ML102571908
| ML102571908 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar |
| Issue date: | 08/30/2010 |
| From: | Office of Nuclear Reactor Regulation |
| To: | Division of Operating Reactor Licensing |
| References | |
| Download: ML102571908 (53) | |
Text
1 WBN2Public Resource From:
Bailey, Stewart Sent:
Monday, August 30, 2010 4:07 PM To:
'Crouch, William D' Cc:
Poole, Justin
Subject:
Open item list Attachments:
20100827 Open Items List Master - sent version.xlsx I think I forgot to send this last Friday.
Hearing Identifier:
Watts_Bar_2_Operating_LA_Public Email Number:
100 Mail Envelope Properties (87B1F1BDFE5A554CA9DC5EAA75EB6D0D231179056E)
Subject:
Open item list Sent Date:
8/30/2010 4:07:05 PM Received Date:
8/30/2010 4:07:08 PM From:
Bailey, Stewart Created By:
Stewart.Bailey@nrc.gov Recipients:
"Poole, Justin" <Justin.Poole@nrc.gov>
Tracking Status: None
"'Crouch, William D'" <wdcrouch@tva.gov>
Tracking Status: None Post Office:
HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 44 8/30/2010 4:07:08 PM 20100827 Open Items List Master - sent version.xlsx 176446 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments 19-Nov-09 Originator: EICB (Carte)
Date: 3/15/2010 Responsibility: NRC (All) and TVA (Hilmes)
December 11, 2009 (ML093431118, RAI 6)
NRC POC: EICB (Garg)
Date: 2/16/2010 Responsibility: NRC (Garg)
December 11, 2009 (ML093431118, RAI 7)
NRC POC: EICB (Garg)
Date: 1/13/2010 Responsibility: NRC (Garg)
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action 6
1/13/10 Public Meeting: Responder: Webb TVA identified a schedule for docketing some Post Accident Monitoring System (PAMS) documentation, and the new setpoint methodology. No other documentation was discussed.
Add: By letter dated June 30, 2010, TVA docketed WNA-LI-00058-WBT-P &-NP, "PAMS Licensing Technical Report." WNA-LI-00058-WBT-P Section 4.11 addressed CCF and BTP 7-19.
TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 4 on Page 3 of 15): TVA responded to this request for additional Information Foxboro I/A Segmentation Analysis Calculation DCSSEGMENT, Rev. 0 submitted on TVA letter dated August 11, 2010.
4 Please identify the information that will be submitted for each unreviewed digital I&C system and component and the associated docketing schedule.
TVA to address the question of how a Foxboro IA common mode or complete failure impacts the plant accident analysis as described in Chapter 15 of the FSAR. (Demonstrate segments are independent and how a common mode or complete failure is prevented by power supply design and segmentation.)
NNC 8/19/10: The justification for not performing and D3 analysis contained in the CQ PAMS Licensing Technical Report is not acceptable. TVA to docket a D3 analysis for the CQ PAMS.
NNC 8/25/10: The segmentation analysis has been read. Please explain why it is believed that faliure will not propagate over the peer-to-peer network.
Amendment 95 of the FSAR, Chapter 7.3, shows that change 7.3-1 consists of updating a reference from revision 5 to revision 7 and making it applicable to Unit 1 only, while adding a new reference, applicable only to Unit 2.
Reagan, J. R., "Westinghouse Setpoint Methodology for Protection Systems, Watts Bar Units 1 and 2, Eagle 21 Version," WCAP-12096 Rev. 7, (Westinghouse Proprietary Class 2). Unit 1 Only WCAP Westinghouse Setpoint Methodology for Protection System, Watts Bar Unit 2, Eagle 21 Version, WCAP-17044-P. Unit 2 Only.
Please provide both setpoint methodology documents identified above.
The Westinghouse Setpoint methodology document (WCAP-17044-P Revision 0) identifies that the intermediate and source range calculations were performed by TVA (2-NMD-092-0131). Please provide the intermediate and source range calculations performed by TVA (2-NMD-092-0131).
The Westinghouse Setpoint methodology document (WCAP-17044-P Revision 0) identifies that the undervoltage and underfrequency calculations were performed by TVA (2-27-068-0031). Please provide the undervoltage and underfrequency calculations performed by TVA (2-27-068-0031).
Work with Item 7 for WCAP-12906 issues.
By letter dated February 5, 2010: TVA provided the Unit 2 setpoint methodology (WCAP-177044-P Revision 0 - dated December 2009).
TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 6 on Page 7 of 15): TVA responded to this request for additional Information.
- a. TVA to docket Rev. 8 and identify that Rev. 8 is the current revision for Unit 1. TVA to identify any NRC approval of Rev. 8.
In accordance with item 2, below, there is no change to the methodology, therefore revision 8 is not included in this response.
Westinghouse letter WAT-D-10502 (Attachment 1) describes the two changes to WCAP-12096 Revision. 8. The first change addresses the containment sump level transmitter replacement. This change was submitted under 50.59 summary report (ML073460444, Page 77). The second change is to delete the power range negative flux rate trip. This item was submitted as a Technical Specification change (ML073201052). The Technical Specification change was subsequently approved.
The current revision of Unit 1 WCAP-12096 is Revision 9. Revision 9 was issued to make the changes required by the Steam Generator Replacement Project. Unit 2 is using the original steam generators, therefore the changes in Revision 9 are not applicable to Unit 2.
- b. TVA to describe how TVA calculations for Unit 2 are different than Unit 1. If they are the same, TVA to docket such statement under oath and Affirmation.
TVA response letter dated March 12, 2010, Enclosure 1, Item Number. 7 addressed this request; however, the March 12 letter was not submitted under oath and affirmation. This letter fulfills the oath and affirmation requirements for the previous response.
7 NNC 11/19/09: LIC-110 Rev. 1 Section
6.2.2 states
"Design features and administrative programs that are unique to Unit 2 should then be reviewed in accordance with current staff positions.TVA will supply a description of the changes implemented at Unit 1 but have not been reviewed for Unit 2 by the NRC technical staff...TVA will also provide the applicable portion of the FSAR and the proposed TSs...In addition, the staff should review items that are identical for WBN Units 1 and 2 that have not previously been reviewed and approved by the NRC staff. These items are changes in the design and licensing basis for WBN Unit 1 that TVA has implemented without NRC prior approval under the 10 CFR 50.59 process."
NNC 4/15/10: The response addresses many systems and should be read by all EICB reviewers.
TVA to docket a D3 analysis for the Common Q PAMS.
NNC 8/19/10: TVA segmentation analysis has been received -
NRC to review.
Same as Open Item 6 above.
NNC: WCAP-12096 Rev. 7 (ML073460281) is in ADAMS.
NNC: WCAP-12096 Rev. 8 is the current revision for Unit 1.
NNC 4/15/10: Hukam, please update this open item as appropriate.
TVA to docket Rev. 8 and identify that Rev. 8 is the current revision for Unit 1.
TVA to identify any NRC approval of Rev. 8.
TVA to describe how TVA calculations for Unit 2 are different than Unit 1. If they are the same, TVA to docket such statement under oath and Affirmation.
TVA to reference TI-28 for as found and as left value. Also provide the reference to FSAR Section 7.1 for the setpoint methodology.
November 19, 2010 ML093230343 RAI 4 January 13, 2010 March 12, 2010 June 30, 2010 August 11, 2010 NNC 4/15/10: Related to setpoints and SE Section 7.1.3.1.
TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 7 on Page 7 of 15): TVA responded to this request for additional Information.
File: rad8C078.xlsx Page 1 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action December 11, 2009 (ML093431118, RAI 10)
NRC POC: EICB (Darbali)
Date: 3/15/2010 Responsibility: NRC (Darbali)
December 11, 2009 (ML093431118, RAI 12)
NRC POC: EICB (Darbali)
Date: 3/15/2010 Responsibility: TVA December 11, 2009 (ML093431118, RAI 13)
NRC POC: EICB (Garg)
Date: 3/15/2010 Responsibility: NRC (Garg)
December 22, 2009 (ML093560019, item 4)
NRC POC: EICB (Darbali)
Date: 4/27/10 Responder: TVA Date: 4/27/10 Responsibility: NRC (Darbali)
RAI response received. NRC to review response.
TVA will submit WCAP-12096, Rev. 8 if there is a change to the methodology.
TVA will supply the 50.59 letter for Rev. 8 TVA to locate transmittal letter that submitted Rev. 7.
TVA to determine the last revision of WCAP-12096 where there was a change in methodology.
Work with Item 6 for WCAP-12906 issues.
The original SER on Watts Bar (NUREG-0847) documents that the scope of the review of FSAR Section 7.4, "Systems Required for Safe Shutdown," included single-line and schematic diagrams:
"The scope of the review of the systems required for safe shutdown included the single-line and schematic diagrams and the descriptive information for these systems and for the auxiliary systems essential for their operation."
Please provide the single-line and schematic diagrams for the systems required for safe shutdown that are applicable to Unit 2, and include a description of all changes since these diagrams were reviewed and approved by the NRC staff.
TVA provided the following:
- 1. Description of what is different from Unit 1
- 2. Road map between functions listed in 7.4 and the FSAR section that describes the equipment that performs the function. Item Closed.
17 Identify precedents in LARs, if any, for the solid state protection system. Also, identify any hardware deviation from the precedent.
By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 4).
Awaiting NRC evaluation of response.
TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 10 on Page 8 of 15): TVA responded to this request for additional Information.
TVA Letter (ML073550386) dated FEB 26 1992: docketed WCAP-12374 Rev. 1 (ML080500664).
10 The original SER on Watts Bar (NUREG-0847) documents that the scope of the review of FSAR Section 7.3, Engineered Safety Features Actuations System, included: included single-line, function logic and schematic diagrams, and descriptive information for the ESFAS and those auxiliary supporting systems that are essential to the operation of either the ESFAS or the ESF systems. The review included the applicant's design criteria and design bases for the ESFAS and the instrumentation and controls of auxiliary supporting systems. The review also included the applicant's analyses of the manner in which the design of the ESFAS and the auxiliary supporting systems conform to the design criteria."
Please provide the information referred to in the quotation and include a description of all changes since this information was reviewed and approved by the NRC staff.
If some parts of this information is included in the FSAR (e.g., Design Criteria) this information can be explicitly referenced in the response to this question.
NRC evaluating TVA response.
NRC to discuss document requirements and provide additional information to resolve this item.
12 The setpoint methodology has been reviewed and approved by the NRC staff in Section 7.1.3.1 of NUREG-0847 (ML072060490), NUREG-0847 Supplement No.4 (ML072060524), and NUREG-0847 Supplement No. 15 (ML072060488).
Please describe all changes from the methodology that has been reviewed and approved by the staff.
NNC 4/15/10: Related SE Section 7.3.
NRC Review RAI response received. Westinghouse is completing the setpoint calculations which will be completed by May 11, 2011. NRC to review response.
NRC Review NNC 4/15/10: Hukam, please update this open item as appropriate.
TVA to provide Rev. 8 of the Unit 1 document (which is the current one) if there is a change in methodology and identify how the Unit 2 document differs from it.
TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 12 on Page 13 of 15): TVA responded to this request for additional Information A revised response was included in the 7/30 letter that provides the requested information.
- a. TVA will submit WCAP-12096, Rev. 8 if there is a change to the methodology.
No change in methodology, therefore WCAP-12906, Revision 8 is not submitted.
- b. TVA will supply the 50.59 letter for Rev. 8 Westinghouse letter WAT-D-10502 (Attachment 1) describes the two changes to WCAP-12096 Revision. 8. The first change addresses the containment sump level transmitter replacement. This change was submitted under 50.59 summary report (ML073460444, Page 77). The second change is to delete the power range negative flux rate trip. This item was submitted and approved as a Technical Specification change (ML073201052).
- c. TVA to locate transmittal letter that submitted Rev. 7.
Refer to reponse to Item 1. TVA responded to this request for additional Information in letter dated March 12, 2010, Enclosure 1, Item Number 6.
- d. TVA to determine the last revision of WCAP-12096 where there was a change in methodology.
Previous revisions to WCAP-12096 have been due to hardware changes. The calculation methodology has not changed since revision 0.
NRC Review This item is closed for chapter 7. NRC will review T.S.
under different chapter.
NNC 4/15/10: Related SE Section 7.4.
TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 13 on Page 14 of 15): TVA responded to this request for additional Information 13 Chapter 7 and Chapter 16 of Amendment 95 to the FSAR do not include any setpoint values.
Please describe how and when setpoint values (e.g., TS allowable values) will be provided for Unit 2.
Please describe the information that will be provided to justify the acceptability of these values.
TS have been docketed.
NNC 4/15/10: Related to setpoints and SE Section 7.1.3.1.
NNC 4/15/10: Hukam, please update this open item as appropriate.
Related to SE Section 7.1.3.1.
File: rad8C078.xlsx Page 2 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action December 22, 2009 (ML093560019, item 6)
NRC POC: EICB (Garg)
Date: 4/27/10 Responder: TVA Date: 4/27/10 Responsibility: NRC (Garg)
December 22, 2009 (ML093560019, item 8)
NRC POC: EICB (Garg)
Date: 5/25/10 Responder: D. McNeil Date: 5/24/10 Responsibility: TVA December 22, 2009 (ML093560019, item 9)
NRC POC: EICB (Darbali)
Date: 4/27/10 Responder: McNeil Date: 4/27/10 Responsibility: NRC (Garg)
December 22, 2009 (ML093560019, item 11)
NRC POC: EICB (Carte)
Date: 4/27/10 Responsibility: NRC (Carte & Darbali) 22 No vendor system description is available for the Foxboro Spec 200 system. The hardware description and qualification documents are provided on a component level basis. A TVA generated system description is provided to assist the reviewer. The hardware differences from the unit 1 systems are provided in the loop and card comparison documents. As agreed with the reviewer, the component level documents are not required to be submitted at this time, but may be required later based on the review of attached documents. The following TVA generated documents are provided (Attachment 1):
- 1. Analog loop comparison
- 2. Analog card comparison
- 3. Analog system description The understanding reached in the meeting on April 14, 2010, was that TVA should identify any changes, or state under oath and affirmation that there were no changes. If there were no changes, then the NRC would confirm by inspection.
A revised response was requested at the 5/24/10 public meeting.
By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 9).
The control function of the Auxiliary Feedwater (AFW) Flow for Steam Generator Level is the same as Unit 1. The controllers and signal modifiers/conditioners are Foxboro SPEC 200 discrete analog modules as Unit 1 control loops. The only different Unit 1 uses a 10-50ma signal and Unit 2 is using a 4-20ma. The SPEC 200 control modules operate with a 0-10mv system for both Unit 1 and Unit 2.
The differences between the Units that have a control function for the AFW system is the differential pressure control upstream of the motor driven AFW pumps 2A-A and 2B-B. Unit 1 still has the analog Bailey/GEMac controllers and signal conditioners. Whereas Unit 2 has converted the controllers and signal conditioners to Foxboro SPEC 200 discrete analog components. Both loops still maintain a Fisher modifier for valve control.
The four (4) control loops are described below:
2-P-3-122A This loop controls the differential pressure of the Auxiliary Feedwater Pump 2A-A by varying valve 2-PCV-3-122. Differential Pressure Indicating Controller 2-PdIC-3-122A (on panel 2-M-4) can be used either in manual mode or in automatic mode. This loop controls this valve from the Main Control Room when transfer switch 2-XS-3-122 (on panel 2-L-11A) is in the normal position.
2-P-3-122C This loop controls the differential pressure of the Auxiliary Feedwater Pump 2A-A by varying valve 2-PCV-3-122. Differential Pressure Indicating Controller 2-PdIC-3-122C (on panel 2-L-
- 10) can be used either in manual mode or in automatic mode. This loop controls this valve from the Auxiliary Control Room when transfer switch 2-XS-3-122 (on panel 2-L-11A) is in the auxiliary position.
2-P-3-132A Verify the auxiliary feedwater control refurbishment results in a like-for-like replacement, and identify any changes from the identified precedents.
TVA should confirm if Woodward Governer is the only change.
Item will be closed based on resolution of item 285.
NNC 4/30/10: Carte to address response with respect to PAMS and Darbali to address response This item will remain open until TVA dockets all of the By latter dated April 27, 2010 TVA responded to this request for information (Enclosure 1, Item No. 6) for the ratemeter.
A newer model, RD-52, of the RD-32 detector assembly used in Unit 1. The detector assembly replacement is due to obsolescence and improved reliability.
Response unacceptable. Should discuss all changes.
19 Verify that the containment purge isolation radiation monitor is the same as used in Watts Bar Unit 1, or identify any hardware changes.
21 NRC Review NRC Review For the Foxboro Spec 200 platform, identify any changes in hardware from the precedent systems. Provide the design report and the equipment qualification information.
24 During the January 13, 2010 meeting, TVA presented a schedule for completing various documents for the PAMS system. This schedule did not support TVA's desired schedule.
TVA was so informed and said they would work on improving the schedule. TVA said that the File: rad8C078.xlsx Page 3 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action December 22, 2009 (ML093560019, item 12)
NRC POC: EICB (Singh)
Date: 4/27/10 Responder: TVA Date: 07/28/2010 Responsibility: NRC (Singh)
December 22, 2009 (ML093560019, item 15)
NRC POC: EICB (Garg)
Date: 4/27/10 Responder: Mark Scansen Date: 4/27/10 Responsibility: NRC (Darbali)
December 22, 2009 (ML093560019, item 17)
NRC POC: EICB (Garg)
Date: 4/27/10 Responder: Clark Date: 4/27/10 Responsibility: NRC (Garg)
February 4, 2010 NRC POC: EICB (Garg)
Date: 4/27/10 Responder: TVA Date: 4/27/10 Responsibility: NRC (All)
Responsibility: NRC (Garg)
Responsibility: NRC (Singh)
Responsibility: NRC (Garg)
Responsibility: NRC (Darbali)
Responsibility: NRC (Carte)
FSAR Section 7.5 Instrumentation Systems Important To Safety - SE Section 7.5.2 28 For the turbine control AEH system, verify that the refurbishment results in a like-for-like replacement.
By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 15).
The requested 50.59 is included in Attachment __.
Provide 50.59 evaluation. Response acceptable.
30 Regarding the refurbishment of I&C equipment, identify any component digital upgrades and, if so, provide the supporting design information.
By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 17).
There are no other I&C upgrades which contain an imbedded digital processor.
Does not state if there are no other upgrade which contain imbedded digital processor. Revised response acceptable.
Provide a schedule by the January 13, 2010, meeting for providing information in accordance with I&C Interim Staff Guidance (ISG) 6.
NRC Review and Darbali to address response with respect to RM1000.
TVA has agreed to submit the requested information on the docket.
dockets all of the information requested.
Design Basis Analysis Parameters Alternate Method for Use of Condenser Steam Dump FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 Chapter 7.3 - ESFAS Foxboro I/A Provide 50.59 34 TVA Revised Response. TVA to document revised response.
Reactor Coolant System Flow Rate Measurement By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 12).
NRC review in progress.
Awaiting NRC evaluation of response.
NRC Review 25 Loose Parts Monitoring Chapter 7.5 - Instrumentation Systems Important to Safety Containment Sump Level Transmitter Replacement Plant Process Computer Replacement Chapter 7.1 - Introduction Reactor Coolant System Flow Rate Measurement By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 21).
In the December 15, 2009 public meeting, TVA listed the significant changes made since the Watts Bar Unit 1 Licensing (see below). For each of the following significant changes:
- 1) Is the change unique to Unit 2, or will it be the same as whats currently installed in Unit 1?
- 2) If its the same as Unit 1, was this change made under a license amendment or under a 50.59?
- 3) When do you plan to submit the detailed information regarding the changes?
TVA was so informed and said they would work on improving the schedule. TVA said that the setpoint methodology would be provided shortly. No other systems of documentation was discussed.
By letter dated February 5, 2010 (see enclosure 1), TVA provided a list of documents and associated availability for PAMS.
By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 11).
By letter Dated June 18, 2010 (see Attachment 3) TVA providded a table, "Watts Bar 2 -
Common Q PAMS ISG-6 Compliance Matrix."
For the containment radiation high radiation monitor, verify that the information provided by TVA is consistent with the information provided with the previously-approved license amendment request for the Duane Arnold plant or provide Phase 3 information.
The explanations provided by TVA (that certain information is not required) are unacceptable.
NNC 8/18/10: The TVA agreement in the Comments column conflicts with the TVA responses to other open items where TVA states that information is available for audit.
Safety Injection Systems Cold Leg Accumulator Level Measurement System Design Basis Analysis Parameters Deletion of Neutron Flux Negative Rate Trip Common Q/PAMs Chapter 7.2 - Reactor Trip System Alternate Method for Use of Condenser Steam Dump Design Basis Analysis Parameters File: rad8C078.xlsx Page 4 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 1 on Page 1 of 15): TVA responded to this request for additional Information.
Responsibility: NRC (Garg)
Responsibility: NRC (Singh)
Responsibility: NRC (Garg)
February 18, 2010 NRC POC: EICB (Singh)
Date:
Responder: Clark Date: 2/18/2010 Responsibility: TVA February 18, 2010 NRC POC: EICB (Marcus)
Date: 5/25/10 Responder: Clark Date: 2/18/2010 Responsibility: TVA NRC POC: EICB (Marcus)
Date: 5/25/10 Responder: Clark Date:
Responsibility: TVA February 19, 2010: Audit NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 2/19/2010 Responsibility: TVA February 19, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 5/25/10 Responsibility: WEC Please provide a system description of the Digital Metal Impact Monitoring System that contains sufficient detail to support a review of this system using current staff positions.
Description provide is not of sufficient detail to allow a regulatory determination. TVA to send the proprietary information for NRC review.
TVA to provide a more detailed description of the loose parts monitoring system.
41 WINCISE /Power Distribution Monitoring System (Beacon)
Foxboro I/A Loose Parts Monitoring System NRC POC: EICB (Singh)
TVA Letter dated March 12, 2010 Enclosure 1, item 4 responded to this request for information.
The attached non-proprietary system description was developed from proprietary Westinghouse Watts Bar Unit 2 DMIMS-DX Operations and Maintenance Manual, 1TS3176 Rev.0 (Reference 1). Westinghouse approved this non-proprietary response via letter WBT-D-
____ dated August, 2010. The system description is contained in Attachment 2.
AMSAC Replacement Eliminate Pressurizer Backup Heaters on High Level Signal Alternate Means for Monitoring Control or Shutdown Rod Position Chapter 7.7 Control Systems 35 Plant Process Computer Replacement Chapter 7.6 - All Other Systems Required for Safety The slides presented at the December 15, 2010 meeting (ML093520967) indicate that the plant process computer has been replaced.
FSAR section 7.1.1.2 is revised in FSAR Amendment 100 submitted to the NRC on TVA letter to the NRC dated August __, 2010 includes the requested information.
August 19, 2010 - TVA to submit markup of FSAR Amendment 100.
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" Items (1) and (2) were docketed by TVA letter dated April 8, 2010.
Items (3), (4) and (5) WNA-CD-00018-GEN Rev. 3, "CGD for QNX version 4.5g," WNA-PT-00058-GEN Rev. 0, "Testing Process for Common Q Safety systems" and WNA-TP-00357-GEN Rev. 4, "Element Software Test Procedure" are available for audit at the Westinghouse Rockville office (Westinghouse letter WBT-D-1526, Reference 6).
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.
FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 See also Open Item Nos. 226 & 270.
FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 NNC 8/25/10: A CQ PAMS ISG6 compliance matrix was dockated on: (1)
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.
TVA to docket information indetified in ISG6.
TVA to provide date when information will be docketed.
TVA to docketed requested material.
TVA to provide date when information will be docketed.
43 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 first 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.
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 routs to review that the NRC can undertake: (1) follow ISG6, and (2) follow the CQ SPM. The TVA response that was orriginally persued was to follow ISG6, but some of the compliance items for ISG6 were addresed 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 applican 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 commercial grade dedication reports; this apparent deviation should be justified or explained.
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 providded a table, "Watts Bar 2 - Common Q PAMS ISG-6 Compliance Matrix."
It is TVAs understanding that this comment is focused on the fact that there are documents that the NRC has requested that are currently listed as being available for audit at the Westinghouse offices. TVA has agreed to provide all requested Common Q PAMS documents requested by the NRC. This item is considered closed.
