, the engineering review of this document was limited to the RM-1000. The document has been accepted for the RM-1000 monitors. Engineering approval will not occur until full review for all covered monitors is complete.
Attachment 23 contains the approved proprietary version of General Atomics Electronic Systems 04508905-QR, "Qualification Test Report for RM-1000
Processor Module and Current-To-Frequency Converter."
319 7.5.2.7.5 (S i TVA p rovided S ystem Verification Test Results 04507007-1TR Res p onder: Tem ples 300. Y Closed Closed RAI No. 29 TVA Letter dated 320 E I Per Westin g house letter WBT-D-2340
, TENNESSEE VALLEY Res p onder: Clark 301. Y Closed Closed N/A N/A Du plicate of item 156 321 E I For the p ur poses of measurin g reactor coolant flow for Reactor Res p onder: Clark 302. Y Closed Closed N/A N/A Du plicate of OI# 157 322 7.7.1.11 (CSection 7.7.1.11 will be added to FSAR Amendment 101 to p rovide Res p onder: Clark 303. Y Closed Closed 323 EICB(Garg) WCAP-13869 revision 1 was previously reviewed under WBN Unit 1 SER SSER 13 (Reference 8). Unit 2 references revision 2. An analysis of the differences and their acceptability will be submitted to the NRC by November 15, 2010 Responder: Hilmes/Unit 1 2 contains the WCAP 13869 Revision 1 to Revision 2 Change Analysis.
- 1. Y Open Due 3/29/11 Open-TVA/Bechtel
Due: TVA Letter dated 10/29/10 Item No. 36 Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments TVA Response to Follow-up NRC Request A FSAR change will be submitted in a future FSAR amendment to change the revision level back to 1.
TVA Response to Second Follow-up NRC Request The differences between the Revision 1 and Revision 2 WCAPs is documented in Attachment 12, "WCAP 13869 Revision 1 to Revision 2 Change Analysis", to TVA to NRC letter dated October 29, 2010 (Reference 2). The design bases for the response to feedwater break inside containment, as documented in Chapter 15 of the WBN Unit
2 FSAR, is the same for WBN Unit 1. Since WBN Unit 2 is required to match the WBN Unit 1 licensing basis to the extent practical, the decision was made to revise the WBN Unit 2 FSAR to agree with the WBN Unit 1 FSAR which uses Revision 1. Revised Response is included in letter dated 10/29/10 The staff is confused with the response since both units have
reference leg not insulated Rev 2 should apply to Unit 1 also and there should be no
difference between Unit 1 and 2 Need to provide additional info on why Rev. 1 is acceptable for both units.
3/10/11 Staff does not agree with the statement that there is no technical
differences between WCAP-13869 rev.1 and rev2., but staff agree
that rev1 and change analysis could be basis for acceptance for both Watts Bar units.
4/6/11 TVA response is acceptable, however this item remains open
until TVA makes changes to FSAR.
324 (M aPer the NRC reviewer
, the BISI calculation is not re q uired to be 304. Y Closed Closed 325 B (G The Unit 2 loo ps in service for Unit 1 that are scheduled to be Res ponder: TVA Startu p Olson 305. Y Closed Closed Closed to o p en item ? 326 B (G TVA uses double-sided methodolo gy for as-found and as-left Res p onder: Webb 306. Y Closed Closed TVA Letter dated 327 DORL (Poole) Attachment 36 contains Foxboro proprietary drawings 08F802403-SC-2001 sheets 1 through 6. An affidavit for withholding and non-proprietary versions of the drawings will be submitted by January 31, 2011.
Responder: Webber In accordance with correspondence from Foxboro, there is no proprietary information contained in the 08F802403-SC-2001 drawings. Based on this, no affidavit for withholding is required. Attachment 1 contains versions of the drawings with the proprietary information block removed.
- 27. Y Open Response Included in letter dated 11/24/10 Open-NRC Review Due 11/24/10 328 7.5.2.7.5 (S iProvide the model number for the four containment hi g h ran g e Res p onder: Tem ples 307. Y Closed Closed RAI No. 30 TVA Letter dated 329 7.6.1 7.6.7 (S iSection 7.6.7 of the FSAR (Amendment 100
) states that
, "The Res p onder: Clark 308. Y Closed Closed RAI No. 1 TVA Letter dated 330 7.3 7.3 (D a Related to Item 298 Res p onder: Hilmes/Faulkner 309. Y Closed Closed EICB RAI No.20 Item 7 , TVA letter 331 7.6.1 7.6.7 (S i A s a follow u p of OI 190
, Staff has reviewed the p ro p rietar y version Res p onder: WEC/Harless/Clark 310. Y Closed Closed RAI No. 8 TVA Letter dated Follow-u p of OI-190.
332 7.5.2.7.5.1 (M a 10/26/2010 311. Y Closed Closed ML103000105 Item TBD EICB RAI ML103000105 sent to DORL 333 7.5.2.7.5.1 (M a 10/27/2010 312. Y Closed Closed ML103000105 Item TBD EICB RAI ML103000105 sent to DORL 334 7 7 (D a FSAR Fi gure 7A-3 "Mechanical Flow and Control Dia g ram Res p onder: Stockton 313. Y Closed Closed RAI not re quired. N/A RAI not re quired because the fi g ure is 335 7.6.1 7.6.7 (S i LPMS: Reference to OI-331
, sub item 2.
Res p onder: WEC 314. Y Closed Closed RAI# 1 , EICB letter TVA letter
, dated We need to confirm when MEEB when 336 7.5.2.7.5 (S iRe: RM-1000 Re p ort 04508905-QR Res ponder: GA 315. Y Closed Closed 337 7.5.2.7.5 (S iRe: RM-1000 Re p ort 04508905-QR Res ponder: GA 316. Y Closed Closed 338 7.5.2.7.5 (S i In p a g e 3-15 and a ppendix B of Qualification Test Re p ort 04508905-QR
, "Qualification Test Re port for RM-1000 317. Y Closed Closed RAI #4 letter dated FSAR amend 103 Note: Item to be added to Section 3.10 339 7.5.2.7.5 (S i In the Qualification Test Re port 04508905-QR
, the licensee A s a g reed to with the reviewer
, Attachment 1 contains the 318. Y Closed Closed RAI #5 letter dated FSAR amend 103 Note: Item to be added to Section 3.10 340 7.5.2.3 7.5 EICB (Singh) Provide test result curves for all EMI/RFI tests listed in Table 3.2.3 (page 3-8) of the Qualification Test Report 04508905-QR. In addition, please provide the standards or the guidance documents used as the source for ENV 50140, ENV 55011 Class A, and EN 55022 Class B. Responder: GA The following responses are based on e-mail: GA-ESI to Bechtel, dated December 8, 2010 (Reference 20),
(1) The EMI/RFI tests described in Table 3-2 are based on GA-ESI report 04509050 and are summarized in GA-
- 2. N Open Due 4/30/11
Response included in letter dated 12/22/10.
Open-TVA/Bechtel
Provide the qual reports by 1/28/11 per TVA letter of 12/22/10.
Due: 2/25/11 Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments ESI report 04508905-QR. The independent laboratory report, with curves, is part of GA-ESI report 04509050.
Subsequent to issuing GA-ESI report 04508905-QR additional EMC testing was performed in accordance with TVA specific requirements. The results of the subsequent EMC testing are reported in GA-ESI report 04038800. GA-ESI report 04038800 includes the test curves and the report is used as the basis for EMC qualification of the Upper and Lower Inside Containment Post Accident Radiation Monitors (2-RE-90-271 through -274). The results of the testing and the acceptability of the RM-1000 monitors for use at WBN Unit 2 are addressed in GA-ESI report 04038903-7SP. This report will be submitted no later than January 28, 2010.
(2) ENV 50140, EN 55011, and EN 55022 are British Standard Institution (BSI) publications concerning equipment electromagnetic and radio frequency performance. The standard titles are shown below:
- a. ENV 50140 - Electromagnetic Compatibility - Basic Immunity Standard - Radiated Radio-Frequency Electromagnetic Field - Immunity Test
- b. EN 55011 - Industrial, scientific and medical equipment - Radio-frequency disturbance characteristics - Limits and methods of measurement
- c. EN 55022 - Information technology equipment -
Radio disturbance characteristics - Limits and methods of measurement TVA Response to Follow-up NRC Request:
The total EMI/RFI testing of the RM-1000 and current-to-frequency converter is documented in the following reports:
Attachment 5 contains the proprietary version of General Atomics Electronic Systems 04508905-1SP, "Qualification Test Report Supplement, RM-1000 Upgrade." See sections 5.1.1, 5.1.2 and 5.1.4 for EMI/RFI. Attachment 7 contains the proprietary version of General Atomics Electronic Systems 04038903-7SP, "Qualification Basis for 04034101 (2-RE-90-271, 272, 273 & 274)." See section 5 for EMC qualification basis.
Attachment 8 contains the proprietary version of General Atomics Electronic Systems 04038903-QSR, "Qualification Summary Report for Watts Bar Nuclear Plant Unit 2 Replacement Radiation Monitors." See section 3.4 for electromagnetic compatibility qualification requirements. Attachment 23 contains the proprietary version of General Atomics Electronic Systems 04508905-QR, "Qualification Test Report for RM-1000 Processor Module and Current-To-Frequency Converter." See sections 3.2.1 through 3.2.5 and 6.2 for EMI/RFI.
