ML11167A071

OL - FW: Updated OI List

ML11167A071
Person / Time
Site:	Watts Bar
Issue date:	06/13/2011
From:	Office of Nuclear Reactor Regulation
To:	Division of Operating Reactor Licensing
References
Download: ML11167A071 (166)

Text

WBN2Public Resource From: Poole, Justin Sent: Monday, June 13, 2011 8:33 AM To: Crouch, William D Cc: Clark, Mark Steven; WBN2HearingFile Resource

Subject:

FW: Updated OI List Attachments: 20110610 Open Item List Master NRC Update 06-10-11.docx Justin C. Poole Project Manager NRR/DORL/LPWB U.S. Nuclear Regulatory Commission (301)4152048 email: Justin.Poole@nrc.gov From: Darbali, Samir Sent: Friday, June 10, 2011 2:57 PM To: Poole, Justin Cc: Rahn, David

Subject:

Updated OI List

Justin, Attached is the updated OI list to be sent out to TVA.

Thanks, Samir Samir Darbali Electronics Engineer NRR/DE/EICB Room: O9D11 3014151360 1

Hearing Identifier: Watts_Bar_2_Operating_LA_Public Email Number: 407 Mail Envelope Properties (19D990B45D535548840D1118C451C74D8CB267ACE6)

Subject:

FW: Updated OI List Sent Date: 6/13/2011 8:33:12 AM Received Date: 6/13/2011 8:33:17 AM From: Poole, Justin Created By: Justin.Poole@nrc.gov Recipients:

"Clark, Mark Steven" <msclark0@tva.gov>

Tracking Status: None "WBN2HearingFile Resource" <WBN2HearingFile.Resource@nrc.gov>

Tracking Status: None "Crouch, William D" <wdcrouch@tva.gov>

Tracking Status: None Post Office: HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 480 6/13/2011 8:33:17 AM 20110610 Open Item List Master NRC Update 06-10-11.docx 574092 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 001 All All The Watts Bar Nuclear Plant FSAR red-line for Unit 2 (Agency 12/15/2009 Presentation Slides 1. Y Closed Closed EICB RAI 3/12/2010 NNC 11/19/09: The FSAR contains EICB (All) wide Documents Access and Management System Accession ML093230343, Item mostly description of the function that Number ML080770366) lists changes to the Unit 1 FSAR and This item was partially addressed during the December 15, Date: 3/15/2010 No. 1 the various TVA systems must perform.

depicts how Chapter 7 of the Unit 2 FSAR will appear at fuel load. 2009 meeting. Therefore this question was asked to Have additional changes been made to Chapter 7 of the Unit 2 RAI response received. determine how the systems have been FSAR beyond those indicated in ML080770366? Which of the TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 1 changed.

changes identified correspond to digital instrumentation and on Page 1 of 15): TVA responded to this request for controls (I&C) components and systems that have not been additional Information. NNC 4/15/10: The response addresses previously reviewed and approved by the NRC? many systems and should be read by all EICB reviewers.

002 All All Are there I&C components and systems that have changed to a 12/15/2009 Presentation Slides 2. Y Closed Closed EICB RAI 3/12/2010 NNC 11/19/09: The FSAR contains EICB (All) new or different digital technology without the change being ML093230343, Item mostly description of the function that reflected in the FSAR markup? Are there any not-redlined I&C This item was partially addressed during the December 15, Date: 3/15/2010 No. 2 the various TVA systems must perform.

components and systems that have been changed or replaced by 2009 meeting. Therefore this question was asked to digital base technology since Unit 1 was approved? TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 2 RAI response received. determine how the systems have been on Page 2 of 15): TVA responded to this request for changed.

additional Information.

NNC 4/15/10: The response addresses many systems and should be read by all EICB reviewers.

003 All All Because a digital I&C platform can be configured and programmed 12/15/2009 Presentation Slides 3. Y Closed Closed EICB RAI 3/12/2010 NNC 11/19/09: The FSAR contains EICB (All) for different applications, the review process can be divided ML093230343, Item mostly description of the function that between a review of the platform and a review of the application. This item was partially addressed during the December 15, Date: 3/15/2010 No. 3 the various TVA systems must perform.

For planning and scheduling reasons, it is important to know 2009 meeting. Therefore this question was asked to beforehand which platform has been used in each digital TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 3 RAI response received. determine how the systems have been component and system. What is the base platform of each on Page 2 of 15): TVA responded to this request for changed.

unreviewed digital I&C component and system (e.g., Common Q)? additional Information.

NNC 4/15/10: The response addresses many systems and should be read by all EICB reviewers.

004 All All Please identify the information that will be submitted for each Responder: Webb 1/13/10 Public Meeting 4. Y Closed Closed EICB RAI January 13, 2010 NNC 11/19/09: LIC-110 Rev. 1 Section EICB (All) unreviewed digital I&C system and component and the associated ML093230343, Item 6.2.2 states: "Design features and docketing schedule. TVA identified a schedule for docketing some Post Accident Date: 3/15/2010 Responsibility: TVA to docket a D3 No. 4 March 12, 2010 administrative programs that are unique Monitoring System (PAMS) documentation, and the new NRC (All) and TVA (Hilmes) analysis for the to Unit 2 should then be reviewed in setpoint methodology. No other documentation was Common Q PAMS. June 30, 2010 accordance with current staff discussed. TVA to address the question of how positions.TVA will supply a a Foxboro IA common mode or NNC 8/19/10: TVA August 11, 2010 description of the changes implemented Add: By letter dated June 30, 2010, TVA docketed WNA-LI- complete failure impacts the plant segmentation analysis at Unit 1 but have not been reviewed for 00058-WBT-P &-NP, "PAMS Licensing Technical Report." accident analysis as described in has been received - TVA Letter dated Unit 2 by the NRC technical staff...TVA WNA-LI-00058-WBT-P Section 4.11 addressed CCF and Chapter 15 of the FSAR. NRC to review. 10/5/10 will also provide the applicable portion BTP 7-19. (Demonstrate segments are of the FSAR and the proposed TSs...In independent and how a common addition, the staff should review items TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 4 mode or complete failure is that are identical for WBN Units 1 and 2 on Page 3 of 15): TVA responded to this request for prevented by power supply design that have not previously been reviewed additional Information and segmentation.) and approved by the NRC staff. These items are changes in the design and Foxboro I/A Segmentation Analysis Calculation NNC 8/19/10: The justification for licensing basis for WBN Unit 1 that TVA DCSSEGMENT, Rev. 0 submitted on TVA letter dated not performing and D3 analysis has implemented without NRC prior August 11, 2010. contained in the CQ PAMS approval under the 10 CFR 50.59 Licensing Technical Report is not process."

acceptable. TVA to docket a D3 NNC 4/15/10: The response addresses Data Storm Testing analysis for the CQ PAMS. This will many systems and should be read by all be responded to in Item 64. EICB reviewers.

(a) Foxboro I/A Segmentation Analysis, Calculation DCSSEGMENT, Rev. 0 submitted on TVA letter to the NNC 8/25/10: The segmentation NRC dated August 11, 2010 (Reference). analysis has been read. Please explain why it is believed that failure

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N (b) Attachment 36 to letter dated 10/5/10 contains Foxboro will not propagate over the peer-to-proprietary drawings 08F802403-SC-2001 sheets 1 peer network.

through 6. An affidavit for withholding and non-proprietary versions of the drawings will be submitted Looking for an architectural no later than January 31, 2011. description of the network interconnections similar to the ICS (c) Credible Mesh Network Failure Modes overview, identification of credible failure modes caused by the mesh Attachment 42 to letter dated 10/5/10 contains the network and what component(s) mesh network failure analysis. prevent mesh network failures from disabling the entire system. What (d) Refer to the response to item (c) above. prevents a segment failure from propagating across the mesh network and affecting other segments.

005 7.1.3. By letter date February 28, 2008 (Agencywide Documents Access Responder: Craig/Webb 5. Y Closed Closed EICB RAI TVA Letter dated EICB (Garg) 1 and Management System (ADAMS) Accession Number ML093431118, Item 2/5/10 ML080770366) TVA provided a "red-lined" version of the FSAR for TVA Letter Dated February 5, 2010: TVA provided the Unit 2 Date: 3/15/2010 FSAR AMD 100 No. 5 WBN Unit 2. The purpose of this FSAR "red-line" version was to setpoint methodology (WCAP-177044-P Revision 0 - dated Responsibility: NRC (Garg) and TVA Letter depict how the Unit 2 FSAR will appear at fuel load. This letter December). TVA (Hilmes and Crouch) dated3/12/10 identified significant FSAR changes and provided a X-REF number for each. TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 5 RAI response received. This item is on Page 5 of 15): TVA responded to this request for closed as this is covered under item Change 7.3-1 refers to the following two Summary Reports: additional Information 154 later on.

TVA Letter, P. L. Pace to NRC, dated February.9, 1998, "Watts Bar This item is addressed as follows: This item requires further discussion Nuclear Plant (WBN) Unit 1 - 10 CFR 50.59(b)(2), Changes, Tests between TVA and the staff and Experiments Summary Report 1. FSAR Amendment 100 which was submitted on TVA letter concerning the setpoint to the NRC dated August __, 2010 incorporates as-found methodology employed for WBN2.

TVA Letter, P. L. Pace to NRC, dated September 30, 2005, "Watts and as-left setpoint tolerance discussion into section Bar Nuclear Plant (WBN) Unit 1 - 10 CFR 50.59, Changes, Tests 7.1.2.1.9, adds EEB-TI-28, Setpoint Methodology to the See Item 8.

and Experiments Summary Report" section 7.1 references and adds a reference to 7.1.2.1.9 to section 7.2.1.1.10.

Please submit the 50.59 Evaluations for each of these Summary Reports and identify which parts are relevant to the Unit 2 Setpoint TSTF-493, Rev. 4 Option A has been incorporated into the Methodology. Unit 2 Tech Spec submittal dated February 2, 2010.

006 Amendment 95 of the FSAR, Chapter 7.3, shows that change 7.3-1 By letter dated February 5, 2010: TVA provided the Unit 2 6. Y Closed Closed EICB RAI TVA Letter dated NNC: WCAP-12096 Rev. 7 EICB (Garg) consists of updating a reference from revision 5 to revision 7 and setpoint methodology (WCAP-177044-P Revision 0 - dated ML093431118, Item 2/5/10 (ML073460281) is in ADAMS.

making it applicable to Unit 1 only, while adding a new reference, December 2009). This item is reviewed in FSAR No. 6 applicable only to Unit 2. amendment 100 review. TVA to reference TI-28 TVA Letter dated NNC: WCAP-12096 Rev. 8 is the TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 6 for as found and as left 3/12/10 current revision for Unit 1.

Reagan, J. R., "Westinghouse Setpoint Methodology for Protection on Page 7 of 15): TVA responded to this request for Date: 2/16/2010 value. Also provide the Systems, Watts Bar Units 1 and 2, Eagle 21 Version," WCAP- additional Information. reference to FSAR TVA Letter dated TVA to docket Rev. 8 and identify that 12096 Rev. 7, (Westinghouse Proprietary Class 2). Unit 1 Only The Westinghouse Setpoint Section 7.1 for the 7/30/10 Rev. 8 is the current revision for Unit 1.

a. TVA to docket Rev. 8 and identify that Rev. 8 is the methodology document (WCAP- setpoint methodology. TVA to identify any NRC approval of WCAP Westinghouse Setpoint Methodology for Protection current revision for Unit 1. TVA to identify any NRC approval 17044-P Revision 0) identifies that Rev. 8.

System, Watts Bar Unit 2, Eagle 21 Version, WCAP-17044-P. Unit of Rev. 8. the intermediate and source range This is addressed in 2 Only. calculations were performed by TVA FSAR Amendment 100. TVA to describe how TVA calculations In accordance with item 2, below, there is no change to the (2-NMD-092-0131). Please provide for Unit 2 are different than Unit 1. If Please provide both setpoint methodology documents identified methodology, therefore revision 8 is not included in this the intermediate and source range they are the same, TVA to docket such above. response. calculations performed by TVA (2- statement under oath and Affirmation.

NMD-092-0131).

Westinghouse letter WAT-D-10502 (Attachment 1) describes the two changes to WCAP-12096 Revision. 8. The first The Westinghouse Setpoint change addresses the containment sump level transmitter methodology document (WCAP-replacement. This change was submitted under 50.59 17044-P Revision 0) identifies that summary report (ML073460444, Page 77). The second the undervoltage and change is to delete the power range negative flux rate trip. underfrequency calculations were

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N This item was submitted as a Technical Specification change performed by TVA (2-27-068-0031).

(ML073201052). The Technical Specification change was Please provide the undervoltage subsequently approved. and underfrequency calculations performed by TVA (2-27-068-0031).

The current revision of Unit 1 WCAP-12096 is Revision 9.

Revision 9 was issued to make the changes required by the Work with Item 7 for WCAP-12906 Steam Generator Replacement Project. Unit 2 is using the issues.

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.

007 7.1.3. The setpoint methodology has been reviewed and approved by the TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 7 7. Y Closed Closed EICB RAI TVA Letter dated TVA to provide Rev. 8 of the Unit 1 EICB (Garg) 1 NRC staff in Section 7.1.3.1 of NUREG-0847 (ML072060490), on Page 7 of 15): TVA responded to this request for This item is reviewed in FSAR 100 ML093431118, Item 3/12/10 document (which is the current one) if NUREG-0847 Supplement No.4 (ML072060524), and NUREG- additional Information. review. No. 7 there is a change in methodology and 0847 Supplement No. 15 (ML072060488). Same as Item 6 above TVA Letter dated identify how the Unit 2 document differs

a. TVA will submit WCAP-12096, Rev. 8 if there is a change Date: 1/13/2010 7/30/10 from it.

Please describe all changes from the methodology that has been to the methodology. This is addressed in reviewed and approved by the staff. RAI response received. NRC to FSAR Amendment 100.

No change in methodology, therefore WCAP-12906, review response.

Revision 8 is not submitted.

TVA will submit WCAP-12096, Rev.

b. TVA will supply the 50.59 letter for Rev. 8 8 if there is a change to the methodology.

Westinghouse letter WAT-D-10502 (Attachment 1) describes the two changes to WCAP-12096 Revision. 8. The first TVA will supply the 50.59 letter for change addresses the containment sump level transmitter Rev. 8 replacement. This change was submitted under 50.59 summary report (ML073460444, Page 77). The second TVA to locate transmittal letter that change is to delete the power range negative flux rate trip. submitted Rev. 7.

This item was submitted and approved as a Technical Specification change (ML073201052). TVA to determine the last revision of WCAP-12096 where there was a

c. TVA to locate transmittal letter that submitted Rev. 7. change in methodology.

Refer to response to Item 1. TVA responded to this request Work with Item 6 for WCAP-12906 for additional Information in letter dated March 12, 2010, issues.

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.

008 7.3 There are several staff positions that provide guidance on setpoint TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 8 8. Y Closed Closed EICB RAI TVA Letter dated EICB (Garg) methodology (e.g., Reg Guide 1.105, BTP 7-12, RIS-2006-17 and on Page 7 of 15): TVA responded to this request for ML093431118, Item 3/12/10 TSTF-493 Rev. 4). Please identify how the Unit 2 setpoint additional Information FSAR AMD 100. No. 8 methodology addresses staff guidance. Closed as it will be This item is addressed as follows: covered under item 154

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

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.

009 7.3.2 5.6, Change 7.3-2, identified in Watts Bar Nuclear Plant FSAR red-line TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 9 9. Y Closed Closed EICB RAI 3/12/10, EICB (Darbali) 6.3.5 for Unit 2 (ADAMS Accession Number ML080770366), refers to the on Page 8 of 15): TVA responded to this request for ML093431118, Item ML101680598, following Summary Report: TVA Letter, P. L. Pace to NRC, dated additional Information Date: 3/15/2010 No. 9 Item 9 September 20, 2002, "Watts Bar Nuclear Plant (WBN) Unit 1 - 10 Responsibility: NRC (Darbali)

CFR 50.59, Changes, Tests and Experiments Summary Report" 50.59 evaluation was submitted in Please provide the 50.59 Evaluation summarized in this Summary the RAI response.

Report.

010 7.3 7.3 The original SER on Watts Bar (NUREG-0847) documents that the TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 10 10. Y Closed Closed EICB RAI 3/12/10, EICB (Darbali) scope of the review of FSAR Section 7.3, Engineered Safety on Page 8 of 15): TVA responded to this request for ML093431118, Item ML101680598, Features Actuations System, included: included single-line, additional Information. Replaced by OI 314 No. 10 Item 10 function logic and schematic diagrams, and descriptive information for the ESFAS and those auxiliary supporting systems that are TVA Letter (ML073550386) dated FEB 26 1992: docketed essential to the operation of either the ESFAS or the ESF systems. WCAP-12374 Rev. 1 (ML080500664).

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.

011 7.3.2 5.6, NUREG-0847 Supplement No. 2 Section 7.3.2 includes an TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 11 11. Y Closed Closed EICB RAI ML101680598, EICB (Darbali) 6.3.5 evaluation of a change in containment sump level measurement. on Page 13 of 15): TVA responded to this request for ML093431118, Item Item 9 Provide information to demonstrate that Unit 2 implements the additional Information Date: 3/15/2010 No. 11 containment sump level indication as described and evaluated in Responsibility: NRC (Darbali)

NUREG-0847 Supplement No. 2, Section 7.3.2, for Unit 1.

Requested information was submitted in the RAI response.

012 7.4 7.4 The original SER on Watts Bar (NUREG-0847) documents that the TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 12 12. Y Closed Closed EICB RAI TVA Letter dated EICB (Darbali) scope of the review of FSAR Section 7.4, "Systems Required for on Page 13 of 15): TVA responded to this request for ML093431118, Item 3/12/10 Safe Shutdown," included single-line and schematic diagrams: additional Information Date: 3/15/2010 No. 6 "The scope of the review of the systems required for safe shutdown TVA Letter dated included the single-line and schematic diagrams and the A revised response was included in the 7/30 letter that TVA provided the following: 7/30/10 descriptive information for these systems and for the auxiliary provides the requested information.

systems essential for their operation." 1. Description of what is different ML101680598, from Unit 1 Item 9 Please provide the single-line and schematic diagrams for the systems required for safe shutdown that are applicable to Unit 2, 2. Road map between functions and include a description of all changes since these diagrams were listed in 7.4 and the FSAR section reviewed and approved by the NRC staff. that describes the equipment that performs the function. Item

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Closed.

013 7.1.3. Chapter 7 and Chapter 16 of Amendment 95 to the FSAR do not TVA Letter Dated March 12, 2010 (Enclosure 1, Item No. 13 13. Y Closed Closed EICB RAI TVA Letter dated TS have been docketed.

EICB (Garg) 1 include any setpoint values. Please describe how and when on Page 14 of 15): TVA responded to this request for ML093431118, Item 3/12/10 setpoint values (e.g., TS allowable values) will be provided for Unit additional Information Date: 3/15/2010 This item is closed for No. 13

2. chapter 7. NRC will RAI response received. review T.S. under Please describe the information that will be provided to justify the Westinghouse is completing the different chapter.

acceptability of these values. setpoint calculations which will be completed by May 11, 2011. NRC to review response.

014 All All Provide the justification for any hardware and software changes Date: 4/27/10 14. Y Closed Closed NRC Meeting TVA Letter dated EICB (All) that have been made since the previous U.S. Nuclear Regulatory Responder: TVA Summary 4/27/10 Commission (NRC) staff review for Eagle 21 and other platforms NNC: I do not recall saying that the ML093560019, Item By letter dated April 27, 2010: TVA responded to this request NRC is not interested in changes in No. 1 for information (Enclosure, Item No. 1) stated: "In discussion other platforms. Please provide a with the staff, TVA's understanding is that the focus of this description of changes to other question is the Eagle 21 system. Please refer to Reference platforms (e.g., SSPS).

2 [TVA Letter Dated March 12, 2010], Question 10, and TVA letter to NRC dated August 25, 2008, 'Watts Bar Nuclear For Eagle 21, this response points Plant (WBN) - Unit 2 - Westinghouse Eagle 21 Process to Open Item No. 10.

Protection System, Response to NRC I&C Branch request for additional information' (Reference 3 [TVA letter dated Response understood. Additional August 25, 2008]) for the discussion of changes to the Eagle material will be requested 21 system." separately to understand the systems described.

A listing of changes to other platforms was provided in TVA letter dated April 27, 2010, Enclosure 1, items 21 and 23.

015 Verify that the refurbishment of the power range nuclear Date: 4/27/10 15. Y Closed Closed NRC Meeting TVA Letter dated EICB (Garg) instrumentation drawers resulted in only like-for-like replacements. Responder: TVA Summary 4/27/10 Date: 4/27/10 ML093560019, Item By letter dated April 27, 2010 TVA responded to this request Responsibility: NRC (Garg) No. 2 for information (Enclosure, Item No. 2).

Response acceptable. Close 016 Identify the precedents in license amendment requests (LARs), if Date: 4/27/10 16. Y Closed Closed NRC Meeting TVA Letter dated EICB (Carte) any, for source range monitors or intermediate range monitors. Responder: TVA Summary 4/27/10 Date: 4/27/10 ML093560019, Item By letter dated April 27, 2010 TVA responded to this request Responsibility: NRC (Garg) No. 3 for information (Enclosure, Item No. 3).

Acceptable. Close 017 7.3.1 7.3.1, Identify precedents in LARs, if any, for the solid state protection Date: 4/27/10 17. Y Closed Closed NRC Meeting TVA Letter dated 5.5.5, EICB system. Also, identify any hardware deviation from the precedent. Summary 4/27/10 5.6 (Darbali) By letter dated April 27, 2010 TVA responded to this request ML093560019, Item for information (Enclosure, Item No. 4). No. 4 ML101230248, Item 4 018 Identify any changes made to any instrumentation and control Date: 4/27/10 18. Y Closed Closed NRC Meeting TVA Letter dated EICB (Garg)

(I&C) system based on prior knowledge of failures. Responder: TVA Summary 4/27/10 Date: 4/27/10 ML093560019, Item By letter dated April 27, 2010 TVA responded to this request Responsibility: NRC (Garg) No. 5 for information (Enclosure, Item No. 5).

Acceptable. Close 019 Verify that the containment purge isolation radiation monitor is the Date: 4/27/10 19. Y Closed Closed NRC Meeting TVA Letter dated EICB (Garg) same as used in Watts Bar Unit 1, or identify any hardware Summary 4/27/10 changes. By latter dated April 27, 2010 TVA responded to this request Date: 4/27/10 NRC Review ML093560019, Item for information (Enclosure 1, Item No. 6) for the ratemeter. No. 6 TVA Letter dated A newer model, RD-52, of the RD-32 detector assembly 6/18/10 used in Unit 1. The detector assembly replacement is due to

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N obsolescence and improved reliability.

Clarify electronics are analog and the same as unit 1 and the only difference is the detector assembly.

020 Provide environmental qualification information pursuant to Section Date: 4/27/10 20. Y Closed Closed NRC Meeting TVA Letter dated NNC 4/30/10: SRP Section 7.0 states:

EICB (Garg) 50.49 of Title 10 of the Code of Federal Regulations (10 CFR) for Responder: TVA Summary 4/27/10 "The organization responsible for the safety-related actuation transmitters. Date: 4/27/10 ML093560019, Item review of environmental qualification By letter dated April 27, 2010 TVA responded to this request Responsibility: NRC (EEEB) No. 7 reviews the environmental qualification for information (Enclosure, Item No. 7). of I&C equipment. The scope of this Garg to coordinate with Weibi to review includes the design criteria and ensure EEEB takes responsibility qualification testing methods and for this one. procedures for I&C equipment."

021 7.3 For the Foxboro Spec 200 platform, identify any changes in Date: 5/25/10 21. Y Closed Closed NRC Meeting TVA Letter dated The resolution of this item will be EICB (Garg) hardware from the precedent systems. Provide the design report The resolution of this item will be Summary 6/18/10 covered by OI#288..

and the equipment qualification information. No vendor system description is available for the Foxboro covered by OI#288 ML093560019, Item Spec 200 system. The hardware description and No. 8 qualification documents are provided on a component level Date: 5/24/10 basis. A TVA generated system description is provided to assist the reviewer. The hardware differences from the unit The understanding reached in the 1 systems are provided in the loop and card comparison meeting on April 14, 2010, was that documents. As agreed with the reviewer, the component TVA should identify any changes, or level documents are not required to be submitted at this state under oath and affirmation that time, but may be required later based on the review of there were no changes. If there attached documents. The following TVA generated were no changes, then the NRC documents are provided (Attachment 1): would confirm by inspection.