LIC-110 Section 6.2.2 states: Design features and administrative programs that are unique to Unit 2 should be reviewed in accordance with the current staff positions. Unit 2 FSAR Section 7.6.7, Loose Part Monitoring (LPMS) system Description, describes a system design that is unique to Unit 2.
FSAR Amd 100 38 Please provide a description of the interfaces between: (1) the Safety Parameter Display System and (2) the Technical Support Center and Nuclear Data Links with the plant control and safety systems. This Description should contain sufficient detail to support a review of these interfaces using current staff positions.
FSAR Section 7.5, Instrumentation System Important to Safety, consists of two major subsections: 7.5.1, Post Accident Monitoring Instrumentation (PAM), and 7.5.2, Plant Computer System.
Regulatory Guide 1.70, Standard format and content of Safety Analysis Reports for Nuclear Power Plants, Revision 3 FSAR Amd 100 37 Is the plant computer a safety-related display system?
As identified in TVA letter dated March 12, 2010, Enclosure 1, item 2, the plant computer system is non-safety related.
FSAR section 7.5 describes both safety and non-safety related devices and systems. FSAR section 7.1.1.2 is revised in FSAR Amendment 100 submitted to the NRC on TVA letter to the NRC dated August __, 2010.
August 19, 2010 - TVA to submit markup of FSAR Amendment 100.
File: rad8C078.xlsx Page 5 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action April 8, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 4/8/10 Responsibility: TVA April 8, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 4/8/10 Responsibility: TVA April 8, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 4/8/10 Responsibility: TVA April 19, 2010 NRC POC: EICB (Darbali)
Date: 5/25/10 Responder: Slifer Date: 4/19/10 Responsibility: NRC April 19, 2010 NRC POC: EICB (Darbali)
Date: 5/25/10 Responder: Slifer Date: 4/19/10 Responsibility: NRC 50 How should the "shall" statements outside of the bracketed requirements be interpreted?
These sections are descriptive text and not requirements. The next revision of the Watts Bar Unit 2 PAMS System Requirements Specification will remove shall from the wording in those sections. A date for completing the next revision of the System Requirements Specification will be provided no later than August 31, 2010.
TVA response is inconsistent (e.g., WNA-DS-01667-WBT Rev. 1 page 1-1, Section 1.3.1 implies that "SysRS Section ###" has requirements.
See also SDS4.4.2.1-1 on page 4-32).
FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 Document not received from Westinghouse on schedule. This item will be delayed.
FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 TVA to revise response or other documentation.
TVA to provide date when information will be docketed.
TVA to provide requestd information TVA to provide date when information will be docketed.
49 Please provide 00000-ICE-30156 Rev. 6. The PAMS SysRS incorporates sections of this document by reference.
Per Westinghouse letter WBT-D-2024 (Reference 7), this document is available for audit at the Westinghouse Rockville office.
This information must be on the docket.
47 The PAMS System Requirements Specification (SysRS) references RG 1.97 Rev. 3 where the FSAR References Rev. 2. Please explain.
The licensing basis for WBN Unit 2 is Regulatory Guide 1.97 Revision 2. The Common Q PAMS system was designed to Regulatory Guide 1.97 Revision 3, which is why the basis for the System Requirements Specification referencinges revision 3. In order to resolve this discrepancy an engineering evaluation of the Common Q PAMS was performed. contains an engineering evaluation of the Common Q PAMS design against the requirements of Reg. Guide 1.97 Rev. 2. The evaluation concluded that the Common Q PAMS meets all requirements of Reg Guide 1.97 Rev. 2. This evaluation will be added to design criteria WB-DC-30-7, Post Accident Monitoring Instrumentation by October 1, 2010.
TVA provided information by letter dated July 30, 2010 (ML102160349) - See Enclosure 1 Item No. 5.
NNC 8/9/10: There are two aspects of this issue. The first aspect has been addresed by the response. The second aspect is: How could Westinghouse Design, and TVA approve a design to the wrong requirement?
FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 55 NRC Review NRC Review TVA to provode aditional information as described.
54 Please describe all the different environments in which the RM-1000 will be required to operate.
Please group these environments into two categories (a) Harsh environment, per 10 CFR 50.49, and (b) Mild Environment.
The only safety-related application for the RM-1000 is the Containment High Range radiation monitors. The Containment High Range radiation monitors will be installed in the Main Control Room, a mild environment. The detectors will be installed remotely in the containment.
For WBN Unit 2, a mild environment is defined as:
A defined 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 condition, (2) the temperature will not exceed 130°F due to the indirect effects of a DBE (e.g., increased heat loads from electrical equipment), (3) the event radiation dose is less than or equal to 1 x 104 rads, and (4) the total event plus the 40 year TID (total integrated dose) is less than or equal to 5 x 104 rads. (Reference 3).
FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section File: rad8C078.xlsx Page 6 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action April 19, 2010 NRC POC: EICB (Singh)
Date: 5/25/10 Responder: TVA I&C Staff Date: 4/19/10 Responsibility: NRC March 12, 2010 NRC POC: EICB (Carte)
Date: 4/8/2010 Responder: Webb Date: 4/8/10 Responsibility: NRC Response path acceptable. TVA to submit the information for docketing.
FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 Please describe the ability to change the software of the RM-1000 at site, including all required equipment and administrative controls (e.g., temporary digital connections).
(7) A physical control switch is located behind the front panel on the front edge of the Output Board to change between Operate and Calibration modes on the RM-1000. Placing the switch in the Calibrate position makes the monitor inoperable.
(8) See the response to Item 1.
The "Qualification Test Report Supplement, RM-1000 Upgrades," Document No. 04508905-1SP Rev. A states that the qualification was done in accordance with IEEE 323-1974 and -1983.
Please describe and justify all differences in this qualification methodology and that endorsed by Regulatory Guide 1.209. Specifically address EMI and RFI The detectors for these loops will be located in a harsh environment (inside containment). The RM-1000 will be located in the main control room, which is a mild environment. The RM-1000 and associated I/F converters have been tested to the requirements present in IEEE Std. 323-1983 and -1974, as well as the System Requirements including EPRI TR 102323 (Sept. 94) in the design basis.
Electro-Magnetic-Interference and Radio Frequency Interference (EMI-RFI) testing was performed (the results of the testing are included in the Equipment Qualification Test Report submitted under TVA letter dated March 12, 2010, Reference 4). Since RG 1.209 was not issued until 2007, General Atomics test reports do not reference it.
For WBN Unit 2, a harsh environment is defined as:
A defined room or building zone where either (1) the temperature, pressure, and relative humidity resulting from the direct effects of a DBE (e.g., temperature rise due to steam release) are more severe than those which would occur during an abnormal plant operational condition, (2) the temperature will exceed 130°F due to the indirect effects of DBE (e.g.,
increased heat loads from electrical equipment), (3) the event radiation dose is greater than 1 x 104 rads, or (4) the total event plus the 40-year TID is greater than 5 x 104 rads. (Reference 3) 57 Firmware/software changes are done by connecting a laptop to a port on the front of the RM-1000 and placing the Operate/Calibrate switch in the Calibrate position. The first physical barrier to access is the location of the RM-1000 in the main control room which has limited access. The RM-1000 Operate/Calibrate switch is located behind the hinged front panel. The front panel must be opened (held closed by two thumbscrews) to access the switch. This provides a physical barrier to inadvertent switch operation. The system malfunction alarm is visible locally and will annunciate on the control board when the switch is in the Calibrate position.
Administrative control of software/firmware updates is in accordance with TVA Standard Specification SS-E18.15.01, Software Requirements for Real-Time Data Acquisition and Control Computer Systems, and TVA procedures SPP-9.3, Plant Modifications and Engineering Change Control, and SPP-2.6, Computer Software Control. Approved changes to software/firmware are implemented utilizing the TVA work order process.
(1) A laptop is not used to calibrate the monitor. All TVA in-house activities (calibration, alarm setpoint adjustment, etc.) are performed using the touchpad on the monitor. An external computer (laptop etc.) is only used to perform software or firmware updates. TVA does not perform software or firmware updates using in-house resources therefore no TVA computer is ever connected to the monitor. If software or firmware updates are required, they are approved via the TVA design change process previously described and implemented by a vendor representative under the TVA work order and Quality Assurance processes.
(2) A laptop is not used to calibrate the monitor.
(3) See the response to Item 1.
(4) See the response to Item 1.
(5) No. The connection between the computer and the RM-1000 is made via a standard RS-232 cable.
(6) The RS-232 connection on the RM-1000 is used to upload new software versions and is not for calibration.
Requested information provided. NRC to review.
Further Information Requested: Please confirm that the laptop is secure and access to this laptop is commensurate with the access to the equipment for which it will be used. Is the laptop dedicated for calibration of radiation monitors? If the laptop is used for more than one application then please describe the equipment for which the laptop may be used. In addition please explain how software security is assured and that only the software intended for the specific application is used. Is the connection to the radiation monitors made via a special cable/connectors? Please confirm that the RS-232 communication port of the radiation monitors will only be used for calibration purposes. Also please confirm that the radiation monitor will not be in operation during the calibration mode. In addition please confirm that password protection is provided for logging on to the laptop prior to start of calibration.
Monitoring Instrumentation - SE Section 7.5.2 FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 64 TVA to provide requested information.
File: rad8C078.xlsx Page 7 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action March 12, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 3/12/10 Responsibility: TVA March 12, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 3/12/10 Responsibility: TVA March 12, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 3/12/10 Responsibility: TVA March 12, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 3/12/10 Responsibility: TVA March 12, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 3/12/10 Responsibility: TVA March 12, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 5/6/10 Responsibility: TVA March 12, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 3/12/10 Responsibility: TVA 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.
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.
Regulations require that the NRC review be based on docketed material.
66 TVA to provide remaining information.
NRC to review information provided.
FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 By letter dated March 12, 2010 TVA stated that the target submittal date for the "Watts Bar 2 PAMS Software Design Description (two documents, one for flat panel display and one for AC160)" was March 31, 2010.
TVA to provide requested information.
TVA to provide date when information will be docketed.
Monitoring Instrumentation - SE Section 7.5.2 By letter dated March 12, 2010 TVA stated that the target submittal date for the D3 Analysis was April 2, 2010.
By letter dated April 8, 2010 TVA docketed WNA-LI-00058-WBT Rev. 0, April 2010. Section 4.11, "Plant Specific Action Item 6.11." addresses the D3 Analysis.
TVA provided roughly a page of description as to why a D3 analysis is not required. The NRC requires additional information to determine the acceptability of this response.
requested information.
TVA to provide date when information will be docketed.
No change to the original schedule Awaiting for document to be docketed by TVA.
65 TVA to provide requested information.
TVA to provide date when information will be docketed.
Per Westinghouse letter WBT-D-1961 (Reference 8), these items are available for audit at the Westinghouse Rockville office.
- WNA-SD-00250-WBT Rev. 0 (AC160) was submitted on TVA letter to the NRC dated August __, 2010 (Reference 7).
- WNA-SD-00248-WBT, Rev. 0 (FPDS) was submitted on TVA letter to the NRC dated August __, 2010 (Reference 8).
Regulations require that the NRC review be based on docketed material. The SRP directs that reviewer to review the Software Design Specification (softimes called an SDD).
NNC 8/25/10: By letter dated august 20, 2010, one (Reference 7)
SDD has been provided.
68 FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 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.
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.
Awaiting for document to be docketed by TVA.
67 FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.0 & 7.5.2 Open Due 9/14/10 FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 By letter dated March 12, 2010 TVA stated that the target submittal date for the FMEA was August 31, 2010.
71 Open FSAR Section 7.5.1 Post Accident 69 Open Due 11/15/10 FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 By letter dated March 12, 2010 TVA stated that the target submittal date for the "Watts Bar 2 PAMS Specific FAT Report" was October 2010.
No change to the original schedule Awaiting for document to be docketed by TVA.
70 NRC to review information provided FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 By letter dated March 12, 2010 TVA stated that the target submittal date for the "Concept and Definition Phase V&V Report" was March 31, 2010.
Per Westinghouse letter WBT-D-1961, (Reference 8) this document is available for audit at the Westinghouse Rockville office.
WNA-VR- 00283-WBT, Rev 0 was submitted on TVA letter to the NRC dated August __,
2010 (Reference 7).
Regulations require that the NRC review be based on docketed material. Awaiting for document to be docketed by TVA.
NNC 8/25/10: Requirements Phase SVVR provided by TVA letter dated 8/20/10.
File: rad8C078.xlsx Page 8 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action March 12, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 3/12/10 Responsibility: TVA March 12, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 3/12/10 Responsibility: TVA March 12, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 3/12/10 Responsibility: TVA March 12, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 3/12/10 Responsibility: TVA March 12, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 3/12/10 Responsibility: TVA March 12, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 3/12/10 Responsibility: TVA April 26, 2010 NRC POC: EICB (Garg)
Date: 5/25/10 Responder: Clark Date: 4/26/2010 Responsibility: TVA April 26, 2010 NRC POC: EICB (Garg)
Date: 5/25/10 Responder: Clark Date: 4/26/2010 Responsibility: TVA Due 9/23/10 Monitoring Instrumentation - SE Section 7.5.2 By letter dated March 12, 2010 TVA stated that the target submittal date for the "Design Phase V&V Report" was July 30, 2010.
No change to the original schedule Awaiting for document to be docketed by TVA.
72 Open Due 10/15/10 FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 By letter dated March 12, 2010 TVA stated that the target submittal date for the "Implementation Phase V&V Report" was September 30, 2010.
No change to the original schedule Awaiting for document to be docketed by TVA.
75 Open Due 10/15/10 FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 By letter dated March 12, 2010 TVA stated that the target submittal date for the "Watts Bar 2 PAMS Specific FAT Procedure" was September 30, 2010.
No change to the original schedule Awaiting for document to be docketed by TVA.
76 Open Due 9/15/10 FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 By letter dated March 12, 2010 TVA stated that the target submittal date for the "Watts Bar 2 PAMS Specific Processor Module Software Test" was August 31, 2010.
No change to the original schedule Awaiting for document to be docketed by TVA.
73 Open Due 11/15/10 FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 By letter dated March 12, 2010 TVA stated that the target submittal date for the "Integration Phase V&V Report" was October 29, 2010.
No change to the original schedule Awaiting for document to be docketed by TVA.
74 Open Due 12/15/10 FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 By letter dated March 12, 2010 TVA stated that the target submittal date for the "Final V&V Report" was November 30, 2010.
No change to the original schedule Awaiting for document to be docketed by TVA.
77 TVA to provide requested information.
TVA to provide date when information will be docketed.
FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 By letter dated March 12, 2010 TVA stated that the target submittal date for seven other documents was "TDB". Please provide a schedule for the docketing of the remaining documents.
The availability dates for these documents are included in the revised WBN2 Common Q ISG-6 Compliance Matrix submitted in response to item 43. As stated in the March 12, 2010 letter (Reference 4), the dates in the matrix are the dates the documents will be available to TVA to prepare for submittal or being Available for Audit. They do not reflect the dates the documents will be submitted to the NRC. Expected submittal date is two weeks after TVA receives the document.
Note: There is a typo in the matrix in line item 33. The power supply entry date says TBD.
Per Westinghouse letter WBT-D-2035 (Reference 12) this item is complete and the documents are available for audit at the Westinghouse Rockville office.
Regulations require that the NRC review be based on docketed material. Awaiting for document to be docketed by TVA.
79 This item is closed 78 FSAR Amd 100 SSER 13 for unit 1 references rev. 1 of WCAP 13869. Rev. 2 is used for Unit 2.
Identify all the differences between Rev.1 and Rev.2 and justify their acceptability.
FSAR Section 7.1.2.1.8 adds a reference 6 to the FSAR. However, Reference 6 is for instrument setpoint and has nothing to do with the diversity discussion on the FSAR Section. We believe the TVA wants to add reference 7 which is the diversity document, WCAP 13869, "Reactor Protection System Diversity in Westinghouse Pressurized Water Reactors." Please confirm this and add commitment to revise FSAR to correct the reference. (Q1) Also, confirm whether this WCAP has been reviewed by NRC, if yes, provide reference and if not, then submit the WCAP to NRC. (Q2)
Also provide the justification for this reference to WBN2. (Q3)
(Q1) The cross reference information is corrected in FSAR Amendment 100 submitted to the NRC on TVA letter to the NRC dated August __, 2010 (Reference 2).
(Q2) WCAP-13869 was previously reviewed under WBN Unit 1 SER SSER 13 (Reference 9).
(Q3) Westinghouse confirmed the applicability of this WCAP to Watts Bar Unit 2 in letter WBT-D-1321, Final Response to WBT-TVA-0713 Unit 2 WCAP Reviews, dated December 2, 2009 (Reference 10).
Awaiting TVA response.
File: rad8C078.xlsx Page 9 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action April 26, 2010 NRC POC: EICB (Singh)
Date:
Responder: WEC Date: 4/26/2010 Responsibility: TVA May 6, 2010 NRC POC: EICB (Carte)
Date: 6/18/10 Responder: WEC Date: 5/6/2010 Responsibility: TVA May 6, 2010 NRC POC: EICB (Carte)
Date: 6/18/10 Responder: WEC Date: 5/6/2010 Responsibility: TVA as it will be reviewed under item 154.
FSAR Amd 100 FSAR Section 7.1.2.1.9, Trip Setpoints, adds reference to 3, 4, and 5. However, reference 3 was deleted by FSAR amendment 81. Reference 4 has been changed to ISA-DS-67.04-1982. Justify applicability of this standard for WBN 2.(Q1) Why the latest ISA standard endorsed by NRC has not been used? (Q2) Also reference 5 is a topical report for Eagle 21, system. Please confirm that this topical report also discusses the setpoint for Eagle 21 system and whether it meets the recent guidance for the setpoint issued by the staff. (Q3) Also, W setpoint methodology do not provide discussion on the AS Found Tolerance and As left value determination and how these values are used for the instrument operability, therefore, add the discussion of these topics in the FSAR. (Q4) and add reference to other documents if it is discussed in some other document.
(Q5) Provide this document to the staff for review and approval. (Q6)
(Q1) WBN Unit 2 is licensed based on WBN Unit 1. The WBN Unit 1 licensing basis is ISA-DS-67.04-1982. Therefore this methodology is used for the same SSDs for WBN Unit 2. This maintains consistency in the licensing bases for both units.
(Q2) Please refer to the response to Q1.
(Q3) FSAR Reference 4 is the Eagle 21 Topical Report. FSAR Reference 5, WCAP-17044, Westinghouse Setpoint Methodology for Protection Systems Watts Bar Unit 2 submitted under TVA letter to the NRC dated February 12, 2010 (Reference 11) discusses the setpoint methodology used for Eagle 21 loops.
(Q4) (Q4) FSAR Amendment 100 which was submitted on TVA letter to the NRC dated August __, 2010 (Reference 2) incorporates as-found and as-left setpoint tolerance discussion into section 7.1.2.1.9, adds EEB-TI-28, Setpoint Methodology to the section 7.1 references and adds a reference to 7.1.2.1.9 to section 7.2.1.1.10.
(Q5) Please refer to the response to Q4.
(Q6) EEB-TI-28, Setpoint Methodology was submitted in TVA letter to the NRC dated May 13, 2010 (Reference 12).
Awaiting TVA response.
80 NRC Review FSAR Table 7.1-1, Note 12 has been added to the table but it's justification has not been provided to the staff for review and approval.
A revised note was included in the 7/30 letter along with justification for the note.
81 TVA to provide requested information.
TVA to provide date when information will be docketed.
FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 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 a justification for the acceptability PAMS with respect to these differences.
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.
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 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.
82 Updated compliance matrix provided.
Awaiting WEC submittal FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 File: rad8C078.xlsx Page 10 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action May 6, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date: 5/6/2010 Responsibility: TVA May 6, 2010 NRC POC: EICB (Carte)
Date: 5/24/10 Responder: WEC Date: 5/6/2010 Responsibility: TVA May 6, 2010 NRC POC: EICB (Garg)
Date:
Responder: Clark Date: 5/24/2010 Responsibility: NRC May 6, 2010 NRC POC: EICB (Garg)
Date: 5/25/10 Responder: Clark Date: 5/24/2010 Responsibility: NRC May 20, 2010 NRC POC: DORL (Bailey)
Date:
Responder: Hilmes Date:
Responsibility:
May 20, 2010 NRC POC: EICB (Garg)
Date: 5/25/10 Responder: Clark Date:
Responsibility:
TVA to review Licensee Open Item list and determine which items are proprietary.
Next review due 6/18/10 92 89 86 90 NRC Review FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 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 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.
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 comparison review.
The response does not address the request. This request was regarding guidance that did not exist at the time that the CQ topical report was reviewed. The WBN2 PAMS applicaton must address current regulatory criteria.
NNC: Docketed response states that only the Pressurizer Heater Control Function is implemented using Focborro IA.
What FSAR Systems are implemented using Foxboro Intelligent Automation (IA)?
Garg to identify Function review responsibility.
NRC Review NNC: Docketed response states that the applicable FSAR Sections are:
5.6 -
7.2.2.3.2 - Garg 7.2.2.3.3 - Garg 7.2.2.3.4 - Garg 7.2.2.3.5 - Garg 7.2.3 - Garg 7.6.8 -
7.7.1.6 -
7.7.1.7 -
7.7.1.8 -
9.3.4.2.1.C -
10.4.7.2 -
The list of FSAR functions is listed in TVA letter dated March 12, 2010, Enclosure 1, item 12 85 Need WEC to provide make and model information after FAT.
NNC 8/25/10: Disagree with path forward input by TVA above. An explanation is about the design is needed.
94 NRC Review Continuous review as items are added TVA to provide requested information.
TVA to provide date when information will be docketed.
What FSAR functions are implemented using Foxboro Intelligent Automation (IA)?
The list of FSAR systems is listed in TVA letter dated March 12, 2010, Enclosure 1, item 12 Awaiting WEC submittal of documents to TVA.
7.5.2 The PAMS Licensing Technical Report (WNA-LI-00058-WBT Rev. 0, Dated April 2010), in Section 2.3, lists hardware/software changes to the Common Q PAMS previously reviewed by the NRC.
However the Common Q ISG-6 Compliance Matrix does not contain activities that address qualification of all changes specifically:
2.c - CI527 AF100 Peripheral Component Interconnect (PCI) interface card
- 3. - Common Q TC514 AF100 Fiber Optic Modems (Evolutionary Product Maintenance/Improvements) 4.a - PM646A Processor Module 4.b - CI631 AF100 Communication Interface Module 4.e - DO620 Digital Output Card Please provide sufficient detail regarding the changes for the NRC to independently evaluate the acceptability of the changes.
Regulations require that the NRC review be based on docketed material. Awaiting for document to be docketed by TVA.
NNC 8/9/10: per telephone conversation on 8/5/10, it is not clear how Westinghouse Commercial Grade Dedication Plans and Reports for Digital I&C. Westinhouse agree to present to the NRC in a public meeting on August 17, 2010, and explanation of how their system addreses regulatory criteria for both commercial grade dedication and equipment qualification.
NNC 8/25/10: In the August 17, 2010 public meeting Westinghouse stated that the CDi were the plans. The NRC requested that the plans and associated reports be docketed.
A response will be provided by 10/31/10 NNC 8/11/10: Design information should be avaialble now. By letter dated July 30, 2010 (ML102160349) TVA stated that the MTP was connected to a Red Hat Linux Server (see Enclosure 1, Item No. 14 part b.). It is presumed that this server is not safety-related. IEEE 603-1991 Clause 5.6.3(1) states, "Isolation devices used to affect a safety system boundry shall be classified as part of the safety system."
Please describe how the MTP serves as the isolation device.
Garg to idnetify FSAR section responsibility in comments column.
These components can be found in the Summary Qualification Report Of Hardware Testing For Common Q Applications, 00000-ICE-37764, Rev 3 and TWICE Qualification Status Report, WNAQR-00011-SSP Per Westinghouse letter WBT-D-2024, (Reference __) dated June 9, 2010, these documents are available for audit at the Westinghouse Rockville Office.
TVA provided information by letter dated July 30, 2010 (ML102160349) - See Enclosure 1 Item No. 7.
Please provide a detailed description of the PAMS MTP data link to the plant computer. This description should identify all equipment (model & version) and describe the functions that each piece of equipment performs. This description should be of sufficient detail for the NRC to independently evaluate the statements made in WNA-LI-00058-WBT Rev. 0, Section 5.3.
FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 File: rad8C078.xlsx Page 11 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action May 20, 2010 NRC POC: EICB (Darbali)
Date:
Responder:
Date:
Responsibility:
April 12, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
April 12, 2010 NRC POC: DORL (Bailey)
Date:
Responder: Slifer Date:
Responsibility:
May 27, 2010 NRC POC: EICB (Darbali)
Date: 5/27/10 Responder: Clark Date: 5/27/10 Responsibility: TVA May 27, 2010 NRC POC: EICB (Darbali)
Date: 5/27/10 Responder: Clark Date: 5/27/10 Responsibility: TVA May 6, 2010 NRC POC: EICB (Darbali)
Date: NA Responder: NA Date: NRC Responsibility:
May 6, 2010 NRC POC: EICB (Carte)
Date: NA Responder: NA Date: NRC Responsibility:
June 1, 2010 NRC POC: EICB (Garg)
Date: 6/1/2010 Responder: Clark Date:
Responsibility:
June 1, 2010 NRC POC: EICB (Garg)
Date:
Responder: WEC Date:
Responsibility:
TVA to provide requested information.
TVA to provide date when information will be docketed.
NRC Review EDCR is scheduled for issue 10/13/10 NRC Review TVA is working with the vendor to meet the 6/30 date, however there is the potential this will slip to 7/14.
96 This items will be closed upon the resolution of item 283.
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.
TVA to locate and provide information on the TMI action item to add an anticipated reactor trip on turbine trip to the design bases in the FSAR does not show the vendor and model no. of the Power Supply.
109 b NRC Action The reviewer was unable to identify the sections of the FSAR that correspond to the standard review plan sections7.9.
NA J. Wiebe accepted this action.
109 a NRC Action The reviewer was unable to identify the sections of the FSAR that correspond to the standard review plan sections 7.8.
NA This item is described in FSAR amendment 98, Section 7.2.1.1.2 item 6 page 7.2.9, and Table 7.2-1 item 14, page 7.2-39.
NRC staff will review.
TVA to provide information on implementation of IEN 79-22 and how it is addressed in the FSAR Response provided. NRC staff to review response.
EDCR is scheduled for issue 11/30/10 101 103 100 TVA has not yet docketed all items requested.
The following Common Q proprietary documents listed in the response and the affidavits for the proprietary documents will be provided by April 9, 2010.
- 1. System Design Specification WNA-DS-01667-WBT, Rev. 1
- 2. System Requirements Specification WNA-DS-01617-WBT, Rev. 1
- 3. Watts Bar 2 - Common Q PAMS ISG-6 Compliance Matrix dated March 4, 2010
- 4. Watts Bar Unit 2 (WBN2) Post Accident Monitoring System (PAMS) Licensing Technical Report LTR-RCPL-10-XX
- 5. Software Requirements Specification WNA-SD-00239-WBT, Rev. 1 The documents, and affidavits for withholding for the listed documents were submitted to the NRC on TVA letter to the NRC dated April 8, 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 Open Due 10/31/10 Submittal date is based on current EDCR scheduled issue date.
104 Open Due 12/15/10 Submittal date is based on current EDCR scheduled issue date.
113 NRC Review 114 J. Wiebe accepted this action.
IEN 79-22 is not specifically listed or discussed in the WBN Unit 1 UFSAR or Unit 2 FSAR. IEN 79-22 is one of the precursors to 10CFR50.49 environmental qualification. The initial SQN and WBN Unit 1 response was developed prior to TVA implementing 10CFR50.49. As such, the discussion of safety-related actuations is no longer valid. In implementing 10CFR50.49, TVA upgraded susceptible safety-related devices located in harsh environments to fully qualified devices. For WBN Unit 2, only fully qualified safey-related devices are installed in areas susceptible to a high energy line break. The non-safety-related device/systems within the scope of IEN 79-22 are:
- 1. Steam generator power operated relief valve control system
- 2. Pressurizer power operated relief valve control system
- 3. Main feedwater control system
- 4. Automatic rod control system.
Failure of these systems/devices due to a high energy line break is fully addressed in Chapter 15, Accident Analysis of the WBN Unit 2 FSAR.
TVA to submit excerpts of EDCR 52351 Are the new model Eagle 21 power supplies installed in Unit 1?
Yes. Attachment 9 provides a work order excerpt and unit difference form.
Revised attachment provided on 7/30 letter.
TVA to submit excerpts of EDCR 52321 File: rad8C078.xlsx Page 12 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action February 25, 2010 NRC POC: EICB (Carte)
Date: 6/2/10 Responder: Clark Date:
Responsibility:
June 3, 2010 NRC POC: EICB (Garg)
Date:
Responder: WEC Date:
Responsibility:
NRC POC: EICB (Garg)
Date:
Responder: Webb/Powers Date:
Responsibility:
June 8, 2010 NRC POC: EICB (Darbali)
Date:
Responder: Clark Date:
Responsibility:
OPEN TVA need to address that trip setpoint and allowable value Does TVA use a single sided or double sided methodology for as-found and as-left instrument setpoint values. (RIS2006-7)
TVA uses double-sided as-found and as-left tolerances for all trip setpoints within the scope of TSTF-493, Rev. 4.
The Eagle 21 boards originally had a conformal coating. However, the new boards do not.
Provide the basis for deletion of the conformal coating.
117 118 Open Due 11/15/10 Submittal date is based on current EDCR scheduled issue date. Note: The RVLIS EDCR has been split into two EDCRs. The first EDCR is 52601 (Open Item 91) The second EDCR is 55385.
TVA to submit excerpts from EDCR 55385 TVA has agreed to submit the EDCR by 11/15/10.
This version of the 80287 had an improved specification for calculation speed. Use of this chip on both the Unit 2 LCP and the test bed LCP allowed proper performance of the LCP when making parameter updates using the Unit 1/Unit 2 Rack 5 software. Also, use of the slower 80287 on any of the three LCP boards caused failure in parameter update with the Unit 1/Unit 2 Rack 5 software.
Through investigation of historical records, Westinghouse found that the 80287 XL chip had been evaluated and used by its former Process Control Division (now Emerson) for this application, but the current Westinghouse documentation had not been updated. This part has now been evaluated, and the Westinghouse documentation and drawing have been revised to allow use of the 80287 XL coprocessor. The 80287 XL coprocessor has been installed on the Unit 2 Rack 5 LCP, and the appropriate factory acceptance testing has been successfully conducted using this updated board. Additionally, the LCP boards in the balance of the Unit 2 racks have been updated with the 80287 XL coprocessor.
TVA to Update response Provide a list of digital 1E systems that have a digital communications path to non safety related systems and if it has:
- a. Been reviewed before for unit 1
- b. Or installed in unit 1 under 50.59, or
- c. Is unique to unit 2 The writeup shows that there was differences between Unit 1 and 2 but was not identified to NRC in earlier response. Are there any more surprises like this?
The response to this RAI was submitted in TVA letter to the NRC dated June 21, 2010.
116 How is the tin whisker issue is addressed. I think conformal coating Letter sent to Westinghouse requesting the basis information and documentation for submittal to the NRC.
115 The CQ PAMS SysRS (WNA-DS-01617-WBT Rev. 1 Figure 2..1-1) shows that the OM has a TCP interface to non-safety. Please provide a list of ALL digital communications paths to non-safety-related systems.
NNC 8/12/10: The staff pinted out this inconsistency to TVA. The staff could consider PAMS Licensing Technical Report to be a correction if TVA specifically identified the inconsistency to the staff, or identified where the error in the SysRSs, SRS, & SDS had already been identified. This apppreas to be a feature in the CQ TR appendix that was carried forward to WBN2 PAMS inappropriately The following non-proprietary response was developed from proprietary Westinghouse letter WBT-D-2027 (Reference 11), which provided the resolution of this issue. Westinghouse approved this non-proprietary response via e-mail from A. Drake to M. Clark on June 15, 2010.
As documented in WBT-D-1917, Eagle-21 Rack 5 LCP Diagnostic Failures, (Reference 14),
during the factory acceptance testing for the Unit 2 Eagle-21 System, Westinghouse noted an occasional diagnostic failure while performing the parameter update function on Rack 5.
Subsequently, TVA provided to Westinghouse for testing and examination, a Loop Control Processor (LCP) board removed by TVA from Unit 1 Rack 5 for life cycle-based preventive maintenance. TVA personnel familiar with Unit 1 had indicated they had not experienced problems when performing parameter updates on Unit 1 Rack 5.
Based on Westinghouse examination and testing, a difference in hardware was identified between the Unit 1 LCP shipped to Westinghouse, the new Unit 2 Rack 5 LCP, and an older LCP (older than the Unit 1 LCP) from the Westinghouse Eagle 21 test bed. Installed on the Unit 1 LCP was a different version of an 80287 math coprocessor chip (80287 XL).
Provide the resolution of the Eagle 21 Rack 5 lockup on update issue.
Response states that Eagle21 and the CQ PMAS MTP have communications links to non-safety-related systems..
This item was identified during TVA review of Figure 2.2-1 of the PAMS Licensing Technical Report WNA-LI-00058-WBT, Rev.0 and the figure was revised to remove the connection. It was addressed with Westinghouse at that time. However other Common Q PAMS documents had been issued before the issue was identified to Westinghouse. The Licensing Technical has been corrected and the other documents will be corrected at the next revision.
There are no communications from the Operators Module to the plant computer or any other system. The Common Q PAMS SysRS WNA-DS-01617-WBT Rev. 1, Figure 2.1-1 will be revised to remove this connection by April 1, 2011 and submitted to the NRC by April 15, 2011.
File: rad8C078.xlsx Page 13 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action May 6, 2010 NRC POC: EICB (Carte)
Date:
Responder: Hilmes/Merten/Costley Date:
Responsibility:
May 6, 2010 NRC POC: EICB (Garg)
Date:
Responder: Webb/Webber Date:
Responsibility:
June 14, 2010 NRC POC: EICB (Darbali)
Date:
Responder:
Date:
Responsibility:
June 14, 2010 NRC POC: EICB (Darbali)
Date:
Responder:
Date:
Responsibility:
June 14, 2010 NRC POC: EICB (Darbali)
Date:
Responder:
Date:
Responsibility:
120 TVA to provide information requested 121 NRC Review If not previously provided, provide the requested information in items a, b and c for changes to all platforms between Unit 1 and 2. (Specific request for information on Foxboro IA). D. Webb/H.
Webber
- a. Describe the hardware differences between unit 1 and unit 2
- b. Identify which systems have been transferred to the Foxboro Spec 200 system that utilize a different platform in Unit 1.
- c. Identify the functions (ensure all control functions are addressed) that have been transferred to the Foxboro Spec 200 system that utilize a different platform in Unit 1.
The information in the letter provides references to previous submittals and a cross reference for the Foxboro I/A system.
TVA respinded by letter dated July 30, 2010 (ML102160349) - See Enclosure 1 Item No. 14:
Detailed discussion is provided including technical information on the data diode.
NNC 8/9/10: By letter dated July 30, 2010 (ML102160349) - See Item No. 14 -
- a. TVA stated no new information was found in Westinghouse documentation and that this information would be addressed in the V&V reports, and that the final hardware drawing will be provided.
Neither of these two documents will contain the information requested. Please provide a detailed description of the MTP hardware connections and the software that perform the communications.
- b. The information provided indicates that the MTP is connected directly to a non-safety-related Red Hat Linux Server which is then connected to the data diode divices. Please describe the secure development and operational environment of these Red Hat Linux Servers.
- c. The answer is not complete. A chattering node is one of the failure modes of an ethernet link. The MTP is connected to a linux server over an ethernet link. What prevents this link from locking up the MTP by a data storm?
Safety Evaluation(SE) Section 7.7.3 Volume Control Tank Level Control System
- 1. Confirm whether or not any Instrumentation & Control (I&C) systems or equipment have been changed in the Volume Control Tank Level Control System.
- 2. In the original Safety Evaluation(SE), NUREG-0847 (ML072060490), Section 7.7.3, the staff addressed a concern that was raised by Westinghouse regarding an adverse control and protection system interaction. (a single random failure in the VCT level control system could cause the letdown flow to be diverted to the liquid holdup tank). Based on your responses to the staffs questions related to this concern, the staff considered the issue resolved. Confirm that your responses are applicable to Unit 2.
- 1. The devices in the Volume Control Tank Level Control System have been replaced. The Volume Control Tank Level Indication and Control functions have been relocated to the Foxboro IA system. The transmitters and indicators have been replaced with 4-20mA technology and the transmitters have been changed to Rosemount.
- 2. Upscale failure of LT-62-129A: Flow is diverted to the holdup tank but makeup continues to maintain level and alarms alert the operator.
Upscale failure of LT-62-130A: Unlike Unit 1, the makeup control system uses inputs from both LT-62-130A and LT-62-129A. This results in a more robust design that eliminates a single point of failure for LT-62-130A. If transmitter LT-62-130A fails >20mA, the system disregards the input and uses the LT-62-129A signal for control. If transmitter LT-62-130A is high but <20 mA, the deviation between the two causes an alarm, and the diverter valve loop and makeup control both use the last good value of the average. Once the level goes high or low, alarms on LT-62-129A alert the operator to take action to mitigate.
Staff is reviewing response.
123 NRC Review 124 NRC Review In reviewing the Maintenance Test Panel (MTP) link to the plant computer, the reviewer noted that the MTP software is not purely one directional in that it does allow low level handshaking to support the communications protocol. M. Merten/S. Hilmes
- a. The reviewer stated that this was a potential concern and requested additional information on how the MTP ws protected from feedback from the plant computer.
- b. The reviewer stated that in the Oconee review, it was found that the non-safety related data diode was easier to credit than a software barrier. It was suggested we look at changing our position to credit the data diode provided it provided a physical barrier to feedback. Need OWL Information SAH
- c. During this discussion, the reviewer asked if we had information from Westinghouse that demonstrated the ability of Common Q PAMs to withstand a data storm. A verbal response was that this was required by contract as part of the Factory Acceptance Test and would not be available until the FAT was completed. Need to docket the verbal response and provide a date the information will be available. Believe we stated this in the Tech Report. SAH SE Section 7.7.5 IE Information Notice 79-22
- 1. In the original SE, Section 7.7.5, the staff determined that Information Notice 79-22 was resolved based on your statement that the control and logic functions of the Watts Bar plant were identical to the Sequoyah plant, thus making the Sequoyah evaluation applicable to Watts Bar.
Confirm that your statements regarding the control and logic functions are applicable to Unit 2s control and logic functions or describe any changes and why they are acceptable.
Refer to response to Item 12 10 above.
Staff is reviewing response.
125 NRC Review File: rad8C078.xlsx Page 14 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action June 16, 2010 NRC POC: EICB (Garg)
Date: 6/16/10 Responder: WEC/Clark Date:
Responsibility:
NRC Review June 18, 2010 NRC POC: EICB (Garg)
Date:
Responder: WEC Date:
Responsibility:
April 12, 2010 NRC POC: DORL (Bailey)
Date:
Responder: WEC Date:
Responsibility:
June 28, 2010 NRC POC: DORL(Bailey)
Date:
Responder: Clark Date:
Responsibility:
June 28, 2010 NRC POC: DORL(Bailey)
Date:
Responder: Clark Date:
Responsibility:
June 28, 2010 NRC POC: DORL(Bailey)
Date:
Responder: Clark Date:
Responsibility:
TVA committed to revise in Amendment 100: table 4.3-1 to add ID and OD nomenclature to thimble guide tube dimensions.
FSAR Amendment 100 submitted to the NRC on TVA letter to the NRC dated August __,
2010 added the ID and OD nomenclature.
The documents, and affidavits for withholding for the listed documents were submitted to the NRC on TVA letter to the NRC dated July 14, 2010.
FSAR Amendment 100 submitted to the NRC on TVA letter to the NRC dated August __,
2010 updated the reference document number information.
- 1. The AMSAC system was not previously installed in Unit 2. EDCR 52408 installs the system. Attachment 3 contains excerpts from the EDCR that describe the Unit 2 system and how it differs from the Unit 1 system.
- 2. EDCR 52408 incorporates the AMSAC system into the Unit 2 drawings.
Staff is reviewing response.
128 Open. Staff will issue SE with this as an open item.
Due 12/3/10 TVA Unit 1 has to address first and Unit 2 will follow Unit 1.
TVA committed to revise in Amendment 100: FSAR 3.10 references to eliminate (LATER) for document numbers.
130 FSAR Amd 100 The following non-proprietary response was developed from proprietary Westinghouse letter WBT-D-2034 (Reference 15), which provided the details of this issue. Westinghouse approved this non-proprietary response via e-mail from A. Drake to M. Clark on June 16, 2010.
During the Watts Bar Unit 2 Eagle 21 Factory Acceptance Test (FAT) of Rack 2 it was discovered that the narrow range Resistance Temperature Detector (RTD) temperature inputs were consistently reading about 0.2 °F higher than expected. Investigation revealed that these inputs are configured in the Loop Calculation Processor software as a shared RTD. This is incorrect. Rack 2 RTD's are not shared. Racks 6, 10 and 13 RTD's are. Configuration as a shared RTD input alters the equation used for the temperature calculation. Watts Bar Unit 1 uses identical software to Unit 2.
Further investigation by Westinghouse showed this configuration error causes the Narrow Range Temperatures for only Division I to read 0.2 to 0.27 °F higher over the Narrow Range span of 510-650 °F. The 0.2 °F shift affects Thot and Tcold equally and thus will not affect the indication of Delta T. Tavg will indicate high by 0.2 °F which will decrease the Over temperature and Overpower set points; which is in the conservative direction.
TVA will provide non-proprietary versions of the following Common Q attached proprietary documents and the affidavits for the proprietary documents by June 30, 2010.
- 1. System Design Specification WNA-DS-01667-WBT, Rev. 1
- 2. System Requirements Specification WNA-DS-01617-WBT, Rev. 1
- 3. Software Requirements Specification WNA-SD-00239-WBT, Rev. 1 129 Open Due 7/16/10 131 FSAR Amd 100 132 FSAR Amd 100 The indicated high 0.2 °F Tavg, if selected for control (via auctioneered high), would cause the controlling temperature to result in an actual temperature 0.2°F low; which is in the conservative direction for consideration of DNB. The Tavg - Low-Low function (P-12) would be non-conservative by 0.2 °F, which would cause the permissive/interlock for block of steam dump post reactor trip to be delayed slightly via that channel. This delay would not be considered significant. Westinghouse will discuss this issue with Watts Bar Unit 1 personnel in accordance with their Part 21/Potential Issue process.
Westinghouse initiated a corrective action item (CAPS # 10-140-M021) and performed an Evaluation of Potential Nuclear Safety Issue. Based upon the above investigations, Westinghouse determined that this issue does not represent a substantial safety hazard at Watts Bar Unit 1 even it left uncorrected.
Provide the status of the Eagle 21 Rack 2 RTD accuracy issue.
Describe the changes, if any.
- 2. NUREG-0847, Supplement 14 (ML072060486), documents the staffs review of FSAR Amendment 81 that found that the AMSAC automatic initiation signal [to start the turbine-driven and motor-driven AFW pumps] was not added to the logic diagram for the AFW system shown in FSAR Figure 7.3-3, Sheet 2. The issue was resolved in Amendment 88. Confirm that this signal has been incorporated in the Unit 2 drawings.
Submit the report on the final resolution of the Eagle 21 Rack 2 RTD input issue File: rad8C078.xlsx Page 15 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action June 28, 2010 NRC POC: DORL(Bailey)
Date:
Responder: Clark Date:
Responsibility:
June 28, 2010 NRC POC: DORL(Bailey)
Date:
Responder: Clark Date:
Responsibility:
June 30, 2010 NRC POC: EICB (Darbali)
Date:
Responder: Clark Date:
Responsibility:
June 30, 2010 NRC POC: EICB (Darbali)
Date:
Responder: Clark Date:
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140 137 (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.
Open TVA to provide date when information will be docketed.
Waiting for Amendment 100 Open TVA to provide date when information will be docketed.
FSAR Amendment 100 submitted to the NRC on TVA letter to the NRC dated August __,
2010 updated the "service water" and "emergency raw cooling water" nomenclature as required to read essential raw cooling water.
FSAR Amendment 100 submitted to the NRC on TVA letter to the NRC dated August __,
2010 corrected the numbering in the text.
FSAR Amendment 100 submitted to the NRC on TVA letter to the NRC dated August __,
2010 removed the reference to IEEE 344-1987.
FSAR Amd 100 TVA committed to revise in Amendment 100: FSAR Table 1.3-3 to reflect modifications to WBN2 TVA committed to revise in Amendment 100: FSAR 3.10 to remove references to IEEE 344-1987.
Open TVA to provide date when information will be docketed.
WBN2 PAMS System Requirements Specification TVA docketed WNA-DS-01617-WBT Rev. 1, RRAS Watts Bar 2 NSSS Completion Program I&C Projects Post 134 139 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.
138 Several WBN2 PAMS documents contain a table titled, Document Traceability & Compliance.
(a) Please explain the purpose of this table.
(b) Please describe how this table is different than a reference list.
(c) What does it mean for a document to be listed in this table?
TVA committed to revise in Amendment 100: FSAR 3.10 to correct differences between the list on page 3.10-4 and the numbering refrenced by the text below the list.
Open WBN2 PAMS System Requirements Specification 136 FSAR Amd 100 The WBN2 PAMS System Requirements Specification (WBN2 PAMS SysRS) contains a table (see page iii) titled, Document Traceability & Compliance, which states that the WBN2 PAMS SysRS was created to support no documents. Please explain.
133 FSAR Amd 100 135 FSAR Amd 100 TVA committed to add in Amendment 100 a reference to 7.3.1.1.1 in 6.2.5.2.b.
FSAR Amendment 100 submitted to the NRC on TVA letter to the NRC dated August __,
2010 added the reference.
FSAR Amendment 100 submitted to the NRC on TVA letter to the NRC dated August __,
2010 updated the table to reflect the WBN2 modifications.
TVA committed to replace in Amendment 100 the terms "service water" and "emergency raw cooling water" where they are used incorrectly with "Essential Raw Cooling Water" in sections 7.4, 6.2.1, Table 3.7-25, Table 9.3-3, Table 15.4-14, 1.9.2.7, 7.3.2.2.5 and 11.2.4.
File: rad8C078.xlsx Page 16 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action June 17, 2010 NRC POC: EICB (Carte)
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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).
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.
143 142 Open TVA to provide date when information will be docketed.
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.
The applicable regulatory guidance for reviewing the WBN2 PAMS SysRS would be IEEE 830 as endorsed by Regulatory 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 How did TVA ensure the traceability of each requirement in the WBN2 PAMS SysRS.
Open TVA to provide date when information will be docketed.
Open TVA to provide date when information will be docketed.
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.
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?
(d) Please briefly describe all of the documents that implement the WBN2 PAMS SysRS.
The first requirement in the WBN2 PAMS SysRS (i.e., R2.2-1) states: The PAMS shall be capable of operation during normal and abnormal environments and plant operating modes. The rational for this requirement is that it is necessary to meet Regulatory Guide (RG) 1.97.
What document specifies which RG 1.97 variables are implemented in the Common Q based WBN2 PAMS?
144 TVA to provide date when information will be docketed.
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.
File: rad8C078.xlsx Page 17 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
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147 148 Open TVA to provide date when information will be docketed.
Open. TVA to confirm if this description is the same as for Unit 1.
If it is same as Unit 1 then why this was shown as change in redline version of FSAR Amendment 96.
TVA to provide date when information will be docketed.
FSAR Section 7.2, Reactor Trip System Deleted portion of FSAR section 7.2.3.3.4 and moved to FSAR section 7.2.1.1.5. However, the FSAR section 7.2.1.1.5 does not include the discussion of ambient temperature and also on the calibration of the sealed reference leg system. No justification was provided for deleting this discussion. Please explain the bases for deletion of this information.
FSAR Section 7.2, Reactor Trip System Open TVA will send FSAR Section 7.1.1.2(2), Overtemperature delta T and Overpressure delta T equations have been simplified and many values are removed from the FSAR. Provide the justification for this change.
In FSAR amendment 96, the values of the constants have been moved to TS or plant procedures. Need to document the basis for this change.
Open TVA to provide date when information will be docketed.
FSAR Section 7.2, Reactor Trip System Many of the changes were based on the Westinghouse document N3-99-4003. Provide this document for staffs review so the staff can determine the basis for these changes.