Attachments 7 and 8 document the EMI/RFI testing specific Clarification Needed:
Per 2/25/11 response TVA document SS-E18.14.01, Rev. 3 is the source document
for all testing. Please provide this document for staff review. In
addition British
Standards (e.g. ENV 50140) have been cited in testing which are not
per RG 1.180, R1. TVA to describe compliance of SS-E18-14.01 to RG 1.180 with justification for deviations. No test curves have been provided in any of the reports. As a minimum
TVA to provide a few
sample test curves or justify not supplying them.
No EMI/RFI curves
have been provided as yet. TVA to provide representative curves.
NRC review proceedin g in parallel.
NRC current review guidance is based on compliance with RG 1.180 or equal with justification for variations. TVA is requested to provide the roadmap for compliance to RG
1.180 with justifications for any deviations. Simply following TVA
standard specification
SS E18.14.01, Rev. 3 is not sufficient.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments to the WBN Unit 2 RM-1000 monitors and current-to-frequency converters.
TVA Response to Second Follow-up NRC Request:
GA-ESI qualification report 04038903-7SP, "Qualification Basis for 04034101 (2-RE-90-271, 272, 273 & 274)" Revision C dated February 22, 2011(Proprietary), submitted on TVA to NRC letter dated February 25, 2011 (Reference 2), section 5.1 states:
"GA-ESI has performed the tests on a 2 channel RM-1000 radiation monitoring system the configuration of which is shown in GA-ESI drawing 04509000 System Installation Configuration, RFI/EMI Test, RM-1000 the results of which are issued in GA-ESI report 04038800, RM-1000 EMC Test Report, TVA and 04509050, RM-1000 EMC Test Report.
The equipment tested used an RM-1000 microprocessor radiation monitor Display/Control NIM Bin Assembly, an I-F Converter, line filter, and an RD-23 detector. The monitor system being qualified is the same as the monitor system tested and includes ECO-17656 modifications to ensure EMC compliance."
Attachment 1 contains the TVA "Browns Ferry High Range Radiation Monitor" which contains the requested EMI test curves. We have confirmed that the GA-ESI reports (04509050, "RM-1000 EMC Test Report," dated 4/22/03 and 04038800, RM-1000 EMC Test Report," dated 11/11/99) included in the TVA report are applicable to the WBN Unit 2 RM-1000 monitors. The non-proprietary versions and affidavit for withholding of GA-ESI reports (04509050 and 04038800) will be submitted within two weeks of receipt from GA-ESI. GA-ESI qualification report 04038903-7SP, section 5, provides a detailed discussion of the test results in GA-ESi report 04509050.
TVA Response to Follow-up NRC Request Attachment 1 provides a comparision of the TVA EMC specification SS E18.14.01, Revision 3 requirements to RG 1.180 requirements.
341 7.5.2.7.5 (S iFSAR Tables 3.10 list seismicall y q ualified e q ui p ment. However
, A review of WBN Unit 2 FSAR amendment 102 cha p ters 319. Y Closed Closed RAI #1 letter dated FSAR amend 103 342 7.5.2.7.5 (S iPlease confirm that RM-1000 monitors and the associated The RM-1000 containment hi g h ran g e radiation monitors are 320. Y Closed Closed 343 7.5.2.7.5 (S iSeismic RRS in the 04508905-QR re p ort Fi gures 3-2 and 3-3 (1) The cause of the difference between the RRS and TRS 321. Y Closed Closed 344 7.6.6 ? g (GUnit 1 SE discussed in Section 7.6.5
, "Valve Power Lockout".
(a) In accordance with0PDP-6
, "Locked Valve/Breaker 322. Y Close Closed Close based on TVA letter dated 345 7.5.2.7.5 (S i Provide the normal tem peratures and ex p ected p eriods of hi g h/low RM-1000 in a NIM Bin was Tested at 39°F for 72 Hrs and 323. Y Closed Closed Res p onse 346 7.5.2.3 7.5 EICB (Singh) TVA has previously stated in response to open item 319 that RM-1000 System Verification Test Results report, 04507007-1TR is not applicable to WBN-2. However, TVA has not provided a WBN-2 specific test results report. Please identify and provide the appropriate test results reports to complete the review. Document 04507007-1TR is the RM-1000 System Verification Test Results. 04038903-QSR, "Qualification Summary Report for Watts Bar Nuclear Plant Unit 2 Replacement Radiation Monitors" (Attachment 8) and and 04038903-7SP, "Qualification Basis for 04034101 (2-RE-90-271, 272, 273 & 274) (Attachment 7) are the Watts Bar Unit 2 equipment specific qualification reports.
- 3. N Open Due 4/15/11 Open-TVA/Bechtel
Due: 2/25/11 The proposed response
appears to be conflicting with the Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments TVA Response to Follow up NRC Request:
Report 04507007-1TR "RM-1000 System Verification Test Results" is applicable to the WBN Unit 2 monitors. The applicability is that 04507007-1TR includes all test cases called out in the 04507006 "RM-1000 System Test Procedure Specification" and contains evidence that the V&V tests were performed with version 1.0 software code. The verification report for version 1.1 software is document 04508005 "RM-1000 Software Version 1.1 Software Verification Report." Document 04508006 "RM-1000 Version 1.2 Software Verification and Validation Report" shows that the required test was completed to validated version 1.2 code for the RM-1000.
The En g ineerin g reviewed and approved proprietar y versions of 04507007-1TR, 04508005 and 04508006 will be submitted within two weeks of receipt from GA-ESI. The unreviewed proprietary versions, non-proprietary versions and affidavit for withholding were submitted on TVA to NRC letter July 15, 2010 (Reference 3).
TVA Response to Follow up NRC Request The safety-related production modules and the Sequoyah non-safety-related modules are physically identical. The difference is that one was produced under the GA-ESI QA program and the other was not.
proposed response for OI-351 regarding not submitting the 04508905-QR report.
TVA to re-assess
proposed response for both OIs.
TVA to re-evaluate
previous responses to OI-316 and OI-319 which have conflicting
responses regarding the applicability of 04507007-1TR.
NRC Follow-up question Report 04507007-1TR, 1999 states in the Test Summary that "Initially the testing was done using the SE safety
related production modules that had
undergone software V&V testing. The majority of the testing
was done by using two of the Sequoyah non-safety related production modules for
the TVA contract, substituted for the SE modules." Since the report is based on primarily non safety
related components TVA to clarify and justify why NRC should accept this test report
for safety related V&V testing. 347 7.5.2.7.5 (S i Qualification re port 04508905-1SP does not address EMI/RFI Qualification re port 04038903-7SP
, Qualification Basis for 324. Y Closed Closed 348 7.5.2.7.5 (S i Qualification re port 04508905-2SP does not address EMI/RFI Qualification re port 04038903-7SP
, Qualification Basis for 325. Y Closed Closed 349 7.5.2.3 7.5 EICB (Singh) Radiation testing was not considered in any of the test reports as all the equipment has been assumed to be located in nuclear power plant areas with mild environments and radiation dosages less than 1 x 10 3 rads for total integrated dose (TID). However, the radiation monitors and the I/F converters are located in the main control room which is defined as mild environment. For WBN-2 mild environment is defined as room or building zone where (1) the temperature, pressure, or relative humidity resulting from the direct effects of a design basis event (DBE) (e.g.,
temperature rise due to steam release) are no more severe than
those which would occur during an abnormal plant operational The design criteria provides the criteria for determining what is a mild environment at WBN Unit 2. Calculation WBNAPS4004 "Summar y of Mild Environment Conditions for Watts Bar Nuclear Plant" provides the actual values for each area of the plant. In accordance with Table 1, the Control
Room has a 40 year maximum TID of 3.5x10 2 RAD and a maximum integrated accident dose of 710.5 RAD for a maximum TID of 1060.5 RAD.
The accident dose of 710.5 RAD is the dose for a 100 day
LOCA at the surface of the HEPA filter in the Mechanical
- 1. Y Open Open-TVA/Licensing Due: 2/25/11
TVA to provide the assessment document or a summary of the document with the reference to the
appropriate document/documents.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments condition, (2) the temperature will not exceed 130ºF due to indirect effects of a DBE, (3) the event radiation dose is less than or equal to 1 x 10 4 rads, and (4) the total event plus the 40 year TID (total integrated dose) is less than or equal to 5 x 10 4 rads (reference WB-DC-40-54). TVA to address lack of radiation qualification for
WBN-2. Equipment Room. This is documented in TVA calculation WBNTSR-005, "Dose Due to the Control Building Emergency Air Cleanup Filters" Revision 3. However, on page 25 of WBNTSR-005, the shine from this source into the control room is negligible and is not considered in the dose calculation for the control room.
Calculation WBNAPS3-126, "EQ Dose in the U1/U2 Auxiliary Instrument Rooms and the Computer Room in the Control Building" Revision 0 documents the environmental qualification (EQ) radiation dose in the control building. A review of this document by the TVA radiation protection engineer determined that the TID including the normal and accident dose values for the control room is less than 1x10 3 RAD. Calculation WBNAPS3-126, will be revised to include the control room b y Jul y 1, 2011. Since the control room TID has been determined to be less than 1x10 3 RAD, radiation qualification of the RM-1000.
February 25, 2011 response is acceptable. Item will be tracked as
a confirmatory item in
the SE. TVA to provide calculation or summary of calculation when complete.