1. Analog loop comparison A revised response was requested at the 5/24/10 public meeting.

2. Analog card comparison Add a brief discussion of the

3. Analog system description Foxboro Spec 200 to the FSAR let Hukam know on Thursday which section we will add the discussion to.

022 7.3.2 5.6, Verify the auxiliary feedwater control refurbishment results in a like- Date: 4/27/10 22. Y Closed Closed NRC Meeting TVA Letter dated EICB (Darbali) 6.3.5 for-like replacement, and identify any changes from the identified Summary 4/27/10 precedents. By letter dated April 27, 2010 TVA responded to this request Date: 4/27/10 to open item 285 ML093560019, Item for information (Enclosure, Item No. 9). No. 9 TVA Letter dated TVA should confirm if Woodward 10/5/10 The control function of the Auxiliary Feedwater (AFW) Flow Governor is the only change.

for Steam Generator Level is the same as Unit 1. The controllers and signal modifiers/conditioners are Foxboro See Item 285 for follow up question.

SPEC 200 discrete analog modules as Unit 1 control loops.

The only different Unit 1 uses a 10-50ma signal and Unit 2 is Response is included in letter dated using a 4-20ma. The SPEC 200 control modules operate 10/5/10.

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:

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 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 This loop controls the differential pressure of the Auxiliary Feedwater Pump 2B-B by varying valve 2-PCV-3-132.

Differential Pressure Indicating Controller 2-PdIC-3-132A (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-3-132 (on panel 2-L-11B) is in the normal position.

2-P-3-132C This loop controls the differential pressure of the Auxiliary Feedwater Pump 2B-B by varying valve 2-PCV-3-132.

Differential Pressure Indicating Controller 2-PdIC-3-132C (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-3-132 (on panel 2-L-11B) is in the auxiliary position.

Unit 2 controllers are Foxboro model N-250HM-M2NH-F; Signal Converters, current-voltage IN are model N-2AI-I2V, and voltage-current OUT are N-2AO-VAI; Control Card is model N-2AX+A4.

All components are supplied in accordance with requirements of 10CFR50 Appendix B and ASME NQA-1 as defined in Invensys Systems, Inc. Corporate Quality Assurance Program Requirements, QMS, Revision S, dated October 26, 2007.

All components were manufactured with the same materials and processes as those qualified for Nuclear Class 1E Service per IEEE-323-1974 and IEEE-344-1975.

023 EICB Provide environmental qualification (10 CFR 50.49) information for Date: 4/27/10 23. Y Closed Closed NRC Meeting TVA Letter dated NNC 4/30/10: SRP Section 7.0 states:

(Garg

) safety-related control transmitters and complete the deviation Responder: TVA Summary 4/27/10 "The organization responsible for the section of the table. Date: 12/22/09 ML093560019, Item review of environmental qualification

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N By letter dated April 27, 2010 TVA responded to this request Responsibility: NRC (EEEB) No. 10 reviews the environmental qualification for information (Enclosure, Item No. 10). of I&C equipment. The scope of this Garg to coordinate with Weibi to review includes the design criteria and ensure EEEB takes responsibility qualification testing methods and for this one. procedures for I&C equipment."

024 Provide a schedule by the January 13, 2010, meeting for providing During the January 13, 2010 meeting, TVA presented a 24. Y Closed Closed NRC Meeting N/A - Request for NNC 4/30/10: Carte to address EICB (Carte) information in accordance with I&C Interim Staff Guidance (ISG) 6. schedule for completing various documents for the PAMS Summary schedule response with respect to PAMS and system. This schedule did not support TVA's desired The explanations provided by TVA to Open Item No. 43 ML093560019, Item information Darbali to address response with schedule. TVA was so informed and said they would work (that certain information is not No. 11 respect to RM1000.

on improving the schedule. TVA said that the setpoint required) are unacceptable.

methodology would be provided shortly. No other systems TVA has agreed to submit the of documentation was discussed. NNC 8/18/10: The TVA agreement requested information on the docket.

in the Comments column conflicts By letter dated February 5, 2010 (see enclosure 1), TVA with the TVA responses to other provided a list of documents and associated availability for open items where TVA states that PAMS. information is available for audit.

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 provided a table, "Watts Bar 2 - Common Q PAMS ISG-6 Compliance Matrix."

025 7.5.2 7.5.1 For the containment radiation high radiation monitor, verify that the Date: 4/27/10 25. Y Closed Closed NRC Meeting ML101230248, EICB information provided by TVA is consistent with the information Summary Item 12 (Singh) provided with the previously-approved license amendment request By letter dated April 27, 2010 TVA responded to this request (See OI 300 for additional ML093560019, Item 4/27/2010 for the Duane Arnold plant or provide Phase 3 information. for information (Enclosure, Item No. 12). questions.) No. 12 026 Provide environmental qualification (10 CFR 50.49) information for Date: 4/27/10 26. Y Closed Closed NRC Meeting TVA Letter dated NNC 4/30/10: SRP Section 7.0 states:

EICB (Garg) safety-related monitoring transmitters. Responder: TVA Summary 4/27/10 "The organization responsible for the Date: 12/22/09 ML093560019, Item review of environmental qualification By letter dated April 27, 2010 TVA responded to this request Responsibility: NRC (EEEB) No. 13 reviews the environmental qualification for information (Enclosure, Item No. 13). of I&C equipment. The scope of this Garg to coordinate with Weibi to review includes the design criteria and ensure EEEB takes responsibility qualification testing methods and for this one. procedures for I&C equipment."

027 7.7.1. For Foxboro I/A provide information regarding safety/non-safety- Date: 4/27/10 27. Y Closed Closed NRC Meeting TVA Letter dated EICB (Carte) 4 related interaction, common cause failures, and communication Responder: TVA Summary 4/27/10 with safety related equipment in accordance with ISG 4. ML093560019, Item By letter dated April 27, 2010 TVA responded to this request No. 14 for information (Enclosure, Item No. 14): "There is no digital communications or interactions between Foxboro Intelligent Automation (IA) and any Safety-related system."

028 For the turbine control AEH system, verify that the refurbishment Responder: Mark Scansen 28. Y Closed Closed NRC Meeting TVA Letter dated EICB (Garg) results in a like-for-like replacement. Date: 4/27/10 Summary 10/5/10 Response is included in letter dated Provide 50.59 ML093560019, Item By letter dated April 27, 2010 TVA responded to this request 10/5/10. No. 15 for information (Enclosure, Item No. 15).

Provide 50.59 evaluation.

The requested 50.59 is included in Attachment 1. Response acceptable.

029 For the rod control system, verify that the refurbishment results in a Date: 4/27/10 29. Y Closed Closed NRC Meeting TVA Letter dated EICB (Carte) like-for-like replacement. Responder: TVA Summary 4/27/10 ML093560019, Item By letter dated April 27, 2010 (ML101230248) TVA No. 16 responded to this request for information (Enclosure, Item No. 16 & Attachment 5): TVA stated on a card by card basis that the refurbished cards have the same form fit and

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N function.

030 Regarding the refurbishment of I&C equipment, identify any Responder: Clark 30. Y Closed Closed NRC Meeting TVA Letter dated EICB (Garg) component digital upgrades and, if so, provide the supporting Summary 10/5/10 design information. Date: 4/27/10 Response is included in letter dated ML093560019, Item 10/5/10. No. 17 By letter dated April 27, 2010 TVA responded to this request Date: 4/27/10 for information (Enclosure, Item No. 17).

Does not state if there are no other There are no other I&C upgrades which contain an upgrade which contain imbedded imbedded digital processor. digital processor. Revised response acceptable.

031 For the rod position indication system (CERPI), provide information Date: 4/27/10 31. Y Closed Closed NRC Meeting TVA Letter dated CERPI is non-safety related.

EICB in accordance with ISG 4. Need to consider cyber-security issues. Responder: TVA Summary 4/27/10 Note: The issue of interlock with rod (Carte) ML093560019, Item withdrawal system is addressed in open By letter dated April 27, 2010 TVA responded to this request No. 18 item 301. (Singh Sept22, 2010) for information (Enclosure, Item No. 18).

032 For the process computer, need to consider cyber security issues Date: 4/27/10 32. Y Closed Closed NRC Meeting TVA Letter dated EICB will no longer consider cyber EICB and emergency response data system needs. Responder: TVA Summary 4/27/10 issues.

(Carte) ML093560019, Item By letter dated April 27, 2010 TVA responded to this request No. 19 for information (Enclosure, Item No. 19).

033 For the loose parts monitoring system, provide information Date: 4/27/10 33. Y Closed Closed NRC Meeting TVA Letter dated The loose parts monitoring system is EICB (Carte) regarding interactions with safety related equipment. Responder: TVA Summary 4/27/10 not connected to any other system.

ML093560019, Item By letter dated April 27, 2010 TVA responded to this request No. 20 for information (Enclosure, Item No. 20): Loose parts is not connected to any other system.

034 2/4/2010 Responder: TVA 34. Y Closed Closed N/A TVA Letter dated EICB (Garg)

Awaiting NRC evaluation of 4/27/10 In the December 15, 2009 public meeting, TVA listed the significant By letter dated April 27, 2010 TVA responded to this request response.

changes made since the Watts Bar Unit 1 Licensing (see below). for information (Enclosure, Item No. 21).

For each of the following significant changes:

Remove all references to Elbow Tap Methodology from Unit

1) Is the change unique to Unit 2, or will it be the same as whats 2 Licensing Bases.

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?

034. Chapter 7.1 - Introduction 35. Y Closed Closed N/A N/A EICB 1 (Garg/Si Reactor Coolant System Flow Rate Measurement ngh) Design Basis Analysis Parameters Loose Parts Monitoring 034. Chapter 7.2 - Reactor Trip System 36. Y Closed Closed N/A N/A EICB (Garg) 2 Deletion of Neutron Flux Negative Rate Trip Design Basis Analysis Parameters Alternate Method for Use of Condenser Steam Dump Reactor Coolant System Flow Rate Measurement Foxboro I/A

37. Y

(

034. 7.3 7.3 Chapter 7.3 - ESFAS Closed Closed N/A N/A D

a

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 3 Design Basis Analysis Parameters Alternate Method for Use of Condenser Steam Dump to item 153 034. 7.5.1. 7.5.2 Chapter 7.5 - Instrumentation Systems Important to Safety 38. Y Closed Closed N/A N/A Closed EICB (Marcus) 4 1 Plant Process Computer Replacement Containment Sump Level Transmitter Replacement to Item 192 RAI not required.

Safety Injection Systems Cold Leg Accumulator Level Measurement System For plant process computer see Items Common Q/PAMs This is closed by Norbert. 192, 193, 194, 195, 196, 198, 199, 203, 204, 206, 216, and 224.

034. 7.5.1. 7.5.2 Chapter 7.6 - All Other Systems Required for Safety 39. Y Closed Closed N/A N/A Closed EICB 5 1 7.6.7 Plant Process Computer Replacement 7.6.1 Loose Parts Monitoring System to Item 192 RAI not required.

(Marcus/Singh) For plant process computer see Items 192, 193, 194, 195, 196, 198, 199, 203, 204, 206, 216, and 224.

034. Chapter 7.7 Control Systems 40. Y Closed Closed N/A N/A EICB (Singh/Darbali) 6 Alternate Means for Monitoring Control or Shutdown Rod Position to item 301 for alternate Eliminate Pressurizer Backup Heaters on High Level rod position indication.

Signal AMSAC Replacement Foxboro I/A WINCISE /Power Distribution Monitoring System (Beacon) 035 2/18/2010 Responder: Clark 41. Y Closed Closed RAI No. 1 TVA Letter dated LIC-110 Section 6.2.2 states: Design EICB (Singh)

ML102980005 3/12/10 features and administrative programs Please provide a system description of the Digital Metal Impact TVA Letter dated March 12, 2010 Enclosure 1, item 4 Response is included in letter dated Att.2 to 10/5/2010 TVA 10/26/2010 that are unique to Unit 2 should be Monitoring System that contains sufficient detail to support a responded to this request for information. 10/5/10. letter provided the TVA Letter dated reviewed in accordance with the current review of this system using current staff positions. information. 10/5/10 staff positions. Unit 2 FSAR Section Attachment contains the non-proprietary system description Description provide is not of 7.6.7, Loose Part Monitoring (LPMS) which was developed from proprietary Westinghouse Watts sufficient detail to allow a regulatory system Description, describes a system Bar Unit 2 DIMMS-DX Operations and Maintenance Manual, determination. TVA to send the design that is unique to Unit 2.

1TS3176 Rev.0 (Reference ). Westinghouse approved this proprietary information for NRC non-proprietary version for public release via letter WBT-D- review. At the 9-2 meeting G. Singh 2281 dated August 17, 2010 (Reference ) stated the system description provided was acceptable and the proprietary information was not required at this time.

036 7.5.2 7.5.1 February 18, 2010 Date: 5/25/10 42. Y Closed Closed NRC Meeting NNC: Unit 2 FSAR Section 7.5.1, Post EICB (Carte)

Responder: Clark Summary Accident Monitoring Instrumentation, Please provide a system description of the Post Accident ML093560019, Item describes a system design that is Monitoring System that contains sufficient detail to support a In previous letters TVA has provided the Common Q No. 11 unique to Unit 2. LIC-110, "Watts Bar review of this system using current staff positions. documents that address this item: 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."

037 7.5.1. 7.5.2 2/18/2010 Responder: Clark Date: 5/25/10 43. Y Closed Closed N/A TVA Letter dated FSAR Amendment 100 provides EICB (Marcus) 1 09/16/10 10/5/10 information Is the plant computer a safety-related display system? As identified in TVA letter dated March 12, 2010, Enclosure Response is included in letter dated 1, item 2, the plant computer system is non-safety related. 10/5/10. FSAR Section 7.5, Instrumentation System Important to Safety, consists of FSAR section 7.5 describes both safety and non-safety August 19, 2010 - TVA to submit two major subsections: 7.5.1, Post

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N related devices and systems. FSAR section 7.1.1.2 is markup of FSAR Amendment 100. Accident Monitoring Instrumentation revised in FSAR Amendment 100 submitted to the NRC on (PAM), and 7.5.2, Plant Computer TVA letter to the NRC dated September 1, 2010. FSAR Amendment 100 states Plant System.

computer system is non-safety related. Regulatory Guide 1.70, Standard format and content of Safety Analysis Reports for Nuclear Power Plants, Revision 3 dated November 1978 states (see Section 7.1.1): List all instrumentation, control, and supporting systems that are safety-related including alarms, communication, and display instrumentation. FSAR Section 7.1.1.2, Safety-Related Display Instrumentation, describes, in the first paragraph, the PAM system, and the second paragraph states: All other safety-related instrumentation is discussed in Section 7.5. Therefore, to be consistent with the preceding paragraph, the FSAR states that the plant computer system is safety related.

Contrary to the FSAR the slides presented at the December 15, 2010 meeting indicate that the plant process computer is not safety-related.

Therefore the docketed material is inconsistent and needs to be clarified.

RAI not required 038 7.5.1. 7.5.2 2/18/2010 Responder: Clark Date: 5/25/10 44. Y Closed Closed EICB RAI TVA Letter dated The slides presented at the December EICB (Marcus) 1 ML102861885 10/5/10 15, 2010 meeting (ML093520967)

Please provide a description of the interfaces between: (1) the FSAR sections 7.1.1.2 and 7.5.2 are revised to address this Response is included in letter dated NRC issue formal RAI. Item No. 19 indicate that the plant process computer Safety Parameter Display System and (2) the Technical Support comment in FSAR Amendment 100 submitted to the NRC on 10/5/10. has been replaced.

Center and Nuclear Data Links with the plant control and safety TVA letter to the NRC dated September 1, 2010.

systems. This Description should contain sufficient detail to August 19, 2010 - TVA to submit EICB RAI ML102861885 sent to DORL support a review of these interfaces using current staff positions. markup of FSAR Amendment 100.

NRC confirmed FSAR Amendment 100 provides details on interfaces.

039 January 13, 2010 Responder: Clark Date: 5/25/10 45. Y Closed Closed EICB RAI FSAR amendment The equation for the calculation of the EICB (Garg)

ML102910008 98 estimated average hot leg temperature Please describe the change to the calculation of the estimated Refer to revised equations in FSAR amendment 98. Date: 1/13/2010 OI#37 on page 7.2-13 of Revision WBNP-96 of average hot leg temperature (see FSAR Section 7.2.1.1.4, page Responsibility: TVA the Unit 2 FSAR is different than the 7.2-14 Version WBNP-96) in sufficient detail to support a review of calculation of the average hot leg this system using current staff positions. NRC staff will review temperature shown at the top of page 7.2-14 of version WBNP-1 of the UNIT 1 FSAR.

040 January 13, 2010 Responder: Clark Date: 5/25/10 46. Y Closed Closed EICB RAI EICB RAI FSAR amendment The equation for the calculation of the EICB (Garg)

ML102910008 98 power fraction on page 7.2-14 of Please describe the change to the calculation of the power fraction Refer to revised equations in FSAR amendment 98. Date: 1/13/2010 OI#38 Revision WBNP-96 of the Unit 2 FSAR (see FSAR Section 7.2.1.1.4, page 7.2-13 Version WBNP-96) in Responsibility: TVA is different than the calculation of the sufficient detail to support a review of this system using current power fraction shown at the top of page staff positions. NRC staff will review 7.2-14 of version WBNP-1 of the UNIT 1 FSAR.

1.

(

041 7.5.2 7.5.1 C 2/19/2010 Responder: WEC N Open Open-NRC Review NRC Meeting TVA Letter dated See also Open Item Nos. 226 & 270.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Summary NRC 6/18/10 Please provide the following Westinghouse documents: Items (1) and (2) were docketed by TVA letter dated April 8, Pending Submittal of the Test Due 3/29/11 Meeting Summary (1) WNA-DS-01617-WBT Rev. 1, "PAMS System Requirements 2010. Summary Report due 3/29/11 ML093560019, Item TVA Letter dated Specification" NNC 1/27/11: Issues No. 11 10/5/10 (2) WNA-DS-01667-WBT Rev. 0, "PAMS System Design Item (3) will be addressed by Revision 2 of the Licensing Final Response included in letter with the STP were Specification" Technical Report. Due 12/3/10 dated 12/3/10 discussed in the weekly (3) WNA-CD-00018-GEN Rev. 3, "CGD for QNX version 4.5g" public meetings.

Please provide the following Westinghouse documents or pointers Item (4) will be addressed by Westinghouse developing a Partial Response is included in Westinghouse to:

to where the material was reviewed and approved in the CQ TR or WBN2 Specific Test Plan to compensate for the fact that the letter dated 10/5/10. (1) perfrom STP self SPM: NRC disapproved WNA-PT-00058-GEN during the original The SysRS and SRS incorporate assessment., and (4) WNA-PT-00058-GEN Rev. 0, "Testing Process for Common Q Common Q review. Due 12/7/10 requirements from many other (2) Augment Test Safety systems" documents by reference. Summary report to (5) WNA-TP-00357-GEN Rev. 4, "Element Software Test Item (5) Procedures that are listed in the SPM compliance provide missing test Procedure" table in the Licensing Technical Report revision 1 supersede NNC 8/25/10: (3) An earlier version plan information that test procedure WNA-TP-00357-GEN.Due 10/22/10 of this report was docketed for the Common Q topical report; therefore, NNC 2/3/11: At next For Item 3, Attachment 19 contains the Westinghouse there should be no problem to audit compare &

document Post-Accident Monitoring System (PAMS) docket this version. (4) Per discuss:

Licensing Technical Report, WNA-LI-00058-WBT, Revision ML091560352, the testing process (1) WNA-PT-00058-2, dated December 2010. Attachment 20 contains the document does not address the test GEN Rev. 0 Westinghouse Application for Withholding for the Post- plan requirements of the SPM. (2) WNA-PT-00138-Accident Monitoring System (PAMS) Licensing Technical Please provide a test plan that WBT Rev. 0 Report, WNA-LI-00058-WBT, Revision 2, dated December implements the requirements of the (3) AP1000 STP 2010. SPM.

For Item 4, Attachment 9 contains the Westinghouse document Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Post Accident Monitoring System Test Plan, WNA-PT-00138-WBT, Revision 0, dated November 2010. Attachment 10 contains the Westinghouse Application for Withholding for the WNA-PT-00138-WBT, Revision 0 Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Post Accident Monitoring System Test Plan, WNA-PT-00138-WBT, Revision 0, dated November 17, 2010.

TVA Response to Follow-up NRC Request:

(1) WEC presented the results of the self assessment to the NRC on February 2, 2011.

(2) By agreement between TVA, WEC and the NRC, the Post Accident Monitoring System Test Plan, WNA-PT-00138-WBT, Revision 0 will not be revised. Instead a non-proprietary Common Q PAMS Test Summary Report will be developed and submitted to address the issues with the STP. Attachment 1 contains non-proprietary WNA-TR-02451-WBT, Revision 0, Test Summary Report for the Post Accident Monitoring System, dated March 2011.

042 All All February 25, 2010: Telecom Date: 5/25/10 47. Y Closed Closed EICB RAI TVA Letter dated The drawing provided did not have the EICB (All)

Responder: Clark ML102910002 6/18/10 identification numbers as in the FSAR.

On December 16, 2009: EICB stated to DORL: "I am having Date: 2/25/2010 Item No. 1 trouble reading the drawings in the binder that was given to me. Is Attachment 2 provides a drawing cross reference list for Responsibility: TVA it possible to produce a set of full size drawing that are in the FSAR Chapter 7 and electronic copies of the fully legible FSAR?" current drawings previously submitted in full size hard TVA provided readable drawings.

copies.

On February 23, 2010: EICB received a set of enlarged Chapter 7

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N FSAR pages (drawings) that are still unreadable.

Please provide readable drawings 043 7.5.2 7.5.1 2/19/2010 Responder: WEC 2. N Open Open-NRC Review EICB RAI TVA Letter dated NNC 8/25/10: A CQ PAMS ISG6 EICB (Carte)

Date: 5/25/10 ML102910002 2/5/10 compliance matrix was docketed on: (1)

The PAMS ISG6 compliance matrix supplied as Enclosure 1 to Pending Submittal of Revision 3 of Due 3/29/11 Item No. 2 February, 5 12010, (2) March 12, 2010, TVA letter dated February 5, 2010 is a first draft of the information The PAMS ISG6 compliance matrix supplied as Enclosure 1 the Licensing Technical Report due TVA Letter dated & (3) June 18, 2010. The staff has needed. The shortcomings of the first three lines in the matrix are: to TVA letter dated February 5, 2010 is a first draft of the 3/29/11. NNC 2/2/11: Issues 5/12/10 expressed issued with all of these information needed. with Common Q TR & compliance evaluations. The staff is still Line 1: Section 11 of the Common Q topical report did include a Revised response included in letter SPM compliance were TVA Letter dated waiting for a good compliance commercial grade dedication program, but this program was not By letter dated April 8, 2010 TVA provided the PAMS dated 12/22/10. discussed in the weekly 6/18/10 evaluation.

approved in the associated SE. Westinghouse stated that this was Licensing Technical Report provided additional information. public meetings.

the program and it could now be reviewed. The NRC stated that Response is included in letter dated Westinghouse to TVA Letter dated NNC 11/23/10: WNA-LI-00058-WT-P TVA should identified what they believe was previously reviewed Attachment 3 contains the revised Common Q PAMS ISG-6 10/5/10. perform Common Q TR 10/5/10 Rev. 1 Section 7 does not include the and approved. Compliance Matrix, dated June 11, 2010, that addresses & SPM compliance self RSED documents, and it should. Table these items (Reference 13). Revised compliance matrix is assessment; his will be 6-1 Item No. 15 should also include the Line 2: TVA stated the D3 analysis was not applicable to PAMS, unacceptable. discussed in detail on RSED RTMs.

but provided no justification. The NRC asked for justification since By letter Dated June 18, 2010 (see Attachment 3) TVA the next audit.