Open TVA to provide date when information will be docketed.
FSAR Section 7.2, Reactor Trip System Provide the EDCR 52378 and 54504 which discusses the basis for many changes to this FSAR section.
Closed PAMS System Requirements Specifications deleted 150 151 152 153 Closed PAMS System Requirements Specifications 149 PAMS System Requirements Specifications deleted deleted Closed The text was revised to match the Unit 1 UFSAR. The Unit 1 text was modified in Amendment 1 by FSAR Change Package 1553 S00 which is contained in Attachment 30.
The basis for the change in the change package is:
16 The update to Section 7.2.1.1.5 is taken from text in Section 7.2.2.3.4 with clarifications and editorial changes. The relocated discussion of the pressurizer water level instrumentation Is more appropriately included in this section than Section 7.2.2.3.4, which deals with control and protection system interaction. The changes to 7.2.1.1.5 are based on a general description of the Westinghouse pressurizer level design, channel independence, and actual installation attributes found on TVA physical drawings. Also, the hydrogen gas entrainment issue documented in NRC Information Bulletin No. 92-54, Level Instrumentation Inaccuracies Caused by Rapid Depressurization, is retained and clarified. Similar clarification is made to Reactor Protection System Description N3-9g.4003 Section 3.1.1.2(d). The original text in 7.2.2.3.4 provides some information that is too detailed and is not pertinent to the subject of discussion. It also includes a statement that the error effect on the level measurement during a blowdown accident would be about one inch. The basis for this value is not known; however, the worst case reference leg loss of fill error due to a rapid RCS depressurization event Is no more than 12 inches elevation head. This value is based on the relative elevation difference between the condensing chamber and the reference leg sensor bellows. The Westinghouse Owners Group response to this issue is found in RIMS # L44930216800. The channel error value discrepancy is documented in WBPER980417. The remaining text in 7.2.2.3.4 is revised to clarify the control and protection system interaction discussion.
146 In FSAR amendment 96 the equations were revised to agree with the Unit 1 UFSAR which is the basis document for the Unit 2 FSAR. This resulted in the equations being simplified and the removal of the values for the constants. The equations were revised to match those used in the Technical Specifications. The values for the constants are contained in the Technical Specifications and were removed as redundant.
Open TVA to provide date when information will be docketed.
WBN2 PAMS System Design Specification TVA docketed WNA-DS-01667-WBT Rev. 1, RRAS Watts Bar 2 NSSS Completion Program I&C Projects Post Accident Monitoring System-System Design Specification, dated December 2009.
145 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.
(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.
System description N3-99-4003, Reactor Protection System is contained in Attachment __
EDCR 54504 has been voided and replaced with EDCR 52378 which is contained in (Attachment ___ ) and EDCR 52671 is contained in (Attachment ___ ).
FSAR Section 7.2, Reactor Trip System File: rad8C078.xlsx Page 18 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
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FSAR Amedment 99 reflects the change to Criterion 23.
The condition is defined in the preceeding discussion as operating with a reactor coolant pump out of service and core power less than 25%.
Elbow taps are used to measure reactor coolant flow for both Unit 1 and 2. However the method used to verify reactor coolant flow, as required by the Technical Specifications, is not the same. Unit 1 uses a simplified methodology based on elbow tap P measurements correlated with precision calorimetric data over several cycles of operation as described in Reference 17, WCAP-16067, Rev 0, RCS Flow Measurement Using Elbow Tap Methodology at Watts Bar Unit 1.
Unit 2 will verify reactor coolant flow Technical Specification requirements using the precision flow calorimetric methodology until sufficient data is collected to correlate elbow tap P measurements with actual flow. There is no change to the Unit 2 reactor coolant elbow tap measurement design.
Open TVA to provide date when information will be docketed.
FSAR Section 7.2, Reactor Trip System Response on hold pending Westinghouse review.
FSAR section 7.2.2.1.1 states that dashed lines in Figure 15.1-1designed to prevent exceeding 121% of power.The value of 121% is changed from 118%. The justification for this change states that this was done to bring the text of this section in agreement with section 4.3.2.2.5, 4.4.2.2.6 and table 4.1-1. However, Table 4.1-1 and section 4.3.2.2.5 still show this value as 118%. Justify the change.
FSAR Section 7.2, Reactor Trip System FSAR section 7.2.2.1.1, fifth paragraph was deleted except for the last sentence. The last sentence states that, The P-8 interlock acts essentially as a high nuclear power reactor trip when operating in this condition. This sentence is confusing because the condition is not defined.
Please clarify this discrepancy.
Open TVA to provide date when information will be docketed.
FSAR Section 7.2, Reactor Trip System FSAR section 7.2.2.1.2 discusses reactor coolant flow measurement by elbow taps. However, it further states that for Unit 2, precision calorimetric flow measurement methodology will be used.
If elbow taps are not used for Unit 2, then why does this section discuss this methodology? It is the staffs understanding that TVA plans to use elbow taps methodology in the future for Unit 2.
Please revise this section to describe the current plant design/methodology.
FSAR section 7.2.1.1.10, setpoints: NRC staff has issued RIS 2006-17 to provide guidance to the industry regarding the instrument setpoint methodology which complies with 10 CFR 50.36 requirements. Provide the information on how the WBN2 setpoint methodology meets the guidance of RIS 2006-17 and include this discussion in this section. Also, by letter dated May 13, 2010, TVA provided Rev. 7 of EEB-TI-28 to the staff. The staff noted that section 4.3.3.6 of EEB-TI-28 discusses the correction for setpoints with a single side of interest. It should be noted that the staff has not approved this aspect of setpoint methodology for Unit 1. The staff finds this reduction in uncertainties is not justified unless it can be demonstrated that the 95/95 criteria is met. Therefore, either remove this reduction factor for single sided uncertainties or justify how you meet the 95/95 criteria given in RG 1.105.
50.59.
TVA to provide date when information will be docketed.
Open TVA to provide date when information will be docketed.
FSAR section 7.2.2.1.1, paragraph six was changed to state that the design meets the requirements of Criterion 23 of the 1971 GDC instead of the Criterion 21 of the GDC. The Criterion 21 is about protection system reliability and testability, while Criterion 23 is about protection system failure modes. Since this paragraph deals with the evaluation of design with respect to common-mode failure, the staff believes that Criterion 23 is the right reference for this paragraph. Please clarify.
FSAR Section 7.2, Reactor Trip System Open TVA to provide date when information will be docketed.
154 156 157 158 159 160 FSAR Amd 100.
Since all the setpoint and allowable value for Unit 2 is calculated and added to TS, TVA needs to address the latest criteria and that include 95/95 criteria.
FSAR Section 7.2, Reactor Trip System Open FSAR section 7.2.1.1.7 added the reference to FSAR section 10.4.4.3 for exception to P-12.
However, FSAR section 10.4.4.3 states bypass condition is not displayed and it is not automatically removed when conditions for bypass are no longer met. Provide the basis for this.
Add alternate method of RCS cooldown using additional steam dump valves after entering Mode 4, by disabling the P-12 Interlock. Operators use additional condenser dump valves to aid in maintaining a cooldown rate closer to the administrative limit established by operating procedure.
Refer to Unit 1 UFSAR Amendment 3 Change Package 1676 S00 (Attachment 6) for the safety evaluation and basis for this change.
(Q1) Refer to the response to letter item 13, RAI Matrix Item 51.
(Q2) EEB-TI-28's single sided methodology conforms with WBN's design basis commitment to ensure that 95% of the analyzed population is covered by the calculated tolerance limits as defined in NRC Reg Guide 1.105, Revision 2, 1986 that was in affect during WBN Unit 1 licensing.
FSAR Section 7.2, Reactor Trip System File: rad8C078.xlsx Page 19 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
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Status/Current Action June 25, 2010 NRC POC: EICB (Garg)
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The text was revised to match the Unit 1 UFSAR. The Unit 1 text was modified in Amendment 1 by FSAR Change Package 1553 S00 which is contained in Attachment 30.
The basis for the change in the change package is:
- 23. (page 7.2-24): Portions of the discussion of control and protection system interaction are revised to clarify the requirement. The discussion of how the SG low-low water level protective function and the control system Median Signal Selector satisfy this requirement is deleted since it Is redundant to the information provided In Section 7.2.2.3.5. Reactor Protection System Description N3-99-4003 is also revised to move and clarify the discussion of the requirements for control and protection system Interaction from Section 3.1.1.2 to Section 2.2.11, where the Issue is also discussed.
FSAR Amendment 99 reflects the changes associated with the Foxboro I/A system design.
The Bypassed and Inoperable Status Indication System (BISI) compliance with Reg. Guide 1.47 is described in detail in FSAR Section 7.5.2.2.
The reference to Section 7.2.2.2 for the general discussion for control and protection interactions is provided in Section 7.2.2.3. The reference in Section 7.2.2.3 is applicable to all Sub-Section paragraphs, including 7.2.2.3.2. An additional reference in this section is not necessary and would be redundant to the Section 7.2.2.3 reference.
FSAR section 7.2.2.3 states that changes to the control function description in this section are expected to be required after vendor design of the Unit 2 Foxboro IA design is complete. Provide the schedule for the completion of the design and when this information will be available to the staff for review and approval.
162 Open TVA to provide date when information will be docketed.
FSAR Section 7.2, Reactor Trip System Open TVA to provide date when information will be docketed.
168 Continuous rod withdrawal events are analyized in FSAR sections 15.2.1 and 15.2.2. While the rod stops a mentioned, they are not credited in the analysis.
165 166 167 Open FSAR Section 7.2, Reactor Trip System FSAR Section 7.2, Reactor Trip System Changes to FSAR section 7.2.2.2(20) are justified based on the statement that the integrated computer system is implemented through EDCR 52322. Provide a copy of EDCR 52322 for staff review.
EDCR 52322, Design, Procure And Construct An Intergrated Computer System (Ics) For Watts Bar Nuclear Plant Unit 2. Provide All Appropriate Documentation To Support Design Input. Generate Or Revise All Official Drawings To Represent Final Constuction Configuration is contained in Attachment __
FSAR Section 7.2, Reactor Trip System Open TVA to provide date when information will be docketed.
FSAR Section 7.2, Reactor Trip System FSAR section 7.2.2.2(14) states that bypass of a protection channel during testing is indicated by an alarm in the control room. Explain how this meets RG 1.47.
Open TVA to provide date when information will be docketed.
Open TVA to provide date when information will be docketed.
FSAR section 7.2.2.2(7) deleted text which has references 12 and 14. These references are not included in the revised text. Provide the basis for the deletion of these references. Also, the revised text states that typically this requirement is satisfied by utilizing 2/4 logic for the trip function or by providing a diverse trip. Provide any exception to this and their basis for acceptability.
FSAR Section 7.2, Reactor Trip System FSAR section 7.2.2.3.2, last paragraph of this section has been deleted. The basis for this deletion is that discussion regarding the compliance with IEEE-279, 1971 and GDC 24 is covered in section 7.2.2.2. However, there is no reference to this section in 7.2.2.3.2 to direct the reader to 7.2.2.2. Please revise 7.2.2.2 accordingly.
Open TVA to provide date when information will be docketed.
164 161 TVA to provide date when information will be docketed.
FSAR section 7.2.2.4, provide an analysis or reference to chapter 15 analysis which demonstrate that failure of rod stop during a rod withdrawal event will not affect the safety limit.
FSAR section 7.2.2.2(20) has been revised to include the plant computer as a means to provide information read out for all signals which can cause a reactor trip. Justify the use of the plant computer for this function. Include the discussion on the effect of plant computer failure on the system functions.
FSAR Section 7.2, Reactor Trip System File: rad8C078.xlsx Page 20 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
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Status/Current Action June 18, 2010 NRC POC: EICB (Garg)
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176 172 Open TVA to provide date when information will be docketed.
174 170 Placeholder: The staff has identifed questions regarding unidirectional communications interface.
The staff will keep this item open until TVA confirms testing has demonstrated that two way communication is impossible with the described configurations.
FSAR Amendment 99 Section 7.5.1.2 states: "Type A Variables Those variables that provide primary information to the MCR operators to allow them to take preplanned manually controlled actions for which no automatic action is provided and that are required for safety systems to accomplish their safety functions for Chapter 15 design basis events. Primary information is information that is essential for the direct accomplishment of specified safety functions."
Clarify whether Unit 2 has the same Type A variables as Unit 1.
August 19, 2010 - TVA to submit calculation.
177 Open TVA to provide date when information will be docketed.
EEB-TI-28 discusses the correction for setpoints with a single side of interest. The staff finds this correction factor is not justified. TVA should justify this correction factor and demonstrate that, with this correction, factor 95/95 criteria identified in RG 1.105 is met.
Open TVA to docket calculation.
Closed During a FAT diagnostic test, the Loop Calculation Processor (LCP) failed while performing a parameter update. TVA should identify the cause and fix for the problem encountered. (Open Item # 1 of Eagle 21 audit)
This is a duplicate of the rack 5 update issue item 114.
171 173 Open TVA to provide date when information will be docketed.
This this change is in accordance with the Unit 1 UFSAR. The change was made by FSAR Change Package 1553 S00 (Attachment __). The justification for the change is:
38 (Table 7.2-4): This table lists the reactor trips and the various accident analyses for which each trip could provide protection. The intent of the table is to demonstrate the diversity of and comprehensive protection provided by the reactor trip system against various postulated events and to correlate the trip functions with the analyses in which they may be utilized, either as a primary or secondary protective function. Chapter 15, along with the Accident Analysis Parameters Checklist, WB-OC-40-70, provides the accident analysis discussion and identifies the protection system functions which provide accident mitigation. The additions and deletions to the table are made for consistency with the safety analyses of record as reflected in the design and licensing basis and do not represent analysis changes or protection system changes. Therefore. they are considered to be non-significant as discussed at the beginning of this section. Neutron Monitoring System Description N3-85-4003 Table 2 is also revised for consistency with WB-DC-40-70.
169 Describe the design changes which were made to Unit 1 by 10CFR50.59 process and which significantly affect the instrumentation and controls systems discussed in FSAR Chapter 7.
This is a duplicate of items 2, 10, 11 and 44 Closed An external unidirectional communications interface was installed between the Eagle 21 test subsystem and the plant process computer. TVA should confirm that testing has demonstrated that two way communication is impossible with the described configuration. (Open Item # 3 of Eagle 21 audit)
TVA to provide date when information will be docketed.
FSAR table 7.2-4, item 9 deleted loss of offsite power to station auxiliaries (station blackout) based on the fact that station blackout is not listed in AAPC events. Explain what are AAPC events and how it justifies deleting this accident from the list.
Closed TVA needs to document that Arnold Magnetics power supplies have been used and environmentally qualified at Unit 1 and therefore meet the licensing basis for Unit 2. If these power supplies are not used and qualified in Unit 1, then TVA will have to discuss the qualification of these power supplies based on the guidance provided in RG 1.209 (Open Item # 2 of Eagle 21 audit.)
This is a duplicate of item 113.
Open TVA to provide date when information will be docketed.
Placeholder: The staff has identified questions regarding instrument setpoints. The staff will keep the instrument setpoint methodology issue open until TVA provides additional information regarding RIS 2006-17 and single sided correction factor for uncertainty determination.
The type A variables are the same in Unit 1 and Unit 2. See calculation WBNOSG4047 Rev.
4 (Attachment )
File: rad8C078.xlsx Page 21 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action July 15, 2010 NRC POC: EICB (Marcus)
Date:
Responder: Clark Date:
Responsibility:
July 15, 2010 NRC POC: EICB (Halverson)
Date:
Responder: WEC Date:
Responsibility:
July 15, 2010 NRC POC: EICB (Halverson)
Date:
Responder: WEC Date:
Responsibility:
July 15, 2010 NRC POC: EICB (Halverson)
Date:
Responder: WEC Date:
Responsibility:
July 15, 2010 NRC POC: EICB (Halverson)
Date:
Responder: WEC Date:
Responsibility:
181 August 19, 2010 - TVA to submit calculation.
Open TVA to provide date when information will be docketed.
180 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 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 Explain the source(s) of the requirements present in the Post Accident Monitoring Systems 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 Requirments Specification, what directed the author to include the requirement there?
182 Open TVA to provide date when information will be docketed.
The SRP, BTP 7-14, Section B.3.3.1 states that Regulatory Guide 1.172 endorses, with a few noted exceptions, IEEE Std 830-1993. IEEE Recommended Practices for Software Requirements Specifications.
Clarify whether the WBU2 Post Accident Monitoring Systems Software Requirements Specification adheres to IEEE std 830-1993 as modified by Regulatory Guide 1.172?
If yes, please provide an evaluation that includes an identification and description of all differences proposed from the modified standard. Please describe how the alternatives provide an acceptable method of complying with those regulations that underlie the corresponding SRP acceptance criteria.
If no then please provide an evaluation that includes an identification and description of all differences proposed from the acceptance criteria given in SRP, BTP 7-14, Section B.3.3.1.
Please describe how the alternatives provide an acceptable method of complying with those regulations that underlie the corresponding SRP acceptance criteria.
Open TVA to provide date when information will be docketed.
Open 178 179 Open TVA to docket calculation.
Please provide WBN-OSG4-047, "PAM Type A Variable Determination."
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 regarding backwards traceability 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 Discuss how TVA has ensured that the re is traceability (and particularly backward traceability) for each requirement. If requirements are not traceable, please explain how the SRS complies with the regulations that underlie the SRP.
See response to item 177 above.
File: rad8C078.xlsx Page 22 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action July 15, 2010 NRC POC: EICB (Halverson)
Date:
Responder: WEC Date:
Responsibility:
July 15, 2010 NRC POC: EICB (Halverson)
Date:
Responder: WEC Date:
Responsibility:
July 15, 2010 NRC POC: EICB (Halverson)
Date:
Responder: WEC Date:
Responsibility:
184 Open TVA to provide date when information will be docketed.
The NRC considers that a System Requirements Specification is the complete set of requirements used for the design 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.
Are there any sources of requirements in parallel with the Post Accident Monitoring Systems 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?
Open Characteristics that the SRP states that an Software Requirements Specifications should have include unambiguity, verifiability, and style, part of the latter is that Each requirement should be uniquely and completely defined in a single location in the SRS.
Clarify whether the unnumbered paragraphs in the Post Accident Monitoring Systems 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.
183 185 TVA to provide date when information will be docketed.
Open TVA to provide date when information will be docketed.
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 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 On page 1-2 of the Post Accident Monitoring Systems 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 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?
File: rad8C078.xlsx Page 23 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action July 15, 2010 NRC POC: EICB (Darbali)
Date:
Responder: Perkins/Clark Date:
Responsibility:
187 July 20, 2010 NRC POC: EICB (Carte)
Date:
Responder: Clark Date:
Responsibility:
Open Are these connections already docketed?
July 20, 2010 NRC POC: EICB (Carte)
Date:
Responder: Clark Date:
Responsibility:
Open NNC 8/25/10: Why did TVA not catch this on the review of the PAMS SysRS or SRS? Does TVA check that the CQ PAMS system meets the requirements in its purchase specifications?
TVA to provide date when information will be docketed.
Once FSAR Amendmet 101 is received, the item will be closed.
- 1) TVA previously identified this discrepancy to Westinghouse during review of the Common Q PAMS Licensing Technical Report. The other documents were already in the submittal process when this discrepancy was identified to Westinghouse and were issued before the correction was made. The discrepany will be corrected at the next revision of the PAMS System Requirements Specification.
- 2) This is a duplicate of closed RAI Matrix Item 45.
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 design 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 Systems 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 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?
Along with Amendment 96, TVA submitted a list of Bechtel changes for each section. Change number 45 addresses a change to section 7.7.1.12, AMSAC, however, the Justification column states This change is not included. EDCR 52408 installs the AMSAC in Unit 2. It does not have a trouble alarms. The existing words better reflect the operation of the system.
Even thought this change was not included in Amendment 96, will it be included in a future amendment?
Also, please submit a summary of EDCR 52408.
This change will be included in FSAR Amendment 101.
EDCR 52408 Summary:
A Purchase Order was issued to Nutherm International to provide a Unit 2 cabinet with the same functions as the current Unit 1 AMSAC. EDCR 52408 will install the cabinet and route/install cabling to provide the necessary inputs/outputs for/from the AMSAC cabinet. The EDCR will only route and install cables from the cabinet to the field side of a terminal block in the Main Control Room panel 2-M-3. These cables will provide the AMSAC NOT ARMED and AMSAC ACTUATED signals to annunciator windows.
Two pressure transmitters will also be installed in two local panels. Cables will be routed to the transmitters to provide the signal and power. Four cables will be routed to a local panel to provide steam generator level signals. Other cables will be routed to provide an output signal to start a Motor Driven Auxiliary Feedwater Pump and to provide an output signal to trip the turbine.
This work will make the Unit 1 and 2 Main Control Room panel inputs to plant computer and annunciator light box windows nomenclature identical to each other.
Response is satisfactory. Issue date of Amendment 101 is not yet determined.
By letter dated June 18, 2010, TVA docketed responses to NRC requests for information.
- 1) Enclosure 1, Item No. 33 of the TVA letter dated June 18, 2010, did not identify any connection from the PAMS Operator Modules (OMs) to the plant computer and printers; however, Figure 2.1-1 of the PAMS System Requirements Specification (WNA-DS-01617-WBT Rev. 1 -
ML101680578) shows a TCP connection from the OMs to the plant computer and printer. Please explain.
- 2) Please clarify whether any digital safety-related systems or components have a digital communications path to non-safety-related systems or with safety related systems in another division. If so, NRC staff will need these paths identified on the docket.
188 186 File: rad8C078.xlsx Page 24 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action TVA to respond or provide proposed date of response.
189 July 20, 2010 NRC POC: EICB (Carte)
Date:
Responder: Clark Date:
Responsibility:
Open TVA to Docket FSAR Amendment 100.
NRC to check for inclusion in Amendment 100.
July 20, 2010 NRC POC: EICB (Carte)
Date:
Responder: Clark Date:
Responsibility:
Open TVA to revise response.
191 July 20, 2010 NRC POC: EICB (Carte)
Date:
Responder: Jimmie Perkins Date:
Responsibility:
Open NRC to review information provided NNC 8/9/10: In response to TVA's requet for clarification, a reference to appropriate SRP section was added.
July 20, 2010 NRC POC: EICB (Marcus)
Date:
Responder: Clark Date:
Responsibility:
Open
- 1) TVA previously identified this discrepancy to Westinghouse during review of the Common Q PAMS Licensing Technical Report. The other documents were already in the submittal process when this discrepancy was identified to Westinghouse and were issued before the correction was made. The discrepany will be corrected at the next revision of the PAMS System Requirements Specification.
- 2) Please refer to Item 1) above.
NNC 8/25/10: Information received, and read.
WBN Unit 2 is in compliance with the regulatory requirements for data communications systems as described in Attachment 33 (Data Communications Systems Description and Regulatory Compliance Analysis).
- 1) TSR 3.3.6.3 specifies 18 months as the calibration frequency.
- 2) Per the Technical Requirements Manual (TRM) Bases 3.3.6 (Attachment __) the surveillance requirements and frequency are provided in Regulatory Guide 1.133, "Loose-Part Detection Program for the Primary System of Light-Water-Cooled Reactors."
- 3) TRM section 3.3.6 and its bases are contained in Attachment __.
NNC 8/25/10: Acceptable response.
This is a typographical error. The correct reference is Table 7.1-1. The reference will be corrected in FSAR Amendment 100.
By letter dated June 30, 2010, TVA docketed, Tennessee Valley Authority (TVA) Watts Bar Unit 2 (WBN2) - Post-Accident Monitoring System (PAMS) Licensing Technical Report, (Document Number WNA-LI-00058-WBT-P, Revision 0, June 2010) (Westinghouse Proprietary Class 2).
- 1) Figure 2.2-1 of the PAMS Licensing Topical Report does not show any connection between the Operators Modules and the plant computer or printer; however, Figure 2.1-1 of the PAMS System Requirements Specification (WNA-DS-01617-WBT Rev. 1 - ML101680578) shows a TCP connection from the OMs to the plant computer and printer. Please explain.
- 2) Section 5.3, Response to individual criteria in DI&C-ISG-04, of the PAMS Licensing Topical Report does not address the TCP connection between the OM and non-safety components depicted in Figure 2.1-1 of the PAMS System Requirements Specification (WNA-DS-01617-WBT Rev. 1 - ML101680578). Please explain.