350 7.5.2.7.5 (S iThe seismic re q uired res p onse s p ectra (RRS) is shown in Fi g ures The RM-1000 was seismicall y tested in a NIM Bin and the 326. Y Closed Closed RAI # 9 , letter FSAR amend 103 Note: Item to be added to Section 3.10 351 7.5.2.7.5 (S i The re placement schedule for the com ponents that have a The re placement schedules stated in 04508905-1SP
, 327. Y Closed Closed 352 7.5.2.7.5 (S i Please clarif y how man y RM-1000 radiation monitors are bein g The total number of RM-1000 units p rocured under MR 328. Y Closed Closed 353 7.5.2.3 7.5 EICB (Singh) Please provide a summary of the [manufacturer's] commercial dedication plan for radiation monitors with references to the guidance document that it follows. Also please include different facets (e.g. receiving, inspection, testing etc.) of the plan.
GA-ESI submitted their commercial grade dedication procedure (OP-7.3-240, "Safety-Related Commercial Grade Item Parts Acceptance," Revision H) to engineering for review. Engineering review of the procedure found that the procedure, Section 5, did not require multiple dedication methods for complex CGI or CGI used in digital safety systems. As a result, it was determined that the GA-ESI program did not meet the requirements of NUREG-800, Section 7.0A, Revision 5.
A discussion with GA-ESI found that while not required by procedure, GA-ESI does perform vendor surveys as required by Method 2 of NP-5652. The surveys are done based on prudent business practices. Based on this discussion, GA-ESI agreed to review the CGI used in the WBN Unit 2 digital safety-related monitors to determine if they had been dedicated by more than one method.
The review of the CGI used in the WBN Unit 2 digital safety-related monitors determined that all CGI had been dedicated using Method 1 of EPRI guideline NP-5652. However, in the sample of items reviewed, there were CGI that were dedicated usin g a sin gle method. Based on the results of the engineering procedure review and the results of the GA-ESI CGI review, Service Request 346896 was initiated to document the condition and to place the monitors in "Conditional Release" status.
Based on the results of the previous reviews, GA-ESI agreed to the following plan of action to resolve the CGD issue:
- 1. GA-ESI shall revise its commercial grade dedication procedure (OP-7.3-240) to require multiple dedication methods be utilized for complex commercial grade items and commercial grade items for digital safety class systems. The evidence that this has been
- 4. N Open Due 4/15/11 Open-TVA/Bechtel
TVA to note that staff has written a safety evaluation and accepted EPRI TR-106439 (1996) as an acceptable method of addressing commercial dedication. EPRI NP-
5652 must be used in conjunction with the additional guidance in EPRI TR-106439 for
commercial dedication processes e.g. EPRI NP-6404, EPRI TR-
102260, GL 89-02, and GL-91-05 per Section
3.3 of EPRI TR-106439.
Follow-up clarification:
TVA to review and satisfy itself with the procedure and provide NRC a copy of the procedure for review.
In addition, TVA and
GA to provide information as to what additional measures
were taken by GA with
available Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments completed will be provided to TVA by April 15, 2011.
Specifically, Method 1 and at least one additional method from the list below will be used to ensure that the CGD procedure complies with the current SRP.
Method 1 - Special Tests and Inspections Method 2 - Commercial Grade Survey of Supplier Method 3 - Source Verification Method 4 - Acceptable Supplier/Item Performance Record 2. GA-ESI shall take actions consistent with the revised operating procedure to address the CGls used in the WBN Unit 2 safety-related digital monitors. Evidence that those actions have been completed will be provided no later than September 1, 2011.
Based on the above action plan, TVA will resolve the issues with the GA-ESI CGD of CGI used in the WBN Unit 2 monitors and submit documentation of the resolution to the NRC by: GA-ESI procedure OP-7.3-240 revision: April 30, 2011 Resolution of CGD of CGI used in WBN Unit 2 RM-1000 monitors: September 15, 2011 TVA Response to Follow up NRC Request (1) TVA has reviewed the revised GA-ESI procedure and determined that changes bring the CGD program into conformance with the requirements of NUREG-800, Section 7.0A, Revision 5 EPRI topical report TR-106439 and EPRI guideline NP-5652. Attachment 2 contains GA-ESI procedure OP-7.3-240 "Safety-Related Commercial Grade Item Parts Acceptance," Revision I.
(2) As stated in TVA to NRC letter dated April 15, 2011(Reference 1), Attachment 4, List of New Commitment Items, item 2, the due date for resolution of this issue is September 15, 2011. documentation to prove that more than one method was followed for commercial dedication.
354 7.5.2.7.5 (S i RG 1.180 endorsed the g uidance of IEEE-1050-1996 with (1) The WBN Unit 2 g roundin g s ystem desi gn is in 329. Y Closed Closed The g roundin g s pecification used b y 355 7.5.2.7.5 (S iStaff has not found the stated exclusion zone for EMI/RFI Cautions and distance limitations for WBN Unit 1 le g ac y 330. Y Closed Closed 356 7.5.2.7.5 (S iThe attachment number refers to your Februar y 25 , 2011 letter. The loss of the RM-3 out p ut (current to fre q uenc y (I/F) 331. Y Closed Closed Closed b y TVA 357 7.5.2.3 7.5 EICB (Singh) In Attachment 5, Qualification Test Report Supplement, RM-1000 (04508905-1SP), Attachment 6, Qualification Test Report Supplement, I-F Converter Upgrade (04508905-2SP), and 3, Qualification Test Report for RM-1000 Processor Module and Current-To-Frequency Converter (04508905-QR), t he applicant made a statement that the results for these tests are provided in SE document 04508903-1TR. Please provide SE document 04508903-1TR for the staff to review. IF this report has been submitted earlier then please advise us the letter number and date by which it was submitted. Attachment 8 contains GA-ESI qualification report 04508903-1TR "Seismic Qualification Test Results RM-1000 and Current-to Frequency (I/F) Converter" original release, dated April 1999.
- 28. N Open-NRC Review 358 7.5.2.3 7.5 CB (Si n gThe attachment numbers refer to your February 25, 2011 letter. In , "Wyle Test Report 41991 Safety Shutdown An incomplete response was inadvertentl y submitted in TVA to NRC letter dated March 31, 2011 (Reference 1
). The 29. N Open Due 4/15/11 Open-NRC Review Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Earthquake (SSE) Test Response Spectra (TRS) Plots" all five (5) pages, in Attachment 5, "General Atomics Electronic Systems 04508905-1SP", page 5-5, Figure 5-2, and in Attachment 23, Qualification Test Report for RM-1000 Processor Module and Current-To-Frequency Conver ter (04508905-QR)", page 4-25, Figure 4-5 X-Axis SSE Test Response Spectra (TRS) versus Required Response Spectra (RRS), it show s that the TRS were below the RRS at various frequenc y (5% Dampin g). Please provide an explanation regarding why this is acceptable
. following response supersedes the previous response in its entiret y. 1. Attachment 2, "Wyle Test Report 41991 Safety Shutdown Earthquake (SSE) Test Response Spectra (TRS) Plots" all five (5) pages. These five Test Response Spectra (TRS) Plots versus Required Response Spectra (RRS) show that the TRS were below the RRS at various frequency (5% Damping).
Please provide an explanation regarding why this is acceptable.
Attachment 2 of this letter provides five pages from the first seismic test (Wyle Test report 41991) from GA-ESI report 04508903-1TR, submitted in response to OI-357 on TVA to NRC letter dated March 31, 2011 (Reference 1). The following discussion refers to these pages.
Wyle test report 41991 provided the seismic test results for two RM-1000 monitors (one area monitor and one process monitor) and one I/F converter. During the test, the RM-1000 monitor confi g ured as an area monitor was damaged due to the test table impacting its mechanical
stop (see page 4 of Wyle Test Report 41991 attached).
This first test was completed for the RM-1000 monitor configured as a process monitor and the I/F converter.
A second seismic test for the RM-1000 monitor configured as an area monitor and two I/F converters (Wyle Test Report 41991-1) is also included in 04508903-1TR. The RM-1000 monitor used in this second test was the same RM-1000 process monitor used in the first seismic test reconfigured (switch in
application t ype 1 mode) as an area monitor. One of the I/F converters tested was the same I/F converter tested in the first seismic test. This second test was performed to complete the testing which could not be performed during the first seismic test due to the damage to the RM-1000 area monitor and the loss of the high voltage power supply to the I/F converter that occurred during the first seismic test. None of the TRS plots in this second seismic test report 41991-1 were below the RRS. General Atomics "Qualification Test Report for RM-1000
Processor Module and Current-To-Frequency Converter" (04508905-QR) refers to both Wyle Reports 41991 and 41991-1 included in report 04508903-1TR. It is recognized that the five TRS Plots versus the RRS
where the TRS were below the RRS is an exceedance that must be justified. From Wyle report 41991 it can be determined that these five TRS versus RRS plots are for the seismic response in the front to back panel direction.