SRP Chapter 7.5 identified SRM to SECV-93-087 Item II.Q as provided a table, "Watts Bar 2 - Common Q PAMS ISG-6 NNC 8/12/10: It is not quite enough being SRP acceptance criteria for PAMS. Compliance Matrix." to provide all of the documents requested. There are two possible Line 3: TVA identified that the Design report for computer integrity It is TVAs understanding that this comment is focused on routes to review that the NRC can was completed as part of the common Q topical report. The NRC the fact that there are documents that NRC has requested undertake: (1) follow ISG6, and (2) noted that this report is applicable for a system in a plant, and the that are currently listed as being available for audit at the follow the CQ SPM. The TVA CQ topical report did no specifically address this PAMS system at Westinghouse offices. For those Common Q PAMS response that was originally Watts Bar Unit 2. documents that are TVA deliverable documents from pursued was to follow ISG6, but Westinghouse, TVA has agreed to provide those to NRC. some of the compliance items for NRC then concluded that TVA should go through and provide a Westinghouse documents that are not deliverable to TVA will ISG6 were addressed by more complete and thorough compliance matrix. be available for audit as stated above. Requirements referencing the SPM. The NRC Traceability Matrix issues will be tracked under NRC RAI approved the CQ TR and Matrix Items 142 (Software Requirements Specification) and associated SPM; it may be more 145 (System Design Specification). Commercial Item appropriate to review the WBN2 Dedication issues will be tracked under NRC RAI Matrix PAMS application to for adherence Item 138. This item is considered closed. to the SPM that to ISG6. In either path chosen, the applicant should TVA Response to Follow-up NRC Request: provide documents and a justification for the acceptability of WNA-LI-00058-WT-P, Revision 2, Post-Accident Monitoring any deviation from the path chosen.

System (PAMS) Licensing Technical Report submitted in For example, it appears that the TVA Letter to NRC dated December 3, 2010, (Reference 1) Westinghouse's CDIs are contains the following changes to address the NRC commercial grade dedication plans, requests: but Westinghouse maintains that they are commercial grade (1) While RSEDs are not specifically mentioned, Section 7 dedication reports; this apparent has been revised to be applicable to both hardware and deviation should be justified or software which includes the RSEDs. explained.

(2) Table 6-1 item 15 reference added for WNA-VR-00280-WBT (RESD)

TVA Response to Second Follow-up NRC Request:

The NRC audited the Westinghouse commercial item dedication process for both hardware and software during the week of February 28 to March 4, 2011. The audif found the processes acceptable. Westinghouse and TVA previously agreed to provide additional information to address this item in Revision 3 of the Licensing Technical Report.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Attachment 2 contains WNA-LI-00058-WBT-P, Post-Accident Monitoring System (PAMS) Licensing Technical Report, Revision 3, dated March 2011 (proprietary).

Attachment 3 contains WNA-LI-00058-WBT-NP, Post-Accident Monitoring System (PAMS) Licensing Technical Report, Revision 3 dated March 2011 (non-proprietary).

Attachment 4 contains CWA-11-311, Application for Withholding Proprietary Information from Public Disclosure, WNA-LI-00058-WBT-P, Revision 3 Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Post-Accident Monitoring System (PAMS) Licensing Technical Report, dated March 14, 2011.

044 7.5.2 7.5.1 February 25, 2010 Date: 5/25/10 48. Y Closed Closed EICB RAI TVA Letter dated EICB (Carte)

Responder: Clark ML102910002 6/18/10 The PAMS system described in Section 7.5 of the FSAR is Item No. 3 implemented in various manners. TVA should identify: By letter Dated June 18, 2010 (see Enclosure 1 Item 6) TVA (1) Those variables that are implemented identical to what was provided information requested.

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.

045 February 25, 2010 Date: 5/25/10 49. Y Closed Closed EICB RAI TVA Letter dated EICB (Carte)

Responder: Clark ML102910002 7/30/10 For each system implemented using a digital technology, please Item No. 4 (ML102160349 -

identify any communications between divisions, or between safety- There are no communications between divisions. The See Enclosure 1 related equipment and non-safety-related equipment. Please response includes the description of communications and Item No. 4.)

describe the implementation of the associated communications isolation between the Common Q PAMS, Eagle 21 and RM-isolation. 1000 radiation monitors and non safety systems.

046 February 25, 2010 Date: 5/25/10 50. Y Closed Closed N/A - Request for N/A EICB (Carte)

Responder: Clark help finding The Watts Bar Unit 1 Ser (Section 7.2.1, page 7-3) identifies that information the RTS includes a trip from the "general warning alarm". Please FSAR amendment 98, Section 7.2.2.2, page 7.2-29 second identify where this trip is described in the current FSAR, or what paragraph states:

SSER approved its removal.

"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."

047 7.5.2 7.5.1 4/8/2010 Responder: WEC/Hilmes Date: 5/25/10 51. Y Closed Closed EICB RAI TVA Letter dated EICB (Carte)

ML102910002 7/30/10 The PAMS System Requirements Specification (SysRS) The licensing basis for WBN Unit 2 is Regulatory Guide 1.97 NNC 8/9/10: There are two aspects Item No. 5 (ML102160349 -

references RG 1.97 Rev. 3 where the FSAR References Rev. 2. Revision 2. The Common Q PAMS system was designed to of this issue. The first aspect has See Enclosure 1 Please explain. Regulatory Guide 1.97 Revision 3, which is why the basis for been addressed by the response Item No. 5) the System Requirements Specification references revision dated 7/30/10. The second aspect

3. In order to resolve this discrepancy an engineering is: How could Westinghouse TVA Letter dated evaluation of the Common Q PAMS was performed. Design, and TVA approve a design 10/21/10 to the wrong requirement? Enclosure 1 Item Attachment 2 contains an engineering evaluation of the No. 1 Common Q PAMS design against the requirements of Reg. The revised response was provided Guide 1.97 Rev. 2. The evaluation concluded that the in TVA Letter to the NRC Dated Common Q PAMS meets all requirements of Reg Guide 1.97 10/21/10.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Rev. 2. This evaluation will be added to design criteria WB-DC-30-7, Post Accident Monitoring Instrumentation by October 1, 2010.

TVA Revised Response:

The difference in revisions of Reg. Guide 1.97 was not identified during the contract review process. Therefore Westinghouse designed the system to the Common Q standard design which is revision 3. When the design work was assigned to a new engineer, the difference in revisions was not identified as an issue. When the issue was identified by the NRC, it was entered into the TVA Corrective Action Process as WBPER233598 (Attachment 3) 048 7.5.2 7.5.1 April 8, 2010 Date: 5/25/10 52. Y Closed Closed EICB RAI TVA Letter dated EICB (Carte)

Responder: WEC ML102910002 6/18/10 Reference 16 of the PAMS System Requirements Specification Item No. 6 (SysRS) is the Unit 1 precautions Limitations and Setpoints To ensure technical fidelity with the Unit 1 ICCM-86 system, document. When and how will the transition to the unit 2 document the Unit 1 PLS was used as an input to the Common Q be made? 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.

049 7.5.2 7.5.1 4/8/2010 Responder: WEC Date: 5/25/10 53. Y Closed Closed EICB RAI TVA Letter dated EICB (Carte)

ML102910002 6/18/10 Please provide 00000-ICE-30156 Rev. 6. The PAMS SysRS Per Westinghouse letter WBT-D-2024 (Reference 7), this Item No. 7 incorporates sections of this document by reference. document is available for audit at the Westinghouse TVA Letter dated Rockville office. 10/5/10 This document was submitted on September 2, 2010.

050 7.5.2 7.5.1 4/8/2010 Responder: WEC Date: 5/25/10 54. N Closed Closed EICB RAI TVA Letter dated NNC 11/18/10: SysRS Rev. 2 contains EICB (Carte)

ML102910002 6/18/10 several Reference 8, however, How should the "shall" statements outside of the bracketed These sections are descriptive text and not requirements. Revised response included in letter Due12/22/10 Item No. 8 Reference 8 has been deleted.

requirements in Common Q requirements documents be The next revision of the Watts Bar Unit 2 PAMS System dated 12/22/10. Discuss at 11/22 phone TVA Letter dated interpreted? Requirements Specification will remove shall from the call. 10/29/10 wording in those sections. A date for completing the next Enclosure 1 Item revision of the System Requirements Specification will be TVA response is inconsistent (e.g., This will be corrected in No. 1 provided no later than August 31, 2010. WNA-DS-01667-WBT Rev. 1 page the Revision 3 1-1, Section 1.3.1 implies that document due to TVA The System Requirements Specification will be revised by "SysRS Section ###" has 12/10/10 September 30, 2010 and submitted within two of receipt from requirements. See also Westinghouse. SDS4.4.2.1-1 on page 4-32). NNC 2/3/11: The docketed material (to TVA Revised Response Is there a requirement on the shall date) still has a few referenced above?? unitended shalls in it

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Shall statements within the scope of the System which can be Requirements Specification (SysRS) and System Design Response is provided in letter dated addressed as an open Specification (SysDS) were reviewed by Westinghouse. The 10/29/10. item in the SE.

statements were either relocated to the numbered requirements section or the wording was changed to identify TVA Revised Response in TVA that it was not a requirement. This item is resolved by Letter dated 10/29/10 Enclosure 1 submittal of revision 2 of the SysRS and the SysDS Item No. 1 is Acceptable (attachments 7 and 8 of TVA Letter to NRC dated 10/25/10).

NNC 11/18/10: Revised Response TVA Response to Follow-up NRC Request: is not a statement of fact. SysRS Rev. 2 (i.e., WNA-DS-01617-WBT This item is corrected in the revision 3 requirements Rev. 2) contains many shalls that documents. are not within numbered requirements sections, for example:

Attachment 1 contains the proprietary version of WNA-DS- (1) Page 2-1, Section 2.3.1 - See 01617-WBT-P, Revision 3, Post Accident Monitoring guidance statement System- System Requirements Specification, dated (2) Page 2-10, top of page 1 - See November 2010. Attachment 2 contains the non-proprietary guidance statement version WNA-DS-01617-WBT-NP, Revision 3, Post Accident Monitoring System - System Requirements Specification, dated December 2010. Attachment 3 contains the Application for Withholding Proprietary Information from Public Disclosure, WNA-DS-01617-WBT-P, Revision 3, Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Post Accident Monitoring System - System Requirements Specification (Proprietary),

dated December 6, 2010.

Attachment 4 contains the proprietary version of WNA-DS-01667-WBT-P, Revision 3, Post Accident Monitoring System - System Design Specification, dated November 2010. Attachment 5 contains the non-proprietary version WNA-DS-01667-WBT-NP, Revision 3, Post Accident Monitoring System - System Design Specification, dated December 2010. Attachment 6 contains the Application for Withholding Proprietary Information from Public Disclosure, WNA-DS-01667-WBT-P, Revision 3, Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects Post Accident Monitoring System - System Design Specification (Proprietary), dated December 6, 2010.

Attachment 7 contains the proprietary version of WNA-SD-00239-WBT-P, Revision 3, Software Requirements Specification for the Post Accident Monitoring System, dated November 2010. Attachment 8 contains the non-proprietary version WWNA-SD-00239-WBT-NP, Revision 3, Software Requirements Specification for the Post Accident Monitoring System, dated December 2010. Attachment 9 contains the Application for Withholding Proprietary Information from Public Disclosure, WNA-SD-00239-WBT-P, Revision 3, Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Software Requirements Specification for the Post Accident Monitoring System (Proprietary), dated December 8, 2010.

051 April 15, 2010 Date: 5/25/10 55. Y Closed Closed N/A N/A Review addressed by another Open EICB Responder: Craig/Webb Item, (Garg)

NRC staff has issued RIS 2006-17, to provide guidance to the Date: 4/15/2010 This item is closed as it industry regarding the instrument setpoint methodology which This item is addressed as follows: Responsibility: TVA will be reviewed under

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N complies with 10CFR50.36 requirements. The staff has requested item 154. FSAR AMD all the licensees for the existing license to demonstrate how they 1. FSAR Amendment 100 which was submitted on TVA letter This item is to be worked with item 100 meet the guidance provided in this RIS. The staff consider WBN 2 to the NRC dated August __, 2010 incorporates as-found 108.

as a license amendment for all the setpoints in the TS. Provide the and as-left setpoint tolerance discussion into section information on how WBN 2's setpoint methodology meets the 7.1.2.1.9, adds EEB-TI-28, Setpoint Methodology to the guidance of RIS 2006 -17. You may also consider the guidance section 7.1 references and adds a reference to 7.1.2.1.9 to provided in TSTF - 493, rev.4 as a basis for meeting the RIS 2006 - section 7.2.1.1.10.

17 guidance.

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.

052 7.5.2 7.5.1 April 19, 2010 Date: 5/25/10 56. Y Closed Closed RAI No. 12 EICB (Singh)

Responder: Slifer ML102980005 Please identify the systems that will use the RM-1000 radiation Date: 4/19/2010 10/26/2010 monitors. As identified in TVA letter dated March 12, 2010, Enclosure Responsibility: NRC 1, item 3 the RM-1000 radiation monitors are used for the Containment High Range Post Accident Monitors.

053 7.5.2 7.5.1 April 19, 2010 Date: 5/25/10 57. Y Closed Closed RAI No. 13 EICB (Singh)

Responder: Slifer ML102980005 Please identify all FSAR sections that apply to the RM-1000. Date: 4/19/2010 10/26/2010 The containment high range post accident radiation monitors Responsibility: NRC are discussed in FSAR amendment 98 sections 7.5 and 12.3.

054 7.5.2 7.5.1 4/19/2010 Responder: Slifer/Clark Date: 5/25/10 58. Y Closed Closed RAI No. 14 TVA Letter dated EICB (Singh)

-Response acceptable ML102980005 6/18/10 Please describe all the different environments in which the RM- The only safety-related application for the RM-1000 is the Revised response is included in 10/26/2010 1000 will be required to operate. Please group these environments Containment High Range radiation monitors. The letter dated 10/29/10.(TVA to TVA Letter dated into two categories (a) Harsh environment, per 10 CFR 50.49, and Containment High Range radiation monitors will be installed confirm) Design Criteria is WB-DC- Due 10/14/10 10/29/10 (b) Mild Environment. in the Main Control Room, a mild environment. The 40-54 is attached to this letter. Enclosure 1 Item detectors will be installed remotely in the containment. Identify source of No. 2 reference 3.

For WBN Unit 2, a mild environment is defined as:

TVA to identify when A defined room or building zone where (1) the temperature, and by what letter pressure, or relative humidity resulting from the direct effects number WB-DC-40-54 of a design basis event (DBE) (e.g., temperature rise due to was submitted to NRC.

steam release) are no more severe than those which would If not previously occur during an abnormal plant operational condition, (2) the submitted then please temperature will not exceed 130°F due to the indirect effects submit this document.

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).

What is Reference 3?

TVA Revised Response:

Reference 3 is TVA Design Criteria WB-DC-40-54, Environmental Qualification To 10CFR50.49, which provides the definition of mild and harsh environments. Attachment 13 to TVA letter dated October 29, 2010 contains WB-DC-40-54, Revision 4.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 055 7.5.2 7.5.1 4/19/2010 Responder: Slifer/Clark Date: 5/25/10 59. Y Closed Closed RAI No. 15 TVA Letter dated EICB (Singh)

-Response acceptable ML102980005 6/18/10 The "Qualification Test Report Supplement, RM-1000 Upgrades," The detectors for these loops will be located in a harsh Revised response is included in 10/26/2010 Document No. 04508905-1SP Rev. A states that the qualification environment (inside containment). The RM-1000 will be letter dated 10/29/10. (TVA to Due 10/14/10 10/14/10 was done in accordance with IEEE 323-1974 and -1983. Please located in the main control room, which is a mild confirm) Design Criteria is WB-DC-describe and justify all differences in this qualification methodology environment. The RM-1000 and associated I/F converters 40-54 is attached to this letter. Identify source of TVA Letter dated and that endorsed by Regulatory Guide 1.209. Specifically have been tested to the requirements present in IEEE Std. reference 3. 10/29/10 address EMI and RFI 323-1983 and -1974, as well as the System Requirements Enclosure 1 Item including EPRI TR 102323 (Sept. 94) in the design basis. No. 3 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)

What is Reference 3?

TVA Revised Response:

Reference 3 is TVA Design Criteria WB-DC-40-54, Environmental Qualification To 10CFR50.49, which provides the definition of mild and harsh environments. Attachment 13 to TVA letter dated October 29, 2010 contains WB-DC-40-54, Revision 4.

056 April 19, 2010 Date: 5/25/10 60. Y Closed Closed RAI No. 16 TVA Letter dated Sorrento Radiation Monitoring EICB (Singh)

Responder: Slifer ML102980005 6/18/10 The "RM-1000 Version 1.2 Software Verification and Validation Date: 4/19/2010 10/26/2010 Report," Document No. 04508006 Rev. A, is an incremental report. The initial draft Software Verification and Validation (V&V) Responsibility: NRC That is to say it addresses the verification an validation for changes report document, version 1.0, was never issued.

that resulted in Version 1.2; therefore, the NRC has not received a TVA provided the requested software verification and validation report for all other aspects of Attachment 4 contains the latest complete proprietary Software V&V Report.

the software. Please provide the last complete verification and version 1.1 Software V&V report (04508005). The non-validation report, and all incremental reports after the complete proprietary version and withholding affidavit will be submitted report. 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

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N June 30, 2010.

057 7.5.2 7.5.1 4/19/2010 Responder: TVA I&C Staff Date: 5/25/10 61. Y Closed Closed RAI No. 17 TVA Letter dated EICB (Singh)

ML102980005 6/18/10 Please describe the ability to change the software of the RM-1000 Firmware/software changes are done by connecting a laptop Response is included in letter dated Closed by 10/5/2010 10/26/2010 at site, including all required equipment and administrative controls to a port on the front of the RM-1000 and placing the 10/5/10. TVA letter (Item 11 of TVA Letter dated (e.g., temporary digital connections). Operate/Calibrate switch in the Calibrate position. The first letter). 10/5/10 physical barrier to access is the location of the RM-1000 in the main control room which has limited access. The RM- Requested information provided.

1000 Operate/Calibrate switch is located behind the hinged NRC to review. Further Information front panel. The front panel must be opened (held closed by Requested: Please confirm that the two thumbscrews) to access the switch. This provides a laptop is secure and access to this physical barrier to inadvertent switch operation. The system laptop is commensurate with the malfunction alarm is visible locally and will annunciate on the access to the equipment for which it control board when the switch is in the Calibrate position. will be used. Is the laptop dedicated for calibration of radiation Administrative control of software/firmware updates is in monitors? If the laptop is used for accordance with TVA Standard Specification SS-E18.15.01, more than one application then Software Requirements for Real-Time Data Acquisition and please describe the equipment for Control Computer Systems, and TVA procedures SPP-9.3, which the laptop may be used. In Plant Modifications and Engineering Change Control, and addition please explain how SPP-2.6, Computer Software Control. Approved changes to software security is assured and software/firmware are implemented utilizing the TVA work that only the software intended for order process. the specific application is used. Is the connection to the radiation (1) A laptop is not used to calibrate the monitor. All TVA in- monitors made via a special house activities (calibration, alarm setpoint adjustment, etc.) cable/connectors? Please confirm are performed using the touchpad on the monitor. An that the RS-232 communication port external computer (laptop etc.) is only used to perform of the radiation monitors will only be software or firmware updates. TVA does not perform used for calibration purposes. Also software or firmware updates using in-house resources please confirm that the radiation therefore no TVA computer is ever connected to the monitor. monitor will not be in operation If software or firmware updates are required, they are during the calibration mode. In approved via the TVA design change process previously addition please confirm that described and implemented by a vendor representative password protection is provided for under the TVA work order and Quality Assurance processes. logging on to the laptop prior to start (2) A laptop is not used to calibrate the monitor. of calibration.

(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.

(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.

058 7.5.0 7.5 April 19, 2010 Date: 5/25/10 62. Y Closed Closed RAI No. 18 TVA Letter dated EICB (Singh)

Responder: Slifer ML102980005 6/18/10 Please describe all digital communications used in the installed Date: 4/19/2010 10/26/2010 configuration. There are no digital communications between the RM-1000 Responsibility: NRC ML101940236, and any other plant system or component. Encl 1, Item 13 Requested information provided.

NRC to review.

059 7.5.2 7.5.1 CB (Si April 19, 2010 Date: 63. Y Closed Closed RAI No. 19 TVA Letter dated ng Responder: Slifer ML102980005 6/18/10

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Previously TVA provided the "RM-1000 Digital Radiation Processor Date: 4/19/2010 10/26/2010 Technical Manual," Document No. 04508100-1TM Revision C (a) The technical manual is applicable to versions 1.1 and Responsibility: NRC dated October 2003. The "RM-1000 Version 1.2 Software 1.2 of the software.

Verification and Validation Report," Document No. 04508006 Rev. Requested information provided.

A is dated April 2008. (a) What software version does the technical (b) Version 1.2 was implemented April 1, 2008 NRC to review.

manual address? (b) When was Version 1.2 implemented?

060 7.5.2 7.5.1 April 19, 2010 Date: 5/25/10 64. Y Closed Closed N/A N/A Addressed by Open Item No. 47 EICB Responder: Clark (Carte) The PAMS System Requirements Specification (SysRS) references RG 1.97 Rev. 3 where the FSAR References Rev. 2. Duplicate of Item 47 Please explain.

061 7.5.2 7.5.1 April 19, 2010 Date: 5/25/10 65. Y Closed Closed N/A N/A Addressed by Open Item No. 48 EICB (Carte)

Responder: Clark Reference 16 of the PAMS System Requirements Specification (SysRS) is the Unit 1 precautions Limitations and Setpoints Duplicate of Item 48.

document. When and how will the transition to the unit 2 document be made.

062 7.5.2 7.5.1 April 19, 2010 Date: 5/25/10 66. Y Closed Closed N/A N/A Addressed by Open Item No. 49 EICB Responder: Clark (Carte) Please provide 00000-ICE-30156 Rev. 6. The PAMS SysRS incorporates sections of this document by reference. Duplicate of Item 49 063 7.5.2 7.5.1 April 19, 2010 Date: 5/25/10 67. Y Closed Closed N/A N/A Addressed by Open Item No. 50 EICB Responder: Clark (Carte) How should the "shall" statements outside of the bracketed requirements be interpreted? Duplicate of Item 50 064 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: Webb Date: 4/8/2010 68. Y Closed Closed N/A - No question TVA Letter dated EICB (Carte) date for the D3 Analysis was April 2, 2010. was asked. Item 10/5/10 The WBN2 Common Q PAMS provides redundant signal was opened to track processing and indication of two RG-1.97 Type A variables: commitment made Core-Exit Temperature (CET) and Subcooled Margin. In the by applicant.

event of a common-cause failure of the Common Q PAMS, instrumentation diverse from Common Q is available for these two variables. Wide Range (WR) Hot Leg Temperature indication is specified as a diverse variable for CET in the Post-Accident Monitoring Design Criteria, WB-DC-30-7 (Attachment ). WR Hot Leg Temperature indication from all four hot legs is available on control board indicators and plant computer displays.

Temperature and pressure saturation margin calculations are also performed in the plant computer independently of Common Q utilizing different hardware and software.

Isolated outputs from the Eagle 21 protection system are provided to the plant computer for four WR Hot Leg Temperature channels and four WR RCS Pressure channels. The temperature channels and two of the pressure channels are the same as those used in the Common Q saturation margin calculations.

The plant computer temperature saturation margin is calculated as the difference in the maximum temperature input and the saturation temperature of the minimum pressure input. The temperature saturation margin is displayed as point ID U0987.

The plant computer pressure saturation margin is calculated

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N as the difference in the minimum pressure input and the saturation pressure of the maximum temperature input. The pressure saturation margin is displayed as point ID U0984.

Reactor Vessel Level Indication (RVLIS) is defined as a Type B1 variable. Redundant indication for this variable is provided by the core exit thermocouples/Thot and reactor coolant system (RCS) pressure. So long as the RCS pressure is greater than the saturation pressure for the temperature indicated by the core exit thermocouples/Thot, there is reasonable assurance that a steam void has not formed in the core and the vessel is full. This is indicated by the subcooled margin monitor/plant computer previously discussed.

065 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 69. Y Closed Closed N/A - No question TVA Letter dated EICB (Carte) date for the FMEA was August 31, 2010. was asked. Item 10/5/10 Attachment 37 to letter dated 10/5/10 contains the was opened to track proprietary version of the Common Q PAMS FMEA and the commitment made affidavit for withholding. A non-proprietary version will be by applicant.

provided at a later date.