FSAR Section 7.6.7States: Conformance with Regulatory Guide 1.133, Revision 1 is discussed in Table 7.1-7. FSAR Chapter 7 does not contain any such numbered table. Please explain.
190 192 NUREG-0800 Chapter 7, Section 7.9, "Data Communication Systems" contains review criteria for data communication systems. The WBN2 FSAR did not include any description of data communications systems.
- 1) Please identify all data communications systems.
- 2) Please describe each data communications system identified above.
- 3) Please provide a regulatory evaluation of each data communications system against the applicable regulatory criteria.
FSAR Table 7.1-1 states: Regulatory Guide 1.133, May 1981 Loose-Part Detection Program for the Primary System of Light-Water Cooled Reactors, Revision 1 (See Note 12)Note 12 Conforms except as noted belowPositi[o]ns C.3.a.(3) and C.5.c. recommend a channel calibration be performed at least once pe[r] 18 months. In lieu of this recommendation, the DMIMS will be calibrated at the frequency stated in subsection TSR 3.3.6.3 of TR 3.3.6 (Loose-Part Detection System).
- 1) Clarify what frequency is specified in TSR 3.3.6.3.
- 2) Please explain why the stated calibration frequency is adequate for meeting regulatory requirements.
- 3) Please provide sufficient documentation for the NRC to independently evaluate the conformance claims stated in the FSAR.
NNC 08/25/10: See Open Item No. 187.
File: rad8C078.xlsx Page 25 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action NRC to review Response.
193 July 20, 2010 NRC POC: EICB (Marcus)
Date:
Responder: Clark Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
July 20, 2010 NRC POC: EICB (Marcus)
Date:
Responder: Costley/Norman Date:
Responsibility:
Open The WBU2 FSAR, Section 7.5.2, Plant Computer System, contains three subsections, 7.5.2.1, Safety Parameter Display System 7.5.2.2, Bypassed and Inoperable Status Indication System (BISI) 7.5.2.3, Technical Support Center and Nuclear Data Links Are there three separate sets of hardware that implement these functions, or are these three functions that are implemented on a single set of hardware?
194 The NRC Staff is using SRP (NUREG-0800) Chapter 7 Section 7.5, Instrumentation Systems Important to Safety, to review the WBU2 FSAR Section 7.5, Instrumentation Systems Important to Safety. The following requests are for information that the SRP directs the reviewers to evaluate.
The role of the EICB Technical reviewer is to determine if there is reasonable assurance that the equipment will perform the required functions. The WBU2 FSAR, Section 7.5.2, Plant Computer System, does not contain any description of the equipment that performs the functions described in the section. Enclosure 1 Item 3 of letter dated March 12, 2010, TVA stated that the platform of the Process Computer was, Hewlett Packard RX2660 and Dell Poweredge R200 servers with RTP Corp 8707 I/O. In addition TVA provided (a) two pages of marketing literature by DELL on the Poweredge R200 Server, (b) the HP Integrity rx2660 Server Unser Service Guide, and (c) the Integrated Computer System Network Configuration Connection Diagram (2-45W2697-1-1 dated 8/27/09). This provided information is not sufficient for evaluating whether the equipment will, with reasonable assurance, perform the functions described in the FSAR.
- 1) Is the Plant Computer System another name for the Process Computer?
- 2) Please provide an architectural description of the Plant Computer System.
- 3) Please describe the relationship between the Plant Computer System and the Integrated Computer System.
August 19, 2010 - NRC to review TVA response.
- 11. At WBN Unit 1 and 2, there is a single computer system named the Integrated Computer System or ICS. That system is sometimes described as the Plant Computer System, the Process Computer, the Technical Support Center Data System (TSCDS) or the Emergency Response Facility Data System (ERFDS). At one time, the TSCDS and ERFDS were separate computers on unit 1 but their functions were all incorporated into the ICS when it was installed.
- 2. The Watts Nuclear Plant (BFN) Integrated Computer System (ICS), a non-safety related system, is designed as a single, large-scale nuclear plant computer system which integrates balance of plant (BOP) monitoring with extensive nuclear steam supply system (NSSS) application software into a comprehensive computer based tool for plant operations. The system is comprised of the following major components:
- Remote multiplexers in the Computer Room, Auxiliary Instrument Room and 480V Board rooms.
- Redundant Central Processing Units (CPUs)
- Data Storage Devices
- Man-Machine Interfaces (MMI) - Satellite Display Stations (SDS) terminals in the Main Control Room (MCR), Technical Support Center (TSC) and Computer Room.
- Networking equipment including switches, firewalls and terminal servers
- Printers
- Data Links to other plant computer devices (serial and network)- These systems or devices include but are not limited to:
o System Foxboro I/A Systems (unit 2 only) o Arreva Beacon core monitoring systems o Multi-pen recorders o Landis & Gyr switchyard monitoring system o Computer Enhanced Rod Position Inidication (CERPI) o Eagle 21 o Ronan Annunicator o Leading Edge Flow Meter (LEFM) o Bently-Nevada vibration monitoring system o Inadequate Core Cooling Monitor (ICCM) (unit 1 only) o Common Q (unit 2 only) o WinCISE (unit 2)
There is a single set of hardware that incorporates the functionality of Safety Parameter Display System (SPDS), Bypass and Inoperable Status Indication System (BISI) and the Technical Support Center (TSC).
Also refer to the response to item 71.
The function of the Nuclear Data Links or Emergency Response Data System (ERDS) is actually provided by the TVA Central Emergency Control Center (CECC) which acts as the Emergency Offsite Facility (EOF) for all of TVAs nuclear units. Plant data will be sent on a periodic basis from the ICS to the CECC via PEDs. That data is then available to be sent from the CECC to the NRC.
File: rad8C078.xlsx Page 26 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action TVA to respond or provide proposed date of response.
195 July 20, 2010 NRC POC: EICB (Marcus)
Date:
Responder: Costley/Norman Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
July 20, 2010 NRC POC: EICB (Marcus)
Date:
Responder: Costley/Norman Date:
Responsibility:
Open Bypassed and Inoperable Status Indication (BISI)
The WBU2 FSAR Section 7.5.2.2, Bypassed and Inoperable Status Indication System (BISI),
contains a description of the Bypassed Inoperable Status Indication System (BISI).
SRP Section 7.5, Subsection II, Acceptance Criteria states:
Requirements applicable to bypassed and inoperable status indication 10 CFR 50.55a(a)(1),
Quality Standards.
Please provide a description of how BISI meets this regulatory requirement.
The WBU2 FSAR Section 7.5.2.1, Safety Parameter Display System, contains a description of the Safety Parameter Display System.
SRP Section 7.5, Subsection II, Acceptance Criteria states:
Requirements applicable to the review of SPDS10 CFR 50.55a(a)(1), Quality Standards.
Please provide a description of how SPDS meets this regulatory requirement.
196 The principal purpose and function of the SPDS is to aid control room personnel during abnormal and emergency conditions in determining the safety status of the plant and in assessing if abnormal conditions require corrective action by the operators to avoid a degraded core. It also operates during normal operations, continuously displaying information from which the plant safety status can be readily and reliably accessed.
To ensure quality, the design, testing, and inspection of the SPDS is controlled by qualified personnel and by using TVA procedure SPP-2.6, Computer Software Control. 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 TVAs nuclear power plants consistent with the Nuclear Quality Assurance Plan.
This ensures that the design and operation of the SPDS complies with the 10 CFR 50.55a(a)(1) quality standards requirements. The controls and processes outlined in the procedure provide assurance that the SPDS will perform its intended function correctly.
The plant Integrated Computer System(ICS) provides the SPDS for WBN. Any changes to the SPDS software must be documented and controlled using a Software Service Request(per SPP-2.6) and must be implemented under the engineering design change process(Design Change Notice, DCN). Controls in SPP-2.6 guide the development and testing of the SPDS changes.
Other controls put in place by this procedure to further maintain quality standards are:
- Changes to SPDS software from remote locations is prohibited.
- 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.
- 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.
- The software source code is kept in a physically secure, environmentally controlled space The BISI system is a computer based system that provides automatic indication and annunciation of the abnormal status of each ESFAS actuated component of each redundant portion of a system that performs a safety-related function.
To ensure quality, the design, testing, and inspection of the BISI system is controlled by qualified personnel and by using TVA procedure SPP-2.6, Computer Software Control. 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 TVAs nuclear power plants consistent with the Nuclear Quality Assurance Plan.
This ensures that the design and operation of the BISI System complies with the 10 CFR 50.55a(a)(1) quality standards requirements. The controls and processes outlined in the procedure provide assurance that the BISI system will perform its intended function correctly.
The plant Integrated Computer System(ICS) provides the BISI system for WBN. Any changes to the BISI software must be documented and controlled using a Software Service Request(per SPP-2.6) and must be implemented under the engineering design change process(Design Change Notice, DCN). Controls in SPP-2.6 guide the development and testing of the BISI changes.
Other controls put in place by this procedure to further maintain quality standards are:
- Changes to BISI software from remote locations is prohibited.
- 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.
- 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.
- All documentation related to the BISI 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.
File: rad8C078.xlsx Page 27 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action TVA to respond or provide proposed date of response.
198 July 20, 2010 NRC POC: EICB (Marcus)
Date:
Responder: Costley/Norman Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
199 July 20, 2010 NRC POC: EICB (Marcus)
Date:
Responder: Costley/Norman Date:
Responsibility:
Open Section C of the Regulatory Guide lists the following six regulatory positions for guidance to satisfy the NRC requirements with respect to the bypassed and inoperable status indication(BISI) for nuclear power plant safety systems:
- 1. Administrative procedures should be supplemented by an indication system that automatically indicates, for each affected safety system or subsystem, the bypass or deliberately induced inoperability of a safety function and the systems actuated or controlled by the safety function. Provisions should also be made to allow the operations staff to confirm that a bypassed safety function has been properly returned to service.
Response: The BISI system provides indication(displays and annunciation) that a functional path for each train of a safety system or support system has been rendered in a state which could cause inoperability. The BISI system monitors and provides system level alarms for these plant safety-related systems:
- Main and Aux Feedwater
- Safety Injection
- Emergency Gas Treatment
- Essential Raw Cooling Water
- Chemical and Volume Control
- Ventilating
- Component Cooling
- Control Air( including Aux Control Air)
- Standby Diesel Generator The system level displays/indicating lights indicate the status of each systems train functional path as well as the status of any support system that might put the system in an inoperable or bypassed condition.
The BISI system software runs on the Integrated Computer System(ICS) and it provides the capability to monitor in real time the parameters required to provide a BISI system as described in the Reg Guide.
Bypassed and Inoperable Status Indication (BISI)
The NRC staff is performing its review in accordance with LIC-110, Rev. 1, Watts Bar Unit 2 License Application Review. LIC-110 directs the staff to review systems unique to Unit 2 in accordance with current staff guidance. Regulatory Guide (RG) 1.47 Revision 1, Bypassed and Inoperable Status indication for Nuclear Power Plant Safety Systems, is the current regulatory guidance for BISI. Please provide a regulatory evaluation of BISI against the current RG.
SRP Section 7.5, Subsection III, Review Procedures states: Recommended review emphasis for BISI F. Scope of BISI indications - As a minimum, BISI should be provided for the following systems:
- Reactor trip system (RTS) and engineered safety features actuation system (ESFAS) - See SRP Appendix 7.1-B subsection 4.13, Indication of Bypasses, and SRP Appendix 7.1-C subsection 5.8.3, Indication of Bypasses.
- Interlocks for isolation of low-pressure systems from the reactor coolant system - See SRP BTP 7-1.
- ECCS accumulator isolation valves - See SRP BTP 7-2.
- Controls for changeover of residual heat removal from injection to recirculation mode - See SRP BTP 7-6.
G. Conformance with Regulatory Guide 1.47, Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety Systems.
H. Independence - See SRP Appendix 7.1-B subsection 4.7, Control and Protection System Interaction, and SRP Appendix 7.1-C subsections 5.6, Independence, and 6.3, Interaction Between the Sense and Command Features and Other Systems. The indication system should be designed and installed in a manner that precludes the possibility of adverse effects on plant safety systems. Failure or bypass of a protective function should not be a credible consequence of failures occurring in the indication equipment, and the bypass indication should not reduce the required independence between redundant safety systems.
I. Use of digital systems - See SRP Appendix 7.0-A and Appendix 7.1-D.
Please provide a description of how BISI meets each item above, or provide appropriate justification for not doing so.
F. The scope of the WBN BISI indications are based on engineering calculation WBPEVAR8807025 Rev. 7 (Attachment __). This calculation has not been updated for Unit
- 2. The calculation does include Common and Unit 2 equipment required to support Unit 1 operation.
G. Compliance to Regulatory Guide 1.47 is described in design criteria document WB-DC 29 Rev. 8, Integrated Computer System (Attachment __) which is a design input to calculation WBPEVAR8807025 Rev. 7 (Attachment __).
H. Design criteria document WB-DC-30-29 Rev. 8, Integrated Computer System (Attachment
__), section 3.4.1, BISI Design and Operation states: The BISI shall not be designed to safety related system criteria and therefore is not to be used to perform functions essential to the health and safety of the public. Class 1E isolation is required, however, to maintain the independence of safety related equipment and systems.
I. - Response under development File: rad8C078.xlsx Page 28 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action TVA to respond or provide proposed date of response.
Related SE Section 7.5.5.3 200 July 21, 2010 NRC POC: EICB (Carte)
Date:
Responder: Tindell Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
Related to SE Section 7.5 201 July 21, 2010 NRC POC: EICB (Carte)
Date:
Responder: Webb Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
Related to SE Section 7.7.1.1.1 202 July 22, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
Relates to SE Section 7.5.2, PAMS 203 July 26, 2010 NRC POC: EICB (Marcus)
Date:
Responder: Clark Date:
Responsibility:
Open Amendment 99, FSAR Section 7.7.1.1.1, "Reactor Control Input Signals (Unit 2 Only)," contains a description of functions performed uniquely for Unit 2. Please describe the equipment that performs this function (in sufficient detail to support a regulatory evaluation), and evaluate this equipment against the appropriate regulatory criteria.
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.
The WBU2 FSAR Section 7.5.2.3, Technical Support Center and Nuclear Data Links, contains a description of the Technical Support Center and Nuclear Data Links.
SRP Section 7.5, Subsection II, Acceptance Criteria states:
Requirements applicable to the review ofERF information systems, and ERDS information systems 10 CFR 50.55a(a)(1), Quality Standards.
Please provide a description of how the nuclear data links meets this regulatory requirement.
Amendment 99 of the Watts Bar Unit 2 FSAR Section 7.5, Instrumentation Systems Important to Safety, does not include any description of instrumentation for normal operation; therefore, Section 7.5 of the FSAR does not support statements made in the SER Section 7.5; compare SER (ML072060490) Section 7.5.1 and FSAR Amendment 99 Section 7.5. Please identify where, in the docketed material, information exists to support the statements in the SER Section 7.5.1.
The Technical Support Center is intended to be an accident mitigation support center and provides Satellite Display Stations (SDS) capable of displaying information on plant systems for Unit 1, Unit 2 or the Simulator. Stations in the TSC receive data from the plant Integrated Computer System (ICS) over the ICS network. Separate PCs receive data from the simulator computer over the WBN site network to support drills and training exercises. Those PCs can also access the Plant Engineering Data System (PEDS) as a backup to ICS. The TSC also has a separate computer that connects to the CECC to allow additional access to meteorological station.
The ICS data is also transmitted from the PEDS server through the PEDS Firewall over the WBN Site Network to the CECC computers (Chattanooga). The CECC computers transmit the data over the TVA Corporate Network, through the TVA Firewall (provided by NRC),
through the NRC Firewall to the NRC. Transmission of this data from the ICS and Meteorological Station over data link (High Speed Communications Link) to the CECC and NRC meet the requirements of NUREG-0696, Functional Criteria for Emergency Response Facilities and NUREG-1394, Emergency Response Data System Implementation.
File: rad8C078.xlsx Page 29 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action TVA to respond or provide proposed date of response.
204 July 26, 2010 NRC POC: EICB (Marcus)
Date:
Responder: Costley/Norman Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
Relates to SE Section 7.5.2, PAMS 205 July 26, 2010 NRC POC: EICB (Garg)
Date:
Responder: Clark Date:
Responsibility:
Open By letter dated March 12, 2010 (ML101680577) TVA provided drawing No. 2-45W2697-1-1, "Integrated Computer System Network Configuration Connection Diagram," that depics three "Data Diode"s. Please provide a detailed description of the equipment, software, and configurations of each "Data Diode".
The plant computer system is one set of hardware. The Safety Parameter Display System, Bypassed and Inoperable Status Indication System (BISI), Technical Support Center and Nuclear Data Links are all functions of the Plant Computer System. Historically the Westinghouse P2500 Plant Process Computer and Emergency Response Facilities Data System (ERFDS) were individual systems but were merged together with the implementation of DCN 39911-A, implemented for WBN Unit 1 in December 1998, to become the Plant Integrated Computer System (ICS). A similar system is being installed for WBN Unit 2 based on the same software with more modern hardware.
The ICS is composed of a number of pieces of hardware, all utilized as a system, to provide the functions listed in the FSAR sections 7.5.2.1, 7.5.2.2 and 7.5.2.3. This hardware includes but is not limited to Hewlett Packard (HP) servers (CPU), DELL servers (CPU), Fiber Optic Panels, Fiber Optic Converters, Switches, Firewalls, Network Taps, Multiplexors (RTP), LCD displays and fiber optic and copper Ethernet cables. As all the applicable hardware make up the system it is all common to more than one function and there is no separate set of equipment for any of the functions referenced in FSAR Section 7.5.2.1 and 7.5.2.2.
The Nuclear Data Link and EOF functions described in 7.5.2.3 are provided by the CECC in Chattanooga. In order for the CECC to have access to ICS data, both the PEDS and the data diode isolating the PEDS from the ICS must be operational.
Meteorological data from the Environmental Data Station (EDS) is gathered by the Unit 1 ICS. That data is sent over to the unit 2 ICS via the inter-unit firewall.
- 1. Three data diodes.
- 2. Two provide an interface between train A and B of Common Q.
- a. These are identical systems consisting of the following:
- i. Dual DELL R200 computers ii. Red Hat Enterprise Linux software that is locked down by CTI iii. 55 Mbs Owl cards iv. Fiber optic Ethernet interface to trained Maintenance test panel
- b. Software is configured to allow only specific traffic from the MTP to pass through to the ICS
- c. The secure side of the data diode will initiate the connection to the MTP, so there will be a bidirectional connection between the secure side of the data diode and the MTP. There will be no bidirectional data flow from the ICS to the MTP since the diode will block all incoming traffic from the ICS.
- 3. The third data diode is placed between the two ICS systems and the two PEDS computer systems.
- a. Hardware is identical to that used by TVA in other plants
- i. Dual HP DL360GS computers ii. Red Hat Enterprise Linux software that is locked down by CTI iii. 155 Mbs OWL cards iv. RJ45 Ethernet to PEDS network
- b. Diode is configured to allow certain types of data to flow from the ICS network to the PEDS network. This includes but is not limited to the following:
- i. Once per second current values and qualities for all points ii. History data archived by the ICS iii. Data files
- c. The data diode does not allow any data to be transferred between the PEDS network and the ICS network.
By letter datedApril 27, 2010 (ML101230248), TVA stated (Enclosure Item No.19): "The WBN Unit 2 Itegrated Computer System(ICS) modification merges the ERFDS and plant computer into a single computer network."
FSAR Section 7.5.2, "Plant Computer System," has three subsections:
7.5.2.1, "Safety Parameter Dispaly System" 7.5.2.2, "Bypassed and Inoperable Status Indication System (BISI)"
7.5.2.3, "Technical Cupport Center and Nuclar Data Links" This arrangement implies that the each of these function are part of the plant computer, and not a separate sets of equipment. Please describe the equipment for each function and identify any equipment common to more than one function.
File: rad8C078.xlsx Page 30 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action TVA to respond or provide proposed date of response.
Question B related to prior NRC approval of this system or 50.59 information. This question will be addressed in the August plant visit.
206 July 27, 2010 NRC POC: EICB (Marcus)
Date:
Responder: Clark Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
Relates to SE Section: 7.5.5, Plant Computer 208 July 27, 2010 NRC POC: EICB (Marcus)
Date:
Responder: Clark Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
Relates to SE Section: 7.5.2, PAMS 209 July 27, 2010 NRC POC: EICB (Marcus)
Date:
Responder: Clark Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
Relates to SE Section: 7.5.2, PAMS 210 July 27, 2010 NRC POC: EICB (Marcus)
Date:
Responder: Clark Date:
Responsibility:
Open The NRC Requested a description of the plant computer and TVA provided:
(1) Dell marketing literature for Dell Poweredge R200 Server, which can be found on the internet (http://www.dell.com/downloads/global/products/pedge/en/pe_R200_spec_sheet_new.pdf), and (2) HP Integrity rx2660 Server User Service guide (edition 6), which has not yet been found on the internet, but many other editions have been found.
This information is not adequate for answering the question. (Note: TVA also provided a network configuration connection diagram, which is necessary but not sufficient.)
Please provide a description of the plant computer:
(1) Please include sufficinet detail so that an evaluation can be mde against the SRP acceptance criteria in SRP Section 7.7.
(2) Please identify the equipment (hardware and software) that performes each function described in the FSAR.
By letter dated June 18, 2010 (ML101940236), TVA responded to an NRC request for additional information. Enclosure 1 Item No. 6 of this letter identified, for each PAM variable whether the variable was: (1) implemented identically to Unit 1 and reviewed by the NRC, (2) implemented identically to Unit 1 but modified under 10 CFR 50.59 after it was reviewed by the NRC, and (3) implemented in a manner that is unique to Unit 2. There were sixteen variables modified under 10 CFR 50.59; please describe the changes that were performed under 50.59.
The notes provided with the table include the change to the variable under 10 CFR 50.59. For ease of review, the other note references have been deleted for these variables and only the note dealing with the Unit 1 change has been retained in the Notes column of the table excerpt. The applicable notes are highlighted in the notes list.
(1) The Plant Computer is not just a computer but is a system and is designated the Integrated Computer System or ICS. The ICS is composed of multiple computer CPUs, LCD displays, RTP Multiplexer Assemblies, network fiber optic panels, fiber optic converters, Ethernet switches and network taps previously described in items 71, 81 and 82 above. For a detailed discussion of the ICS functions refer to design criteria document WB-DC-30-29 Rev.
8, Integrated Computer System submitted under TVA letter dated August __, 2010.
(2) As previously discussed in item 82, there is no unique set of hardware for any specific function.
By letter dated June 18, 2010 (ML101940236), TVA responded to an NRC request for additional information. Enclosure 1 Item No. 6 of this letter identified, for each PAM variable whether the variable was: (1) implemented identically to Unit 1 and reviewed by the NRC, (2) implemented identically to Unit 1 but modified under 10 CFR 50.59 after it was reviewed by the NRC, and (3) implemented in a manner that is unique to Unit 2. There were nine variables that were identified as both Unique to Unit 2 and identical to what was reviewed and approved on Unit 1. Please explain.
The first eight variables in question are primary chemistry parameter. The parameters are the same for both units, but in Unit 1, the sample is obtained via the post accident sampling system, while in Unit 2 the sample is obtained using a grab sample via the normal sample system.
The last variable was somewhat difficult to characterize. The method of detection and the hardware manufacturer is the same in both units. However, due to obsolescence some of the parts are different than what is installed in Unit 1. The differences are described in Note 21 of the original response.
Regarding the Foxboro Spec 200 system installed at Unit 2:
a-Is it similar to Unit 1? If not, identify the differences and evaluation of the acceptability of these differences.
b-deleted c-For each system which is discussed in the FSAR and utilizes the Spec 200 system, please provide the instrument logic diagram, loop/block diagram with reference to where the system is discussed in the FSAR.
As discussed at the August 3 and 4 meeting in Knoxville between TVA and the NRC, the Foxboro Spec 200 is not a system. The Foxboro Spec 200 analog hardware is used to replace the existing obsolete hardware with the same functions. There are no interconnections between the analog loops unless such interconnections existed prior to the replacement. This is strictly an analog to analog upgrade due to equipment obsolescence.