The RRS used in the Wyle test reports envelopes the
TVA standard RRS shown in Fig 3.1 of TVA Standard Specification CEB-SS-5.10, "For Seismic Qualification of Electrical, Mechanical and I&C Devices," submitted on TVA to NRC letter dated February 25, 2011, (Reference
- 2) below 33 Hz. This TVA standard RRS conservatively Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments envelopes the in panel seismic demand for most TVA applications. For specific cases when required the actual in panel RRS can be developed. Calculation WCG-ACQ-0766, "In-Cabinet Required Response Spectra for RM-1000 Radiation Monitors in MCR Panel 2-M-30," Revision 0, (Attachment 3) has been issued to generate the 5% RRS for these safety related RM-1000 monitors, I/F converters and NIM bins for the WBN2 panel (2-M-30) where they will be installed. As can be seen from the RRS plots in calculation WCG-ACQ-0766 the front to back 5% RRS broad band peak is 9.76 g which is lower than the front to back 5% TRS shown in
the subject five (5) plots.
- 2. Attachment 5, "General Atomics Electronic Systems 04508905-1SP," page 5-5, Figure 5-2. The Figure 5-2 Test Response Spectra (TRS) Plots versus Required Response Spectra (RRS) shows the TRS to be below the RRS at various frequency (5% Damping).
Please provide an explanation regarding why this is acceptable
. The display module for the RM-1000 monitors procured for WBN2 differs from that used in previous RM-1000 qualification tests. The seismic qualification basis for the WBN2 display module is established by similarity to the display module used in RM-2000 monitor qualification tests shown on page 5-4 and 5-5 of 04508905-1SP (pages attached). The basis for the similarity discussion is provided on pages 5-2 and 5-3 of 04508905-1SP. The TRS non-exceedance at
approximately 6-7 Hz shown on page 5-5 is not applicable to WBN2 since the RRS shown on that figure is not used for WBN2 qualification. The correct
comparison for WBN2 would be the TVA standard RRS shown in Fig 3.1 of CEB-SS-5.10 for 5% damping. The TRS shown on page 5-5 meets or exceeds all points of the TVA standard RRS. Therefore, the seismic qualification of the WBN2 display module is provided by pages 5-4 and 5-5 for which the TRS completely envelopes the TVA standard RRS shown in Fig 3.1 of CEB-SS-5.10. Additionally, as previously stated, Calculation WCG-ACQ-0766 was issued to generate the 5% RRS for the WBN2 panel (2-M-30) where the safety related RM-1000 monitors will be installed. The vertical 5% RRS plot in calculation WCG-ACQ-0766 broad band peak is 4.2 g which is lower than the 5% TRS shown in 04508905-1SP", page 5-5, Figure 5-2. 3. Attachment 23, Qualification Test Report for RM-1000 Processor Module and Current-To-Frequency Converter (04508905-QR)", page 4-25, Figure 4-5 X-Axis SSE Test Response Spectra (TRS) versus Required Response Spectra (RRS) shows the TRS to be below the RRS at various frequency (5% Damping). Please provide an explanation regarding why this is acceptable.
This Figure 4-5 is one of the same figures identified in item 1. See item 1. for the appropriate discussion.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments 359 7.7.1.1 EICB (Carte) Was the CERPI system developed under a 10 CFR 50 Appendix B compliant program?
CERPI is a non-safety related system. Therefore, 10 CFR 50 Appendix B is not applicable.
- 30. Open Due 4/15/11 Open-NRC Review 360 EICB (Garg) In order for staff to review the acceptability of the Incore Instrumentation System (IIS): (a) Provide a brief system description of IIS and its regulatory compliance. In your discussion include the discussion of WINCISE and BEACON system which are part of the IIS. Also provide the differences between the system used at
WBN Unit vs. at Unit 2, e.g. Movable vs. fixed IIS. For WINCISE provide the basis for acceptance. (b) If this system has been accepted by the staff previously at some other plant then provide the reference to that SE. Identify the document that describes the functionally of the IIS that is identical to the IIS used in the Westinghouse AP1000 reactor design. (c) If this has not been evaluated by the staff previously, then provide the effect of CCF of this system and its effect on safety system or chapter 15 analysis. (d) Does this have any interconnection with safety system? (e) For BEACON provide the acceptability of this system. I believe that this system was accepted at WBN Unit 1. If that is the case then provide the reference to that review. Also provide any differences of this system to the one at WBN Unit 1 system.
(f) Please provide detailed information about the In-core Instrumentation System (IIS) to be installed in Watts Bar Unit
- 2. This information should indicate how the system meets the requirements established in the Standard Review Plan, including system concept, system requirements, system design, and system development, as well as the regulatory requirements identified for Watts Bar Unit 2.
(g) Please provide a description on how the system will meet the regulatory requirements identified in Table 7.1-1 of the SRP, applicable to the IIS.
(h) Provide detailed description about the connection and communication for the signals to be transmitted from the Core
Exit Thermocouples to the Common Q Post Accident Monitoring System (PAMS). Also, describe how this communication will meet the NRC communications regulatory
requirements.
(i) Please provide the following Westinghouse document: NO-WBT-002, "Westinghouse Incore Information Surveillance &
Engineering (WINCISEŽ) System Technical Manual."
(j) Provide the failure modes and effects analyses for the IIS, documented in calculation WBNOSG4220 "WB Incore (a) The Watts Bar Unit 2 In-core Instrumentation System (IIS) replaces all of the functionality provided by the Movable Incore Detector System (MIDS) used at Watts Bar Unit 1. The IIS to be used at Watts Bar Unit 2 is a Westinghouse IN-Core Information, Surveillance, and Engineering (WINCISE) System that is functionally
described in Section 7.7.1.9 of the Watts Bar Unit 2 Final Safety Analysis Report (FSAR). The WINCISE-st yle IIS used at Watts Bar Unit 2 is essentiall y the same as the in-core power distribution measurement systems used at most Combustion Engineering style of operating reactors that use a type of in-core neutron sensors commonly called "Fixed In-core Detectors (FID)." The Watts Bar Unit 2 IIS is functionally identical to the IIS used in the Westinghouse 1 AP1000Ž reactor design. The Watts Bar Unit 2 IIS includes the FIDs, Core Exit Thermocouples (CET), FID and CET signal cables, the FID signal processing hardware, and the FID signal processing software. This hardware and software is required to provide the measured signals to the associated BEACON System to periodically determine whether the reactor is operating within design core peaking factor limits. A detailed description of the Watts Bar Unit 2 IIS hardware is provided in the document titled, "Westinghouse Incore Information Surveillance &
Engineering (WINCISE) System Technical Manual," NO-WBT-002, Revision 0 supplied by Westinghouse to TVA in September of 2010.
The qualification for the BEACON S y stem to perform the core power distribution measurement function using the Watts Bar Unit 2 WINCISE style IIS instrumentation is documented in the generic NRC Safety Evaluation Reports (SER) provided with WCAP-12472-P-A, "BEACON Core Monitoring and Operations Support
System", Addendum I-A and Addendum 2-A.
(b) The WINCISE style IIS used at Watts Bar Unit 2 is essentially the same as the in-core power distribution measurement systems used at all Combustion Engineering style of operating reactors that use a type of in-core neutron sensors commonly called "Fixed In-core Detectors (FID)." The Watts Bar Unit 2 IIS is functionally identical to the IIS described in the Westin g house AP1000 desi gn documents and approved in the Westinghouse AP1000 SER section 7.5.7 as documented in Westinghouse Letter WBT-D-____ ,
"title," dated April 14, 2011 (Attachment 7)
(c) The digital in-core flux monitoring portion of the IIS is non-safety-related. As such, CCF analysis is not required by NUREG-800 section 7.0-A. The IIS has no
- 31. Open Due 4/15/11 Open-NRC Review 1 AP-1000 is a registered trademark of the Westinghouse Electric Company LLC Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Instrumentation System Failure Modes and Effects Analyses," and demonstrate how these potential failures do not adversel y affect reactor safety.
impact on any Safety Analysis documented in Chapter 15 of the Watts Bar Unit 2 FSAR.
(d) The IIS includes the 1E qualified CET and CET analog signal cables required to allow the CETs to be directly connected to the Common Q Post Accident Monitoring System (PAMS). There is no other interface to safety systems. The CET signals are electrically isolated from signals output from the non-1E FID signals and signal processing electronics.
(e) The qualification for the BEACON S y stem to perform the core power distribution measurement function using the Watts Bar Unit 2 WINCISE style IIS instrumentation is documented in the generic NRC Safety Evaluation Reports (SER) provided with WCAP-12472-P-A. This WCAP generically approves the BEACON System for use at PWR reactors including those using Movable In-core Detector Systems (MIDS) like Watts Bar Unit 1 and, through Addendum I-A and 2-A, those like Watts
Bar Unit 2 using a WINCISE type fixed in-core instrumentation system.
The specific differences between the Unit 1 and Unit 2 core power distribution measurement systems are too numerous to simply list. A detailed description of the Watts Bar Unit 2 IIS hardware is provided in section 2 of the WINCISE System Technical Manual NO-WBT-002 (Attachment 5).
(f) NUREG-800 section 7.0-A, Table 7.0-A-1. Review Topics for Various Systems, requires only a limited review for non-safety related system discussed in NUREG-800 section 7.7 Control. WINCISE is a non-
safety-related, indication onl y s y stem within the scope of NUREG-800 section 7.7. The limited review required is: "Control systems receive a limited review as necessary to confirm that control system failures cannot have an adverse effect on safety system functions and will not pose frequent challenges to the safety systems." The only WINCISE interface with a safety-related system is the CET in the IITA which is hardwired to the Common Q PAMS system. See item (g) below for a description of the qualification process that demonstrates that failures in the balance of the WINCISE s ystem do not impact the performance of the safety-related CET function.