066 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 70. Y Closed Closed N/A - No question TVA Letter dated EICB (Carte) date for the "Watts Bar 2 PAMS Software Design Description (two was asked. Item 6/18/10 documents, one for flat panel display and one for AC160)" was Per Westinghouse letter WBT-D-1961 (Reference 8), these was opened to track March 31, 2010. items are available for audit at the Westinghouse Rockville comm8ittment TVA Letter dated office. made by applicant. 8/20/10

• WNA-SD-00250-WBT Rev. 0 (AC160) was submitted on TVA Letter dated TVA letter to the NRC dated August 20, 2010 (Reference 7). 9/2/10

• WNA-SD-00248-WBT, Rev. 0 (FPDS) was submitted on TVA letter to the NRC dated SEPT 2, 2010 (Reference 8). TVA Letter dated 10/5/10 067 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 3. N Open Open-NRC Review N/A - No question TVA Letter dated EICB (Carte) date for the "Commercial Grade Dedication Instructions for AI687, Due: 3/29/11 was asked. Item 6/18/10 AI688, Upgraded PC node box and flat panels." was September The following status is from the revised WB2 Common Q Pending Submittal of Revision 3 of was opened to track 28, 2010. PAMS ISG-6 Compliance Matrix submitted in response to the Licensing Technical Report due comm8ittment Item 43: 3/29/11. NNC 2/2/11: Section 7 made by applicant.

of the WBN2 PAMS

a. AI687, AI688 - Scheduled for September 28, 2010 Response included in letter dated LTR should be updated 12/22/10. to include:

b. Upgraded PC node box and flat panel displays - Per (1) non-proprietary Westinghouse letter WBT-D-2024 (Reference 7), these items This item is addressed in Rev. 2 of description of are available for audit at the Westinghouse Rockville office. the Licensing Technical Report commercial grade dedication, and

c. Power supplies - Per Westinghouse letter WBT-D-2035 (2) Software example (Reference 12), these items are available for audit at the Westinghouse Rockville office. Commercial grade dedication will also be To be addressed during 9/20-9/21 audit addressed at the next audit.

TVA Response to Follow-up NRC Request:

WNA-LI-00058-WT-P, Revision 2, Post-Accident Monitoring System (PAMS) Licensing Technical Report submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1) contains the following change to address the NRC request:

Section 7, Commercial Grade Dedication Process, has

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N been revised to describe the general commercial grade dedication process for both hardware and software and uses a description of the AI687 dedication process as an example of how the process is applied.

TVA Response to Follow-up NRC Request dated 2/2/11:

The non-proprietary commercial grade dedication discussion is included in Attachment 3, WNA-LI-00058-WBT-NP, Post-Accident Monitoring System (PAMS) Licensing Technical Report, Revision 3 dated March 2011 (non-proprietary)

Section 7. The software example is included in Attachment 2, WNA-LI-00058-WBT-P, Post-Accident Monitoring System (PAMS) Licensing Technical Report, Revision 3, dated March 2011 (proprietary) Section 7.

068 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 4. N Open Open-NRC Review N/A - No question TVA Letter dated EICB (Carte) date for the "Summary Report on acceptance of AI687, AI688, was asked. Item 6/18/10 Upgraded PC node box, flat panels, and power supplies." was The following status is from the revised WB2 Common Q Response included in letter dated NNC 2/2/11: was opened to track September 28, 2010. PAMS ISG-6 Compliance Matrix submitted in response to 12/22/10. Commercial grade comm8ittment Item 43: dedication will be made by applicant.

addressed at the next

a. AI687, AI688 - Scheduled for September 28, 2010 This item is addressed in Rev. 2 of audit. Summary the Licensing Technical Report reports for AI687 &

b. Upgraded PC node box - Per Westinghouse letter WBT- AI688 were docketed D-2024 (Reference 7), this item is available for audit at the one month late.

Westinghouse Rockville office.

c. Flat panel displays - Per Westinghouse letter WBT-D-2024 (Reference 7), this item is available for audit at the Westinghouse Rockville office.

d. Power supplies - Per Westinghouse letter WBT-D-2035 (Reference 12), these items are available for audit at the Westinghouse Rockville office.

To be addressed during 9/20-9/21 audit TVA Response to Follow-up NRC Request:

For the commercial grade dedication process, please see the response to Request for Additional Information (RAI) item 3 in this letter, NRC Matrix Item 067.

The component level EQ/Seismic summary reports for the hardware listed above are available for NRC review/audit as described below:

(1) AI687 and AI688, the following documents were submitted in TVA Letter to NRC dated October 26, 2010, Watts Bar Nuclear Plant (WBN) Unit 2 -

Instrumentation and Controls Staff Information Requests, (Reference 5):

a. EQ-EV-62-WBT, Revision 0, Common Q PAMS Comparison of Tested Conditions for the AI687 and AI688 Common Q Modules and Supporting Components to the Watts Bar Unit 2 (WBT)

Requirements, dated September 10, 2010

b. EQLR-171, Revision 0, Environmental and

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Seismic Test Report, Analog Input (AI)687 &

AI688 Modules for use in Common Q PAMS, dated September 10, 2010

c. CN-EQT-10-44, Revision 0, Dynamic Similarity Analysis for the Watts Bar Unit 2 Post Accident Monitoring System (PAMS), dated September 28, 2010 (2) Upgraded PC Node Box - As stated in Westinghouse letter WBT-D-2024, dated June 9, 2010 NRC Access to Common Q Documents at the Westinghouse Rockville Office, (Reference 6), the following documents are available for NRC audit at the Westinghouse Rockville office:

a. CDI-3722, Revision 7, Next Generation PC Node Box Commercial Dedication Instruction

b. LTR-EQ-10-50 PC Node Box/Flat Panel Display System Components Qualification Summary (3) Flat Panel Displays - As stated in Westinghouse letter WBT-D-2024, dated June 9, 2010 NRC Access to Common Q Documents at the Westinghouse Rockville Office, (Reference 6), the following documents are available for NRC audit at the Westinghouse Rockville office:

a. CDI-3803, Revision 8, Next Generation Flat Panel Display (FPD) Commercial Dedication Instruction

b. LTR-EQ-10-50 PC Node Box/Flat Panel Display System Components Qualification Summary (4) Power supplies - As stated in Westinghouse letter WBT-D-2035 dated June 11, 2010 NRC Access to Common Q Documents at the Westinghouse Rockville Office (Reference 7), the following documents are available for NRC audit at the Westinghouse Rockville office:

a. CDI- 4057, Revision 4, Commercial Dedication Instruction

b. EQ-TP-1 05-GEN, Revision 0, Electromagnetic Compatibility Test Plan and Procedure for Quint Power Supplies and Safety System Line Filter

c. Breakers, EQ-TP-114-GEN, Revision 0, Seismic Qualification Test Procedure For Common Q Power Supplies, Quint Power Supplies, Line Filter Assemblies, and South Texas Units 3 & 4 Circuit

d. EQ-TP-117-GEN, Revision 0, Environmental Qualification Test Procedure For Common Q Powe Supplies, Quint Power Supplies, and Line Filter Assemblies 069 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 5. N Open Open-NRC Review N/A - No question N/A EICB (Carte) date for the "Watts Bar 2 PAMS Specific FAT Report" was October Due 3/29/11 was asked. Item 2010. Attachment 1 contains non-proprietary WNA-TR-02451- Pending Submittal of the Test was opened to track WBT, Revision 0, Test Summary Report for the Post Summary Report due 3/29/11 NNC 2/3/11: The comm8ittment As agreed, the Watts Bar 2 PAMS Specific FAT Report will not be Accident Monitoring System, dated March 2011. current due dated made by applicant.

submitted. Instead a non-proprietary PAMS Test Summary Report Awaiting for document to be above is 4 months will be submitted. docketed by TVA. later than planned.

070 7.5.2 7.5.1 CB (C By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 71. N Closed Closed N/A - No question TVA Letter dated NNC 11/23/10: The dues date in this art date for the "Concept and Definition Phase V&V Report" was was asked. Item 6/18/10 open item does not agree with the due

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N March 31, 2010. Per Westinghouse letter WBT-D-1961, this document is Final Response included in letter Due 12/17/10 was opened to track dated in Open Item No. 71.

available for audit at the Westinghouse Rockville office. dated 12/3/10 comm8ittment TVA Letter dated NNC 2/3/11: SVVR made by applicant. 8/20/10 WNA-VR- 00283-WBT, Rev 0 was submitted on TVA letter Partial Response is included in (WNA-VR-00283-WBT) to the NRC dated August 20, 2010. letter dated 10/5/10. Rev. 0 (dated March TVA Letter dated 2010) was docketed by 10/5/10 The submitted V&V did not address the Requirements Regulations require that the NRC TVA letter dated Traceability Matrix and did not summarize anomalies. At the review be based on docketed 8/20/10, but was not September 15th public meeting, Westinghouse agreed to material. Awaiting for document to complete. SVVR Rev.

include the Concept and Definitions Phase Requirements be docketed by TVA. 1 (dated November Traceability Matrix (RTM) in the next IV&V report along with 2010) was docketed by partial Design Phase updates to the RTM. NNC 8/25/10: Requirements Phase TVA letter dated SVVR provided by TVA letter dated 12/3/2010, this is a TVA Revised Response: 8/20/10. delay of more than 8 TVA submitted WNA-VR- 00283-WBT, Rev 0 to NRC in months.

letter dated August 20, 2010 NNC 11/23/10: The requirements (Reference 6). Phase SVVR provided by TVA on The next Independent Verification and Validation (IV&V) 8/20/10, is not complete. This report will include the Design report should address the RTM, Phase Requirements Traceability Matrix. The Design Phase which it did not. TVA/WEC agreed IV&V Report will be submitted to address the concept phase RTM to NRC by February 11, 2011. in the next revision.

Attachment 14contains the Westinghouse document Nuclear Automation Watts Bar Unit 2 NSSS Completion Program I&C Projects, IV&V Summary Report for the Post Accident Monitoring System, WNA-VR-00283-WBT, Revision 1, dated November 2010. Attachment 15 contains the Westinghouse Application for Withholding for the WNA-VR-00283-WBT, Revision 1, Nuclear Automation Watts Bar Unit 2 NSSS Completion Program I&C Projects, IV&V Summary Report for the Post Accident Monitoring System, dated November 8, 2010.

NOTE: Due to document sequencing, this IV&V Phase Summary Report references a previous version of the contract compliance matrix. Refer to the Licensing Technical Report Revision 2 (Attachment

19) for the current contract compliance matrix.

071 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 72. N Closed Closed N/A - No question N/A NNC 11/23/10: The dues date in this EICB (Carte) date for Revision 2 of the I V&V Report" covering the Design and was asked. Item open item does not agree with the due Implementation phases was July 30, 2010. Attachment 16 contains the Westinghouse document IV&V Response included in letter dated NNC 1/27/11: Issues was opened to track dated in Open Item No. 70.

Summary Report for the Post Accident Monitoring System, 12/3/10 with the SVVR were commitment made WNA-VR-00283-WBT, Revision 2, dated November 2010. discussed in the weekly by applicant.

Attachment 17 contains the Westinghouse Application for Awaiting for document to be public meetings.

withholding for the IV&V Summary Report for the Post docketed by TVA. Westinghouse to Accident Monitoring System, WNA-VR-00283-WBT, perfrom SVVR self Revision 2, dated November 2010. assessment.

NOTE: Due to document sequencing, this IV&V Phase NNC 2/3/11: SVVR Summary Report references a previous version of Rev. 2 was docketed by the contract compliance matrix. Refer to the TVA latter dated Licensing Technical Report Revision 2 (Attachment 12/3/10; this is 4

19) for the current contract compliance matrix. months later than planned.

072 7.5.2 7.5.1 EICB By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 73. Y Closed Closed N/A - No question N/A (Carte date for the "Implementation Phase V&V Report" was September to item 71. Per WEC, was asked. Item

)

30, 2010. Awaiting for document to be the design and was opened to track

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N docketed by TVA. implementation phase commitment made IV&V reports are by applicant.

combined.

073 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 74. N Closed Closed N/A - No question N/A EICB (Carte) date for Revision 3 of the IV&V Report covering the Integration was asked. Item phase was October 29, 2010. WNA-VR-00283-WBT, Revision 3, IV&V Summary Report Response included in letter dated NNC 1/27/11: Issues was opened to track for the Post Accident Monitoring System, covers the 12/22/10 with the SVVR were commitment made Integration phase. Attachment 10 contains the proprietary discussed in the weekly by applicant.

version of IV&V Summary Report for the Post Accident Awaiting for document to be public meetings.

Monitoring System, WNA-VR-00283-WBT-P, Revision 3, docketed by TVA. Westinghouse to dated December 2010. Attachment 11 contains the non- perfrom SVVR self proprietary version IV&V Summary Report for the Post assessment.

Accident Monitoring System, WNA-VR-00283-WBT-NP, Revision 3, dated December 2010. Attachment 12 contains NNC 2/3/11: SVVR the Application For Withholding Proprietary Information From Rev. 3 was docketed by Public Disclosure WNA-VR-00283-WBT, Revision 3, TVA latter dated Nuclear Automation Watts Bar 2 NSSS Completion 12/22/10; this is 2 Program I&C Projects, IV &V Summary Report for the Post months later than Accident Monitoring System (Proprietary), dated December planned.

10, 2010.

074 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 6. N Open Open-NRC Review N/A - No question N/A Rev. 4 will be available for the NRC EICB (Carte) date for the Post FAT IV&V Phase Summary Report was was asked. Item audit on 2/28/11. This document will not November 30, 2010. Attachment 1 contains WNA-VR-00283-WBT-P, IV&V Response in letter dated March 16, Due TBD was opened to track be submitted. Rev. 5 will be submitted Summary Report for the Post Accident Monitoring System, 2011 commitment made after resolution of the datastorm display Revision 4, dated March 2011 (proprietary). Attachment 2 NNC 2/3/11: At least 3 by applicant. issue.

contains WNA-VR-00283-WBT-NP, IV&V Summary Report months later than for the Post Accident Monitoring System, Revision 4, dated planned.

March 2011 (non-proprietary). Attachment 3 contains CWA-11-3121, Application for Withholding Proprietary Information from Public Disclosure, WNA-VR-00283-WBT-P, Revision 4 Nuclear Automation IV&V Summary Report for the Post Accident Monitoring System" (Proprietary), dated March 3, 2011.

075 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 75. N Closed Closed N/A - No question N/A EICB (Carte) date for the "Watts Bar 2 PAMS Specific FAT Procedure" was was asked. Item September 30, 2010. Attachment 12 contains the Westinghouse document Response included in letter dated NNC 2/3/11: FATP was opened to track Nuclear Automation Watts Bar Unit 2 NSSS Completion 12/3/10 docketed as commitment made Program I&C Projects, Post Accident Monitoring System Attachment 12 to TVA by applicant.

Channel Integration Test/Factory Acceptance Test, WNA- Awaiting for document to be letter dated December TP-02988-WBT, Revision 0, dated November 2010. docketed by TVA. 3, 2010; this is a delay Attachment 13 contains the Westinghouse Application for of more than 2 Withholding for WNA-TP-02988-WBT, Revision 0,Nuclear months.

Automation Watts Bar Unit 2 NSSS Completion Program I&C Projects, Post Accident Monitoring System Channel Integration Test/Factory Acceptance Test, dated November 2010.

076 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: Clark Date: 5/25/10 76. Y Closed Closed N/A - No question N/A EICB date for the "Watts Bar 2 PAMS Specific Processor Module was asked. Item (Carte) Software Test" was August 31, 2010. Verify schedule dates for the next submittal of this matrix Awaiting for document to be to OI 71 and 41(4) was opened to track against update WEC schedule. docketed by TVA. commitment made by applicant.

077 7.5.2 7.5.1 By letter dated March 12, 2010 TVA stated that the target submittal Responder: WEC Date: 5/25/10 77. Y Closed Closed N/A - No question TVA Letter dated EICB date for seven other documents was "TDB". Please provide a was asked. Item 6/18/10 (Carte) schedule for the docketing of the remaining documents. The availability dates for these documents are included in Open was opened to track the revised WBN2 Common Q ISG-6 Compliance Matrix commitment made 10/22/10 submitted in response to item 43. As stated in the March 12, Regulations require that the NRC by applicant.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 2010 letter (Reference 4), the dates in the matrix are the review be based on docketed dates the documents will be available to TVA to prepare for material. Awaiting for document to submittal or being Available for Audit. They do not reflect be docketed by TVA.

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.

The Licensing Technical Report now includes a SPM compliance matrix. Submit a revised response.

078 4/26/2010 Responder: Clark Date: 5/25/10 78. Y Closed Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 10/5/10 FSAR Section 7.1.2.1.8 adds a reference 6 to the FSAR. (Q1) The cross reference information is corrected in FSAR Response provided in letter dated to OI323 OI# 18 However, Reference 6 is for instrument setpoint and has nothing to Amendment 100 submitted to the NRC on TVA letter to the 10/5/10 do with the diversity discussion on the FSAR Section. We believe NRC dated August __, 2010 (Reference 2). FSAR AMD 100 SSER the TVA wants to add reference 7 which is the diversity document, 13 for unit 1 references WCAP 13869, "Reactor Protection System Diversity in (Q2) WCAP-13869 revision 1 was previously reviewed under Awaiting TVA response. rev. 1 of WCAP 13869.

Westinghouse Pressurized Water Reactors." Please confirm this WBN Unit 1 SER SSER 13 (Reference 8). Unit 2 references Rev. 2 is used for Unit and add commitment to revise FSAR to correct the reference. (Q1) revision 2. A review to identify the differences and justify 2. Identify all the Also, confirm whether this WCAP has been reviewed by NRC, if their acceptability will be performed by September 30, 2010 differences between yes, provide reference and if not, then submit the WCAP to NRC. and submitted to the NRC no later than November 15, 2010. Rev.1 and Rev.2 and (Q2) Also provide the justification for this reference to WBN2. (Q3) justify their (Q3) Westinghouse confirmed the applicability of this WCAP acceptability.

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).

079 4/26/2010 Responder: Clark Date: 5/25/10 79. Y Closed Closed EICB RAI TVA Letter dated Reviewed under Item 154 EICB (Garg)

ML102910008 10/5/10 FSAR Section 7.1.2.1.9, Trip Setpoints, adds reference to 3, 4, and (Q1) WBN Unit 2 is licensed based on WBN Unit 1. The Response provided in letter dated This item is closed as it OI#19

5. However, reference 3 was deleted by FSAR amendment 81. WBN Unit 1 licensing basis is ISA-DS-67.04-1982. 10/5/10 will be reviewed under Reference 4 has been changed to ISA-DS-67.04-1982. Justify Therefore this methodology is used for the same SSDs for item 154. FSAR AMD applicability of this standard for WBN 2.(Q1) Why the latest ISA WBN Unit 2. This maintains consistency in the licensing 100 standard endorsed by NRC has not been used? (Q2) Also bases for both units.

reference 5 is a topical report for Eagle 21, system. Please confirm that this topical report also discusses the setpoint for Eagle 21 (Q2) Please refer to the response to Q1.

system and whether it meets the recent guidance for the setpoint issued by the staff. (Q3) Also, W setpoint methodology do not (Q3) FSAR Reference 4 is the Eagle 21 Topical Report.

provide discussion on the AS Found Tolerance and As left value FSAR Reference 5, WCAP-17044, Westinghouse Setpoint determination and how these values are used for the instrument Methodology for Protection Systems Watts Bar Unit 2 operability, therefore, add the discussion of these topics in the submitted under TVA letter to the NRC dated February 12, FSAR. (Q4) and add reference to other documents if it is discussed 2010 (Reference 11) discusses the setpoint methodology in some other document. (Q5) Provide this document to the staff used for Eagle 21 loops.

for review and approval. (Q6)

(Q4) (Q4) FSAR Amendment 100 which was submitted on TVA letter to the NRC dated September 1, 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

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N TVA letter to the NRC dated May 13, 2010 (Reference 12).

080 4/26/2010 Responder: WEC 80. Y Closed Closed RAI No. 2 TVA Letter dated EICB ML102980005 7/30/10 (Singh) FSAR Table 7.1-1, Note 12 has been added to the table but it's A revised note was included in the 7/30 letter along with NRC review complete. 10/26/2010 ML102160349, justification has not been provided to the staff for review and justification for the note. Item 6 approval.

081 7.5.2 7.5.1 5/6/2010 Responder: Merten/WEC 7. N Open Open-NRC Review EICB RAI TVA Letter dated NNC 1/5/11: See Also Open Item No.

EICB (Carte)

ML102910002 6/18/10 86 and 202.

The PAMS Licensing Technical Report (WNA-LI-00058-WBT Rev. The codes and standards documents listed in Section 7 of ML101600092 Item No.1: There Due 2/25/11 Item No. 9 0, Dated April 2010), in Section 7, lists codes and standards the Common Q PAMS Licensing Technical Report are the are three sets of regulatory criteria NNC 4/125/2011: See Open Item No.

applicable to the Common Q PAMS. This list contains references documents that the Common Q platform was licensed to that relate to a Common Q TVA to provide 364.

to old revisions of several regulatory documents, for example: when the NRC approved the original topical report and application (e.g. WBN2 PAMS): requested information.

(1) RG 1.29 - September 1978 vs. March 2007 issued the approved SER. The WBN Unit 2 Common Q (a) Common Q platform (2) RG 1.53 - June 1973 vs. November 2003 PAMS is designed in accordance with the approved components - Common Q TR NNC 2/3/11: The (a) IEEE 379-1994 vs. -2000 Common Q topical report and approved SER and the codes (b) Application Development above due date has (3) RG 1.75 - September 1975 vs. February 2005 and standards on which the SER was based. Since the Processes - Common Q SPM been missed by at (a) IEEE 384-1992 vs. -1992 current versions referenced are not applicable to WBN Unit (c) Application Specific - current least 2 months.

(4) RG 1.100 - June 1988 vs. September 2009 2, there is no basis for a comparison review. regulatory criteria Please provide new (a) IEEE 344-1987 vs. -2004 The Common Q Topical Report and due date.

(5) RG 1.152 - January 1996 vs. January 2006 Bechtel to develop a matrix and work with Westinghouse to associated appendices primarily (a) IEEE 7-4.33.2-1993 vs. -2003 provide justification. addressed (a) and (b). The (6) RG 1.168 - September 1997 vs. February 2004 Common Q SER states:

(a) IEEE 1012-1986 vs. -1998 TVA Response to Follow-up NRC Request:

(b) IEEE 1028-1988 vs. -1997 Appendix 1, Post Accident (7) IEEE 279-1991 vs. 603-1991 Attachment 4 contains the results of the TVA analysis of Monitoring Systems, provides the (8) IEEE 323-1983 vs. -1974 (RG 1.89 Rev. 1 June 1984 endorses standards and regulatory guides applicable to the Common functional requirements and 323-1974) Q PAMS. Based on the results of the analysis, the Common conceptual design approach for However, LIC-110, "Watts Bar Unit 2 License Application Review," Q PAMS design meets the applicable requirements and is upgrading an existing PAMS based states: "Design features and administrative programs that are acceptable. on Common Q components (page unique to Unit 2 should then be reviewed in accordance with the 58, Section 4.4.1.1, current staff positions." Please identify all differences between the Description)On the basis of the versions referenced and the current staff positions. Please provide above review, the staff concludes a justification for the acceptability PAMS with respect to these that Appendix 1 does not contain differences. 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

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N and Other Systems, contain application specific requirements that must be addressed by a PAMS system.

Awaiting TVA Response.

082 7.5.2 7.5.1 5/6/2010 Responder: WEC Date: 6/18/10 81. N Closed Closed EICB RAI TVA Letter dated NNC 11/18/10: See also Open Item No.

EICB (Carte)

ML102910002 7/30/10 41, Item No. 3.

The PAMS Licensing Technical Report (WNA-LI-00058-WBT Rev. These components can be found in the Summary NNC 8/9/10: per telephone to Open Item No. 138. Item No. 10 0, Dated April 2010), in Section 2.3, lists hardware/software Qualification Report Of Hardware Testing For Common Q conversation on 8/5/10, it is not changes to the Common Q PAMS previously reviewed by the Applications, 00000-ICE-37764, Rev 3 and clear how Westinghouse NNC 2/2/11: The NRC. However the Common Q ISG-6 Compliance Matrix does not TWICE Qualification Status Report, WNAQR-00011-SSP Commercial Grade Dedication description of the contain activities that address qualification of all changes Per Westinghouse letter WBT-D-2024, (Reference __) dated Plans and Reports for Digital I&C. commercial grade specifically: June 9, 2010, these documents are available for audit at the Westinghouse agree to present to dedication process in Westinghouse Rockville Office. the NRC in a public meeting on the CQ PAMS LTR 2.c - CI527 AF100 Peripheral Component Interconnect (PCI) August 17, 2010, and explanation of Rev. 2 should be interface card TVA provided information by letter dated July 30, 2010 how their system addresses updated to include a

3. - Common Q TC514 AF100 Fiber Optic Modems (Evolutionary (ML102160349) - See Enclosure 1 Item No. 7. regulatory criteria for both non-proprietary Product Maintenance/Improvements) commercial grade dedication and description and to 4.a - PM646A Processor Module Revision 1 of the Licensing Technical Report provides equipment qualification. include a software 4.b - CI631 AF100 Communication Interface Module additional detail on the platform specific to WBN2 and example.