The Foxboro hardware is installed in existing cabinets which require modifications to accept the Foxboro hardware racks.
a-A listing of the replacements and differences was previously provided as Attachment 1 to TVA letter to the NRC dated June 18, 2010. Within Unit 1, only portions of the AFW controls were replaced. In Unit 2 all safety-related analog loops were replaced. The Foxboro Spec 200 is a fully qualified industry standard for replacement of obsolete analog instrument and control loop hardware.
b-deleted c-c- The Foxboro Spec 200 hardware has not been installed. Therefore the revised drawings have not been issued. Based on this, EDCR excerpts for the logic diagrams and loop/logic drawings were provided as attachments to TVA letter to the NRC dated July 30, 2010. The cross reference between the functions upgraded as part of the Foxboro Spec 200 change is contained in Attachment 33.
File: rad8C078.xlsx Page 31 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action TVA to respond or provide proposed date of response.
Relates to SE Section: 7.5.2, PAMS 211 July 27, 2010 NRC POC: EICB (Carte)
Date:
Responder: Tindell Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
Relates to SE Sections:
7.5.5, Plant Computer 7.6.10, Loose Part Monitoring 7.7.1, Control System Description 7.7.2, Safety System Status Monitoring System 7.7.4, Pzr & SG Overfill 7.9, Data Communications 212 July 27, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
Relates to SE Section 7.5.2 213 July 27, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
Relates to SE Section 7.5.2 214 July 27, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
215 July 29, 2010 NRC POC: DORV (Bailey)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
216 July 29, 2010 NRC POC: EICB (Marcus)
Date:
Responder: Clark Date:
Responsibility:
Open By leter 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 claer how this is the case.
(1) Please describe how the infomation provided demonstrates compliance with IEEE 603-1991 Clauses 5.5, 5.7, 5.10, &6.5.
(2) Please describe how the infomation provided demonstrates conformance with IEEE 7-4.3.2-2003 Clauses 5.5 & 57.
By leter 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 "Theory of Operation Description." The staff has reviewed these documents, and it is not claer how this is the case. The docketed material does not appear to contain the design basis information that is required to evaluaate compliance with the Clause of IEEE 603.
(1) Please provide the design basis (as described in IEEE 604 Calsue 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 opration.
For example: Regarding IEEE 603 Clause 5.8.4 (1) What are the manually controled protective actions? (2) How do the documents identified demonstrate compliance with this clause?
By leter dated June 18, 2010 (ML101940236) TVA stated (Enclosure 1, Attachment 3, Item No.
- 10) that the approved Common Q Topical Report contains information to address the "Safety Analysis." The Common Q SPM however states that a Preliminary Hazards Analysiss Report and the V&V reports document the software hazards analysis. Please Provide these documents.
FSA Table 7.1-1 shows: "The extent to which the recommendations of the applicable NRC regulatory guides and IEEE standards are followed for the Class 1E instrumentation and control systems is shown below. The symbol (F) indicates full compliance. Those which are not fully implemented are discussed in the referenced sections of the FSAR and in the footnotes as indicated."
Please describe how systems that are important to safety, but not 1E, comply with 10 CFR 50.55a(a)1: "Structures, systems, and components must be designed, fabricated, erected, constructed, tested, and inspected to quality standards commensurate with the importance of the safety function to be performed."
By letter dated June 18, 2010 (ML101940236), TVA responded to an NRC request for additional information. Enclosure 1 Item No. 6 of this letter identified, for each PAM variable whether the variable was: (1) implemented identically to Unit 1 and reviewed by the NRC, (2) implemented identically to Unit 1 but modified under 10 CFR 50.59 after it was reviewed by the NRC, and (3) implemented in a manner that is unique to Unit 2. There were seven variables that were identified as both identical to Unit 1 and changed under 10 CFR 50.59. Please explain.
By letter dated June 18, 2010, TVA provided a talbe showing the documents that had been completed and were available for staff review. In a conference call on July 27, 2010, TVA agreed to submit the requested documents on the docket. Please provide the schedule for submitting the documents.
File: rad8C078.xlsx Page 32 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action TVA to respond or provide proposed date of response.
217 NRC Garg 7/6/2010 NRC POC: EICB (Garg)
Date:
Responder: Clark Date:
Responsibility:
NRC Review 218 NRC Garg 7/6/2010 NRC POC: EICB (Garg)
Date:
Responder: Clark Date:
Responsibility:
NRC Review 219 NRC Garg/Kemper 4-Aug-10 Date:
Responder: TVA Licensing Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
220 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Garg)
Date:
Responder: Ayala Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
221 NRC Marcus 8/4/2010 NRC POC: EICB (Garg)
Date:
Responder: Trelease Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
222 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Garg)
Date:
Responder: Clark Date:
Responsibility:
Open By letter dated March 12, 2010 (ML101680577), TVA stated that it would provide five documents to describe the Process computer: (1) EDCR 52322 Rev. A excerpts, (2) HP RX2660 Users Guide AB419-9002C-ed6, (3) Dell Poweredge R200 Server sheet November 2007, (4) RTP Corp 8707 I/O Brochure RTP 8707-02, 2004, and (5) Integrated Computer System Drawing.
By letter dated April 27, 2010 (ML101230248), TVA stated (Enclosure Item No. 20) stated that design changes are planned, therefore a revision to the drawing (5) and EDCR (1) are required.
Please privide updated version of (1) and (5).
The EDCR _____ Source and Intermediate Range, Scope and Intent, Unit Difference and Technical Evaluations are contained in Attachment __.
- 1) EDCR 52322 is contained in Attachment 7.
- 5) The design change referred to is the addition of a data diode. This has not been incorporated into the drawing. Please see the response to letter item 88 (RAI Matrix Item 224).
Provide copies excerpts of the EDCRs and DCNs that provide the block and logic diagrams for the Foxboro Spec 200 implementation.
The excerpt of work order WO 08-813412-000 provided with the June 18 letter did not contain the information showing that the new type (Arnold) power supplies had been installed in the Unit 1 Eagle 21 system. Please provide the necessary pages of the work order to verify the installation of Arnold power supplies in the Unit 1 Eagle 21 System. contains the required correct work order excerpt.
Transmit copy of February 8, 2008 FSAR Red-Line for Unit 2 letter with attachments [CD].
For Safety Related SSPS, submit letter justifying delta between U1 [utilizing ARs] & U2 [utilizing ARs and MDRs]. [Requires TS change ???]
Submit EDCR Technical Evaluation for the source and intermediate range updated electronics for Unit 2 A copy was hand carried by Mr. W. Crouch and delivered to Stewart Bailey at the August 17 meeting at NRC headquarters.
Submit updated list for Foxboro Spec 200 [replacement of Bailey and Robert-Shaw electronics The updated listing of Foxboro Spec 200 loop functions is contained in Attachment 34.
Provide copies excerpts of the EDCRs and DCNs that provide the block and logic diagrams for the Foxboro Spec 200 implementation. contains excerpts of the following change documents:
DCN 52376 Note: These changes are scheduled to be implemented after Unit 2 Fuel Load DCN 52641 NOTE: DCN 52376 and 52641 impact loops already in service for Unit 1 ansd as such are implemented under 10CFR50.59.
EDCR 52343 EDCR 52427 The Westinghouse ARLA latch attachment is obsolete. In order to provide a latching relay for Unit 2 Solid State Protection System (SSPS), a MDR latching relay must be used. MDR relays are currently in use and shown to be reliable as SSPS Slave Relays in other Westinghouse plants.
The Technical Specification (TS) Bases was updated in Amendment B to indicate acceptability of testing MDR ESFAS Slave relays on an 18-month interval based on the assessment done in WCAP-13878-P-A, Revision 2, Reliability Assessment of Potter & Brumfield MDR Series Relays.
An initial Unit 2 ESFAS SSPS Slave Relay Service Life and Contact Load study similar to that done in Unit 1 has been completed to show that Unit 2 satisfies the conditions of WCAP-13877-P-A, Revision 2, Reliability Assessment of Westinghouse Type AR Relays used as SSPS Slave Relays, and WCAP-13878, Revision 2, Reliability Assessment of Potter &
Brumfield MDR Series Relays. The Contact Load study also identifies locations in which MDR relays are not acceptable for use.
File: rad8C078.xlsx Page 33 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action 223 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Carte)
Date:
Responder: Webb Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
224 August 4, 2010 NRC POC: EICB (Marcus)
Date:
Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
225 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Garg)
Date:
Responder: Scansen Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
226 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Carte)
Date:
Responder: TVA Licensing Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
See also Open Item Nos. 41 & 270.
227 NRC Garg/Kemper 4-Aug-10 Date:
Responder: Clark Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
228 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Singh)
Date:
Responder: Clark Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
229 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Carte)
Date:
Responder: Clark Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
230 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Carte)
Date:
Responder: Webb Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
231 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Garg)
Date:
Responder: Clark Date:
Responsibility:
FSAR Amd 100 Submit the Foxboro I/A segmentation analysis and ICS Design Criteria documents on an expedited separate letter. Provide a date when the Segmentation analysis will be revised based on discussions at the meeting.
NNC 8/25/10: Segmentation analysis has been received and read.
Please describe why a failure or error will not propagate over the -peer-to-peer network, and cause more than one segment to fail.
Provide copies of 50.59s for the following Unit 1 changes
- a. CERPI (initial installation and 2009 upgrade)
- c. Containment Sump Level Transmitter replacement
- d. Turbine Servo Control Valve Card replacement
- e. Pressurizer Heater deletion of Backup Heaters on for PZR High Level
- f. AMSAC
- g. Significant ESFAS changes A. CERPI, initial installation DCN 51072 and 2009 upgrade DCN 52957 (Attachment __)
B. Upgrade of RCP, TG and FW pumps vibration monitoring to Bentley-Nevada 3300, DCN 39242, DCN 39506, DCN 39548, and DCN 50750 (Attachment __)
C. Containment Sump Level Transmitter replacement, DCN 39608, (Attachment __)
D. Turbine Servo Control Valve Card replacement, DCN 38993, (Attachment 1)
E. Pressurizer Heater deletion of Backup Heaters on for PZR High Level, DCN 51102 (Attachment __)
F. AMSAC DCN 50475 (Attachment __)
G. Significant ESFAS changes
- i. Relocate containment isolation valve functions on relays K002 and K626 to prevent plant shutdown during routine surveillance testing. DCN 38238, (Attachment __)
ii. Revise OTT and OPT turbine runback setpoints, DCN 38842 (Attachment __)
iii. Install Integrated Computer System (ICS), DCN 50301 (Attachment __)
Submit Annunciator system description/design criteria Condition Status/Alarm Design Criteria Document WB-DC-30-21 is contained in Attachment 22.
NNC 8/25/10: Document not yet received.
Submit Foxboro I/A Procurement Specification excerpts that provide system description information The requested Foxboro I/A Procurement Specificaition is contained in Attachment 23.
NNC 8/25/10: Document not yet received.
Update FSAR Amendment 100 Section 7.1.1.2 markup based on discussion with Hukam Garg.
FSAR section 7.1.1.2 is revised in FSAR Amendment 100 submitted to the NRC on TVA letter to the NRC dated August __, 2010 includes the requested clarifications.
Submit EDCR Technical Evaluationn for Foxboro I/A replacing obsolete non-safety related Foxboro H-Line analog electronics with a digital CDS. [selected single point failures being addressed in design]
Submit rod control system description N3-85-4003 The Rod Control Systemt Desciption N3-85-4003 is contained in Attachment 21.
Provide EDCR Technical Evaluation Justify/explain updated hardware [functionally equivalent to Unit 1] for the RCP and Turbine Generator vibration monitoring equipment.
Mike Norman [TVA Computer Eng. Group] will check status of DCN/50.59 for Integrated Computer System upgrade that will install the data diode between the WBN PEDS and the Unit 1 and Unit 2 ICS.
The Data diode to isolate the WBN Unit 1 and Unit 2 ICS computers from the WBN PEDS computers will be installed in PIC 56278 as part of DCN 54971. This DCN is scheduled for implementation in Spring 2011. This date was included in the Cyber Security Plan Implementation Schedules submitted to the NRC on July 23.
The requested information is contained in the Scope and Intent, Unit Difference and Technical Evaluations for EDCRs 52420 (Attachment __) and 53559 (Attachment __)
These documents were submitted under TVA letter dated August 11, 2010.
File: rad8C078.xlsx Page 34 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action 232 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Singh)
Date:
Responder: Clark Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
233 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Carte)
Date:
Responder: Clark Date:
Responsibility:
Open NRC to review documents.
234 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Carte)
Date:
Responder:
Date:
Responsibility:
Closed 235 NRC Garg/Kemper 4-Aug-10 Date:
Responder: TVA Licensing Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
236 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Garg)
Date:
Responder: Clark Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
237 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Carte)
Date:
Responder: Clark Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
238 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Carte)
Date:
Responder: Webb/Hilmes Date:
Responsibility:
Closed 239 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Carte)
Date:
Responder: Hilmes Date:
Responsibility:
Closed 240 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Garg)
Date:
Responder: Clark Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
241 NRC Garg/Kemper 8/4/2010 NRC POC: EICB (Sinh)
Date:
Responder: Davies Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
242 NRC Garg/Kemper 4-Aug-10 Date:
Responder: Hilmes Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
243 August 3, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
244 August 3, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open Bechtel to perform D3 analysis for Common Q PAMS which will be incorporated into Westinghouse Licensing Technical Report.
Duplicate of Item 64 CERPI was designed after Westinghouse stopped using WCAPs. The documents that provides the most detailed information are the CERPI System Requirements Specification WN-DS-00001-WBT Rev. 2 and the Watts Bar 2 - CERPI Functional Diagram Westinghouse drawing number 6661E34 Rev. 1. These documents are containted in Attachment __.
Submit EDCR Technical Evaluation for Foxboro Spec 200 EDCRs Foxboro Spec 200 EDCRs 52343, 52427 and 52641, Scope and Intent, Unit Difference and Technical Evaluations are contained in Attachment 26.
Submit EDCR Technical Evaluation for Annunciator EDCR The Annunciator EDCR 52315 Scope and Intent, Unit Difference and Technical Evaluations are contained in Attachment 27.
NNC 8/25/10: Documents not yet received.
Submit EDCR Technical Evaluation for LPMS EDCR The EDCR 52418 Lose Part Monitoring Scope and Intent, Unit Difference and Technical Evaluations are contained in Attachment 24.
Submit EDCR Technical Evaluation for Foxboro I/A EDCR Foxboro I/A EDCRs 52378 and 52671 Scope and Intent, Unit Difference and Technical Evaluations are contained in Attachment 25.
NNC 8/25/10: Documents received.
TVA to make firm decision on date of transfer (before or after initial startup) of Unit 2 loops in service for Unit 1 to new Foxboro Spec 200 hardware Discuss with TVA adding a description of the Foxboro I/A system to chapter 7 of the FSAR.
Duplicate of item 201 Plan a meeting with TVA the NRC and Westinghouse to review Common Q PAMS documentation.
meeting held 8/17/10 Submit EDCR Technical Evaluation for Vibration Monitoring EDCR(s)
The Scope and Intent, Unit Difference and Technical Evaluations for EDCRs 53559 and 52420 are contained in Attachment 28.
Review CERPI WCAPs for system description information to be submitted to the NRC.
TVA to ensure Stewart Bailey is on cc: for all Chapter 7 RAI response letters.
Stewart Bailey has been added to the standard response letter template used for Chapter 7 responses.
Section 8.2.1 of the Common Q SPM (ML050350234) states that the System Requirements Specification (SysRS) includes the system design basis. Section 1.2, "System Scope," of the WBN2 PAM SysRS (ML101680578) includes a description of the PAMS design bases that does not meet the requirments of IEEE 603-199 Clause 4. Please provide a description of the PAMs design bases that conforms to the requirements of IEEE 603-1991 Clause 4.
File: rad8C078.xlsx Page 35 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action TVA to respond or provide proposed date of response.
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."
245 August 3, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
246 August 3, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
247 August 8, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
248 August 8, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open Section 8.2.2 of the Common Q SPM (ML050350234) states that the Software Requirements Specification (SRS) shall be develped 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 processes 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 requirments, 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.
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 asssess whether the test plan for WBN2 PAMS, is as described in the SPM (e.g., Section 5.8.1).
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 reuired by ISG6. Please provide the PQP. If "PQP" is not the name of the documentation produced, please describe the documentation producted and provide the information that the SPM states should be in the PQP.
As part of the Common Q topical report development effort, Westinghouse developed the Software Program Manual for Common Q Systems (ML050350234) to address software planning documentation. The NRC reviewed the SPM and concluded: the SPM specifies plans that will provide a quality software life cycle process, and that these plans commit to documentation of life cycle activities that will permit the staff or others to evaluate the quality of the design features upon which the safety determination will be based. The staff will review the Implementation of the life cycle process and the software life cycle process design outputs for specific applications on a plant-specific basis. Please identify the implementation documentation produced as a result of following the SPM, and state what information will be docketed.
LIC-101 Rev. 3 Appendix B Section 4, "Safety Evaluation" states: "the 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."
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."
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."
File: rad8C078.xlsx Page 36 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action TVA to respond or provide proposed date of response.
249 August 8, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
250 August 8, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
251 August 8, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
252 August 8, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open As part of the Common Q topical report development effort, Westinghouse developed the Software Program Manual for Common Q Systems (ML050350234) to address software planning documentation. The NRC reviewed the SPM and concluded: the SPM specifies plans that will provide a quality software life cycle process, and that these plans commit to documentation of life cycle activities that will permit the staff or others to evaluate the quality of the design features upon which the safety determination will be based. The staff will review the Implementation of the life cycle process and the software life cycle process design outputs for specific applications on a plant-specific basis. Please identify the design outputs produced as a result of following the SPM, and state when what information will be docketed.
The SVVP in the SPM describes the V&V implementation tasks that are to be carried out. The acceptance criterion for software V&V implementation is that the tasks in the SVVP have been carried out in their entirety. Documentation should exist that shows that the V&V tasks have been successfully accomplished for each life cycle activity group. Please provide information that shows that the V&V tasks havebeen successfully acomplished for each life cycle actifity group.
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.
The SPM describes the software testing 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.
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."
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."
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."
"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."
LIC-101 Rev. 3 Appendix B Section 4, "Safety Evaluation" states: "the File: rad8C078.xlsx Page 37 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action TVA to respond or provide proposed date of response.
253 August 8, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
254 August 10, 2010 NRC POC: EICB (Halverson)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
255 August 10, 2010 NRC POC: EICB (Halverson)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
256 August 10, 2010 NRC POC: EICB (Halverson)
Date:
Responder: WEC Date:
Responsibility:
Open Please make the following available in Westinghouse's Rockville office.
The Reusable Software Elements Documents. These contain requirements for the software.
WNA-DS-01564-GEN, Rev 1. ; WNA-DS-00315-GEN, Rev. 2 ; WNA-DS-01715-GEN, Rev 2 ;
WNA-DS-01838-GEN, Rev. 3 ; WNA-DS-01839-GEN, Rev. 3 ; WNA-DS-01840-GEN, Rev 2. ;
WNA-DS-01841, Rev 2. ; WNA-DS-01842-GEN Rev 2.; WNA-DS-01845-GEN Rev. 1. ; WNA-DS-01846-GEN Rev. 2 ; WNA-DS-01847-GEN Rev. 0 ; WNA-DS-01848 Rev. 1. ; WNA-DS-01849-GEN Rev. 2. ; WNA-DS-01994-GEN Rev. 0 ; WNA-DS-00306-GEN Rev. 5 ; WNA-DS-02065-GEN Rev. 2 ; WNA-DS-01505-GEN Rev. 0 Further documentation for application-specific type circuits and custom PC elements are indicated by the SRS to be in 00000-ICE-3238, Rev 5 ; 00000-ICE-30140, rev 4 and 00000-ICE-30152, Rev. 5 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.
TVA provided information by letter dated July 30, 2010 (ML102160349) - See Enclosure 1 Item No. 8 - that some AC160 module contain FPGAs. For those modules that have not been previously approved, please provide information to address regulatory criteria for FPGAs.
Please make the following available in Westinghouse's Rockville office.
WNA-PD-00056-WBT, Rev 1 Watts Bar Unit 2 NSSS Completion I&C Projects As the indicated source of customer specific requirements for deliverables, as indicated in the project plan, this document may serve as one end of a thread audit, and may contain information relevant to evaluating the completeness of later requirements.
956080, Rev 1. Cabinet mounted electronics - Inadequate core cool monitor (ICCM-86)
Believe this to be the source of the requirements or at least algorithms and justifications for RIVLIS.
NABU-DP-00014-GEN, rev 2 Design Process for Common Q Safety Systems. As it defines the scope of other documents we are reviewing, it may clarify what documents are expected to contain what information.
Related to Open Item no. 83.
LIC-110 Rev. 1 Section 6.2.2 states:
"Design features and administrative programs that are unique to Unit 2 should then be reviewed in accordance with current staff positions" LIC-101 Rev. 3 Appendix B Section 4, "Safety Evaluation" states: "the information relied upon in the SE must be docketed correspondence."
"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."
File: rad8C078.xlsx Page 38 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action TVA to respond or provide proposed date of response.
257 August 10, 2010 NRC POC: EICB (Halverson)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
258 August 10, 2010 NRC POC: EICB (Halverson)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
259 August 10, 2010 NRC POC: EICB (Halverson)
Date:
Responder: WEC Date:
Responsibility:
Open Please make the following available in Westinghouse's Rockville office.
The following are documents that contain requirements used in the SRS which we incorporated by reference within that document.
Coding Standards and Guidelines for Common Q Systems, 00000-ICE-3889, Rev. 10, Westinghouse Electric Company LLC.
Application Restrictions for Generic Common Q Qualification, WNA-DS-01070-GEN, Rev. 3, Westinghouse Electric Company LLC.
System Requirements Specification for the Common Q Generic Flat Panel Display 00000-ICE-30155, Rev. 9, Westinghouse Electric Company LLC.
Software Requirements Specification for the Common Q Generic Flat Panel Display Software, 00000-ICE-3239, Rev. 12, Westinghouse Electric Company LLC.
Common Q Software Configuration Management Guidelines, NABU-DP-00015-GEN, Rev. 2, Westinghouse Electric Company LLC, Standard General Requirements for Cyber security, WNA-DS-01150-GEN, Rev. 0, Westinghouse Electric Company LLC, Please make the following available in Westinghouse's Rockville office.
The following are documents that contain requirements used in the SRS which we incorporated by reference within that document.
AC160 CPU Loading Restrictions, AN03007Sp, ABB Memo, ABB Process Automation Corporation, Software Design Description for the Common Q Generic Flat-Panel Display Software, 00000-ICE-30157, Rev. 16, Westinghouse Electric Company LLC.
System Requirements Specification for the Common Q Post Accident Monitoring System, 0000-ICE-30156, Rev. 06, Westinghouse Electric Company LLC.
Software Requirements Specification for the Common Q Post Accident Monitoring System 00000-ICE-3238, Rev. 5, Westinghouse Electric Company LLC.
Commercial Dedication Report for QNX 4.25G for Common Q Applications, WNA-CD-00018-GEN, Rev. 3, Westinghouse Electric Company LLC, Generic Common Q Software Installation Procedure, WNA-IP-00152-GEN, Rev. 7, Westinghouse Electric Company LLC.
Please make the following available in Westinghouse's Rockville office.
The IV&V Phase Summary Report, (WNA-VR-00283-WBT Rev. 0 ) indicated that the IV&V team had created some information that may facilitate the approval process. However the form the information may have taken was not indicated or referenced in the Phase Summary Report.
Information requested for the Rockville office includes:
-The excel spreadsheet described in section 2.2.2 that verifies all low level requirements have a basis in a higher one, and that all higher level requirements decompose into a lower level.
-A review of the WBU2 SysRS, SDS, and SRS for clarity, completeness, correctness and compatibility
-Comparison of the WBU2 SysRS, SDS, and SRS to source level documents
-An evaluation, per section 2.2.3, of the baseline report
-a second party peer review for the source level documents File: rad8C078.xlsx Page 39 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action TVA to respond or provide proposed date of response.
260 August 10, 2010 NRC POC: EICB (Halverson)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
261 August 10, 2010 NRC POC: EICB (Halverson)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
262 August 10, 2010 NRC POC: EICB (Halverson)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
263 August 11, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
264 August 11, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
265 August 11, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
266 August 11, 2010 NRC POC: EICB (Carte)
Date:
Responder: Webb/Webber Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
267 August 11, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open In order to facilitate visits to the Rockville office, please make the following documents available at the Rockville office.