(g) With the exception of the IITA hardware, WINCISE is a non-safety-related indication system. The IITA assemblies meet the following criteria:
- i. R.G. 1.26 Rev. 3 Quality Group Classification and Standards for Water, Steam and Radioactive Waste Components of Nuclear Power Plants ii. R.G. 1.38 Rev. 2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling of Items for Water-Cooled Nuclear Power Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Plants iii. R.G. 1.71 Rev. 0 Welder Qualification for Areas of Limited Accessibility iv. R.G. 8.8 Rev. 3 Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power Stations will be As Low As Reasonably Achievable
- v. R.G. 8.19 Rev. 1 Occupational Radiation Dose Assessment in Light-Water Reactor Plants Design State Man-Rem Estimates vi. R.G. 1.84 Rev. 27 Design and Fabrication Code Case Acceptability - ASME Section III, Division 1R.G. 1.85 Rev. 27 Material Code Case Acceptability - ASME Section III, Division 1 1.1.4 The design, materials, fabrication, inspection, and testing of the IITA shall be in accordance with the ASME Boiler and Pressure Vessel Code,Section III Class 3, and all applicable Code Cases as proposed by the supplier and approved by Westinghouse. Materials shall be in accordance with this specification.
1.1.5 Component Classification - The IITA is classified as an instrument tube, so it is not under the jurisdiction of the ASME per NCA-1130(c). However, the design, primary pressure boundary materials, and NDE Requirements are per ASME Section III, Class 3 and the IITA is classified as Safety Class 2.
The non-safety-related WINCISE Signal Processing System Cabinets are located inside containment and are therefore required to not impact the function of any safety-related equipment. To meet this requirement the cabinets were tested and passed based on the following criteria:
- i. In accordance with WB-DC-40-31.2, "Watts Bar Nuclear Plant Seismic Qualification of Category 1 Fluid System Components and Electrical or Mechanical Equipment," Revision 8, November 2000 and U.S. N.R.C. Regulatory Guide 1.100, "Seismic Qualification of Electrical and Mechanical Equipment for Nuclear Power Plants," Revision 2, June 1988, the equipment must withstand five OBEs and one SSE without creating missiles. Testing was done in accordance with:
(1) IEEE Std 344-1975, "IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations," Institute of Electrical and Electronics Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Engineers, Inc., 1975 (2) IEEE Std 344-1987, "IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations," Institute of Electrical and Electronics Engineers, Inc., 1987 ii. In accordance with U.S NRC Regulatory Guide 1.180 "Guidelines for Evaluating Electromagnetic and Radio-Frequency Interference in Safety-Related Instrumentation and Control Systems," Revision 1, October 2003 and IEEE 323-1983 "IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generator Stations," Institute of Electrical and
Electronics En g ineers, Inc., 1983, the equipment must not generate spurious elec tromagnetic emissions or suffer some common mode failure due to its operatin g environment that could directl y or indirectl y impact the operation of safety-related equipment
(1) IEC 61000-6-2, "Electromagnetic compatibility (EMC). Generic Standards. Immunity for Industrial Environments," 2005 (2) MIL-STD-461E, "Requirements for the control of Electromagnetic interference Characteristics of Subsystems and Equipment," August 1999 (3) IEC 61000-4-4, "Electromagnetic compatibility (EMC) - Part 4-4: Testing and Measurement Techniques - Electrical Fast Transient/Burst
Immunity Test," 1995 (4) IEC 61000-4-12, "Electromagnetic Compatibility (EMC) - Part 4: Testing and Measurement Techniques, Section 12:
Oscillatory Waves Immunity Tests," 1996 iii. In order to demonstrate that a maximum expected surge of 600 volts on the power input to the cabinets would not propagate and damage the CET cables in the IITA, the cabinets were surge tested in accordance with IEC 61000-4-5, "Electromagnetic compatibility (EMC) - Part 4-5: Testing and Measurement Techniques - Surge Immunity Test,"
1995.
(h) The cables for the CETs separate from the FID cables at the seal table. The CETs are connected directly to the Common Q PAMS cabinet. The FIDs are connected directly to the in-containment signal processing system cabinets.
(i) Attachment 5 is the proprietary section 2 "Equipment Description" of NO-WBT-002, "Westinghouse Incore Information Surveillance & Engineering (WINCISEŽ) System Technical Manual." This is strictly a proprietary Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments document and a non-proprietary version will not be submitted. An affidavit for withholding will be submitted within two weeks of receipt from Westinghouse.
(j) Attachment 6 is the proprietary WINCISE FMEA. A non-proprietary version and affidavit for withholding will be provided within two weeks of receipt from Westinghouse.
Westinghouse is available to discuss any specific questions on the methodolo gy and hardware used in the Watts Bar Unit 2 IIS that the NRC believes are not well defined in the documents listed above.
361 7.7.1.1 EICB (Carte) Was the Foxboro IA system developed under a 10 CFR 50 Appendix B compliant program?
Foxboro I/A is a non-safety related system. Therefore, 10 CFR 50 Appendix B is not applicable.
- 32. Open Due 4/15/11 Open-NRC Review 362 7.6.1 7.6.7 EICB ( Kemper & Singh) OI #331 requested TVA to provide information regarding how the Loose Parts Monitoring System (LPMS) in-containment components (e.g., Accelerometer ( including the integral insulated hardline cable), Softline cable, and Remote Charge Preamplifiers)
were qualified for vibration as addressed in regulatory position C.1.g of RG 1.133, Rev. 1. TVA responded by stating that "TVA has reviewed the information provided by Westinghouse describing how the Loose Part Monitoring System (LPMS) sensor is qualified for normal operating conditions provided in Westinghouse letter WBT-D-2782, dated December 17, 2010 (Reference 11) as addressed in regulatory position C.1.g of Reg. Guide 1.133 and found it acceptable. Vibration qualification is not applicable to the softline cable. Due to the installation location (junction boxes mounted to the shield or fan room walls) and previous seismic qualification, vibration qualification of the charge converter/preamplifier is not required. This completes the response to this item."
However, the staff still desires further clarification on this response. Specifically, please provide a documented basis that demonstrates the LPMS in-containment equipment is qualified for normal operating conditions (e.g., test results compared to the equipment qualification specification), including vibration qualification. Also, provide justification for why vibration qualification if the Remote Charge Preamplifier is not required.
TVA committed to provide a letter on the docket (targeted is for 4/30/2011) stating why the the in-containment equipment has been qualified for vibration per RG 1.133, Rev. 1.
(1) Attachment 4 contains Westinghouse document "
WBT DMIMS-DXŽ Seismic Evaluation of the Digital Metal Impact Monitoring System (DMIMS-DXŽ) for Watts Bar Unit 2," EQ-QR-33-WBT, Revision 0 (proprietary). The non-proprietary version and affidavit for withholding will be submitted within two weeks of receipt from Westinghouse.
Attachment 5 contains Westinghouse non-proprietary white paper WBT-D-2782, "Westinghouse DMIMS-DX In-Containment equipment environmental specifications" EQ-EV-71-WBT-P, Revision 1, "Environmental Evaluation and Operating History of the Westinghouse DMIMS-DX Preamplifier and Softline Cable Used at Watts Bar 2" dated February 2011 was submitted on TVA to NRC letter dated Februay 25, 2011 (Reference 4). WEC to address vibration qualification of the accelerometer/hardline cable assembly.
(2) The Remote Charge Preamplifiers are mounted in junction boxes inside containment. The junction boxes are hard mounted either to the crane wall or to a fan room wall. The crane wall and fan room walls are subject to any significant vibration during normal operation.
- 5. Open-TVA NRC Update (WEK)--On March 27, 2011 TVA provided a
document WBT-D-2782 in response to this OI. This document provides the in-containment LPMS equipment qualification specification(s) and indicates that "-the normal environmental conditions for a Westinghouse containment are reported in Tables 6-1 and 6-2 from WCAP 8587 Rev. 6, "Methodology for Qualifying Westinghouse WRD Supplied NSSS Safety Related Electrical Equipment". These tables are attached."
The EQ specifications are included in the document, however, the documented basis that demonstrates the in-containment equipment has
been successfully tested to
meet or exceed its EQ specification is not included. Please include the in-containment EQ test results.
Open-TVA/Bechtel 363 7.5.1.1.3 and 7.9.1 7.5.2 EICB (Rahn and Mossman) OI#199 requested TVA to provide information concerning how TVA plans to meet regulatory criteria for Quality (10 CFR 50.55a(a)(1)) associated with the Technical Support Center and Nuclear Data Link. TVA responded in Letter Dated October 5, 2010, Item 63; however, TVA's response does not address the quality aspects of these system features. A similar question had been asked for Quality Criteria adherence for the SPDS and the BISI functions of TVA Procedure SPP-2.6 "Computer Software Control" has been superseded by TVA Procedure NPG-SPP-12.7, "Computer Software Control," Revision 0, dated December 17, 2010 (Attachment 3).