4.e - DO620 Digital Output Card references to the evaluation documentation. NNC 8/25/10: In the August 17, 2010 public meeting Westinghouse Please provide sufficient detail regarding the changes for the NRC TVA Response to Follow-up NRC Request: stated that the CDI were the plans.

to independently evaluate the acceptability of the changes. The NRC requested that the plans Please see the response to Request for Additional and associated reports be Information (RAI) item 3 in letter dated 12/22/10, NRC Matrix docketed.

Item 067.

NNC 11/18/10: During the September 20-21, 2010 audit, TVA agreed to put a description of the commercial grade dedication program and implementation in Rev. 2 of the CQ PAMS LTR.

083 7.5.2 7.5.1 May 6, 2010 Date: 6/18/10 82. Y Closed Closed EICB RAI TVA Letter dated EICB (Carte)

Responder: WEC ML102910002 7/30/10 Please identify all FPGAs in the new or changed PAMS hardware. Date: 5/6/2010 Item No. 11 The FPGAs used in the Common Q PAMS AC160 module Responsibility: TVA 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.

084 7.5.2 7.5.1 May 6, 2010 Date: 6/18/10 83. Y Closed Closed EICB RAI TVA Letter dated EICB Responder: Clark ML102910002 6/18/10 (Carte) Please provide: TVA Design Criteria WB-DC-30-7 Rev. 22, Post Date: 5/6/2010 Item No. 12 Accident Monitoring Instrumentation. Attachment 5 contains Design Criteria WB-DC-30-7 Rev. 22, Responsibility: TVA Post Accident Monitoring Instrumentation.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Document received 085 7.5.2 7.5.1 5/6/2010 Responder: WEC 84. N Closed Closed EICB RAI EICB (Carte)

ML102910002 Please provide a detailed description of the PAMS MTP data link to Is the WEC ISG4 evaluation inadequate? Revised response included in letter MTP is postulated, & Item No. 13 the plant computer. This description should identify all equipment dated 12/22/10 tested, to fail, but not (model & version) and describe the functions that each piece of Operation of the MTP as a barrier device. MTP Fails as a propagate failures.

equipment performs. This description should be of sufficient detail barrier device. Describe what prevents a MTP failure from A response will be provided by for the NRC to independently evaluate the statements made in propagating to the AC160? 10/31/10 WNA-LI-00058-WBT Rev. 0, Section 5.3.

Node loss on the bus? Bus loss? NNC 8/11/10: Design information should be available now. By letter Revise the ISG4 section of the Licensing Technical Report dated July 30, 2010 (ML102160349)

(Rev. 2) to provide a more detailed description of the MTP as TVA stated that the MTP was a barrier device. connected to a Red Hat Linux Server (see Enclosure 1, Item No.

TVA Response to Follow-up NRC Request: 14 part b.). It is presumed that this server is not safety-related. IEEE WNA-LI-00058-WBT-P, Revision 2, Post-Accident 603-1991 Clause 5.6.3(1) states, Monitoring System (PAMS) Licensing Technical Report "Isolation devices used to affect a submitted in TVA letter to NRC dated December 3, 2010 safety system boundary shall be (Reference 1), contains the following changes to address the classified as part of the safety NRC requests: system."

Section 2.2, System Description page 2-3 provides a Please describe how the MTP description of the MTP Fiber-Optic (FO) data link to the plant serves as the isolation device.

computer. Section 2.2.1.4, Hardware has been expanded to include a table detailing all hardware changes that have occurred since the initial submittal. Section 2.2.2, Software has been expanded to include a table detailing all software changes that have occurred since the initial submittal.

086 7.5.2 7.5.1 5/6/2010 Responder: WEC Date: 5/24/10 8. N Open Open-NRC Review EICB RAI TVA Letter dated NNC 1/6/11: See Also Open Item No.81 EICB (Carte)

ML102910002 6/18/10 & 202 The PAMS Licensing Technical Report (WNA-LI-00058-WBT Rev. The regulatory documents listed in the Common Q PAMS TVA to address with item OI 81. Due 2/25/11 Item No. 14 0, Dated April 2010), in Section 6, lists references applicable to the Licensing Technical Report are the documents that the Common Q PAMS. This list contains references to old revisions of Common Q platform was licensed to when the NRC NNC 2/3/11: The several regulatory documents, for example: approved the original topical report and issued the approved above due date has (1) DI&C-ISG04 - Rev. 0 (ML072540138) vs. Rev. 1 SER. The WBN Unit 2 Common Q PAMS is designed in been missed by at (ML083310185) accordance with the approved Common Q topical report and least 2 months.

However, LIC-110, "Watts Bar Unit 2 License Application Review," approved SER and the regulatory documents on which the Please provide new states: "Design features and administrative programs that are SER was based. Since the current versions referenced are due date.

unique to Unit 2 should then be reviewed in accordance with the not applicable to WBN Unit 2, there is no basis for a current staff positions." Please identify all differences between the comparison review.

versions referenced and the current staff positions. Please provide a justification for the acceptability PAMS with respect to these Rev 0 of the Licensing Technical Report references Rev. 1 of differences. ISG4 TVA Response to Follow-up NRC Request:

The analysis for compliance with DI&C-ISG04, Revision 0 to Revision 1 was previously submitted as part of the Common Q PAMS Licensing Technical Report Revision 2 on December 22, 2010. Attachment 4 contains the results of the TVA analysis of standards and regulatory guides applicable to the Common Q PAMS. Based on the results of the analysis, the Common Q PAMS design is acceptable.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 087 7.5.2 7.5.1 May 6, 2010 Date: 5/24/10 85. Y Closed Closed RAI No. 20 TVA Letter dated EICB Responder: Slifer ML102980005 6/18/10 (Singh) Regarding the Sorrento RM-1000 Digital Radiation Processor: Date: 5/6/2010 10/26/2010 Please identify the model and version to be installed. Please The rate meter is model RM-1000. The software is version Responsibility: TVA include explicit identification of software version. 1.2 088 7.5.2 7.5.1 May 6, 2010 Date: 5/24/10 86. Y Closed Closed RAI No. 21 TVA Letter dated EICB Responder: Slifer ML102980005 6/18/10 (Singh) Regarding the Sorrento RM-1000 Digital Radiation Processor: Date: 5/6/2010 10/26/2010 Please provide prior software V&V reports. The latest report only See response to item 56 Responsibility: TVA addresses Version 1.2.

089 5/6/2010 Responder: Clark 87. Y Closed Closed EICB RAI TVA Letter dated NNC: Docketed response states that EICB (Carte)

ML102910002 3/12/10 the applicable FSAR Sections are:

What FSAR functions are implemented using Foxboro Intelligent The list of FSAR functions is listed in TVA letter dated March Item No. 15 5.6 -

Automation (IA)? 12, 2010, Enclosure 1, item 12 7.2.2.3.2 - Garg 7.2.2.3.3 - Garg FSAR Section 7.7.11 will add a discussion of the DCS. 7.2.2.3.4 - Garg 7.2.2.3.5 - Garg See item 4 for questions on failure modes and mesh 7.2.3 - Garg network. 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 -

090 5/6/2010 Responder: Clark Date: 5/25/10 88. Y Closed Closed EICB RAI TVA Letter dated EICB (Carte)

ML102910002 3/12/10 What FSAR Systems are implemented using Foxboro Intelligent The list of FSAR functions is listed in TVA letter dated March Item No. 16 Automation (IA)? 12, 2010, Enclosure 1, item 12 FSAR Section 7.7.11 will add a discussion of the DCS.

See item 4 for questions on failure modes and mesh network.

091 7.4 7.4 May 20, 2010 Date: 5/25/10 89. Y Closed Closed EICB RAI No.1 TVA Letter dated EICB (Darbali)

Responder: Clark ML102910017, 6/18/10 TVA to submit excerpts of EDCRs 52421, 52987, 52321, 52351 Two EDCRs have been submitted. Item is Closed and 10/19/10 and 52601 1. Attachment 6 contains the EDCR 52421 excerpt TVA has agreed to submit the replaced by items 103, remaining EDCRs. 104 and 118.

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,

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 2010.

092 5/20/2010 Responder: Hilmes 1. Y Open Open-TVA/Oversight Continuous review as items are added DORL Due SER Issue (Poole) TVA to review Licensee Open Item list and determine which items This item will close when we are no longer using this Due: SER Issue are proprietary. document as a communications tool.

093 May 20, 2010 Date: 5/25/10 90. Y Closed Closed N/A N/A Will be reviewed under item 154 EICB (Garg)

Responder: Knuettel TVA to submit a letter committing to include setpoint methodology discussion in the FSAR no later than amendment 100. Letter Sent 5/25/10 094 5/20/2010 Responder: Clark Date: 5/25/10 91. Y Closed Closed N/A N/A Information was found in FSAR EICB (Garg)

TVA to locate and provide information on the TMI action item to This item is described in FSAR amendment 98, Section NRC staff will review.

add an anticipated reactor trip on turbine trip to the design bases in 7.2.1.1.2 item 6 page 7.2.9, and Table 7.2-1 item 14, page the FSAR 7.2-39.

095 7.8.1, XX May 20, 2010 Date: 92. Y Closed Closed EICB RAI No. 2 TVA Letter dated EICB (Darbali)

7.8.4 Responder

ML102910017, 7/30/10 TVA to review SER supplements 5 and 14 item 7.8.1 and 10/19/10 supplement 4 item 7.8.4 and confirm if they are identical to Unit 1. Q1: Monitoring of the reactor coolant system relief valve If not provide differences. position is the same as Unit 1.

Q2: The reactor trip on turbine trip is the same as Unit 1.

096 7.7.5 XX 5/20/2010 Responder: 93. Y Closed Closed EICB RAI No.3 TVA Letter dated EICB (Darbali)

ML102910017, 7/30/10 TVA to provide information on implementation of IEN 79-22 and IEN 79-22 is not specifically listed or discussed in the WBN Response provided. NRC staff to OI 283 10/19/10 how it is addressed in the FSAR Unit 1 UFSAR or Unit 2 FSAR. IEN 79-22 is one of the review response.

precursors to 10CFR50.49 environmental qualification. The initial SQN and WBN Unit 1 response was developed prior to See Follow up question 283.

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 safety-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.

097 7.4.2 7.4 May 20, 2010 Date: 94. Y Closed Closed EICB RAI No.4 TVA Letter dated EICB (Darbali)

Responder: ML102910017, 7/30/10 TVA to review SER Supplement 7 item 7.4.25 deviation on Aux Response is satisfactory. 10/19/10 Control Room display of RCS cold leg temperature for applicability The deviation to not have RCS cold leg temperature to Unit 2. 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 Licensing bases and this deviation is applicable to Unit 2.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 098 7.4.2 7.4 May 25, 2010 Date: 95. Y Closed Closed EICB RAI No.5 TVA Letter dated EICB Responder: ML102910017, 7/30/10 (Darbali) Unit 1 SER Supplement 7, RCS Cold Leg Temperature 10/19/10 instrumentation. How does Unit 2 address this change? Refer to the response to Item 13 11 above.

099 April 12, 2010 Date: 96. Y Closed Closed Closed to Item 129 DORL (Bailey)

Responder: WEC 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. 1 100 5/20/2010 Responder: WEC 97. Y Closed Closed N/A - No question N/A EICB (Carte) was asked. Item The following Common Q proprietary documents listed in the The documents, and affidavits for withholding for the listed was opened to track response and the affidavits for the proprietary documents will be documents were submitted to the NRC on TVA letter to the commitment made provided by April 9, 2010. NRC dated April 8, 2010. by applicant.

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. 1 101 4/12/2010 Responder: Slifer 9. Y Open Open-NRC Review N/A TVA is working with the vendor to meet DORL (Poole) the 6/30 date, however there is the The non-proprietary versions of the following RM-1000, The documents, and affidavits for withholding for the listed Documents provided in letter dated Due 10/14/10 potential this will slip to 7/14.

Containment High Range Post Accident Radiation Monitor documents were submitted to the NRC on TVA letter to the 07/15/10 documents will be provided by June 30, 2010. NRC dated July 15, 2010. Confirm receipt.

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 102 May 24, 2010 Date: 5/24/10 98. Y Closed Closed N/A TVA Letter dated Request for schedule not information.

EICB (Carte)

Responder: WEC 6/18/10 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 103 7.4 7.4 5/27/2010 Responder: Ayala Date: 5/27/10 99. Y Closed Closed EICB RAI No.1 TVA Letter dated Submittal date is based on current EICB (Darbali)

ML102910017, 10/29/10 EDCR scheduled issue date.

TVA to submit excerpts of EDCR 52321 Attachment 1 contains excerpts from draft EDCR 52321 (i.e., Response is included in letter dated Due 10/31/10. Waiting 10/19/10 Enclosure 1 Item draft Scope and Intent, Unit Difference and Technical 10/29/10. for docketed version to No. 4 Evaluation). The final excerpts will be submitted within two close item.

weeks after issuance of the EDCR.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 104 7.4 7.4 5/27/2010 Responder: Merten Date: 5/27/10 100. Y Closed Closed EICB RAI No.1 TVA Letter dated Submittal date is based on current EICB (Darbali)

ML102910017, 10/29/10 EDCR scheduled issue date.

TVA to submit excerpts of EDCR 52351 Attachment 2 contains excerpts from draft EDCR 52351 (i.e., Response is included in letter dated Due 10/31/10. Waiting 10/19/10 Enclosure 1 Item draft Scope and Intent, Unit Difference and Technical 10/29/10 for docketed version to No. 5 Evaluation). The final excerpts will be submitted within two close item.

weeks after issuance of the EDCR.

105 April 29, 2010 Date: 101. Y Closed Closed N/A N/A Will be reviewed under item 154.

EICB (Garg)

Responder: Langley Provide As-Found/As-Left methodology procedure Date: 5/27/10 Submitted copy of TI-28 May 14/2010. Responsibility: NRC Replaced with new open item 176.

106 May 6, 2010 Date: 5/25/10 102. Y Closed Closed RAI No. 9 TVA Letter dated EICB (Singh)

Responder: Davies ML102980005 6/18/10 Confirm that the Unit 1 and Unit 2 CERPI systems utilize the same Date: 10/26/2010 processor (AC110 or AC160). Westinghouse Unit 2 Drawing 6D31420, Watts Bar 2- CERPI Responsibility:

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.

107 May 6, 2010 Date: 5/28/10 103. Y Closed Closed RAI No. 22 TVA Letter dated EICB (Singh)

Responder: Clark ML102980005 6/18/10 Describe any control functions associated with the RM-1000 Requested information provided. See ML101940236, 10/26/2010 radiation monitors. The RM-1000 radiation monitors do not provide any control NRC to review. Encl 1, Item 29.

functions.

108 May 6, 2010 Date: 5/25/10 104. Y Closed Closed N/A N/A Will be reviewed under OI#154 EICB (Garg)

Responder: Webb/Hilmes We are requested to docket the fact that the appropriate sections This item is to be worked with item This item is closed as it of chapter 7 of the FSAR will be updated to include references to: This item is addressed as follows: 51. will be reviewed under item 154. FSAR AMD

a. TI-28 to address as-found/as-left issues 109. FSAR Amendment 100 which was submitted on 100

b. RISC 2006-17 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.

109. 7.8 XX 5/6/2010 Responder: N/A 105. Y Closed Closed N/A N/A a EICB (Darbali) The reviewer was unable to identify the sections of the FSAR that TVA Provided response J. Wiebe accepted this action.

correspond to the standard review plan sections 7.8.

109. 5/6/2010 Responder: N/A 106. Y Closed Closed N/A N/A Duplicate of another open Item.

b EICB (Carte) The reviewer was unable to identify the sections of the FSAR that TVA Provided response J. Wiebe accepted this action. NRC Action correspond to the standard review plan sections7.9.

110 May 6, 2010 Date: 107. Y Closed Closed N/A N/A Information was found.

EICB (Garg)

Responder: Clark The reviewer was unable to locate the Eagle 21 WCAPs 12374 and 12375 for review within the NRC records. We agreed to These items were docketed under ML073550386 provide the ADAMS numbers for the submittal.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 111 May 6, 2010 Date: 5/28/10 108. Y Closed Closed N/A TVA Letter dated Request to help find, not a request for EICB (Carte)

Responder: Clark 6/18/10 information.

The reviewer was unable to locate information (SER) on the plant computer or annunciator systems and asked us to provide the The annunciator system is not described in the WBN Unit 1 location within the FSAR where these systems are described. 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.

112 June 1, 2010 Date: 109. Y Closed Closed N/A N/A Information was received EICB (Garg)

Responder: Clark 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.

113 6/1/2010 Responder: Clark 110. Y Closed Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 6/18/10 Are the new model Eagle 21 power supplies installed in Unit 1? Yes. Attachment 9 provides a work order excerpt and unit Attachment 9 does not show the Item #34 difference form. vendor and model no. of the Power Revised attachment provided on 7/30 letter. Supply.

114 7.2 7.2 6/1/2010 Responder: WEC 111. Y Close Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 6/18/10 Provide the resolution of the Eagle 21 Rack 5 lockup on update The following non-proprietary response was developed from TVA to provide justification that Due 10/31/10 Item#35 issue. proprietary Westinghouse letter WBT-D-2027 (Reference there are no more surprises. TVA Letter dated 11), which provided the resolution of this issue. The write-up shows that 10/29/10 Westinghouse approved this non-proprietary response via e- there was differences Enclosure 1 Item mail from A. Drake to M. Clark on June 15, 2010. Revised response is included in between Unit 1 and 2 No. 6 letter dated 10/29/10 but was not identified to As documented in WBT-D-1917, Eagle-21 Rack 5 LCP NRC in earlier Diagnostic Failures, (Reference 14), during the factory response. Are there acceptance testing for the Unit 2 Eagle-21 System, any more surprises like Westinghouse noted an occasional diagnostic failure while this?

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).

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.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 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 Revised Response:

The Eagle 21 system is installed and the Site Acceptance Test has been completed. To the best of TVAs knowledge there are no unknown issues with the system.

115 2/25/2010 Responder: Clark 112. Y Closed Closed EICB RAI TVA Letter dated EICB (Carte)

ML102910002 6/18/10 Provide a list of digital 1E systems that have a digital Response states that Eagle21 and the CQ PMAS MTP have Response provided in letter dated Item No. 17 communications path to non safety related systems and if it has: communications links to non-safety-related systems.. 10/5/10 TVA Letter dated

a. Been reviewed before for unit 1 10/5/10

b. Or installed in unit 1 under 50.59, or The original design allowed printing from both the Operator

c. Is unique to unit 2 Module (OM) and Maintenance and Test Panel (MTP) via The CQ PAMS SysRS (WNA-DS-the plant computer. This required both to be connected to 01617-WBT Rev. 1 Figure 2..1-1) the plant computer. Westinghouse did not perceive this as shows that the OM has a TCP an issue, because the standard Common Q PAMS design interface to non-safety. Please includes both the flat panel displays and individual control provide a list of ALL digital panel indicators. The Westinghouse Common Q team did communications paths to non-not realize that WBN does not use the individual control safety-related systems.

panel indicators. As a result, the original design documents provided by Westinghouse included the connection from the NNC 8/12/10: The staff pointed out OM to the plant computer. this inconsistency to TVA. The staff could consider PAMS Licensing The TVA team did not realize that the Westinghouse design Technical Report to be a correction relied on the OM and MTP to be qualified isolation devices if TVA specifically identified the that protected the AC160 functions and individual control inconsistency to the staff, or panel indicators from interference from the plant computer. identified where the error in the It was not until a meeting was held with TVA, Westinghouse SysRS, SRS, & SDS had already and Bechtel to discuss the design of the OM that the issues been identified. This appears to be came to light. That was when Westinghouse understood a feature in the CQ TR appendix that the OM was the PAMS display and WBN did not use that was carried forward to WBN2 individual control panel indicators and TVA/Bechtel PAMS inappropriately understood that the OM was being credited as the qualified isolation device. It became apparent at the meeting to both TVA/Bechtel and Westinghouse that the original design was not acceptable. The team then agreed to delete the OM connection to the plant computer.

116 6/3/2010 Responder: WEC 113. Y Closed Closed EICB RAI TVA Letter dated Letter sent to Westinghouse requesting EICB (Garg)

ML102910008 10/5/10 the basis information and The Eagle 21 boards originally had a conformal coating. However, The response to this RAI was submitted in TVA letter to the Response provided in letter dated How is the tin whisker Item # 20 documentation for submittal to the NRC.

the new boards do not. Provide the basis for deletion of the NRC dated June 21, 2010. 10/5/10 issue is addressed. I conformal coating. think conformal coating As previously stated the technical reason for the coating was credited to protect was to ensure performance at high humidity, with the major against tin whisker concern being the effects of humidity on low level analog issue.

circuitry. Westinghouse letter (WBT-D-2036, TENNESSEE

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT UNIT 2, Basis for Removal of Conformal Coating Requirement on Eagle 21 Boards (Reference 7) does not credit the conformal coating as addressing the tin whisker issue.

As addressed in Resolution of Generic Safety Issues: Issue 200: Tin Whiskers (NUREG-0933, Main Report with Supplements 1-33),

CONCLUSION The low number of reported events associated with this issue, the lack of any increasing trend, the lack of any apparent decrease in reliability of systems or components due to tin whiskers, the existence of applicable regulatory requirements and programs (i.e., 10 CFR Part 21, the maintenance rule requirements, and the Reactor Oversight Program), and the issuance of Information Notice 2005-251878 to alert licensees collectively indicated that tin whiskers did not meet the requirements of NRC Management Directive 6.4. "Generic Issues Program," for further pursuit. Based on the considerations discussed above, RES recommended that the issue be returned to the originator to be evaluated for other possible options. As a result, the issue was DROPPED from further pursuit.1879 Based on the preceding NRC position no further discussion of the tin whisker issue is required.

117 7.1 7.1 6/3/2010 Responder: Hilmes 114. Y Closed Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 10/29/10 Does TVA use a single sided or double sided methodology for as- Reactor Protection System (RPS) (comprised of Reactor Trip Revised response is included in Pending FSAR Item#21 Enclosure 1 Item found and as-left instrument setpoint values. (RIS2006-7) (RPS) and Engineered Safety Features Actuation System letter dated 10/29/10 Amendment 102 No. 7 (ESFAS)) setpoint values are monitored by periodic submittal performance of surveillance tests in accordance with Technical Specification requirements. TVA uses double- Due 12/17/10 sided as-found and as-left tolerances for Reactor Trip and ESFAS trip setpoint surveillance tests as described in FSAR TVA needs to address amendment 100. that trip setpoint and allowable value TVA Revised Response: uncertainties are not reduced by the For TSTF-493 parameters WBN Unit 2 uses only double reduction factor for the sided correction factors. Attachment 3 contains the revised single sided reduction FSAR section 7.1.2.1.9 that will be included in FSAR factor. TVA response Amendment 102 that reflects this change. not acceptable. TVA need to clarify if single sided methodology has been used in calculating trip setpoint and allowable value and if it is used then provide justifications.

118 7.4 7.4 6/8/2010 Responder: Merten 115. Y Closed Closed EICB RAI No.1 TVA Letter dated Submittal date is based on current EICB ML102910017, 10/29/10 EDCR scheduled issue date. Note:

(Darbali) TVA to submit excerpts from EDCR 55385 Attachment 4 contains excerpts from draft EDCR 55385 (i.e., Due 10/31/10. Waiting 10/19/10 Enclosure 1 Item The RVLIS EDCR has been split into draft Scope and Intent, Unit Difference and Technical Response is included in letter dated for docketed version to No. 8 two EDCRs. The first EDCR is 52601 Evaluation). The final excerpts will be submitted within two 10/29/10 close item. (Open Item 91) The second EDCR is

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N weeks after issuance of the EDCR. 55385.

119 June 10, 2010 Date: 116. Y Closed Closed RAI No. 23 TVA Letter dated EICB (Singh)

Responder: ML102980005 7/30/10 Submit the non-proprietary version of Sorrento/GA software V&V 10/26/2010 report version 1.1 04508005 and withholding affidavit Provided 7/15/2010 Date: 07/29/10 Responsibility: NRC 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.