Watts Bar 2 PAMS licensing technical report 00000-ICE-37722 Rev. 0 (ML003733136)
Common Q Software Programming manual (ML050350234)
Common Q topical report. (ML031830959)
Based on an examination of document available at the Westinghouse Rockville offices (i.e., NA 7.4, WEC 7.2, WEC 7.3, CDI-3803, & CDI-3722) a CDI appears to identify the verification activities for each critical characteristic. These activities appear to be documented on the associated dedication data sheets; therefore, it appears that the Westignhouse Commercial Grade Dedication Plan is called a CDI and the completed CDI data sheets are the commercial grade desication Report. If so, please provide the CDI for each new (not previously approved) component and the associated completed dedication data sheets.
Please provide a copy of the commercial grade survey(s) applicable to each new (not previously approved) Common Q component.
Please provide:
WNA-CD-00018-GEN Rev. 3 00000-ICE-35444 Rev. 1 Please provide a high level description of the Foxboro IA equipment used at WBN2. This description should be more detailed than a brochure on the product line (or available on the web),
and less detailed than a technical manual on each field replaceable unit. It is expected that such literature already exists.
Please provide the Requirements Traceability Matrix for generic PAMS and/or any other RTMs applicable to WBN2 PAMS. Some requirements in the Software Requirements Specification are simply not present in the Watts Bar 2 PAMS specific RTM (WNA-VR-00279-WBT).
If some requirements in the SRS are not present in any traceability matrix, please indicate how traceability and verifiability are achieved.
Please make the following available in Westinghouse's Rockville office.
As they may demonstrate that a number of issues raised by, or that will be raised by, the NRC staff are already being resolved by the vendor, we would like to have access to V&V-769 and V&V-770 in the Exception Reports (ER) database for common Q systems.
Please make the following available in Westinghouse's Rockville office.
The Source level documents for the requirements WBT-TVA-0070 Safety Related Digital Logic Cards Circuitry and Related Instrument Racks Restrictions WBT-D-0088 Transmittal Westinghouse comments on TVA specification EDSR 52451 Contract Number 65717 Tennessee Valley Authority Watts Bar Nuclear Plant Unit 2 NSSS Completion Project WEST-WBT-2008-25 TVA Contract Word Authorization LIC-110 Rev. 1 Section 6.2.2 states:
"Design features and administrative programs that are unique to Unit 2 should then be reviewed in accordance with current staff positions" LIC-101 Rev. 3 Appendix B Section 4, "Safety Evaluation" states: "the information relied upon in the SE must be docketed correspondence."
File: rad8C078.xlsx Page 40 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action TVA to respond or provide proposed date of response.
268 August 19, 2010 NRC POC: EICB (Carte)
Date:
Responder: WEC Date:
Responsibility:
Open TVA to respond or provide proposed date of response.
269 August 20, 2010 NRC POC: DORL (Bailey)
Date:
Responder:
Date:
Responsibility:
Open 270 August 23, 2010 NRC POC: EICB (Carte)
Date:
Responder:
Date:
Responsibility:
Open 271 August 23, 2010 NRC POC: EICB (Carte)
Date:
Responder:
Date:
Responsibility:
Open 272 August 26, 2010 NRC POC: EICB (Marcus)
Date:
Responder:
Date:
Responsibility:
Open 273 August 26, 2010 NRC POC: EICB (Marcus)
Date:
Responder:
Date:
Responsibility:
Open 274 August 26, 2010 NRC POC: EICB (Marcus)
Date:
Responder:
Date:
Responsibility:
Open 274 August 26, 2010 NRC POC: EICB (Singh)
Date:
Responder:
Date:
Responsibility:
Open By letter dated August 20, 2010 TVA dockated a Requirements Traceability Matrix for the Common Q PAMS (Requirements Phase).This document does not identify the source of each requirement. The Comon Q PAMS System Requirements Specification (SysRS -ML101680578, ML102040483, & ML102040484) does not explicitly identify the origin of each requirement. The SRP acceptance criteria for requirements specifications is that the origin of the requirements is know. Please explain how to trace each requirement in the SysRS to its origin.
In WBN2 FSAR Table 7.5-2, "Regulatory Guide 1.97 Variable List (Deviation and Justification for Deviations)," (WBNP-96) for Variable 19, "Containment Hydrogem Concentration," Deviation 2 (page 19 of 41), the variable number is listed as 15. The variable number should be listed as 19.
By letter dated June 18, 2010 (ML101940236) TVA stated that the software safety plan (SSP) was not applicable to PAMS applications (see Watts Bar 2 - Common Q PAMS ISG-6 Compliance matrix Item No. 10); however, reference No. 30 of the SRS (ML101050202) is: 00000-ICE-37727, Rev. 0, "Post Accident Monitoring System Softwarre Preliminary Hazard Analysis for the Common Q PAMS Project." A Preliminary Hazard Analysis is required by the SSP. Please explain.
By letter dated March 12, 2010 (ML101680577), TVA stated that the application specific hardware and software architecture descriptions are addressed in the WBN2 PAMS System Design Specification (ML101680579, ML102040481, & ML102040482) and Software Requirements Specification (ML101050202, ML102040486, & ML1022040487).
Neither of these documents contain a non-proprietary figure of the architecture that can be used in the SE. Please provide a non-proprietary figure of the architecture.
DORL to send the Eagle-21 Audit Report to TVA.
By letter dated June 18, 2009 (ML091560352) the NRC informed Westinghouse that WNA-PT-00058-GEN (see pdf page 7 of 25) did not adequately address the test plan criteria of the Software Program Manual (ML050350234); however, by letter dated June 18, 2010 (ML101940236) TVA/Westinghouse stated that WNA-PT-00058-GEN addressed the test plan criteria of the SPM (pdf page 59 of 194, Item No. 12). Please explain.
In WBN2 FSAR Table 7.5-2, "Regulatory Guide 1.97 Variable List (Deviation and Justification for Deviations)," (WBNP-96) for Variable 82, "Steam Generator Level Wide Range," Deviation 10 (page 24 of 41), in the last sentence, of the Justification, SC should be SG.
In WBN2 FSAR Table 7.5-2, "Regulatory Guide 1.97 Variable List (Deviation and Justification for Deviations)," (WBNP-96) for Variable 97g, "Reactor Coolant Sample Activity," Deviation 5 (page 21 of 41), the last two sentences of the Justification read, "TVA meets the intent of RG 1.97 recommended range by monitoring this variable using the gross activity analysis of primary coolant samples taken in the post accident sampling facility. Samples are obtained from the post accident sampling system in Unit 1 only." Please describe how the samples are obtained for Unit 2.
See also Open Item Nos. 41 & 226.
File: rad8C078.xlsx Page 41 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action 275 August 27, 2010 NRC POC: EICB (Singh)
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Open 276 August 27, 2010 NRC POC: EICB (Garg)
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Open 277 August 27, 2010 NRC POC: EICB (Garg)
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Open 278 August 27, 2010 NRC POC: EICB (Garg)
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Open 279 August 27, 2010 NRC POC: EICB (Garg)
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Open 280 August 27, 2010 NRC POC: EICB (Garg)
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Open 281 August 27, 2010 NRC POC: EICB (Garg)
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Open 282 August 27, 2010 NRC POC: EICB (Garg)
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Open 283 August 27, 2010 NRC POC: EICB (Darbali)
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Open NUREG 0847, "Safety evaluation report Related to the operation of Watts Bar Nuclear Plant, Units 1 and 2." has section 7.6.3 which discusses the, "Upper Head Injection Manual Control" system but has been removed from the FSAR. Please provide the information regarding when this system was removed, and the justification for the removal of the system and if the NRC staff has previously reviewed and accepted the removal of the system provide the reference to the staff's SE.
For FSAR Section 7.6.6, provide the justification for adding valves FCV 63-8 and FCV 63-11, which require that power to be removed and will be administratively controlled prior to use of RHR system for plant cooldown. Provide the P & ID and block diagram showing the operation of these valves.
For FSAR Section 7.6.6, provide the justification for the addition of protective covers which operator has to remove before he can have access to control switch to operate two additional valves FCV62-98 and FCV62-99.
For FSAR Section 7.6.6, provide the justification for the acceptability of removing FCV 63-5 from the list of valves which has operating instructions specifying the removal of power during specific modes of plant operation.
For FSAR Section 7.6.8 in amendment 96, redline version has completely rewritten this section of the FSAR, however, the staff is not able to determine any changes made to the section. Explain what changes have been made to this FSAR Section.
For FSAR Section 7.6.9 which discusses the switch over from injection to recirculation, and is a ESF system, the compliance with IEEE 279 has been removed from the FSAR. Justify this deletion.
Loose Parts Monitoring System: RG 1.133, sections C.1.a and C.1.c address sensor locations and channel separation respectively. TR 3.3, FSAR section 7.6.7 and the DMIMMS-DX System Description do not clearly explain the location or address channel separation per the guidance of RG 1.133. Please update the documents as needed.
In order for the staff to review the effects of multi control systems failure, provide the summary of the analyses documenting the effect on the plant based on the following events: (1) loss of power to all control systems powered by a single power supply; (2) failure of each instrument sensor which provides signal to two or more control systems; (3) Break of any sensor impulse line which is used for sensors providing signals to two or more control systems; and (4) failure of digital system based on the common cause software failure affecting two or more control systems. For each of these events, confirm that the consequences of these events will not be outside chapter 15 analyses or beyond the capability of operators or safety systems.
Loose Parts Monitoring System: TR 3.3 refers to section 4.4.6 of the FSARfor description of the loose parts monitoring system. However, this section of the FSAR is not available. TVA to check the reference and respond.
File: rad8C078.xlsx Page 42 of 51 Tab: Open Items
Open Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Licensee Open Items to be Resolved for SER Approval Issue TVA Response(s)
Status/Current Action This item is a followup question to item
- 96.
284 August 27, 2010 NRC POC: EICB (Darbali)
Date:
Responder:
Date:
Responsibility:
Open This item is a followup question to item 123 285 August 27, 2010 NRC POC: EICB (Darbali)
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Date:
Responsibility:
Open This item is a followup question to item 22 286 August 27, 2010 NRC POC: EICB (Darbali)
Date:
Responder:
Date:
Responsibility:
Open 287 August 27, 2010 NRC POC: EICB ()
Date:
Responder:
Date:
Responsibility:
Open Follow-up to item 96 On Open Item 96, regarding the implementation of IEN 79-22, part of TVAs response was:
The non-safety-related device/systems within the scope of IEN 79-22 are:
- 1. Steam generator power operated relief valve control system
- 2. Pressurizer power operated relief valve control system
- 3. Main feedwater control system
- 4. Automatic rod control system.
Failure of these systems/devices due to a high energy line break is fully addressed in Chapter 15, Accident Analysis of the WBN Unit 2 FSAR.
Please identify the sections of FSAR Chapter 15 that address the failures of these systems.
Follow-up to item 123 Please provide a readable electrical logic diagram of the Volume Control Tank Level Control System.
Follow-up to item 22 Do the control loops meet the requirements of IEEE-279? If not are they isolated from the circuit which meets the requirements of 279.
SE 7.7.3, Volume Control Tank Level Control System In FSAR section 9.3.4.2.4 a change was made to the last paragraph of the Volume Control Tank description (page 9.3-31 of the Amendment 97 redline), where the "low-low level alarm" was changed to "low level alarm".
Please explain if this deletion was an editorial change to correct a typo.
File: rad8C078.xlsx Page 43 of 51 Tab: Open Items
Closed Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments 19-Nov-09 NRC POC: EICB (Carte)
Date: 3/15/2010 Responsibility: NRC March 12, 2010 19-Nov-09 NRC POC: EICB (Carte)
Date: 3/15/2010 Responsibility: NRC March 12, 2010 19-Nov-09 NRC POC: EICB (Carte)
Date: 3/15/2010 Responsibility: NRC March 12, 2010 December 11, 2009 (ML093431118, RAI 5)
NRC POC: EICB (Garg)
Date: 3/15/2010 Responsibility: NRC (Garg) and TVA (Hilmes and Crouch)
December 11, 2009 (ML093431118, RAI 8)
NRC POC: EICB (Garg)
Date: 5/24/10 Responsibility: NRC (Garg) and TVA (Hilmes/Crouch)
December 11, 2009 (ML093431118, RAI 9)
NRC POC: EICB (Darbali)
Date: 3/15/2010 Responsibility: NRC (Darbali)
Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Closed Items Resolved for SER Approval Issue TVA Response(s)
Status/Current Action 1
12/15/2009 Presentation Slides: This item was partially addressed during the December 15, 2009 meeting.
TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 1 on Page 1 of 15): TVA responded to this request for additional Information.
Closed November 19, 2010 ML093230343 RAI 1 NNC 11/19/09: The FSAR contains mostly description of the function that the various TVA systems must perform.
Therefore this question was asked to determine how the systems have been changed.
NNC 4/15/10: The response addresses many systems and should be read by all EICB reviewers.
The Watts Bar Nuclear Plant FSAR red-line for Unit 2 (Agency wide Documents Access and Management System Accession Number ML080770366) lists changes to the Unit 1 FSAR and depicts how Chapter 7 of the Unit 2 FSAR will appear at fuel load. Have additional changes been made to Chapter 7 of the Unit 2 FSAR beyond those indicated in ML080770366? Which of the changes identified correspond to digital instrumentation and controls (I&C) components and systems that have not been previously reviewed and approved by the NRC?
RAI response received.
2 12/15/2009 Presentation Slides: This item was partially addressed during the December 15, 2009 meeting.
TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 2 on Page 2 of 15): TVA responded to this request for additional Information.
Closed November 19, 2010 ML093230343 RAI 2 NNC 11/19/09: The FSAR contains mostly description of the function that the various TVA systems must perform.
Therefore this question was asked to determine how the systems have been changed.
NNC 4/15/10: The response addresses many systems and should be read by all EICB reviewers.
NNC 11/19/09: The FSAR contains mostly description of the function that the various TVA systems must perform.
Therefore this question was asked to determine how the systems have been changed.
NNC 4/15/10: The response addresses many systems and should be read by all EICB reviewers.
Because a digital I&C platform can be configured and programmed for different applications, the review process can be divided between a review of the platform and a review of the application.
For planning and scheduling reasons, it is important to know beforehand which platform has been used in each digital component and system. What is the base platform of each unreviewed digital I&C component and system (e.g., Common Q)?
RAI response received.
Are there I&C components and systems that have changed to a new or different digital technology without the change being reflected in the FSAR markup? Are there any not-redlined I&C components and systems that have been changed or replaced by digital base technology since Unit 1 was approved?
RAI response received.
3 12/15/2009 Presentation Slides: This item was partially addressed during the December 15, 2009 meeting.
TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 3 on Page 2 of 15): TVA responded to this request for additional Information.
Closed November 19, 2010 ML093230343 RAI 3 8
TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 8 on Page 7 of 15): TVA responded to this request for additional Information This item is addressed as follows:
- 1. FSAR Amendment 100 which was submitted on TVA letter to the NRC dated August __, 2010 incorporates as-found and as-left setpoint tolerance discussion into section 7.1.2.1.9, adds EEB-TI-28, Setpoint Methodology to the section 7.1 references and adds a reference to 7.1.2.1.9 to section 7.2.1.1.10.
- 2. TSTF-493, Rev. 4 Option A has been incorporated into the Unit 2 Tech Spec submittal dated February 2, 2010.
FSAR Amd 100.
Closed as it will be covered under item 154 TVA stated that they will follow TSTF-493 Rev. 4 as approved by the NRC.
The TS have already been provided to the NRC.
NNC 4/15/10: Related to setpoints and SE Section 7.1.3.1.
NNC 4/15/10: Hukam, please update this open item as appropriate.
There are several staff positions that provide guidance on setpoint methodology (e.g., Reg Guide 1.105, BTP 7-12, RIS-2006-17 and TSTF-493 Rev. 4). Please identify how the Unit 2 setpoint methodology addresses staff guidance.
RAI response received. NRC to review response.
This item requires further discussion between TVA and the staff concerning the applicability of the staff positions to WBN2.
See Item 5 5
Responder: Craig/Webb TVA Letter Dated February 5, 2010: TVA provided the Unit 2 setpoint methodology (WCAP-177044-P Revision 0 - dated December).
TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 5 on Page 5 of 15): TVA responded to this request for additional Information This item is addressed as follows:
__, 2010 incorporates as-found and as-left setpoint tolerance discussion into section 7.1.2.1.9, adds EEB-TI-28, Setpoint Methodology to the section 7.1 references and adds a reference to 7.1.2.1.9 to section 7.2.1.1.10.
TSTF-493, Rev. 4 Option A has been incorporated into the Unit 2 Tech Spec submittal dated February 2, 2010.
FSAR Amd 100 NNC 4/15/10: Related to setpoints and SE Section 7.1.3.1.
By letter date February 28, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML080770366) TVA provided a "red-lined" version of the FSAR for WBN Unit 2. The purpose of this FSAR "red-line" version was to depict how the Unit 2 FSAR will appear at fuel load. This letter identified significant FSAR changes and provided a X-REF number for each.
Change 7.3-1 refers to the following two Summary Reports:
TVA Letter, P. L. Pace to NRC, dated February.9, 1998, "Watts Bar Nuclear Plant (WBN) Unit 1 -
10 CFR 50.59(b)(2), Changes, Tests and Experiments Summary Report TVA Letter, P. L. Pace to NRC, dated September 30, 2005, "Watts Bar Nuclear Plant (WBN) Unit 1 - 10 CFR 50.59, Changes, Tests and Experiments Summary Report" Please submit the 50.59 Evaluations for each of these Summary Reports and identify which parts are relevant to the Unit 2 Setpoint Methodology.
RAI response received. This item is closed as this is covered under item 154 later on.
This item requires futher discussion between TVA and the staff concening the setpoint methodology employed for WBN2.
See Item 8.
9 TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 9 on Page 8 of 15): TVA responded to this request for additional Information Closed NNC 4/15/10: Related SE Section 7.3.
File: rad8C078.xlsx Page 44 of 51 Tab: Closed Items
Closed Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Closed Items Resolved for SER Approval Issue TVA Response(s)
Status/Current Action December 11, 2009 (ML093431118, RAI 11)
NRC POC: EICB (Darbali)
Date: 3/15/2010 Responsibility: NRC (Darbali)
December 22, 2009 (ML093560019, item 1)
NRC POC: EICB (Carte)
Date: 4/27/10 Responder: TVA Date: 4/27/10 Responsibility: NRC (Carte)
December 22, 2009 (ML093560019, item 2)
NRC POC: EICB (Garg)
Date: 4/27/10 Responder: TVA Date: 4/27/10 Responsibility: NRC (Garg)
December 22, 2009 (ML093560019, item 3)
NRC POC: EICB (Carte)
Date: 4/27/10 Responder: TVA Date: 4/27/10 Responsibility: NRC (Garg)
December 22, 2009 (ML093560019, item 5)
NRC POC: EICB (Garg)
Date: 4/27/10 Responder: TVA Date: 4/27/10 Responsibility: NRC (Garg)
December 22, 2009 (ML093560019, item 7)
NRC POC: EICB (Garg)
Date: 4/27/10 Responder: TVA Date: 4/27/10 Responsibility: NRC (EEEB)
December 22, 2009 (ML093560019, item 10)
NRC POC: EICB (Garg)
Date: 4/27/10 Responder: TVA Date: 12/22/09 Responsibility: NRC (EEEB) 11 TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 11 on Page 13 of 15): TVA responded to this request for additional Information Closed NNC 4/15/10: Related SE Section 7.3.
NUREG-0847 Supplement No. 2 Section 7.3.2 includes an evaluation of a change in containment sump level measurement. Provide information to demonstrate that Unit 2 implements the containment sump level indication as described and evaluated in NUREG-0847 Supplement No. 2, Section 7.3.2, for Unit 1.
Requested information was submitted in the RAI response.
Change 7.3-2, identified in Watts Bar Nuclear Plant FSAR red-line for Unit 2 (ADAMS Accession Number ML080770366), refers to the following Summary Report: TVA Letter, P. L. Pace to NRC, dated September 20, 2002, "Watts Bar Nuclear Plant (WBN) Unit 1 - 10 CFR 50.59, Changes, Tests and Experiments Summary Report" Please provide the 50.59 Evaluation summarized in this Summary Report.
50.59 evaluation was submitted in the RAI response. NRC to review.
15 Closed Verify that the refurbishment of the power range nuclear instrumentation drawers resulted in only like-for-like replacements.
By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 2).
Response acceptable. Close 14 Closed NNC 4/30/10: Related to Eagle 21; therefore Garg is responsible.
Provide the justification for any hardware and software changes that have been made since the previous U.S. Nuclear Regulatory Commission (NRC) staff review for Eagle 21 and other platforms.
By letter dated April 27, 2010: TVA responded to this request for information (Enclosure, Item No. 1) stated: "In discussion with the staff, TVA's understanding is that the focus of this question is the Eagle 21 system. Please refer to Reference 2 [TVA Letter Dated March 12, 2010], Question 10, and TVA letter to NRC dated August 25, 2008, 'Watts Bar Nuclear Plant (WBN) - Unit 2 - Westinghouse Eagle 21 Process Protection System, Response to NRC I&C Branch request for additional information' (Reference 3 [TVA letter dated August 25, 2008]) for the discussion of changes to the Eagle 21 system."
A listing of changes to other platforms was provided in TVA letter dated April 27, 2010,, items 21 and 23.
NNC: I do not recall saying that the NRC is not interested in changes in other platforms. Please provide a description of changes to other platforms (e.g., SSPS).
For Eagle 21, this response points to Open Item No. 10.
Response understood. Additioanl material will be requested separately to understand the systems described.
18 Closed Identify any changes made to any instrumentation and control (I&C) system based on prior knowledge of failures.
By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 5).
Acceptable. Close 16 Closed Identify the precedents in license amendment requests (LARs), if any, for source range monitors or intermediate range monitors.
By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 3).
Acceptable. Close 23 Closed NNC 4/30/10: SRP Section 7.0 states: "The organization 20 Closed NNC 4/30/10: SRP Section 7.0 states: "The organization responsible for the review of environmental qualification reviews the environmental qualification of I&C equipment.
The scope of this review includes the design criteria and qualification testing methods and procedures for I&C equipment."
Provide environmental qualification information pursuant to Section 50.49 of Title 10 of the Code of Federal Regulations (10 CFR) for safety-related actuation transmitters.
By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 7).
Garg to coordinate with Weibi to ensure EEEB takes responsibility for this one.
File: rad8C078.xlsx Page 45 of 51 Tab: Closed Items
Closed Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Closed Items Resolved for SER Approval Issue TVA Response(s)
Status/Current Action December 22, 2009 (ML093560019, item 13)
NRC POC: EICB (Garg)
Date: 4/27/10 Responder: TVA Date: 12/22/09 Responsibility: NRC (EEEB)
December 22, 2009 (ML093560019, item 14)
NRC POC: EICB (Carte)
Date: 4/27/10 Responder: TVA Date: 4/27/10 Responsibility: NRC (Carte)
December 22, 2009 (ML093560019, item 16)
NRC POC: EICB (Carte)
Date: 4/27/10 Responder: TVA Date: 4/27/10 Responsibility: NRC (Carte)
December 22, 2009 (ML093560019, item 18)
NRC POC: EICB (Carte)
Date: 4/27/10 Responder: TVA Date: 4/27/10 Responsibility: NRC (Carte)
December 22, 2009 (ML093560019, item 19)
NRC POC: EICB (Carte)
Date: 4/27/10 Responder: TVA Date: 4/27/10 Responsibility: NRC (Carte)
December 22, 2009 (ML093560019, item 20)
NRC POC: EICB (Carte)
Date: 4/27/10 Responder: TVA Date: 4/27/10 Responsibility: NRC (Carte)
February 18, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: Clark Date: 2/18/2010 Responsibility: TVA January 13, 2010 NRC POC: EICB (Garg)
Date: 5/25/10 Responder: Clark Date: 1/13/2010 Responsibility: TVA responsible for the review of environmental qualification reviews the environmental qualification of I&C equipment.
The scope of this review includes the design criteria and qualification testing methods and procedures for I&C equipment."
Provide environmental qualification (10 CFR 50.49) information for safety-related control transmitters and complete the deviation section of the table.
By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 10).
Garg to coordinate with Weibi to ensure EEEB takes responsibility for this one.