To ensure quality, the design, testing, and inspection of all Integrated Computer System (ICS) software including a)
- 6. Due 4/30/11 Open-TVA/Bechtel Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments the Integrated Computer System. In response to that request (same letter) TVA provided a description of TVA procedures, BISI software development procedures, and various management measures that will be taken to assure high quality in the design, operation, and maintenance of the SPDS and BISI functions of the ICS. Since the TSC and Nuclear Data Link information originates in the SPDS function of the ICS, are there any aspects of the quality measures that apply to the TSC and NDL features developed as part of quality processes for the ICS that are applicable to the data communications features?
Specifically, what is the scope of TVA Procedure SPP-2.6 "Computer Software Control"? How does it apply to the ICS
functions of a) SPDS, b) BISI, and c) TSC and NDL functions? Wouldn't there be aspects of the quality procedures that apply to the development, maintenance, and operations of the software needed to support the data communications features. Also, what quality measures will be applied to develop, maintain, and operate the hardware that accomplishes the TSC and NDL functions to ensure that these features will be reliable and available when
needed? SPDS, b) BISI and c) Technical Support Center (TSC) and Nuclear Data Link (NDL) functionality is controlled by qualified personnel in accor dance with TVA procedure NPG-SPP-12.7. The TSC and NDL functions are provided and performed by the ICS and, in the case of NDL, the Central Emergency Control Center (CECC) computers in Chattanooga.
Any changes to ICS software must be documented and controlled using TVA procedure NPG-SPP-12.7. This includes the a) SPDS, b) BISI and c) TSC and NDL functions. The procedure details controls and processes required for the development, modification, and configuration management of computer software used to support the design, operation, modification, and maintenance of TVA's nuclear power plants consistent with the Nuclear Quality Assurance Plan.
Controls in NPG-SPP-12.7 guide the development and testing of the software changes. Other controls established by this procedure to further maintain quality standards are: The application custodian implements controls to prevent unauthorized changes to the software. Changes are made in a non-production environment, and validation testing takes place before the change is installed on the ICS when possible. Once validation testing begins, the source code is placed under configuration control. When the modifications are installed on the ICS, an operability test is performed to demonstrate that the software is installed correctly and is functioning correctly in its operating environment. Documentation related to ICS software changes are QA records. The software source code is kept in a physically secure, environmentally controlled space to prevent inadvertent changes. Cyber security considerations are also considered in the storage environment. The data goes through several validation steps before being presented to the operators. When redundant sensors are used, the data received by the computer can be processed by software to determine if the quality of one or more points is questionable.
The hardware involved in the TSC and NDL functionality is verified to be operable on a periodic basis.
In the case of the NDL functionality, the ICS transmits the required data to the CECC on a continuous basis. The CECC monitors the status of the ICS data communications and alarms are generated when the link is not active. The Emergency Plan (EP) staff conducts a quarterly test that verifies that NDL data is successfully transmitted from each unit to the NRC.
364 7.5.2.2 7.5 CB (C ar t On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an evaluation of the Common Q PAMS against the current staff
- 1. Attachment __
contains the evaluation of the Common Q PAMS against the regulatory requirements in IEEE
- 1. N Open Due 5/15/11 Open-TVA/WEC NNC 4/125/2011: See Open Item No.
- 81.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments position.
By letter dated 2/25/11 (ML110620219
), TVA docketed a response: TVA performed an analysis and concluded that the Common Q PAMS equipment does not need to meet either IEEE 279-1971 or
IEEE 603-1991 and so no analysis was performed or provided.
However, SRP (NUREG-0800 Rev. 2 dated March 2007) Section 7.7, "Information System Important to Safety," specifically identifies IEEE Std 603-1991 as being applicable to accident monitoring instrumentation. Based upon the review of this item, the staff finds the following open items:
1 TVA to demonstrate that the Common Q PAMS meets the applicable regulatory requirements in IEEE Std 603-1991. 2 TVA to updated FSAR (Amendment 103) Table 7.1-1 to reference IEEE Std 603-1991 for WBN2 Common Q PAMS and Sorento Containment High Radiation Monitors.
Std 603-1991. (Awaiting response from Westinghouse)
- 2. Table 7.1-1 will be updated to reference IEEE Std 603-1991 for the Common Q PAMS.
TVA has reviewed the requirements of IEEE Std 603-1991 for the Sorrento Containment High Range Radiation Monitors and determined that IEEE Std 603-1991 is not applicable. IEEE 603-1991 is applicable to actuation systems. While TVA lists the containment high range radiation monitors as RG 1.97 Revision 2 Typa A variables, the classification is not based on the RG 1.97 requirements which states:
"Type A, those variables that provide primary information needed to permit the control room operating personnel to take the specified manually controlled actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for design basis accident event." TVA calculation WBN0SG4047, "
PAM Type "A" Variables Determination" uses a broader definition. The calculation definition is:
"The type "A" variables will be divided into three groups based on the parameter's purpose. The groups are: (1) event identification, (2) event recovery to plant stabilization, and (3) maintaining the stabilized conditions from event recovery to hot standby. Following a reactor trip, the termination point for transients at WBNP is considered a stabilized condition at hot standby per chapter 15 of the WBN FSAR. Event recovery actions are those manual actions taken to mitigate a design basis accident to a stabilized condition. The plant can be considered stabilized when the plant parameters var y slowl y and automatic s y stems are not being initiated. The diagnostic process consciously performed by the operator via the plant variables to interpret an event indication will be considered as a safety-related operator action regardless of the lack of manual manipulation of equipment. This diagnostic process is necessary to enable the operator to distinguish the "type" of transient and take the correct mitigating actions."
A review of TVA calculation WBN0SG4047 and the associated Emergency Instructions found that there are no operator actions that are meet the RG 1.97 Revision 2 definition for a Type A variable which are based on the containment high range radiation monitors. Based on this review, IEEE 603 is not applicable to the containment high range radiation monitors.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments 365 7.5.2.2 7.5 EICB (Carte)
On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an evaluation of the Common Q PAMS against the current staff position.
By letter dated 2/25/11 (ML110620219
), TVA docketed a response: "that WBN2 is not committed in complying with Reg. Guide 1.75-Since WBN2 is not committed to RG 1.75 or IEEE-384, no comparison is required-"
However, WBN2 is committed to RG 1.75 Rev. 2, "Physical Independence of Electric S ystems." RG 1.75 Rev. 3 and IEEE Std. 384-1992 are used, in part, to address IEEE Std 603-1991 Clause 5.6.1. The current NRC staff position for RG 1.75 is documented in Rev. 3. Based upon the review of this item, the staff finds the following open item: 1 TVA to updated FSAR (Amendment 103) Table 7.1-1 to include RG 1.75 Rev. 3 for WBN2 Common Q PAMS and the
Sorento Containment High Radiation monitor.
The Common Q PAMS was designed to meet the requirements of RG 1.75 Rev. 2. WBN2 did not perform an analysis to RG 1.75 Rev. 3. Based upon the review of this item, the staff finds the following open item: 2 TVA to evaluate Common Q PAMS and the Sorento Containment High Radiation monitor for conformance with RG
1.75 Rev. 3.
- 2. Open Due 5/15/11 Open-TVA/WEC NNC 4/125/2011: See Open Item No.
- 81. 366 7.5.2.2 7.5 EICB (Carte)
On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an evaluation of the Common Q PAMS against the current staff position.
By letter dated 2/25/11 (ML110620219
), TVA docketed a response: TVA stated that the Common Q PAMS equipment fully meets the RG 1.100 Rev. 0 and is compliant with Rev. 3, with exception of testing above 33 Hz, which is not applicable to Watts Bar.
The WBN2 FSAR (Amendment 103) references Regulatory Guide 1.100 Rev. 1 "Seismic Qualification of Electrical Equipment for Nuclear Power Plants." The Common Q PAMS was designed to meet the requirements of RG 1.100 Rev. 2. RG 1.100 Rev. 3 is the current revision of this guide and is endorsed by the NRC. RG 1.100 Rev. 3 endorses IEEE 344-2004.
Based upon the review of this item, the staff finds the following
open item: 1 TVA to updated FSAR (Amendment 103) Table 7.1-1 to include RG 1.100 Rev. 3 for WBN2 Common Q PAMS and the
Sorento Containment High Radiation monitor.
or 2 TVA to evaluate Common Q PAMS for conformance with RG 1.100 Rev. 1.
- 3. N Open Due 5/15/11 Open-TVA/WEC NNC 4/125/2011: See Open Item No.
- 81.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments 367 7.5.2.2 7.5 EICB (Carte)
On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an evaluation of the Common Q PAMS against the current staff position.
By letter dated 2/25/11 (ML110620219), TVA docketed a response.
The WBN2 FSAR (Amendment 103) references RG 1.153 Rev. 0, "Criteria for Safety Systems." The Common Q PAMS is designed to meet the requirements of RG 1.153 Rev. 1. By letter dated February 25, 2010 (ML110620219), TVA stated: "The subject Regulatory Guides [RG 1.153 Rev. 0 & 1] endorse and reference other standards. Common Q PAMS has been evaluated to comply with the requirements of these other endorsed standards ([Comparison report in this letter titled IEEE-279-1971 to IEEE-603-1991 Comparison]). Therefore no additional anal ysis needs to be performed and no further action is necessary." However, the "Comparison report in this letter titled IEEE-279-1971 to IEEE-603-1991 Comparison," stated:
"The first of the two standards, IEEE-279, is part of the design basis of WBN2 but is not relevant to Common Q PAMS. The second standard, IEEE-603-1991 is not part of the design basis for the Common Q PAMS forWBN2." Based on the reasoning quoted above, WBN2 did not evaluate the Common Q PAMS against the criteria of RG 1.153 Rev. 1; therefore, the staff finds the following open item (see also Open
Items No. 1 & 2 above.): 1 TVA to evaluate Common Q PAMS for conformance with RG 1.153 Rev. 1.