120 5/6/2010 Responder: Hilmes/Merten/Costley 117. Y Closed Closed EICB RAI TVA Letter dated EICB (Carte)

ML102910002 7/30/10 In reviewing the Maintenance Test Panel (MTP) link to the plant TVA responded by letter dated July 30, 2010 NNC 8/9/10: By letter dated July 30, Item No. 18 computer, the reviewer noted that the MTP software is not purely (ML102160349) - See Enclosure 1 Item No. 14: Detailed 2010 (ML102160349) - See one directional in that it does allow low level handshaking to discussion is provided including technical information on the Enclosure 1 Item No. 14 support the communications protocol. M. Merten/S. Hilmes data diode.

a. The reviewer stated that this was a potential concern and See Item 85. TVA not crediting the data diode.

requested additional information on how the MTP was protected a. TVA stated no new information from feedback from the plant computer. 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

b. The reviewer stated that in the Oconee review, it was found that indicates that the MTP is connected the non-safety related data diode was easier to credit than a directly to a non-safety-related Red software barrier. It was suggested we look at changing our Hat Linux Server which is then position to credit the data diode provided it provided a physical connected to the data diode barrier to feedback. Need OWL Information SAH devices. Please describe the secure development and operational environment of these Red Hat Linux Servers.

c. The answer is not complete. A

c. During this discussion, the reviewer asked if we had information chattering node is one of the failure from Westinghouse that demonstrated the ability of Common Q modes of an Ethernet link. The PAMs to withstand a data storm. A verbal response was that this MTP is connected to a Linux server was required by contract as part of the Factory Acceptance Test over an Ethernet link. What and would not be available until the FAT was completed. Need to prevents this link from locking up docket the verbal response and provide a date the information will the MTP by a data storm?

be available. Believe we stated this in the Tech Report. SAH

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 121 5/6/2010 Responder: Webb/Webber 118. Y Closed Closed EICB RAI TVA Letter dated EICB (Carte)

ML102980066 Item 7/30/10 If not previously provided, provide the requested information in The information in the letter provides references to previous No. 1 items a, b and c for changes to all platforms between Unit 1 and 2. submittals and a cross reference for the Foxboro I/A system.

(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.

122 June 14, 2010 Date: 119. Y Closed Closed N/A - Request for N/A EICB Responder: WEC schedule not (Carte) Provide a date for completing the next revision of the Common Q technical PAMS System Requirements Specification. This is a duplicate of NRC RAI Matrix Item 50 and is information.

considered closed.

123 7.7.3 7.4.1, 6/14/2010 Responder: 120. Y Closed Closed ML101720589, TVA Letter dated EICB (Darbali) 9.3.4.2.4 RAIs 21 and 22, 7/30/10 Safety Evaluation(SE) Section 7.7.3 Volume Control Tank Level 1. The devices in the Volume Control Tank Level Control Follow up question is to request a 6/25/10 and EICB Control System System have been replaced. The Volume Control Tank logic diagram in OI 284. RAI No.8 Level Indication and Control functions have been relocated ML102910017,

1. Confirm whether or not any Instrumentation & Control (I&C) to the Foxboro IA system. The transmitters and indicators 10/19/10 systems or equipment have been changed in the Volume Control have been replaced with 4-20mA technology and the Tank Level Control System. transmitters have been changed to Rosemount.

2. In the original Safety Evaluation(SE), NUREG-0847 2. Upscale failure of LT-62-129A: Flow is diverted to the (ML072060490), Section 7.7.3, the staff addressed a concern that holdup tank but makeup continues to maintain level and was raised by Westinghouse regarding an adverse control and alarms alert the operator.

protection system interaction. (a single random failure in the VCT level control system could cause the letdown flow to be Upscale failure of LT-62-130A: Unlike Unit 1, the makeup diverted to the liquid holdup tank). Based on your responses to the control system uses inputs from both LT-62-130A and LT staffs questions related to this concern, the staff considered the 129A. This results in a more robust design that eliminates a issue resolved. Confirm that your responses are applicable to Unit single point of failure for LT-62-130A. If transmitter LT 2. 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.

124 7.7.5 XX 6/14/2010 Responder: 121. Y Closed Closed ML101720589, Item TVA Letter dated EICB (Darbali)

No. 23, 6/25/10 and 7/30/10 SE Section 7.7.5 IE Information Notice 79-22 Duplicate of item 96 EICB RAI No. 9 ML102910017,

1. In the original SE, Section 7.7.5, the staff determined that 10/19/10 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.

122. Y

(

125 7.7.8 7.7.1.12 6/14/2010 Responder: Closed Closed ML101720589, Item TVA Letter dated D

a

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N No.s 24 and 25, 7/30/10 SE Section 7.7.8 AMSAC 1. The AMSAC system was not previously installed in Unit 2. 6/25/10 and EICB EDCR 52408 installs the system. Attachment 3 contains RAI Nos.10 and 11

1. Confirm whether or not any I&C systems or equipment have excerpts from the EDCR that describe the Unit 2 system and ML102910017, been changed in the AMSAC? Describe the changes, if any. how it differs from the Unit 1 system. 10/19/10

2. NUREG-0847, Supplement 14 (ML072060486), documents the 2. EDCR 52408 incorporates the AMSAC system into the staffs review of FSAR Amendment 81 that found that the AMSAC Unit 2 drawings.

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.

126 7.8 7.8 June 14, 2010 Date: 123. Y Closed Closed ML101720589, Item TVA Letter dated EICB (Darbali)

Responder: No. 26, 6/25/10 and 7/30/10 SE Section 7.8 NUREG-0737 Items EICB RAI No.12 No I&C components or systems are affected by this change. ML102910017,

1. In the SER Cross Reference To FSAR table (06-25-09), section 10/19/10 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?

127 7.2 7.2 6/16/2010 Responder: WEC/Clark 124. Y Closed Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 6/18/10 Provide the status of the Eagle 21 Rack 2 RTD accuracy issue. The following non-proprietary response was developed from Item36 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.

128 7.2 7.2 CB (G 6/18/2010 Responder: WEC Drake /TVA Craig 125. Y Closed Closed EICB RAI TVA Letter dated Track through SE open item ar ML102910008 10/29/10

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Submit the report on the final resolution of the Eagle 21 Rack 2 The Unit 1/Unit 2 Eagle 21 configuration has a sufficient Response is included in letter dated Due 10/31/10 Item46 Enclosure 1 Item RTD input issue number of spare Narrow Range and Wide Range RTD inputs 10/29/10 No. 9 available on the installed ERI-01 and ERI-02 boards to wire these spare inputs to the active channels. The spare input Has it been tested to show that the will provide the parallel resistance to resolve the problem. revised config. Provide the needed The Wide Range (WR) RTD inputs provide the same input accuracy.

impedance as the Narrow Range (NR) RTD inputs. Jumpers will be installed at the Eagle 21 termination frame to provide a parallel connection from each existing NR RTD input to an existing spare input, thus simulating the hardware connection for shared RTDs. Therefore, as configured, the Rack 2 Loop Calculation Processor (LCP) would provide the correct temperature calculation for the NR RTDs.

129 6/12/2010 Responder: WEC 126. Y Closed Closed N/A TVA Letter dated DORL (Poole) 10/5/10 TVA will provide non-proprietary versions of the following Common The documents, and affidavits for withholding for the listed Response provided in letter dated Confirmation by Q attached proprietary documents and the affidavits for the documents were submitted to the NRC on TVA letter to the 10/5/10 10/14/108 proprietary documents by June 30, 2010. NRC dated July 14, 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. 1 130 6/28/2010 Responder: Clark 127. Y Closed Closed N/A TVA Letter dated DORL 10/5/10 (Poole) TVA committed to revise in Amendment 100: table 4.3-1 to add ID FSAR Amendment 100 submitted to the NRC on TVA letter Response provided in letter dated Confirmation by and OD nomenclature to thimble guide tube dimensions . to the NRC dated September 1, 2010 added the ID and OD 10/5/10 10/14/10 nomenclature.

131 6/28/2010 Responder: Clark 128. Y Closed Closed N/A TVA Letter dated DORL 10/5/10 (Poole) TVA committed to revise in Amendment 100: FSAR 3.10 FSAR Amendment 100 submitted to the NRC on TVA letter Response provided in letter dated Confirmation by references to eliminate (LATER) for document numbers. to the NRC dated September 1, 2010 updated the reference 10/5/10 10/14/10 document number information.

132 6/28/2010 Responder: Clark 129. Y Closed Closed N/A TVA Letter dated DORL 10/5/10 (Poole) TVA committed to revise in Amendment 100: FSAR 3.10 to correct FSAR Amendment 100 submitted to the NRC on TVA letter Response provided in letter dated Confirmation by differences between the list on page 3.10-4 and the numbering to the NRC dated September 1, 2010 corrected the 10/5/10 10/14/10 referenced by the text below the list. numbering in the text.

133 6/28/2010 Responder: Clark 130. Y Closed Closed TVA Letter dated DORL 10/5/10 (Poole) TVA committed to revise in Amendment 100: FSAR 3.10 to remove FSAR Amendment 100 submitted to the NRC on TVA letter Response provided in letter dated Confirmation by references to IEEE 344-1987. to the NRC dated September 1, 2010 removed the reference 10/5/10 10/14/10 to IEEE 344-1987.

134 6/28/2010 Responder: Clark 131. Y Closed Closed TVA Letter dated DORL 10/5/10 (Poole) TVA committed to revise in Amendment 100: FSAR Table 1.3-3 to FSAR Amendment 100 submitted to the NRC on TVA letter Response provided in letter dated Confirmation by reflect modifications to WBN2 . to the NRC dated September 1 2010 updated the table to 10/5/10 10/14/10 reflect the WBN2 modifications.

135 7.3.1 7.3.1 6/30/2010 Responder: Clark 132. Y Closed Closed RAI not necessary TVA Letter dated EICB (Darbali) because this item 10/5/10, item 27 TVA committed to add in Amendment 100 a reference to 7.3.1.1.1 FSAR Amendment 100 submitted to the NRC on TVA letter Response provided in letter dated was originated by in 6.2.5.2.b. to the NRC dated Sept 1, 2010 added the reference. 10/5/10 TVA Amendment 100 received.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 136 7.3.2, 7.4, 5.6, 6/30/2010 Responder: Clark 133. Y Closed Closed RAI not necessary TVA Letter dated EICB (Darbali) 7.4 6.3.5 because this item 10/5/10, item 28 TVA committed to replace in Amendment 100 the terms "service FSAR Amendment 100 submitted to the NRC on TVA letter Response provided in letter dated was originated by water" and "emergency raw cooling water" where they are used to the NRC dated Sept 1, 2010 updated the "service water" 10/5/10 TVA incorrectly with "Essential Raw Cooling Water" in sections 7.4, and "emergency raw cooling water" nomenclature as 6.2.1, Table 3.7-25, Table 9.3-3, Table 15.4-14, 1.9.2.7, 7.3.2.2.5 required to read essential raw cooling water.

and 11.2.4. Amendment 100 received.

137 Several WBN2 PAMS documents contain a table titled, Document Responder: WEC 134. Y Closed Closed ML101650255, Item TVA Letter dated EICB (Carte)

Traceability & Compliance. No. 1 10/5/10 (a) The table is to show the document hierarchy (i.e., what Response provided in letter dated (a) Please explain the purpose of this table. documents are predecessors to the document in relationship 10/5/10 to the design life cycle).

(b) Please describe how this table is different than a reference list.

(b) This table is showing a hierarchical relationship between Carte accepted this response 9/1 (c) What does it mean for a document to be listed in this table? documents. These documents are also in the reference list along with other documents that have no hierarchical relationship with the document.

(c) This question is similar to (a). It is to identify the documents that are predecessors to this document in relationship to the design life cycle.

138 By letter dated February 3, 2010, Westinghouse informed TVA that Responder: WEC 10. N Open Open-NRC Review ML101650255, Item See also No. 82.

EICB (Carte) certain PAMS documentation has been completed. No. 2 This item is used to track all Commercial Grade Pending Submittal of Revision 3 of NNC 2/2/11:

(a) The draft ISG6 states that a commercial grade dedication plan Dedication issues. the Licensing Technical Report due Commercial grade should be provided with an application for a Tier 2 review. 3/29/11. dedication will be

a. WNA-LI-00058-WT-P, Revision 2, Post-Accident addressed at the next By letter dated February 5, 2010, TVA stated that the commercial Monitoring System (PAMS) Licensing Technical Report Revised response included in letter audit.

grade dedication plan was included in the Common Q Topical submitted in TVA Letter to NRC dated December 3, dated 12/22/10 Report Section 11, Commercial Grade Dedication Program. 2010, (Reference 1) contains the following changes to NNC 2/17/11: The Section 11 includes a description of the Common Q Commercial address the NRC request: TVA agreed to include a description description of the Grade Dedication Program, and states: A detailed review plan is of the generic Westinghouse commercial grade developed for each Common Q hardware or software component Section 7, Commercial Grade Dedication Process has hardware commercial grade dedication process in that requires commercial grade dedication. been revised to describe the general commercial grade dedication process in the PAMS the CQ PAMS LTR dedication process for both hardware and software and licensing technical report. (see Rev. 2 should be Please provide the commercial grade dedication plans for each uses a description of the AI687 dedication process as ML102920031 Item No 1) updated to include a Common Q hardware or software component that has not been an example of how the process is applied. non-proprietary previously reviewed and approved by the NRC. TVA agreed to include (in the PAMS description and to As listed in Table 6-3. Westinghouse Watts Bar 2 licensing technical report) an include a software (b) The draft ISG6 states that a commercial grade dedication report Common Q PAMS Documents at Westinghouse evaluation of WBN2 critical example.

should be provided within 12 months of requested approval for a Rockville Office, the following commercial grade characteristics for commercial Tier 2 review. dedication documents are available for NRC audit at the Westinghouse hardware Westinghouse Rockville office: (list included in letter) components against the generic (i) Please provide 00000-ICE-37722 Rev. 0, Commercial Grade critical characteristics. (see Dedication Report for the QNX Operating System for Common Q b. It is TVAs understanding that the submittal of the ML102920031 Item No 2)

Applications. documents listed in (b.i) and (b.ii) is no longer required.

Rather, it was agreed, that the inclusion of a description TVA agreed to include a description (ii) Please provide WNA-CD-00018-GEN Rev. 3, Commercial of the commercial grade dedication process in revision of the generic Westinghouse Dedication Report for QNX 4.25G for Common Q Applications. 2 of the Post-Accident Monitoring System (PAMS) software commercial grade Licensing Technical Report, WNA-LI-00058-WT-P, dedication process in the PAMS would be sufficient to address this request. licensing technical report. (see ML102920031 Item No 3)

TVA Response to Follow-up NRC Request:

TVA agreed to include (in the PAMS The non-proprietary commercial grade dedication discussion licensing technical report) an is included in Attachment 3, WNA-LI-00058-WBT-NP, Post- evaluation of WBN2 critical Accident Monitoring System (PAMS) Licensing Technical characteristics for commercial software components against the

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Report, Revision 3 dated March 2011 (non-proprietary) generic critical characteristics. (see Section 7. The software example is included in Attachment ML102920031 Item No 4) 2, WNA-LI-00058-WBT-P, Post-Accident Monitoring System (PAMS) Licensing Technical Report, Revision 3, dated March 2011 (proprietary) Section 7.

139 The WBN2 PAMS System Requirements Specification (WBN2 Responder: WEC 135. Y Closed Closed ML101650255, Item TVA Letter dated WBN2 PAMS System Requirements EICB (Carte)

PAMS SysRS) contains a table (see page iii) titled, Document No. 3 10/5/10 Specification Traceability & Compliance, which states that the WBN2 PAMS The table is to show the document hierarchy (i.e., what Response provided in letter dated SysRS was created to support no documents. Please explain. documents are predecessors to the document in relationship 10/5/10 TVA docketed WNA-DS-01617-WBT to the design life cycle). The table purpose is to provide Rev. 1, RRAS Watts Bar 2 NSSS references to internal Westinghouse documents and is not Completion Program I&C Projects Post intended to reference TVA documents. Accident Monitoring System- System Requirements Specification, dated December 2009.

140 The first requirement in the WBN2 PAMS SysRS (i.e., R2.2-1) Responder: Clark 136. N Closed Closed ML101650255, Item TVA Letter dated WBN2 PAMS System Requirements EICB (Carte) states: The PAMS shall be capable of operation during normal and No. 4 10/29/10 Specification abnormal environments and plant operating modes. The rational WBN Unit 2 FSAR Amendment 100 Section 7.5.1.8, Post Revised response included in letter NNC 2/3/11: This item Enclosure 1 Item for this requirement is that it is necessary to meet Regulatory Accident Monitoring System (PAMS) specifies the Reg. dated 12/22/10 is addressed by: No. 10 TVA docketed WNA-DS-01617-WBT Guide (RG) 1.97. Guide 1.97 variables implemented in the Common Q based (1) WNA-LI-00058- Rev. 1, RRAS Watts Bar 2 NSSS WBN Unit 2 PAMS NNC 11/3/10: The origin of the WBT-P Rev. 2 Section Completion Program I&C Projects Post What document specifies which RG 1.97 variables are requirements in the SysRS are not 11 Accident Monitoring System- System implemented in the Common Q based WBN2 PAMS? TVA Response to Follow-up NRC Request: clearly document. Rev. 1 of the Requirements Specification, dated (2) Attachment 1 to Common Q PAMS Licensing December 2009.

WNA-LI-00058-WT-P, Revision 2, Post-Accident Monitoring Technical Report contains an open TVA letter dated Octobr System (PAMS) Licensing Technical Report was submitted item that will be addressed in Rev. 21, 2010.

in TVA Letter to NRC, dated December 3, 2010 (Reference 2; this open item is to include 1). Revision 2 contains the following change to address this TVAs enhanced contract request: compliance matrix. It is expected that this matrix will address this Section 11, TVA Contract Compliance Matrix has been open item.

added. Specifically the items of concern are addressed by Requirements 7 through 19 (pages 11-1 and 11-2).

141 Deleted by DORL Date: 137. Y Closed Closed ML101650255, Item WBN2 PAMS System Requirements EICB (Carte)

Responder: No. 5 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.

142 The applicable regulatory guidance for reviewing the WBN2 PAMS Responder: WEC 11. N Open Open-NRC Review ML101650255, Item WBN2 PAMS System Requirements EICB (Carte)

SysRS would be IEEE 830 as endorsed by Regulatory Guide 1.172 No. 6 Specification and BTP 7-14 Section B.3.3.1, Requirements Activities - Software This item is used to track all traceability issues with the Due 2/25/11 (document Requirements Specifications. IEEE 830-1994 Section 4.3.8, Software Requirements Specification (SRS). Revised response included in letter submittals) TVA docketed WNA-DS-01617-WBT Traceable, states: A [requirements specification] is traceable of dated 02/25/11 Rev. 1, RRAS Watts Bar 2 NSSS the origin of each of its requirements is clear NNC 2/2/11: Updated Completion Program I&C Projects Post Response included in letter dated Specifications and Accident Monitoring System- System

1. How did TVA ensure the traceability of each requirement in TVA Response to 1: 12/22/10 RTMs to be provided by Requirements Specification, dated the WBN2 PAMS SysRS. Traceability of requirements for the WBN Unit 2 Common Q TVA December 2009.

PAMS is ensured by: TVA/Westinghouse agreed to

a. Preparation of the TVA Contract Compliance Matrix include the V&V evaluation of their Tracability to be contained in WNA-LI-00058-WBT-P, Revision 2, Post- reusable software element addressed during the Accident Monitoring System (PAMS) Licensing development process in the V&V next audit.

Technical Report submitted in TVA Letter to NRC design phase summary report. This dated December 3, 2010 (Reference 1). evaluation would include an

b. Engineering review/comment/status of each revision evaluation against the development

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N of: process requirements. This

i. WNA-DS-01617-WBT, Post Accident evaluation would also include an Monitoring System - System Requirements evaluation of how the WBN2 Specification specific requirements were ii. WNA-DS-01667-WBT, Post Accident addressed by the reusable software Monitoring System - System Design elements. (see ML102920031 Item Specification (hardware) No 5) iii. WNA-SD-00239-WBT, Software Requirements Specification for the Post Accident Monitoring System (software)

TVA Response to 2:

2. Explain the source(s) of the requirements present in the Post As documented in the RTM, some software requirements Accident Monitoring Systems Software Requirements are taken from generic documents. The decision to include Specification. To clarify, many documents have requirements generic software requirements was to reduce the overall that are incorporated by reference into the SRS, but what scope for Common Q features that are unchanged across served to direct the author to include those various projects. Westinghouse reviewed the generic PAMS documents in the SRS or, if the requirement is based on the requirements and included those requirements that were System Requirements Specification, what directed the author applicable to WBN Unit 2 PAMS.

to include the requirement there?

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

3. Clarify whether the unnumbered paragraphs in the Post TVA Response to 3:

Accident Monitoring Systems Software Requirements Unnumbered paragraphs in the Post Accident Monitoring Specification, such as in the section headings, or are all such Systems Software Requirements Specification, such as in sections simply considered to be informative? the section headings, are informative and are not to be interpreted as requirements. All requirements are explicitly Does the same apply to documents referenced by the SRS? numbered.

Such as WCAP-16096-NP-A, Rev. 1A, Software Program Manual for Common Q Systems, which is incorporated by It depends on the document type. The statement would be reference in requirement R2.3-2 in the SRS. true for requirements documents (such as the SysRS or SDS) if they were incorporated by reference. However, for R2.3-2 [The PAMS software shall comply with the the specific item cited, WCAP-16096-NP-A, Rev. 1A, it does requirements and guidelines defined in WCAP-16096-NP-A, not contain numbered requirements. The requirements Software Program Manual for Common Q Systems contained in this document are contained within the text of (reference 5).] the various sections.

If any requirements are expressed in such unnumbered Source: E-mail from Westinghouse (Matthew A. Shakun) to paragraph form instead of individually identified requirements, Bechtel (Mark S. Clark), RE: December 22 letter review, please list them, describe why they satisfy the fundamental dated December 17, 2010 (Reference 13) requirement of unambiguity, and describe how they were verified.

4. Are there any sources of requirements in parallel with the TVA Response to 4:

Post Accident Monitoring Systems Software Requirements The Westinghouse SRS, WNA-SD-00239-WBT, Revision 3 Specification? Meaning does the SRS contain, explicitly or contains references to other Westinghouse software by reference, all the requirements that were used in the requirements documents. Specifically, design phase for the application specific software, or do software design phase activities use requirements found in 00000-ICE-3238, Revision 5, Software Requirements any other source or document? If so, what are these Specification Post Accident Monitoring System sources or documents?

00000-ICE-3239, Revision 13, Software Requirements Specification for the Common Q Generic Flat Panel Display Software Source: E-mail from Westinghouse (Matthew A. Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review,

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N dated December 17, 2010 (Reference 13)

5. References 12, 27, 29, and 31-44 in the Post Accident TVA Response to 5:

Monitoring Systems Software Requirements Specification Requirements for the reusable software elements (RSEDs) are various types of Reusable Software Element. are evaluated in WNA-VR-00283-WBT-P, Revision 3, IV&V Summary Report for the Post Accident Monitoring System, These references are used in the body of the SRS, for dated December 2010 (Attachment 10).

example:

RSED traceability is contained in WNA-VR-00280-WBT, R5.3.14-2 [The Addressable Constants CRC error signal shall Revision 2, Watts Bar 2 NSSS Completion Program I&C be TRUE when any CAL CRC's respective ERROR terminal Projects Requirements Traceability Matrix for the Reactor

= TRUE (WNA-DS-00315-GEN, "Reusable Software Element Vessel Level Indication System (RVLIS) Custom PC Document CRC for Calibration Data" [Reference 12]).] Elements. This document can be made available for audit at the Westinghouse Rockville office.

They are also included via tables such as found in requirement R7.1.2-1 At the September 15 public meeting in Rockville, the following actions were agreed to. These items address the

[The Watts Bar 2 PAMS shall use the application-specific traceability concerns with the Software Requirements type circuits and custom PC elements listed in Table 7.1-1.] Specification.

1. Westinghouse will perform a review of the Do the referenced reusable software element documents include Requirements Traceability Matrix(RTM), using the requirements not explicitly stated in the SRS? If so what is their issues identified at the 9/15 public meeting as a guide origin? (documented below) and update the RTM as required.

TVA Response:

See response to letter Item 13 (NRC Matrix Item 145).

2. The next issue of the IV&V report will include the Requirements phase review of the RTM and a partial review for the Design phase.

TVA Response:

See response to letter Item 13 (NRC Matrix Item 145).

3. Westinghouse will add a comments column in the Requirements Traceability Matrix (RTM) to address items not in the SRS or SysRS.

TVA Response:

A comments column has been added to WNA-VR-00279-WBT, Revision 3, Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System.

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

4. IEEE 830 says you shouldnt have planning information in the SRS. Westinghouse has agreed to remove this information.

TVA Response:

Westinghouse has confirmed that process requirements have been removed from the SRS.