27 Closed For Foxboro I/A provide information regarding safety/non-safety-related interaction, common cause failures, and communication with safety related equipment in accordance with ISG 4.
By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 14): "There is no digital communications or interactions between Foxboro Intelligent Automation (IA) and any Safety-related system."
26 Closed NNC 4/30/10: SRP Section 7.0 states: "The organization responsible for the review of environmental qualification reviews the environmental qualification of I&C equipment.
The scope of this review includes the design criteria and qualification testing methods and procedures for I&C equipment."
Provide environmental qualification (10 CFR 50.49) information for safety-related monitoring transmitters.
By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 13).
Garg to coordinate with Weibi to ensure EEEB takes responsibility for this one.
31 Closed CERPI is non-safety related.
For the rod position indication system (CERPI), provide information in accordance with ISG 4.
Need to consider cyber-security issues.
By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 18).
Response acceptable.
29 Closed For the rod control system, verify that the refurbishment results in a like-for-like replacement.
By letter dated April 27, 2010 (ML101230248) TVA responded to this request for information (Enclosure, Item No. 16 & Attachment 5): TVA stated on a card by card basis that the referbished cards have the same form fit and function.
33 Closed The loose parts monitoring system is not connected to any other system.
For the loose parts monitoring system, provide information regarding interactions with safety related equipment.
By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 20): Loose parts is not connected to any other system.
TVA stated that there are no interactions.
32 Closed For the process computer, need to consider cyber security issues and emergency response data system needs.
By letter dated April 27, 2010 TVA responded to this request for information (Enclosure, Item No. 19).
EICB will no longer consider cyber issues.
39 The equation for the calculation of the estimated average hot leg temperature 36 Closed FSAR Section 7.5.1, SE Section 7.5.2 NNC: Unit 2 FSAR Section 7.5.1, Post Accident Monitoring Instrumentation, describes a system design that is unique to Unit 2. 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 provide a system description of the Post Accident Monitoring System that contains sufficient detail to support a review of this system using current staff positions.
In previous letters TVA has provided the Common Q documents that address this item:
File: rad8C078.xlsx Page 46 of 51 Tab: Closed Items
Closed Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Closed Items Resolved for SER Approval Issue TVA Response(s)
Status/Current Action January 13, 2010 NRC POC: EICB (Garg)
Date: 5/25/10 Responder: Clark Date: 1/13/2010 Responsibility: TVA February 25, 2010: Telecom NRC POC: EICB (Carte)
Date: 5/25/10 Responder: Clark Date: 2/25/2010 Responsibility: TVA February 25, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: Clark Date: 2/25/2010 Responsibility: TVA February 25, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: Clark Date: 2/25/2010 Responsibility: TVA February 25, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: Clark Date: 2/25/2010 Responsibility: TVA April 8, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: WEC Date: 4/8/10 Responsibility: TVA estimated average hot leg temperature on page 7.2-13 of Revision WBNP-96 of the Unit 2 FSAR is different than the calculation of the average hot leg temperature shown at the top of page 7.2-14 of version WBNP-1 of the UNIT 1 FSAR.
Please describe the change to the calculation of the estimated average hot leg temperature (see FSAR Section 7.2.1.1.4, page 7.2-14 Version WBNP-96) in sufficient detail to support a review of this system using current staff positions.
Refer to revised equations in FSAR amendment 98.
NRC staff will review.
42 Closed The drawing provided did not have the identification numbers as in the FSAR.
On December 16, 2009: EICB stated to DORL: "I am having trouble reading the drawings in the binder that was given to me. Is it possible to produce a set of full size drawing that are in the FSAR?"
On February 23, 2010: EICB received a set of enlarged Chapter 7 FSAR pages (drawings) that are still unreadable. provides a drawing cross reference list for FSAR Chapter 7 and electronic copies of the fully legible current drawings previously submitted in full size hard copies.
TVA provided readable drawings.
40 The equation for the calculation of the power fraction on page 7.2-14 of Revision WBNP-96 of the Unit 2 FSAR is different than the calculation of the power fraction shown at the top of page 7.2-14 of version WBNP-1 of the UNIT 1 FSAR.
Please describe the change to the calculation of the power fraction (see FSAR Section 7.2.1.1.4, page 7.2-13 Version WBNP-96) in sufficient detail to support a review of this system using current staff positions.
Refer to revised equations in FSAR amendment 98.
NRC staff will review.
45 Closed For each system implemented using a digital technology, please identify any communications between divisions, or between safety-related equipment and non-safety-related equipment. Please describe the implementation of the associated communications isolation.
There are no communications betweeen divisions. The response includes the description of communications and isolation between the Common Q PAMS, Eagle 21 and RM-1000 rad monitors and non safety systems.
TVA provided information by letter dated July 30, 2010 (ML102160349) - See Enclosure 1 Item No. 4.
44 Closed FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 The PAMS system described in Section 7.5 of the FSAR is implemented in various manners. TVA should identify:
(1) Those variables that are implemented identical to what was reviewed and approved for Unit 1.
(2) Those variable that are implemented identical to Unit 1, but that have been changed (e.g.,
under 50.59) and not reviewed by the NRC.
(3) Those variables that are implemented in a manner that is unique to Unit 2 (e.g., using Common Q).
TVA should supply supporting information appropriate to the manner of implementation.
By letter Dated June 18, 2010 (see Enclosure 1 Item 6) TVA provided information requested.
48 Closed FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 Reference 16 of the PAMS System Requirements Specification (SysRS) is the Unit 1 precautions Limitations and Setpoints document. When and how will the transition to the unit 2 document be made.
To ensure technical fidelity with the Unit 1 ICCM-86 system, the Unit 1 PLS was used as an input to the Common Q PAMS System Requirements Specification. This was done to ensure the Unit 2 PAMS had at a minimum the same capabilities and accuracy as the unit 1 system.
The Unit 2 Common Q PAMS PLS section was developed based on the actual Common Q PAMS system design as reflected in the System Requirements Specification. As such, the Common Q PAMS PLS section is an output of the Common Q PAMS System Requirements Specification. Therefore, no transition from the Unit 1 to the Unit 2 PLS is required.
The Unit 2 PLS is scheduled to be issued December 13, 2010.
Requested information was provided.
46 Closed The Watts Bar Unit 1 Ser (Section 7.2.1, page 7-3) identifies that the RTS includes a trip from the "general warning alarm". Please identify where this trip is described in the current FSAR, or what SSER approved its removal.
FSAR amendment 98, Section 7.2.2.2, page 7.2-29 second paragraph states:
"Auxiliary contacts of the bypass breakers are connected into the SSPS General Warning Alarm System of their respective trains such that if either train is placed in test while the bypass breaker of the other train is closed, both reactor trip breakers and both bypass breakers will automatically trip."
File: rad8C078.xlsx Page 47 of 51 Tab: Closed Items
Closed Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Closed Items Resolved for SER Approval Issue TVA Response(s)
Status/Current Action April 15, 2010 NRC POC: EICB (Garg)
Date: 5/25/10 Responder: Craig/Webb Date: 4/15/10 Responsibility: TVA April 19, 2010 NRC POC: EICB (Darbali)
Date: 5/25/10 Responder: Slifer Date: 4/19/10 Responsibility: NRC April 19, 2010 NRC POC: EICB (Darbali)
Date: 5/25/10 Responder: Slifer Date: 4/19/10 Responsibility: NRC April 19, 2010 NRC POC: EICB (Darbali)
Date: 5/25/10 Responder: Slifer Date: 4/19/10 Responsibility: NRC April 19, 2010 NRC POC: EICB (Darbali)
Date: 5/25/10 Responder: Slifer Date: 4/19/10 Responsibility: NRC April 19, 2010 NRC POC: EICB (Darbali)
Date:
Responder: Slifer Date: 4/19/10 Responsibility: NRC April 19, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: Clark Date: 4/19/10 Responsibility: NRC April 19, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: Clark Date: 4/19/10 Responsibility: NRC 52 Closed FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 Please identify the systems that will use the RM-1000 radiation monitors.
As identified in TVA letter dated March 12, 2010, Enclosure 1, item 3 the RM-1000 radiation monitors are used for the Containment High Range Post Accident Monitors.
51 This item is closed as it will be reviewed under item 154.
FSAR Amd 100 NRC staff has issued RIS 2006-17, to provide guidance to the industry regarding the instrument setpoint methodology which complies with 10CFR50.36 requirements. The staff has requested all the licensees for the existing license to demonstrate how they meet the guidance provided in this RIS. The staff consider WBN 2 as a license amendment for all the setpoints in the TS. Provide the information on how WBN 2's setpoint methodology meets the guidance of RIS 2006 -17. You may also consider the guidance provided in TSTF - 493, rev.4 as a basis for meeting the RIS 2006 -
17 guidance.
This item is addressed as follows:
2010 incorporates as-found and as-left setpoint tolerance discussion into section 7.1.2.1.9, adds EEB-TI-28, Setpoint Methodology to the section 7.1 references and adds a reference to 7.1.2.1.9 to section 7.2.1.1.10.
- 2. TSTF-493, Rev. 4 Option A has been incorporated into the Unit 2 Tech Spec submittal dated February 2, 2010.
- 3. Refer to TVA to NRC letter dated August 25, 2008.
This item is to be worked with item 108.
56 Closed.
Sorrento Radiation Monitoring The "RM-1000 Version 1.2 Software Verification and Validation Report," Document No. 04508006 Rev. A, is an incremental report. That is to say it addresses the verification an validation for changes that resulted in Version 1.2; therefore, the NRC has not received a software verification and validation report for all other aspects of the software. Please provide the last complete verification and validation report, and all incremental reports after the complete report.
The initial draft Software Verification and Validation (V&V) report document, version 1.0, was never issued. contains the latest complete proprietary version 1.1 Software V&V report (04508005). The non-proprietary version and withholding affidavit will be submitted by July 14, 2010. Submittal of the non-proprietary version and withholding affidavit is tracked by Responses to Licensee Open Items to be Resolved for SER Approval item 119.
The latest proprietary version is 1.2, (an incremental report that addresses the differences from the version 1.1 report) was submitted by TVA Letter dated March 12, 2010 (Reference 4). Submittal of the non-proprietary version and withholding affidavit is tracked by Responses to Licensee Open Items to be Resolved for SER Approval item 101, due June 30, 2010.
TVA provided the requested Software V&V Report.
53 Closed FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 Please identify all FSAR sections that apply to the RM-1000.
The containment high range post accident radiation monitors are discussed in FSAR amendment 98 sections 7.5 and 12.3.
FSAR Section 7.5 Instrumentation Systems Important To Safety - SE Section 7.5.0 Please describe all digital communications used in the installed configuration.
There are no digital communications between the RM-1000 and any other plant system or component.
Requested information provided. NRC to review.
59 Closed FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 Previously TVA provided the "RM-1000 Digital Radiation Processor Technical Manual," Document No. 04508100-1TM Revision C dated October 2003. The "RM-1000 Version 1.2 Software Verification and Validation Report," Document No. 04508006 Rev. A is dated April 2008. (a) What software version does the technical manual address? (b) When was Version 1.2 implemented?
(a) The technical manual is applicable to versions 1.1 and 1.2 of the software.
(b) Version 1.2 was implemented April 1, 2008 58 Closed See ML101940236, Encl 1, Item 13 61 Closed FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section Requested information provided. NRC to review.
60 Closed FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 The PAMS System Requirements Specification (SysRS) references RG 1.97 Rev. 3 where the FSAR References Rev. 2. Please explain.
Duplicate of Item 47 File: rad8C078.xlsx Page 48 of 51 Tab: Closed Items
Closed Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Closed Items Resolved for SER Approval Issue TVA Response(s)
Status/Current Action April 19, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: Clark Date: 4/19/10 Responsibility: NRC April 19, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: Clark Date: 4/19/10 Responsibility: NRC May 6, 2010 NRC POC: EICB (Carte)
Date: 6/18/10 Responder: WEC Date: 5/6/2010 Responsibility: TVA May 6, 2010 NRC POC: EICB (Carte)
Date: 6/18/10 Responder: Clark Date: 5/6/2010 Responsibility: TVA May 6, 2010 NRC POC: EICB (Darbali)
Date: 5/24/10 Responder: Slifer Date: 5/6/2010 Responsibility: TVA May 6, 2010 NRC POC: EICB (Darbali)
Date: 5/24/10 Responder: Slifer Date: 5/6/2010 Responsibility: TVA May 20, 2010 NRC POC: EICB (Darbali)
Date: 5/25/10 Responder: Clark Date:
Responsibility:
May 20, 2010 NRC POC: EICB (Garg)
Date: 5/25/10 Responder: Knuettel Date:
Responsibility:
May 20, 2010 NRC POC: EICB (Darbali)
Date:
Responder:
Date:
Responsibility:
May 20, 2010 NRC POC: EICB (Darbali)
Date:
Responder:
Date:
Responsibility:
Monitoring Instrumentation - SE Section 7.5.2 Reference 16 of the PAMS System Requirements Specification (SysRS) is the Unit 1 precautions Limitations and Setpoints document. When and how will the transition to the unit 2 document be made.
Duplicate of Item 48.
63 Closed FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 How should the "shall" statements outside of the bracketed requirements be interpreted?
Duplicate of Item 50 62 Closed FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 Please provide 00000-ICE-30156 Rev. 6. The PAMS SysRS incorporates sections of this document by reference.
Duplicate of Item 49 84 Closed FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 Please provide: TVA Design Criteria WB-DC-30-7 Rev. 22, Post Accident Monitoring Instrumentation. contains Design Criteria WB-DC-30-7 Rev. 22, Post Accident Monitoring Instrumentation.
Document received.
83 Closed FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2 Please identify all FPGAs in the new or changed PAMS hardware.
The FPGAs used in the Common Q PAMS AC160 module are listed in Westinghouse letter WBT-D-2166, (Attachment 5), which provides both the proprietary and non-proprietary information. Attachment 6 (provided by Reference 11) contains the affidavit for withholding for WBT-D-2166-P-Attachment (contained in Attachment 5)..
Additionally, Westinghouse states in, Westinghouse Letter WBT-D-2170, (Reference 10) that their review of Flat Panel displays and PC Node Boxes concluded that they do not contain any FPGAs.
88 Closed.
FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2.
Regarding the Sorrento RM-1000 Digital Radiation Processor: Please provide prior software V&V reports. The latest report only addresses Version 1.2.
See response to item 56 87 Closed.
FSAR Section 7.5.1 Post Accident Monitoring Instrumentation - SE Section 7.5.2.
Regarding the Sorrento RM-1000 Digital Radiation Processor: Please identify the model and version to be installed. Please include explicit identification of software version.
The rate meter is model RM-1000. The software is version 1.2 91 Item is Closed and replaced by items 103, 104 and 118.
TVA to submit excerpts of EDCRs 52421, 52987, 52321, 52351 and 52601
- 1. Attachment 6 contains the EDCR 52421 excerpt
- 2. Attachment 7 contains the EDCR 52987 excerpt
- 3. EDCR 52321 is scheduled to be issued Oct 13, 2010. Submittal of EDCR 52321 excerpts is tracked by Responses to Licensee Open Items to be Resolved for SER Approval item 103 due October 31,2010.
- 4. EDCR 52351 is scheduled to be issued November 30, 2010. Submittal of EDCR 52351 excerpts is tracked by Responses to Licensee Open Items to be Resolved for SER Approval item 104 due December 15, 2010.
- 5. Attachment 8 contains the EDCR 52601 (RVLIS) excerpt. The RVLIS EDCR has been split into two EDCRs. The second EDCR is 55385. Submittal of EDCR 55385 excerpts is tracked by Responses to Licensee Open Items to be Resolved for SER Approval item 118 due November 15, 2010.
Two EDCRs have been submitted. TVA has agreed to submit the remaining EDCRs.
93 Closed TVA to submit a letter committing to include setpoint methodology discussion in the FSAR no later than amendment 100.
Letter Sent 5/25/10 97 Closed.
95 NRC Review TVA to review SER supplements 5 and 14 item 7.8.1 and supplement 4 item 7.8.4 and confirm if they are identical to Unit 1. If not provide differences.
Q1: Monitoring of the reactor coolant system relief valve position is the same as Unit 1.
Q2: The reactor trip on turbine trip is the same as Unit 1.
Response is satisfactory. Item closed.
File: rad8C078.xlsx Page 49 of 51 Tab: Closed Items
Closed Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Closed Items Resolved for SER Approval Issue TVA Response(s)
Status/Current Action May 25, 2010 NRC POC: EICB (Darbali)
Date:
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Date:
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April 12, 2010 NRC POC: DORL (Bailey)
Date:
Responder: WEC Date:
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May 24, 2010 NRC POC: EICB (Carte)
Date: 5/24/10 Responder: WEC Date:
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April 29, 2010 NRC POC: EICB (Garg)
Date:
Responder: Langley Date: 5/27/10 Responsibility: NRC May 6, 2010 NRC POC: EICB (Carte)
Date: 5/25/10 Responder: Davies Date:
Responsibility:
May 6, 2010 NRC POC: EICB (Darbali)
Date: 5/28/10 Responder: Clark Date:
Responsibility: NRC May 6, 2010 NRC POC: EICB (Garg)
Date: 5/25/10 Responder: Webb/Hilmes Date:
Responsibility:
May 6, 2010 NRC POC: EICB (Garg)
Date:
Responder: Clark Date: TVA Responsibility: Clark May 6, 2010 NRC POC: EICB (Carte)
Date: 5/28/10 Responder: Clark Date:
Responsibility:
June 1, 2010 NRC POC: EICB (Garg)
Date:
Responder: Clark Date:
Responsibility:
TVA to review SER Supplement 7 item 7.4.25 deviation on Aux Control Room display of RCS cold leg temperature for applicability to Unit 2.
The deviation to not have RCS cold leg temperature displayed in the Auxiliary Control Room was approved as part of the WBN Unit 1 initial license. WBN Unit 2 complies with the WBN Unit 1 Llicensing basese and this deviaition is applicable to Unit 2.
Response is satisfactory. Item closed.
99 Closed Closed to Item 129 TVA will provide non-proprietary versions of the following Common Q attached proprietary documents and the affidavits for the proprietary documents by June 30, 2010.
- 1. System Design Specification WNA-DS-01667-WBT, Rev. 1
- 2. System Requirements Specification WNA-DS-01617-WBT, Rev. 1
- 3. Watts Bar 2 - Common Q PAMS ISG-6 Compliance Matrix dated March 4, 2010
- 4. Watts Bar Unit 2 (WBN2) Post Accident Monitoring System (PAMS) Licensing Technical Report LTR-RCPL-10-XX
- 5. Software Requirements Specification WNA-SD-00239-WBT, Rev. 1 98 Closed.
Unit 1 SER Supplement 7, RCS Cold Leg Temperature instrumentation. How does Unit 2 address this change?
Refer to the response to Item 13 11 above.
Response is satisfactory. Item closed.
106 Closed Confirm that the Unit 1 and Unit 2 CERPI systems utilize the same processor (AC110 or AC160).
Westinghouse Unit 2 Drawing 6D31420, Watts Bar 2-CERPI AC160 Chassis Configuration, Rev. 2, shows the processors are model AC160, which are the same that are utilized for Unit 1, as shown on Westinghouse drawing 2D82995 Rev. 0, Watts Bar CERPI AC 160 Chassis Configuration.
105 Closed Provide As-Found/As-Left methodology procedure Submitted copy of TI-28 May 14/2010.
Replaced with new open item 176.
108 This item is closed as it will be reviewed under item 154.
FSAR Amd 100 We are requested to docket the fact that the appropriate sections of chapter 7 of the FSAR will be updated to include references to:
- a. TI-28 to address as-found/as-left issues
- b. RISC 2006-17 This item is addressed as follows:
2010 incorporates as-found and as-left setpoint tolerance discussion into section 7.1.2.1.9, adds EEB-TI-28, Setpoint Methodology to the section 7.1 references and adds a reference to 7.1.2.1.9 to section 7.2.1.1.10.
- 2. TSTF-493, Rev. 4 Option A has been incorporated into the Unit 2 Tech Spec submittal dated February 2, 2010.
This item is to be worked with item 51.
107 Closed See ML101940236, Encl 1, Item 29.
Describe any control functions associated with the RM-1000 radiation monitors.
The RM-1000 radiation monitors do not provide any control functions.
Requested information provided. NRC to review.
111 Closed The reviewer was unable to locate information (SER) on the plant computer or annunciator systems and asked us to provide the location within the FSAR where these systems are described.
The annunciator system is not described in the WBN Unit 1 UFSAR. As such it is not included in the WBN Unit 2 FSAR.
With the exception of the ERFDS functions in section 7.5, the plant computer is not described in the WBN Unit 1 UFSAR. As such it is not included in the WBN Unit 2 FSAR.
110 Closed The reviewer was unable to locate the Eagle 21 WCAPs 12374 and 12375 for review within the NRC records. We agreed to provide the ADAMS numbers for the submittal.
These items were docketed under ML073550386 112 Closed 102 Closed Provide a schedule for resolution of items 80, 82 and 83 Item 80 - no later than July 23, 2010 Item 82 - no later than July 23, 2010 Item 83 - no later than July 23, 2010 File: rad8C078.xlsx Page 50 of 51 Tab: Closed Items
Closed Items No Prop Y/N Resolution Path RAI No. & Date RAI Response Date Comments Agenda for Weekly Telecom with TVA (I&C Chapter 7 only)
Closed Items Resolved for SER Approval Issue TVA Response(s)
Status/Current Action June 10, 2010 NRC POC: EICB (Darbali)
Date:
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Date: 7/29/10 Responsibility: NRC June 14, 2010 NRC POC: EICB (Carte)
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June 14, 2010 NRC POC: EICB (Darbali)
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June 17, 2010 NRC POC: EICB (Carte)
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June 25, 2010 NRC POC: EICB (Garg)
Date:
Responder: Stockton Date:
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June 25, 2010 NRC POC: EICB (Garg)
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June 28, 2010 NRC POC: EICB (Garg)
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197 Date:
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Closed 207 July 27, 2010 NRC POC: EICB (Carte)
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Closed 119 Closed Submit the non-proprietary version of Sorrento/GA software V&V report version 1.1 04508005 and withholding affidavit Provided 7/15/2010 TVA provided the non-proprietary version of V&V report version 1.1 04508005 and the withholding affidavit via TVA letter dated July 15, 2010.
What are the differences between the Unit 1 and Unit 2 Eagle 21 Systems?
This information is included in TVA letter dated March 12, 2010, Enclosure 1, Item 10.
122 Closed Provide a date for completing the next revision of the Common Q PAMS System Requirements Specification.
This is a duplicate of NRC RAI Matrix Item 50 and is considered closed.
126 NRC Review SE Section 7.8 NUREG-0737 Items
- 1. In the SER Cross Reference To FSAR table (06-25-09), section 7.8.5 Confirm Existence of Anticipatory Reactor Trip Upon Turbine Trip (II.K.3.12) has the following scope of change:
Common Station Service Transformers (CSST) A and B, eight (8) vital inverters vs. four, fifth DG will be removed from FSAR, Double breaker, double breaker scheme of the new Watts Bar 500kV switchyard.
Is any I&C system or component affected in the scope of this change?
No I&C components or systems are affected by this change.
Item closed.
deleted 175 Close. This item is covered under item 78.
TVA to provide date when information will be docketed.
Placeholder: The staff has identified questions regarding diversity. The staff will keep this item open until TVA provides the related WCAP to the staff for its review and approval.
WCAP-13869 rev.2. is submitted in response to item In FSAR amendment 98, reference 6 added a new WCAP-13869 rev.2. Has this WCAP been reviewed by the staff. If not then provide the copy of WCAP for staff review.
Open Item 197 was never issued.
163 Closed FSAR Section 7.2, Reactor Trip System deleted 155 Open TVA to provide date when information will be docketed.
FSAR Section 7.2, Reactor Trip System Summary of FSAR change document section 7.2 states that sections 7.2.1.1.9 and 7.2.2.2(4) are changed to show that these activities will occur in future. However, no changes were made to the FSAR sections. Please explain.
The change package summary were the changes recommended by Engineering. TVA Licensing is responsible for the actual submittal and elected not to incorporate these recommendations. The activities are complete and the text in Amendment 99 of the FSAR is correct.
Close 141 Closed WBN2 PAMS System Requirements Specification deleted File: rad8C078.xlsx Page 51 of 51 Tab: Closed Items