- 4. N Open Due 5/15/11 Open-TVA/WEC NNC 4/125/2011: See Open Item No.
- 81. 368 7.5.2.2 7.5 EICB (Carte)
On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an evaluation of the Common Q PAMS against the current staff position.
By letter dated 2/25/11 (ML110620219), TVA docketed a response.
The WBN2 FSAR (Amendment 103) references RG 1.152 Rev. 0, "Criteria for Digital Computers in Safety Systems of Nuclear Power Plants." The Common Q PAMS was designed to meet the requirements of RG 1.152 Rev. 1. RG 1.152 Rev. 2 is the current revision of this guide and is endorsed by the NRC. By letter dated February 25, 2010 (ML110620219), TVA stated: "RG 1.152 rev 2 endorses ANSI/IEEE-ANS-7-4.3.2-2003, but also provides extra regulatory guidance concerning computer based cyber security. Since this revision was not part of the design basis of WBN2 or Common Q PAMS, the project makes no commitment to the compliance of RG 1.152 rev 2." Based upon the review of this item, the staff finds the following
open item: 1 TVA to evaluate Common Q PAMS for conformance with RG 1.152 Rev. 2. Attachment 6 contains the evaluation for Common Q PAMS for conformance with RG 1.152 Revision 2
- 5. N Open Due 5/15/11 Open-TVA/WEC NNC 4/125/2011: See Open Item No.
- 81. 369 7.5.2.2 7.5 EICB (Carte)
On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an evaluation of the Common Q PAMS against the current staff position.
By letter dated 2/25/11 (ML110620219), TVA docketed a response.
The WBN2 FSAR (Amendment 103) references IEEE 7-4.3.2-1982, "IEEE Standard Criteria for Digital Computers in Safety
- 6. N Open Due 5/15/11 Open-TVA/WEC NNC 4/125/2011: See Open Item No.
- 81.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Systems of Nuclear Power Generating Stations" as endorsed by Regulatory Guide (RG) 1.152, "Criteria for Use of Computers in Safety Systems of Nuclear Power Plants," Revision 0 for the Eagle 21 system. The current regulatory position is documented in RG 1.152 Rev. 2 which endorses IEEE Std 7-4.3.2-2003 as an acceptable method for using digital computers to meet IEEE Std 603-1991. Based upon the review of this item, the staff finds the following open item:
1 WBN2 to updated FSAR Table 7.1-1 to reference IEEE 7-4.3.2-2003 as being applicable to WBN2 Common Q PAMS and the Sorento Containment High Radiation monitor.
370 7.5.2.2 7.5 EICB (Carte)
On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an evaluation of the Common Q PAMS against the current staff position.
By letter dated 2/25/11 (ML110620219), TVA docketed a response.
The WBN2 FSAR (Amendment 103) does not reference RG 1.168, IEEE 1012, or IEEE 1028. IEEE Std 7-4.3.2-2003 indentifies IEEE Std 1012-1998 as normative. RG 1.168 Rev. 1 endorses, with clarifications, IEEE 1012-1998. The current staff positions are documented in RG 1.168 Rev. 1, IEEE 1012-1998, and IEEE 1020-1997. Based upon the review of this item, the staff finds the following open item: 1 WBN2 to updated FSAR Table 7.1-1 to reference RG 1.168 Rev. 1, IEEE 1012-1998, and IEEE 1020-1997 as being applicable to WBN2 Common Q PAMS and the Sorento Containment High Radiation monitor.
- 7. N Open Due 5/15/11 Open-TVA/WEC NNC 4/125/2011: See Open Item No.
- 81. 371 7.5.2.2 7.5 EICB (Carte)
On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an evaluation of the Common Q PAMS against the current staff position.
By letter dated 2/25/11 (ML110620219), TVA docketed a response.
The WBN2 FSAR (Amendment 103) does not reference
Regulatory Guide 1.209, "Guidelines for Environmental Qualification of Safety-Related Computer-Based Instrumentation and Control Systems in Nuclear Power Plants." Based upon the review of this item, the staff finds the following open item:
1 WBN2 to updated FSAR Table 7.1-1 to reference RG 1.209 and IEEE Std. 323-2003 as being applicable to WBN2 Common Q PAMS and the Sorento Containment High Radiation monitor. TVA did not docket an evaluation against the criteria in RG 1.209. Based upon the review of this item, the staff finds the following open item:
2 WBN2 to evaluate Common Q PAMS for conformance with RG 1.209 and IEEE Std. 323-2003.
- 8. N Open Due 5/15/11 Open-TVA/WEC NNC 4/125/2011: See Open Item No.
- 81. 372 7.5.2.2 7.5 EICB (Carte)
On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an evaluation of the Common Q PAMS against the current staff position.
By letter dated 2/25/11 (ML110620219), TVA docketed a response.
The requirements in the SysRS and SRS are not traceable back to
the design basis (e.g., IEEE Std 603-1991 Section 4) for the system. The SRS does not include any documented evidence that
- 1. Attachment 7 contains the evaluation for how the Common Q PAMS SysRS and SRS implement the design basis requirements of IEEE 603-1991 Clause 4.
- 2. 9. N Open Due 5/15/11 Open-TVA/WEC NNC 4/125/2011: See Open Item No.
- 81.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments it was ever independently reviewed in accordance with the 10CFR50 Appendix B Criterion III, "Design Control." (Note: It appears that the only Common Q or WBN2 PAMS document that was independently reviewed in accordance with 10 CFR 50 Appendix B requirements is the SysRS.)
Based upon the review of the SysRS and SRS, the staff finds that there is reasonable assurance that the systems fully conform to the applicable guidelines, except for the following open items:
1 TVA to produce an acceptable description of how the SysRS and SRS implement the design basis requirements of IEEE 603-1991 Clause 4. 2 TVA to produce a final SRS that is independently reviewed in accordance with 10CFR50Appendix B, "Criterion III Design Control," requirements.
373 7.5.2.2 7.5 EICB (Carte) The SDDs do not include any documented evidence that they were independentl y reviewed in accordance with the 10CFR50 Appendix B Criterion III, "Design Control."
Based upon the review of the SDDs, the staff the following open
item: 1 TVA to produce final SDDs that are independently reviewed in accordance with 10 CFR50 Appendix B Criterion III, "Design Control," requirements.
- 10. N Open Due 5/15/11 Open-TVA/WEC 374 7.5.2.2 7.5 EICB (Carte) By letter dated October 29, 2010 (ML103120711), TVA docketed a draft technical evaluation associated with an engineering design change (ML103120712) that states the Common Q PAMS will require changes in the technical specifications. The technical specifications (TS) have not be received y et for review. The TS will be reviewed once they are received. 1 Confirm/Verify Technical Specification changes associated with Common Q PAMS are acceptable.
- 1. The Technical Specification Changes required by implementation of the Common Q PAMS were made in Revision B of the Technical Specifications which were submitted on TVA to NRC letter dated Februar y 2, 2010, "Watts Bar Nuclear Plant (WBN) - Unit 2 - Developmental Revision B of the Technical Specifications (TS), TS Bases, Technical Requirements Manual (TRM), TRM Bases; and Pressure and Temperature Limits Report (PTLR)" ADAMS ascension number ML100550326 (Reference 2).
- 11. N Open Due 5/15/11 Open-TVA/WEC 375 7.7.9 EICB (Alvarado)
- 1. During the conference call held on 4/12, the staff requested TVA to provide a description of the differences in hardware and/or software design and implementation of the Incore Instrumentation System instrumentation between WBN2 and WBN1. This information was not included in the 4/15 letter. When will this be provided?
- 2. The response for item g provided by TVA does not describe how the regulatory requirements were met. It only listed the criteria and stated that it passed the test. Also, the criteria for IITA does not list criteria for environmental qualifications of
safety-related equipment (e.g., RG 1.29, Environmental Equipment Qualifications). Please provide summary test reports.
- 3. Attachment 4 of the TVA letter 4/15 states that the CET and CET cable assembly, as well as mineral insulated cables and IITA connectors, are EQ and class 1E qualified. Please provide the qualification summary test report for these components.
- 4. Attachment 5 of the TVA letter 4/15 provides the hardware description for the WINCISE (WEC document NO-WBT-002).
Does this document include a section for Software Description? If so, please provide a copy.
- 12. N Open Open-TVA/WEC Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments
- 5. Attachment 7 of the TVA letter 4/15 describes the functionality of the IIS for Watts Bar unit 2 and the IIS used in AP-1000. The description provided only describes the similarity for the core exit thermocouple (CET) and the PAMS system.
However, this document does not describe the other components of the IIS (e.g. IITAs). Please clarify if the only similarity between Watts Bar unit 2 and AP-1000 is for the CETs and PAMS, and that there is not similar for the IITAs.
- 6. The WCAP-12472-P-A for the BEACON system describes that the system has three operational levels: on line
monitoring, tech spec monitor (TSM), and direct margin monitor. For Unit 1, TVA requested approval of the Beacon TSM to be only used as a tech spec monitor for present peaking factor limits. Please confirm that the functionality to
be implemented in Unit 2 is the same than the one requested and approved for unit 1. Note Attachment 5 states that the Beacon servers run the Beacon TSM, but it is not clear that this is the only level operating for the IIS.