Source: E-mail from Westinghouse (Andrew P. Drake) to Bechtel (Mark S. Clark), RE: Common Q RAI

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N concerns, dated December 8, 2010 (Reference 17)

5. IEEE 830 says you shouldnt have process requirements in the SRS. Westinghouse has agreed to remove these requirements.

TVA Response:

Westinghouse confirmed that process requirements have been removed from the SRS.

Source: E-mail from Westinghouse (Andrew P. Drake) to Bechtel (Mark S. Clark), RE: Common Q RAI concerns, dated December 8, 2010 (Reference 17)

6. Westinghouse will perform and document an evaluation of the SRS to ensure compliance with Reg.

Guide 1.172 and justify any deviations.

TVA Response:

WNA-LI-00058-WBT-P, Revision 2, Post-Accident Monitoring System (PAMS) Licensing Technical Report submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1):

Section 9, Compliance Evaluation Of The Watts Bar 2 PAMS Software Requirements Specification To IEEE Standard 830-1998 And Regulatory Guide 1.172 has been added.

7. 25 issues identified by V&V where some requirements have not been included in the System Design Specification (SDS) (14) and SRS (11) at the revisions reviewed by V&V. Have these been addressed?

TVA Response:

The twenty-five (25) issues are captured in Exception Reports (ERs): V&V-769 and V&V-770. These ERs have all been addressed and the ERs have been closed satisfactorily by Westinghouse IV&V.

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

8. Some hardware requirements are contained in the SRS instead of the System Design Specification (SDS). These will be removed from the SRS and incorporated into the next revision of the SDS.

TVA Response:

The hardware requirements in the Software Requirements Specification have been deleted and moved to System Design Specification.

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 16, 2010 (Reference 15)

9. RTM item R4.2-2 protection class software set to 0.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Needs to be fixed internally. Write CAPs to revise the application restrictions document on AC160.

TVA Response:

Westinghouse CAPs IR# 10-259-M034 has been issued. This item will be addressed in revision 4 of the RTM.

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

10. Westinghouse to improve the traceability of the tests that are performed with the function enable (FE) switch in the ENABLE position.

TVA Response:

The tests that are performed with the FE keyswitch in the ENABLE position are defined in the SRS Sections:

6.2 Manually Initiated Testing, 7.2.23 Annunciator Test Display, 7.2.25 Saturation Margin Test Display, and 7.2.26 Analog Output Test Display.

11. Westinghouse to revise documents to be consistent with referring to the FE switch in the ENABLE position.

TVA Response:

Westinghouse has elected to standardize on the terms FE keyswitch and ENABLE. A review of recent documents for compliance with this comment and commitment was performed with the following results:

a. Revision 3 of the SysRS, and SDS have been revised to use the terms FE keyswitch. Revision 3 of the SDS is consistent in use of the term ENABLE.

b. SysRS Revision 3 is not consistent in use of the term ENABLE as noted below:

i. R2.5.2.1-2 uses the term ENABLED instead of ENABLE ii. R2.5.2.1.3-3, R2.6.3.3-1, R2.6.3.3-2, R2.6.3.3-3, and R2.6.3.3-7, use the term Enable instead of ENABLE

c. Revision 3 of the SRS is not consistent in use of the terms FE keyswitch and ENABLE as noted below:

i. Tables 7.2-1 Train A PAMS Data Transmitted to the Plant Computer and 7.2-2 Train B PAMS Data Transmitted to the Plant Computer items 101 and 102 in the SRS refer to the FE switch.

All other items in the SRS refer to the FE keyswitch.

ii. Section 2.1, page 2-4, uses the term Enable instead of ENABLE iii. Requirements R7.2.14-6 and R7.2.16-7 use the term active instead of ENABLE iv. Requirements R7.2.23-2, R7.2.25-2, R7.2.26-2, R7.2.31-4, 7.2.56 FPDS Availability, and R7.2.57-4 use the term enabled instead of

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N ENABLE

d. WNA-AR-00180-WBT-P, Revision 0, Failure Modes and Effects Analysis (FMEA) for the Post Accident Monitoring System, dated October 2010, submitted in TVA letter to NRC dated (Reference

12) is not consistent in use of the term FE keyswitch as noted below:

i. Section 2.2 System Description and Table 3-1 WB2 PAMS FMEA refer to the FE switch.

ii. Table 3-1 describes the switch as the Functional Enable (FE) switch and the FE key-switch

e. Revision 2 of the Licensing Technical Report is not consistent in use of the term FE keyswitch as noted below:

i. Sections 2.2, 5.3 use the term (FE) keylock switch on pages 2-3 (2 places), page 5-3, page 5-6 (4 places)

The identified discrepancies in the use of the terms FE keyswitch and ENABLE in the SysRS, SRS, FMEA and Licensing Technical Report, will be corrected in the next revision of the documents.

12. The flow of information is from the SysRS to the SDS (hardware) and SRS (software). Describe how the documents are used. Describe in 1.1 of the SysRS.

Need a good write up of how the process works.

TVA Response:

See response to letter item 13 (NRC Matrix Item 145).

13. Westinghouse and TVA will develop a revised schedule for document submittals and provide it to the NRC no later than 9/30/10 TVA Response:

The revised document submittal schedule was included as item 3 NRC Request (Matrix Item Number 142, TVA Commitments Nos. 10 and 17) in TVA letter to NRC dated October 26, 2010 (Reference 5).

14. TVA will update the Procurement Requisition Resolution Matrix and submit it to show how the Common Q PAMS design meets the contract requirements.

TVA Response:

The Procurement Requisition Resolution Matrix has been updated and is included in WNA-LI-00058-WBT-P, Revision 2, Post-Accident Monitoring System (PAMS)

Licensing Technical Report submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1), as Section 11, TVA Contract Compliance Matrix.

15. Westinghouse to add the Software Design Descriptions to the RTM TVA Response:

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N The Software Design Description documents were added to the RTM in WNA-VR-00279-WBT, Rev 2.

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

16. Westinghouse to clarify how requirements or documents are incorporated by reference into the Common Q PAMS requirements.

TVA Response:

When a Common Q PAMS requirements document references a section of another document, all requirements in that section are applicable.

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

17. Westinghouse to review the use of shall outside of numbered paragraphs in requirements documents to ensure that all requirements are captured and clearly identified.

TVA Response:

See response in letter dated December 22, 2010, item 2 (NRC Matrix Item 050).

18. Westinghouse to resolve the following questions concerning Software Design Descriptions (SDDs)

a. Is the SDD a standalone document or will it incorporate the generic SDD by reference?

b. What are the SDDs?

c. PAMS is a delta document so how do we capture all the generic requirements for traceability.

TVA Response:

a. There are three SDDs prepared specifically for the Watts Bar 2 PAMS project. These are listed below in Item b. These documents and superior requirements documents refer to other generic SDDs also listed in Item b.

b. The SDDs developed for this project are:

i. WNA-SD-00248-WBT, Revision 1, Watts Bar 2 NSSS Completion Program I&C Projects Software Design Description for the Post Accident Monitoring System Flat Panel Display ii. WNA-SD-00250-WBT, Revision 1, Watts Bar 2 NSSS Completion Program I&C Projects Software Design Description for the Post Accident Monitoring System AC160 Software iii. WNA-SD-00277-WBT, Revision 2, Watts

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Bar 2 NSSS Completion Program I&C Projects Software Design Description for the Post Accident Monitoring System Flat Panel Display System Screen Design Details iv. Other generic SDDs referenced by the PAMS project are:

(a) 00000-ICE-20157, Revision 18, Software Design Description for the Common Q Generic Flat-Panel Software (b) 00000-ICE-30152, Revision 5, Software Design Description Post Accident Monitoring System AC160 (c) 00000-ICE-30140, Revision 4, Software Design Description for the Common Q Core Protection Calculator System Database and Utility Functions

c. Refer to WNA-VR-00279-WBT, Revision 3.

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

19. For Reusable Software Elements, Westinghouse to describe as qualified libraries by following the SPM and qualified using the Software Elements Test procedure under Appendix B program. Provide a summary of RSEDs generic WCAP. Westinghouse to determine if the WCAP was docketed under the AP1000. RSED concept is not in the SPM. WCAP-15927 AP-1000 does not discuss RCEDs. WCAP process was acceptable. RSEDs are listed in the SDD References.

TVA Response:

Section 3.2.4.1 of WCAP-15927 describes the RSED design process for custom PC elements and type circuits. The Glossary of Terms in the SPM defines custom PC elements and type circuits as modules.

Therefore, the relationship between WCAP-15927 describing the RSED process as circuits, is defined in the SPM requirements for software module development.

WCAP-15927 is on the AP1000 docket.

Source: E-mail from Westinghouse (Matthew A.

Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

TVA Response to Follow-up NRC Request:

WNA-VR-00279-WBT, Revision 4, Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System is scheduled to be available for audit at the Westinghouse Rockville office February 21, 2011. The document will be available at the

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Westinghouse Cranberry offices to support the NRC Common Q PAMS audit.

Attachment 9 contains the proprietary version of WNA-DS-01617-WBT-P, Revision 4, Post Accident Monitoring System - System Requirements Specification, dated February 2011. Attachment 10 contains the non-proprietary version WNA-DS-01617-WBT-NP, Revision 4, Post Accident Monitoring System - System Requirements Specification, dated February, 2011. Attachment 11 contains the Application for Withholding Proprietary Information from Public Disclosure, WNA-DS-01617-WBT-P, Revision 4, Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Post Accident Monitoring System - System Requirements Specification (Proprietary),

dated February 10, 2011.

Attachment 12 contains the proprietary version of WNA-DS-01667-WBT-P, Revision 4, Post Accident Monitoring System - System Design Specification, dated February 2011. Attachment 13 contains the non-proprietary version WNA-DS-01667-WBT-NP, Revision 4, Post Accident Monitoring System - System Design Specification, dated February 2011. Attachment 14 contains the Application for Withholding Proprietary Information from Public Disclosure, WNA-DS-01667-WBT-P, Revision 4, Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects Post Accident Monitoring System - System Design Specification (Proprietary), dated February 11, 2011.

Attachment 15 contains the proprietary version of WNA-SD-00239-WBT-P, Revision 4, Software Requirements Specification for the Post Accident Monitoring System, dated February 2011. Attachment 16 contains the non-proprietary version WNA-SD-00239-WBT-NP, Revision 4, Software Requirements Specification for the Post Accident Monitoring System, dated February 2011. Attachment 17 contains the Application for Withholding Proprietary Information from Public Disclosure, WNA-SD-00239-WBT-P, Revision 4, Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Software Requirements Specification for the Post Accident Monitoring System (Proprietary), dated February 10, 2011.

143 The WBN2 PAMS Software Requirements Specification (WBN2 Responder: WEC 12. N Open Open-NRC Review ML101650255, Item WBN2 PAMS System Requirements EICB (Carte)

PAMS SRS - ML101050202) contains a table (see page iii) titled, No. 7 Specification Document Traceability & Compliance, which states that the Addressed in the 9/15 public meeting and 9/20 - 9/21 audit. Response included in letter dated Due 2/25/11 (document WBN2 PAMS SRS was created to support the three documents A detailed explanation will be provided. 12/22/10 submittals) TVA docketed WNA-DS-01617-WBT identified (one of which is the WBN2 PAMS SysRS). Section 1.1, Rev. 1, RRAS Watts Bar 2 NSSS Overview, of the WBN2 PAMS SRS states: This document TVA Response: To be addressed by Completion Program I&C Projects Post describes requirements for the major software components Revision of the RTM, Accident Monitoring System- System (a) and (b) The requested information is provided in the SRS, SysRS, and Requirements Specification, dated (a) Please list and describe each of the major software following documents: SysDS. December 2009.

components. Please include a description of any NRC review for i. WNA-LI-00058-WBT-P, Revision 2, Post-each of these components. Accident Monitoring System (PAMS) Licensing NNC 2/2/11: Updated Technical Report, Table 6-1, Document Specifications and (b) Please list and describe each of the other software Requirements which lists the software RTMs to be provided by components. Please include a description of any NRC review for documentation requirements for the Common Q TVA each of these components. PAMS and Section 11 TVA Contract

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Compliance Matrix submitted in TVA Letter to NNC 2/3/11: The (c) What other documents contain the requirements for the other NRC, dated December 3, 2010 (Reference 1). above due date has software components? ii. WNA-DS-01617-WBT-P, Revision 3, Post been missed by at Accident Monitoring System- System least 2 months.

The WBN2 PAMS System Design Specification (WBN2 PAMS Requirements Specification, dated December Please provide new SDS) contains a table (see page iii) titled, Document Traceability 2010 (Attachment 1) due date.

& Compliance, which states that the WBN2 PAMS SysRS was iii. WNA-SD-00239-WBT-P, Revision 3, Software created to support the WBN2 PAMS SysRS. Section 1.1, Requirements Specification for the Post Accident Purpose, of the WBN2 PAMS SDS states: The purpose of this Monitoring System, dated December 2010 document is to define the hardware design requirements (Attachment 7) iv. WNA-VR-00279-WBT, Revision 3, Watts Bar 2 (c) Do the WBN2 PAMS SRS and SDS, together, implement all of NSSS Completion Program I&C Projects the requirements in the WBN2 PAMS SysRS? Requirements Traceability Matrix for the Post Accident Monitoring System (available for NRC (e) Please briefly describe all of the documents that implement audit at the Westinghouse Rockville office) the WBN2 PAMS SysRS. To the best of TVAs knowledge, no prior NRC review of the software components has been performed.

(c) WNA-VR-00280-WBT, Revision 2, Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Reactor Vessel Level Indication System (RVLIS) Custom PC Elements (available for NRC audit at the Westinghouse Rockville office)

(d) No. Please see Item (e) below.

(e) The documents that describe the requirements that implement the WBN Unit 2 SysRS are:

i. WNA-VR-00279-WBT, Revision 3, Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System (available for NRC audit at the Westinghouse Rockville office) ii. WNA-VR-00280-WBT, Revision 2, Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Reactor Vessel Level Indication System (RVLIS) Custom PC Elements (available for NRC audit at the Westinghouse Rockville office)

Source: E-mail from Westinghouse (Matthew A. Shakun) to Bechtel (Mark S. Clark), RE: December 22 letter review, dated December 17, 2010 (Reference 13)

TVA Response to Follow-up NRC Request:

See Response to item 3 (Item number 142) 144 The WBN2 PAMS Software Requirements Specification (WBN2 Responder: WEC 13. N Open Open-NRC Review ML101650255, Item TVA Letter dated WBN2 PAMS Software Requirements EICB (Carte)

PAMS SRS) contains a table (see page iii) titled, Document No. 8 10/5/10 Specification Traceability & Compliance, which states that the WBN2 PAMS (a) The purpose of NABU-DP-00014-GEN document is to Pending Submittal of Revision 3 of Due 3/29/11 define the process for system level design, software design SRS was created to support the three documents identified (two of the Licensing Technical Report due By letter dated April 8, 2010 these documents have been provided on the docket). and implementation, and hardware design and 3/29/11. Responses to items a (ML10101050203), TVA docketed implementation for Common Q safety system development. and e provided. WNA-SD-00239-WBT, Revision 1, (a) Please describe the third document (i.e., NABU-DP-00014-GEN This document supplements the Common Q SPM, WCAP- "RRAS Watts Bar 2 NSSS Completion Revision 2, Design Process for Common Q Safety Systems). 16096-NP-A. The scope of NABU-DP-00014-GEN includes Revised response included in letter NNC 11/18/10: Program I&C Projects, Software the design and implementation processes for the application dated 12/22/10 (1) Items b-d closed to Requirements Specification for the Post (b) Please describe the flow of information between these three development. For a fuller description of the design process other Open Item nos. Accident Monitoring System, dated

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N documents. described in NABU-DP-00014-GEN please refer to the Response provided in letter dated (2) The point of these February 2010 (ML101050202).

Design Process for AP1000 Common Q Safety Systems, 10/5/10 questions was to (c) Does the PAMS SRS implement the requirements in these WCAP-15927 on the AP1000 docket. Since this is a understand how the three documents? Westinghouse process document that is not specifically NRC Review and WEC to complete origin of the referenced in the SRS, it will be removed in the next revision response. requirements in the (d) Please describe if and how these three documents are used in of the document. requirements the development of the PAMS Software Design Description. b-d to be addressed at public specifications were (b) - Closed to items 142 and 145 meeting and audit. Will require documented. TVA (e) Do the WBN2 V&V activities include verification that the information to be docketed. stated that the origin of requirements of these three documents have been incorporated (c) - Closed 142 the requirements would into the WBN2 PAMS SRS. be demonstrated in (d) - Closed to Item 142 Rev. 2 of the CQ PAMS LTR.

(e) WBN2 PAMS Software Requirements Specification (WNA-SD-00239-WBT, Rev. 1) refers to Document NNC 2/3/11: CQ Traceability & Compliance table on page iii. This table has PAMS LTR Rev. 2 three entries; Design Process for Common Q Safety Section 11 & 12 do not Systems (NABU-DP-00014-GEN, Rev. 2), RRAS Watts Bar adequately 2 NSSS Completion Program I&C Projects Post Accident demonstrate the origin Monitoring System - System Requirements Specification of requirements in (WNA-DS-01617-WBT, Rev. 1), and RRAS Watts Bar 2 SysRS. TVA to NSSS Completion Program I&C Projects Post Accident describe how to Monitoring System - System Design Specification (WNA- address concern.

DS-01667-WBT, Rev. 1).

IV&V performed a Requirements Traceability Assessment during which it reviewed Software Requirements Specification (WBN2 PAMS SRS, WNA-SD-00239-WBT, Rev. 1) against System Requirements Specification (WNA-DS-01617-WBT, Rev. 1) and System Design Specification (WNA-DS-01667-WBT, Rev. 1). Requirements within Software Requirements Specification that are referring to NABU-DP-00014-GEN, Rev 2, Design Process for Common Q Safety Systems, have also been reviewed for traceability and compliance. During IV&V's RTA effort the anomaly reports V&V-769 and V&V- 770 have been initiated and reported in the IV&V Phase Summary Report for the System Definition Phase, WNA-VR-00283-WBT, Rev. 0.

IV&V has verified that the requirements in SRS are derived from the specified documents listed in the Document Traceability and Compliance Table of WBN2 PAMS SRS.

TVA Response to Follow-up NRC Request:

(1) Item (a) in the original list, NABU-DP-00014-GEN Revision 2, Design Process for Common Q Safety Systems, is available for NRC audit at the Westinghouse Rockville office.

(2) WNA-LI-00058-WT-P, Revision 2, Post-Accident Monitoring System (PAMS) Licensing Technical Report submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1) contains the following change to address the NRC request:

Section 11, TVA Contract Compliance Matrix showing the origin of the requirements was added.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N TVA Response to Second Follow-up NRC Request:

Section 13, Origin Tracing of WBN2 PAMS System Requirements Specification was added to the Licensing Technical Report Revision 3 to address this concern.

Attachment 2 contains WNA-LI-00058-WBT-P, Post-Accident Monitoring System (PAMS) Licensing Technical Report, Revision 3, dated March 2011 (proprietary).

145 The WBN2 PAMS System Design Specification (WBN2 PAMS Responder: WEC 14. N Open Open-NRC Review ML101650255, Item WBN2 PAMS System Design EICB (Carte)

SDS) contains a table (see page iii) titled, Document Traceability No. 9 Specification

& Compliance, which states that the WBN2 PAMS SDS was (1) The review and update of the RTM is complete. The Response included in letter dated Due 2/25/11 created to support the WBN2 PAMS SysRS. revised RTM can be made available for NRC audit at 12/22/10 TVA docketed WNA-DS-01667-WBT the Westinghouse office in Rockville. To be addressed by Rev. 1, RRAS Watts Bar 2 NSSS (a) Does the WBN2 PAMS SDS implement all of the hardware During the September 20-21, 2010 Revision of the RTM, Completion Program I&C Projects Post requirements in the WBN2 PAMS SysRS? (2) Please see letter Item 10 (NRC Matrix Item 142, sub audit at Westinghouse, it was SRS, SysRS, and Accident Monitoring System- System item 13). acknowledged that SysDS. Design Specification, dated December (b) Please briefly describe all of the documents that implement the TVA/Westinghouse had previously 2009.

hardware requirements of the WBN2 PAMS SysRS. (3) Please see letter Item 10 (NRC Matrix Item 142, sub (in September 15, 2010 public item 12). meeting) stated:

This item is used to track all traceability issues with the System Design Specification (SDS). (4) Section 11 TVA Contract Compliance Matrix was TVA would provide the RSED RTM.

added to WNA-LI-00058-WBT-P, Revision 2, Post- (see ML102920031 Item No 6)

At the September 15 public meeting in Rockville, the following Accident Monitoring System (PAMS) Licensing actions were agreed to. These items partially address the Technical Report submitted in TVA Letter to NRC TVA would revise and resubmit the traceability concerns with the System Design Specification. dated December 3, 2010, (Reference 1). PAMS RTM to address all types of This item will be updated with the results of the September 20 issues identified in the public and 21 Commercial Grade Dedication and SDS RTM audit. (5) WNA-VR-00283-WBT, Revision 1, IV&V Summary meeting. (see ML102920031 Item Report for the Post Accident Monitoring System, No 7)

1. Westinghouse will perform completed a review of the submitted in TVA to NRC letter dated December 3, Requirements Traceability Matrix(RT), using the issues 2010 (Reference 1) includes the Requirements and TVA would revise and resubmit the identified at the 9/15 public meeting as a guide (documented Design phase reviews. Software Verification and Validation below) and update the RTM as required. phase summary report for the (6) Per Westinghouse letter WBT-D-2268 NRC Access to requirements phase to document

2. Some hardware requirements are contained in the SRS Common Q Documents at the Westinghouse Rockville the completion of the requirements instead of the System Design Specification (SDS). These will Office dated August 16, 2010 (Reference 9) System phase review. (see ML102920031 be removed from the SRS and incorporated into the next Requirements Specification for the Common Q Generic Item No 8) revision of the SDS. Flat Panel Display, 00000-ICE-30155, Revision 9 is available for audit at the Westinghouse Rockville office.

3. 25 issues identified by V&V where some requirements have not been included in the SDS (14) and SRS (11) at the The generic AC160 specifications are contained in the revisions reviewed by V&V. Have these been addressed? documents listed below. The documents are available Yes. The next revisions of the SDS and SRS address these for NRC audit at the Westinghouse Rockville office in issues. accordance with the letter number referenced. List is contained in letter.

4. TVA will update the Procurement Requisition Resolution Matrix and submit it to show how the Common Q PAMS (7) A schedule was developed and is reviewed weekly by design meets the contract requirements. Westinghouse and TVA project management.

5. The next issue of the IV&V report will include the (8) The revised document submittal schedule was Requirements phase review of the RTM and a partial review included as item 3 NRC Request (Matrix Item Number for the Design phase. 142, TVA Commitments Nos. 10 and 17) in TVA letter to NRC dated October 26, 2010.

6. Westinghouse to provide the generic AC160 and flat panel specifications. (9) The flow of documentation information was provided to the NRC inspector during the Common Q PAMS audit.

7. Westinghouse and TVA to develop a schedule of licensing document submittals that can be met by the project team. Source: E-mail from Westinghouse (Andrew P. Drake) to Bechtel (Mark S. Clark), RE: RAI on SysRS, dated

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

8. The flow of information is from the SysRS to the SDS December 8, 2010 (hardware) and SRS (software). Describe how the documents are used. Describe in 1.1 of the SysRS. Need a TVA Response to Follow-up NRC Request:

good write up of how the process works.