- 7. The SE for use of the Beacon System in Unit 1 states that the BEACON system will be used when thermal power is greater than 25% RTP. Page 129 of Attachment 4 states that "the WINCISE system will be capable of performing its required
core monitorin g functions at or above 20%RTP." Please clarif y what the intent is for the Beacon system in Unit 2.
- 8. The technical evaluation provided for the Beacon System for unit 1 states that "the movable incore detectors (MIDs) are used for periodic calibration of the PDMS when thermal power is greater than 25% RTP. Additionally, the MIDs are used whenever the PDMS is inoperable or whenever power distribution is below 25%." Plea se explain how this function will be performed with the fix incore detectors and the Beacon system for unit 2.
- 9. In the NRC SE for WCAP-12472-P-A for the BEACON system, the staff accepted this system but subject to three conditions. In the TVA submittal for use of the Beacon system in unit 1, TVA described how they met these conditions for Unit 1. Please describe how TVA will meet these conditions
for Unit 2.
- 10. Please clarify the following statement provided in Attachment 4, Page 25: "During certain accident scenarios, it is possible for the CETs to see temperatures up to 20 deg F different from Unit 1."
- 11. Attachment 4 and 5 explained that the Mineral Insulation cable allows the isolation of the core exit thermocouples (1E) and self-powered neutron detector (non-1E) signals. Please provide the analysis that evaluated this separation, as well as the evaluation that show that failure of the non-1E si g nal won't affect the 1E signal.
- 12. Page 129 of Attachment 4 states that a minimum of three thermocouples are operable in each quadrant. Table 7.5-2 of the SSER (R.G. 1.97) states that 4 thermocouples should be Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments operable in each quadrant. Please explain if TVA is deviating from the requirements in R.G 1.97, and how this is justified.
- 13. Please provide information regarding the effects of a software common cause failure (SWCCF) on the IIS.
- 14. The FMEA provided by TVA on 4/15 has not been updated (see email from Steve Clark on 4/11). Also, the FMEA provided focus on failures during installation and commissioning and it does not identify measures for failures during operation. Last, this FMEA does not address software failures, only component failures and installation failures.
Please provide an updated and complete version of the FMEA
- 15. A ttachment 4, TVA document "Incore Instrumentation S ystem" describes the system requirements. Therefore, provide a complete system description of the IIS for the staff to evaluate the IIS to be installed in Watts Bar Unit 2.
Also, the description for the incore thermocouple system in this TVA document is inconsistent with the description provided in Westinghouse WINCISE Hardware Description (Attachment 5). For example, Section 1.2 of the TVA document states that there are 65 incore thermocouples and Section 2.2.9 describes that the incore thermocouples provide an input signal to the Inadequate Core Cooling Monitor.
- 16. TVA attachment 4 of the 4/15 letter show modifications to the DBE design criteria. Please provide detailed explanation about these modifications.
- 17. Please explain if new penetration and routing were required for IIS' signals. If new penetrations are required, explain how these were qualified. Also, explain the criteria used to route the power/control cables.
- 18. Questions on Technical Specification: (1) The TVA package states that TS 3.1 and TS Bases 3.1 were modified due to WINCISE. Please provide detailed information to evaluate the modifications to the TS. (2) The TVA mark up does not define the operating limits in the TS for the reactor power distribution. Please provide detailed information on how the IIS may impact the Technical Specification.
- 19. Redundancies are designed and built into the signal processing system to avoid impacting operation in the event of the loss of some SPD signals. The master signal processing rack data interface card provides the output data stream to the Application server. Each cabinet master si gnal processor rack contains redundant data interface cards. Loss of one data interface card will not result in a loss of data output from the cabinet. Provide detailed description on how this works (e.g., is the switchover software based?)
- 20. The Application Servers receive information from Signal Processing System (SPS Cabi nets), Integrated Computer System (ICS), and BEACON. The WINCISE IP Switches provide the main hub for traffic flow from the SPS cabinets, BEACON servers, Application Servers, and ICS. Provide Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments detailed description of the communication among the Integrated Computer System (ICS) and the Beacon System and the Wincise's Application servers.
- 21. A ttachment 4, TVA document "Incore Instrumentation S ystem" describes that the WINCISE system includes a Domain server, which provides a supportive function and is not required for the PDMS to receive needed information from the Application Server. However, the domain server provides an environment for the development and maintenance of application and system software. Please explain how this domain server will be configured and used for WINCISE in WBN2. Note that the domain server is not part of the Westinghouse WINCISE Hardware Description (Attachment 5)
- 22. Page 52 of Attachment 4, question 1.5 was answered yes, but the I&C calculation to be provided in Sections 4 and 5 is not included. Please explain if this calculation was performed, and if so provide a description.
- 23. Pa ge 52 of Attachment 4, Section 6 does not include the block diagram of the proposed modification to WBN2. Please provide a block diagram if the system, including power sources.
376 7.7.9 EICB (Alvarado)
DCI-CVIB Input:
Reference-EDCR # 52321, Revision A-EDCR Unit Difference Form --- Bechtel Document
Page 2 -Maintenance Difference-The proposed In-Core Instrument Thimble Assemblies (IITAs) which will replace Movable In-C ore Detectable Systems (MIDs) have the following features:
(1) IITAs are not fully extracted and they are held in a movable frame assembly.
(2) IITAs exert lower vibration amplitude and therefore, aging degradation due to wear does not occur.
(3) Loss of reactor coolant system pressure boundary due to breach of IITA outer sheath does not occur.
Question:
The staff believes that the licensee should provide an inspection program to confirm that the aforementioned attributes associated with IITAs are valid and this inspection program can be a part of a routine maintenance program.
Replacement of 58 CETs for the current 65 CETs -to be addressed by the fuels division.
- 13. Related to OI 360 377 7.7.9 EICB (Alvarado) 1. (a) Further explanation is required for the sentence in EDCR 52321 Rev A Page 2, "During certain accident scenarios, it is possible for the CETs to see temperatures up to 20 degree F different from Unit 1". 14.
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments (b) Which accident scenarios the above statements refer to? (c) Compare the accuracy for flux mapping with movable detectors (MIDS) and fixed detectors such as SPDs.
- 2. Explain how the linear heat generation rate is monitored using the new IITA system.
- 3. (a) Page 26 of the EDCR 52321-A states that "certain SPS electronics cannot withstand the increased pressure during an Integrated Leak Rate Testing (ILRT). As a result, these SPS electronics need to be removed prior to starting the ILRT." If SPS electronics does not survive an ILRT, what will be their status during a design basis accident, such as, loss of coolant accident?
(b) Page 129 of EDCR 52321-A Item Number 7 CET
Requirements states that "The CET must be operable before, during, and after a design basis accident without loss of safety function, and for the time required to perform the safety function."
Does this CET requirement conflict with the scenario in Part (a) above, such that the malfunction of the electronics during high pressure during the design basis accident?
- 4. BEACON Power Distribution Monitoring System (PDMS)
with WINCSE seems to be functioning different from old conventional BEACON monitoring system. Explain the differences between the new and old system and the advantages, if any, of the new system over the old one.
- 5. EDCR 52321-A Page 129 (WBN2-94-4003 Rev 0000 Page 18 of 41) "WINCISE Requirements" Sections 1 and 2 specify minimum requirements for inputs from SPDs such that "the
WINCISE s ystem shall not require input from 75%
(50% for Section
- 2) of the instrumented locations, with at least five operable SPD associated with the top half of the active core and at least five operable SPD associated with bottom half of the active core per quadrant,-." Section 3 states that "The WINCISE System will be
capable of performing its required core monitoring functions at or above 20% RTP." Provide documents supported by analyses that will show that the incore monitoring systems and the CET system will be fully capable of performing the intended functions under the circumstances prescribed in Sections 1, 2 and 3 of "WINCISE Requirements."
- 6. Section 6.0 of WCAP-12472-P-A Addendum 2-A stipulates that in addition to maintaining power distribution Technical Specification that require surveillance of parameters related to hot rod power and local power density, it will be necessary for the licensees to include a BEACON Operability specification in the
Technical Requirements Manual (TRM) associated with either the NUREG-1430 or NUREG-1432 format TS. Are the minimum requirements (50% and 75% of the instrument locations input) and functions of WINCISE and CET systems specified in Sections 1 through 6 of "WINSCISE Requirements" included in the WBN-2 Technical Specifications? If the answer is "no", explain wh
- y. Also, please provide the agency with a copy of the Technical
Requirements Manual for the WINCISE system proposed for WBN-
2 Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) radD9A82.docx Open Items to be Resolved for SER Approval No. SE Sec. FSAR Sec. NRC POC Issue TVA Response(s) Response Acceptable Y/N Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments
- 7. NRC Staff's search for references listed in Section 7 of EDCR 52321-A resulted in lack of any specific reference to Westinghouse Topical Report in the EDCR 52321-A.
(a) Please specify which of the Addendums for WCAP 12472 Topical Report or any other Westinghouse TR is the basis for the planned WINCISE system to be installed at Watts Bar -2.
(b) Provide the Agency with all relevant calculations and analyses supporting the proposed WINCISE system for Watts Bar 2.