See Response to item 3 (Item number 142) 146 6/17/2010 Responder: 138. Y Closed Closed ML101650255, Item PAMS System Requirements EICB (Carte)

No. 10 Specifications Deleted by DORL WBN2 PAMS documents reference generic PAMS documents, for example:

WBN2 PAMS SysRS

References:

00000-ICE-30156 Rev. 6, System Requirements Specification for the Common Q Post Accident Monitoring System, and 00000-ICE-30155, Rev. 9, System Requirements Specification for the Common Q Generic Flat Panel Display 147 6/17/2010 Responder: 139. Y Closed Closed ML101650255, Item PAMS System Requirements EICB (Carte)

No. 11 Specifications Deleted by DORL WBN2 PAMS documents reference generic PAMS documents, for example:

WBN2 PAMS SysRS

References:

00000-ICE-30156 Rev. 6, System Requirements Specification for the Common Q Post Accident Monitoring System, and 00000-ICE-30155, Rev. 9, System Requirements Specification for the Common Q Generic Flat Panel Display 148 6/17/2010 Responder: 140. Y Closed Closed ML101650255, Item PAMS System Requirements EICB (Carte)

No. 12 Specifications Deleted by DORL WBN2 PAMS documents reference generic PAMS documents, for example:

WBN2 PAMS SysRS

References:

00000-ICE-30156 Rev. 6, System Requirements Specification for the Common Q Post Accident Monitoring System, and 00000-ICE-30155, Rev. 9, System Requirements Specification for the Common Q Generic Flat Panel Display 149 7.2 7.2 FSAR Section 7.1.1.2(2), Overtemperature delta T and Responder: Tindell 141. Y Close Closed ML101720589, Item TVA Letter dated EICB (Garg)

Overpressure delta T equations have been simplified and many No. 1 10/5/10 values are removed from the FSAR. Provide the justification for In FSAR amendment 96 the equations were revised to agree Response provided in letter dated TVA to provide date this change. with the Unit 1 UFSAR which is the basis document for the 10/5/10 when information will TVA Letter dated Unit 2 FSAR. This resulted in the equations being simplified be docketed. TVA 10/29/10 and the removal of the values for the constants. The need to identify when Enclosure 1 Item equations were revised to match those used in the Technical In FSAR amendment 96, the values Unit 1 UFSAR was No. 11 Specifications. The values for the constants are contained in of the constants have been moved revised with this the Technical Specifications and were removed as to TS or plant procedures. Need to information.

redundant. document the basis for this change.

Additional changes were made in FSAR amendments 98 Response is acceptable.

and 99 to correct typographical errors found during FSAR

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N review.

TVA Revised Response:

This change was incorporated in the Unit 1 FSAR in Amendment 0 as part of FSAR change package 1473.

150 7.2 7.2 Many of the changes were based on the Westinghouse document Responder: Clark 142. Y Close Closed ML101720589, Item TVA Letter dated EICB N3-99-4003. Provide this document for staffs review so the staff Response provided in letter dated No. 2 10/5/10 (Garg) can determine the basis for these changes. System description N3-99-4003, Reactor Protection System 10/5/10 is contained in Attachment 3.

151 7.2 7.2 Provide the EDCR 52378 and 54504 which discusses the basis for Responder: Clark 143. Y Close Closed ML101720589, Item TVA Letter dated EICB (Garg) many changes to this FSAR section. No 3 10/5/10 EDCR 54504 has been voided and replaced with EDCR Response provided in letter dated 52378 which is contained in Attachment 4 and EDCR 52671 10/5/10 is contained in Attachment 5.

152 7.2 7.2 Deleted portion of FSAR section 7.2.3.3.4 and moved to FSAR Responder: Merten/Clark 144. Y Close Closed ML101720589, Item TVA Letter dated EICB (Garg) section 7.2.1.1.5. However, the FSAR section 7.2.1.1.5 does not No. 4 10/5/10 include the discussion of ambient temperature and also on the The text was revised to match the Unit 1 UFSAR. The Unit 1 Due 10/22/10 calibration of the sealed reference leg system. No justification was text was modified in Amendment 1 by FSAR Change TVA Letter dated provided for deleting this discussion. Please explain the bases for Package 1553 S00 which is contained in Attachment 30. TVA to confirm if this 10/29/10 deletion of this information. The basis for the change in the change package is: description is the same Enclosure 1 Item as for Unit 1. If it is No. 12 16 The update to Section 7.2.1.1.5 is taken from text in same as Unit 1 then Section 7.2.2.3.4 with clarifications and editorial changes. why this was shown as The relocated discussion of the pressurizer water level change in redline instrumentation Is more appropriately included in this section version of FSAR than Section 7.2.2.3.4, which deals with control and Amendment 96.

protection system interaction. The changes to 7.2.1.1.5 are based on a general description of the Westinghouse TVA to provide date pressurizer level design, channel independence, and actual when information will installation attributes found on TVA physical drawings. Also, be docketed. When the hydrogen gas entrainment issue documented in NRC Unit 1 UFSAR was Information Bulletin No. 92-54, Level Instrumentation revised.

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.

TVA Revised Response:

This change was incorporated in the Unit 1 UFSAR in Amendment 1.

(

153 7.2 7.2 G FSAR section 7.2.1.1.7 added the reference to FSAR section Responder: Craig/Webb 145. Y Close Closed ML101720589, Item TVA Letter dated

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 10.4.4.3 for exception to P-12. However, FSAR section 10.4.4.3 No. 5 10/21/10 states bypass condition is not displayed and it is not automatically EDC E50952-A added an alternate method of RCS Response provided in letter dated Due 10/22/10 Enclosure 1 Item removed when conditions for bypass are no longer met. Provide cooldown using additional steam dump valves after entering 10/21/10 No. 2 the basis for this. Mode 4, by disabling the P-12 Interlock. Operators use TVA will send 50.59.

additional condenser dump valves to aid in maintaining a cooldown rate closer to the administrative limit established TVA to provide date by operating procedure. when information will be docketed. TVA did Refer to Unit 1 UFSAR Amendment 3 Change Package not address why 1676 S00 (Attachment 6) for the safety evaluation and basis bypass condition is not for this change. displayed.

The 50.59 for the change is included in the Change Package.

The process is controlled by the procedures used to shutdown the plant. The procedure initiates the bypass by lifting a wire at a relay and then ensures that it is restored prior to starting the plant. GO-6 Unit Shutdown From Hot Standby To Cold Shutdown, Appendix F prescribes the steps required to bypass and restore the P-12 interlock. GO-6 Appendix F, step 3.0[6] says PLACE Caution Order on 1-HS-1-103A, 1-HS-1-103B, AND 1-PIC-1-33 indicating that P-12 interlock is disabled. This provides indication to the operators that the P-12 interlock is bypassed. GO-6 Appendix F, step 4.0[1] says WHEN steam dumps no longer affect plant cooldown OR plant heatup is desired, THEN ENSURE MIG re-enables P-12 Interlock USING Section 6.0 of this Appendix, LANDING LEADS TO RE-ENABLE P-12 INTERLOCK. GO-6 Appendix F, step 4.0[2] states REMOVE Caution Order on 1-HS-1-103A, 1-HS-1-103B, AND 1-PIC-1-33 indicating that P-12 interlock is disabled.

154 7.2 7.2 FSAR section 7.2.1.1.10, setpoints: NRC staff has issued RIS Responder: Craig/Webb 146. Y Closed Closed ML101720589, Item TVA Letter dated EICB RAI ML102861885 sent to DORL EICB (Garg) 2006-17 to provide guidance to the industry regarding the No. 6 and EICB RAI 10/5/10 instrument setpoint methodology which complies with 10 CFR (Q1) Refer to the response to letter item 13, RAI Matrix Item Response is not acceptable. A Due 12/17/10 ML102861885 Item 50.36 requirements. Provide the information on how the WBN2 51. revised response will be submitted No. 8 TVA Letter dated setpoint methodology meets the guidance of RIS 2006-17 and in the letter dated 10/29/10. Pending FSAR 10/29/10 include this discussion in this section. Also, by letter dated May 13, (Q2) EEB-TI-28's single sided methodology conforms with Amendment 102 Enclosure 1 Item 2010, TVA provided Rev. 7 of EEB-TI-28 to the staff. The staff WBN's design basis commitment to ensure that 95% of the submittal. No. 13 noted that section 4.3.3.6 of EEB-TI-28 discusses the correction for analyzed population is covered by the calculated tolerance setpoints with a single side of interest. It should be noted that the limits as defined in NRC Reg Guide 1.105, Revision 2, 1986 FSAR AMD 100. Since staff has not approved this aspect of setpoint methodology for Unit that was in affect during WBN Unit 1 licensing. The single all the setpoint and

1. The staff finds this reduction in uncertainties is not justified sided methodology is not used for any TSTF-493 setpoints allowable value for Unit unless it can be demonstrated that the 95/95 criteria is met. that use TI-28 methodology. 2 is calculated and Therefore, either remove this reduction factor for single sided added to TS, TVA uncertainties or justify how you meet the 95/95 criteria given in RG TVA Revised Response: needs to address the 1.105. latest criteria and that In order to respond to other NRC comments on the setpoint include 95/95 criteria.

methodology discussion in FSAR Amendment 100, TVA Why the last sentence reviewed the previous response to this RAI. This resulted in has been modified by a complete rewrite of the responses to this question as adding TI-28. It was shown below. As a result, the response does not specifically NRCs understanding address the NRC Follow-up Request. However, the overall that all setpoints have responses to all of the NRC RAIs on setpoint methodology to meet TI-28 addresses this item.

(Q1) WBN 2 implementation of TSTF-493, Rev. 4, Option A includes addition of a discussion of the

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N WBN setpoint methodology in FSAR section 7.1.2.1.9.

(Q2) Electrical Engineering Branch (EEB) Technical Instruction (TI) 28, Setpoint Calculations, single-sided methodology conforms to 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, which was in effect during WBN Unit 1 licensing. Single-sided multipliers are not used for any TSTF-493 setpoints.

There are some areas where a 95% confidence level could not be achieved. Some examples would be harsh environment instrumentation where only 2 or 3 devices were tested in the 10CFR50.49 program. In these situations, the Confidence is referred to as high..

155 7.2 7.2 Summary of FSAR change document section 7.2 states that Date: 147. Y Closed Closed ML101720589, Item EICB (Garg) sections 7.2.1.1.9 and 7.2.2.2(4) are changed to show that these Responder: Stockton No. 7 activities will occur in future. However, no changes were made to TVA to provide date the FSAR sections. Please explain. The change package summary were the changes when information will recommended by Engineering. TVA Licensing is responsible be docketed 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.

156 7.2 7.2 FSAR section 7.2.2.1.1 states that dashed lines in Figure 15.1- Responder: WEC 148. Y Closed Closed ML101720589, Item TVA Letter dated Response on hold pending EICB (Garg) 1designed to prevent exceeding 121% of power.The value No. 8 10/5/10 Westinghouse review.

of 121% is changed from 118%. The justification for this change Per Westinghouse letter WBT-D-2340, TENNESSEE Revised response included in letter Due 12/22/10 states that this was done to bring the text of this section in VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT dated 12/22/10.

agreement with section 4.3.2.2.5, 4.4.2.2.6 and table 4.1-1. UNIT 2 FSAR Markups Units I and 2 118% vs. 121 % and Amendment 101 However, Table 4.1-1 and section 4.3.2.2.5 still show this value as Correction to RAI Response SNPB 4.3.2-7, (Reference 17) Response is included in letter dated Submitted 10/29/10.

118%. Justify the change. the 118% value should be 121%. Depending on the use in 10/5/10 the FSAR either 118% or 121% are the correct values. As a TVA needs to justify result of the question, Westinghouse reviewed all locations why some places 121%

where either 118% or 121% are used and the context of use is used and other and provided a FSAR markup to reflect the correct value at places 118% is used .

the specific location. These changes will be incorporated in What does 121% or a future FSAR amendment. 118% means.

TVA Response to Follow-up NRC Request:

The following response was provided by Westinghouse letter WBT-D-2690 Follow Up -NRC Request on 118% and 121 %

FSAR Power Levels, dated December 6, 2010 (Reference 2). This corrects the information provided in TVA letter to NRC letter dated October 5, 2010 (Reference 21)

A review of the markups provided by Westinghouse (Reference 4) and the current Unit 2 FSAR shows that in the context of the Power Range High Neutron Flux, High Setting, the value of 118% is correct. In the context of the peak core power during certain transients to confirm the fuel melt criterion, the value of 121% is correct. A detailed discussion of peak core power during transients is contained in FSAR Chapter 4.3.2.2.5, Limiting Power Distributions.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 157 7.2 7.2 FSAR section 7.2.2.1.1, fifth paragraph was deleted except for the Responder: Tindell 149. Y Close Closed ML101720589, Item TVA Letter dated EICB (Garg) last sentence. The last sentence states that, The P-8 interlock No. 9 10/5/10 acts essentially as a high nuclear power reactor trip when The condition is defined in the preceding discussion as Response provided in letter dated operating in this condition. This sentence is confusing because operating with a reactor coolant pump out of service and 10/5/10 the condition is not defined. Please clarify this discrepancy. core power less than 25%.

Response Acceptable 158 7.2 7.2 FSAR section 7.2.2.1.1, paragraph six was changed to state that Responder: Tindell 150. Y Closed Closed ML101720589, Item TVA Letter dated EICB (Garg) the design meets the requirements of Criterion 23 of the 1971 GDC No. 10 10/5/10 instead of the Criterion 21 of the GDC. The Criterion 21 is about FSAR Amendment 99 reflects the change to Criterion 23. Response provided in letter dated protection system reliability and testability, while Criterion 23 is 10/5/10 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.

159 7.2 7.2 FSAR section 7.2.2.1.2 discusses reactor coolant flow Responder: Craig 151. Y Close Closed ML101720589, Item TVA Letter dated EICB (Garg) measurement by elbow taps. However, it further states that for No. 11 10/5/10 Unit 2, precision calorimetric flow measurement methodology will For the purposes of measuring reactor coolant flow for Response provided in letter dated Due 10/31 be used. If elbow taps are not used for Unit 2, then why does this Reactor Protection functions, elbow taps are used for both 10/5/10 section discuss this methodology? It is the staffs understanding Unit 1 and 2. The discussion and equation are valid for that TVA plans to use elbow taps methodology in the future for Unit establishing the nominal full power flow which is used to Response Acceptable

2. Please revise this section to describe the current plant establish the Reactor Protection System low flow trip design/methodology. setpoint. 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. The plan is for Unit 2 to transition to this method after sufficient data is obtained. Pending this transaction, 7.2.2.1.2 will be revised as follows:

From:

Nominal full power flow is established at the geginning of each fuel cycle by either elbow tap methodology or, performance of the RCS calorimetric flow measurement, (For Unit 1 elbow tap methodology is implemented for RCS flow measurement (Reference [17]) and Unit 2 may implement elbow tap methodology at a future date) the results of which are used to normalize the RCS flow indicators. This provides a reference point for the low flow reactor trip setpoint, and also provides a relatively simple method for periodic verification of the thermal design flow assumed in the safety analysis, as required by the Technical Specifications.

Accuracy and repeatability of the flow measurement instrumentation are considered in establishment of the low flow setpoint and the minimum required flow and are adequate for these functions. This is for Unit 1 only. For Unit 2, the precision calorimetric flow measurement methodology will be used.

To:

Nominal full power flow is established at the beginning of each fuel cycle by either elbow tap methodology or, performance of the RCS calorimetric flow measurement.

Unit 1 utilizes elbow tap methodology Reference [17]. Unit 2 utilizes the RCS calorimetric flow measurement. The results are used to normalize the RCS flow indicators and provide a

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N reference point for the low flow reactor trip setpoint.

160 7.2 7.2 FSAR section 7.2.2.2(7) deleted text which has references 12 and Responder: Tindell 152. Y Close Closed ML101720589, Item TVA Letter dated EICB (Garg)

14. These references are not included in the revised text. Provide No. 12 10/5/10 the basis for the deletion of these references. Also, the revised The text was revised to match the Unit 1 UFSAR. The Unit 1 Response provided in letter dated 10/21 text states that typically this requirement is satisfied by utilizing 2/4 text was modified in Amendment 1 by FSAR Change 10/5/10 logic for the trip function or by providing a diverse trip. Provide any Package 1553 S00 which is contained in Attachment 30.

exception to this and their basis for acceptability. 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.

161 7.2 7.2 FSAR section 7.2.2.3 states that changes to the control function Responder: Clark 153. Y Closed Closed ML101720589, Item TVA Letter dated EICB (Garg) description in this section are expected to be required after vendor No. 13 10/5/10 design of the Unit 2 Foxboro IA design is complete. Provide the FSAR Amendment 99 reflects the changes associated with Response provided in letter dated schedule for the completion of the design and when this the Foxboro I/A system design. 10/5/10 information will be available to the staff for review and approval.

162 7.2 7.2 FSAR section 7.2.2.2(14) states that bypass of a protection Responder: Tindell 154. Y Closed Closed ML101720589, Item TVA Letter dated EICB (Garg) channel during testing is indicated by an alarm in the control room. No. 14 10/5/10 Explain how this meets RG 1.47. The Bypassed and Inoperable Status Indication System Response provided in letter dated (BISI) compliance with Reg. Guide 1.47 is described in detail 10/5/10 in FSAR Section 7.5.2.2.

163 7.2 7.2 CB (G Deleted by DORL Date: 155. Y Closed Closed ML101720589, Item ar Responder: No. 15 164 7.2 7.2 FSAR section 7.2.2.2(20) has been revised to include the plant Responder: Perkins 156. Y Closed Closed ML101720589, Item TVA Letter dated Item No. 8 sent to DORL EICB (GarglMarcus) 7.5.1. computer as a means to provide information read out for all signals No. 16 and EICB 10/5/10 1 which can cause a reactor trip. Justify the use of the plant The primary purpose of the plant computer is to present Response provided in letter dated NRC to issue formal RAI ML102861885 computer for this function. Include the discussion on the effect of plant process and equipment status information to the 10/5/10 RAI to TVA Item No. 8 plant computer failure on the system functions. control room operators to assist them in the normal operations of the unit, and inform them of any abnormal conditions. The plant computer obtains real-time plant TVA letter dated 10/5/10 Response parameter information via Data Acquisition 44 provided information.

Systems(DAS)(multiplexers, etc.) by scanning preassigned analog, pulse, and contact sensors located throughout the plant. The computer is not defined as being primary safety-related and it is not required to meet the single failure criterion or be qualified to IEEE criteria for Class 1E equipment.

The plant computer system acquires, processes, and displays all data to support the assessment capabilities of the Main Control Room (MCR). To help ensure that reactor trip and other information presented to the Operations staff is reliable:

• The data undergoes several validation steps before being presented to the operators. When redundant sensors are used, the data received by the computer can be processed by software to determine if the quality of one or more points

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N is questionable.

• Any software associated with the computer and the DAS must meet the quality requirements of plant procedure SPP-2.6, Computer Software Control which is based on requirements in NUREG/CR-4640, the Watts Bar Nuclear Quality Assurance Plan, and SS-E18.15.01 - Software Requirements for Real-Time Data Acquisition and Control Computer Systems, which complies with IEEE Std. 279-1971 Criteria for Protection Systems for Nuclear Power Generating Stations. The computer software is controlled by a Software Quality Assurance Plan.

• One of the requirements in 10 CFR 50, Appendix A states that Appropriate controls shall be provided to maintain variables monitored and systems within prescribed operating ranges. Periodic maintenance and calibration will be performed on the computer and DAS. In addition, calibration procedures for instrumentation which is used for input to the computer include verification of the computer input signal at the DAS and as displayed on the display stations.

• The software and associated hardware undergoes a detailed Factory Acceptance Test prior to installation in the plant. After installation in the plant, a Site Acceptance Test (SAT) will be conducted. The SAT will include several tests:

computer accuracy, analog input accuracy, calculated value accuracy, computer performance, system response times, all input/output (from termination strip to display stations/printers), all data ports, and computer power supplies.

• In order to minimize the possibility of bad sensor inputs to the Safety Parameter Display System (SPDS) and/or inaccurate SPDS display of sensor inputs, routine instrument loop calibration of sensors that provide input to the SPDS will include verification that the SPDS-displayed values are correct. WBN's instrument surveillance instructions will incorporate these verifications.

Effect of plant computer failure on system functions The WBN Unit 2 is designed on the basis that it can still operate when the plant computer is inoperable. The computer is not required for safe shutdown of the plant during external design basis events such as tornadoes, floods, rain, and transportation accidents. Operators are trained to respond to accidents both with and without the computer information available. The control room instrumentation provides the operators with the information necessary for safe reactor operations under normal, transient, and accident conditions.

The DAS is mechanically and electrically isolated from the safety systems to avoid degradation of the systems should the computer and/or DAS fail.

The computer is not expected to perform any nuclear safety-related function, therefore, the computer need not be designed to meet nuclear safety-related Class 1E, single-

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N failure criteria. The computer is not designed to safety system criteria and therefore is not to be used to perform functions essential to the health and safety of the public.

165 7.2 7.2 FSAR section 7.2.2.3.2, last paragraph of this section has been Responder: Clark 157. Y Closed Closed ML101720589, Item TVA Letter dated EICB (Garg) deleted. The basis for this deletion is that discussion regarding the No. 17 10/5/10 compliance with IEEE-279, 1971 and GDC 24 is covered in section The reference to Section 7.2.2.2 for the general discussion Response provided in letter dated 7.2.2.2. However, there is no reference to this section in 7.2.2.3.2 for control and protection interactions is provided in Section 10/5/10 to direct the reader to 7.2.2.2. Please revise 7.2.2.2 accordingly. 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.

166 7.2 7.2 Changes to FSAR section 7.2.2.2(20) are justified based on the Responder: Clark 158. Y Closed Closed ML101720589, Item TVA Letter dated EICB statement that the integrated computer system is implemented No. 18 10/5/10 (Garg) through EDCR 52322. Provide a copy of EDCR 52322 for staff EDCR 52322 is contained in Attachment . Response provided in letter dated review. 10/5/10 167 7.2 7.2 FSAR section 7.2.2.4, provide an analysis or reference to chapter Responder: Clark 159. Y Close Closed ML101720589, Item TVA Letter dated EICB (Garg) 15 analysis which demonstrate that failure of rod stop during a rod No. 19 10/5/10 withdrawal event will not affect the safety limit. Continuous rod withdrawal events are analyzed in FSAR Response provided in letter dated sections 15.2.1 and 15.2.2. While the rod stops a 10/5/10 mentioned, they are not credited in the analysis.

168 7.2 7.2 FSAR table 7.2-4, item 9 deleted loss of offsite power to station Responder: Clark 160. Y Close Closed ML101720589, Item TVA Letter dated EICB (Garg) auxiliaries (station blackout) based on the fact that station blackout Response provided in letter dated No. 20 10/5/10 is not listed in AAPC events. Explain what are AAPC events and This change is in accordance with the Unit 1 UFSAR. The 10/5/10 how it justifies deleting this accident from the list. change was made by FSAR Change Package 1553 S00 (Attachment 30). 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 6/18/2010 Responder: Clark 161. Y Closed Closed EICB (Garg)

Describe the design changes which were made to Unit 1 by This is a duplicate of items 2, 10, 11 and 44 10CFR50.59 process and which significantly affect the instrumentation and controls systems discussed in FSAR Chapter 7.

170 6/17/2010 Responder: Clark 162. Y Closed Closed EICB (Garg)

TVA needs to document that Arnold Magnetics power supplies This is a duplicate of item 113.

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

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N discuss the qualification of these power supplies based on the guidance provided in RG 1.209 (Open Item # 2 of Eagle 21 audit.)

171 7.2 7.2 6/17/2010 Responder: Craig 163. Y Closed Closed EICB RAI TVA Letter dated Closed to SE Open Item EICB (Garg)

ML102910008 10/21/10 An external unidirectional communications interface was installed The external Eagle 21 unidirectional communications Response provided in letter dated itemI#49 Enclosure 1 Item between the Eagle 21 test subsystem and the plant process interface will be tested prior to WBN Unit 2 fuel load 10/21/10 No. 3 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) 172 6/17/2010 Responder: Craig 164. Y Closed Closed EICB RAI EICB (Garg)

ML102910008 During a FAT diagnostic test, the Loop Calculation Processor This is a duplicate of the rack 5 update issue item 114. Item#50 (LCP) failed while performing a parameter update. TVA should identify the cause and fix for the problem encountered. (Open Item

1. 1 of Eagle 21 audit) 173 7.1 7.1 6/17/2010 Responder: Craig/Webb/Powers 165. Y Closed Closed EICB RAI EICB (Garg)

ML102910008 EEB-TI-28 discusses the correction for setpoints with a single side Please see the revised response to letter item 3 (I&C Matrix to OI 154 Item#51 of interest. The staff finds this correction factor is not justified. Item 154) question (Q1).

TVA should justify this correction factor and demonstrate that, with TVA to provide date this correction, factor 95/95 criteria identified in RG 1.105 is met. when information will be docketed 174 6/28/2010 Responder: Hilmes/Craig 166. Y Closed Closed EICB RAI EICB (Garg)

ML102910008 Placeholder: The staff has identified questions regarding Duplicate of 171 Item#52 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.

175 June 28, 2010 Responder: 167. Y Closed Closed EICB RAI EICB (Garg)

ML102910008 Placeholder: The staff has identified questions regarding diversity. WCAP-13869 rev.2. is submitted in response to item In FSAR amendment 98, reference This item is covered Item#53 The staff will keep this item open until TVA provides the related 6 added a new WCAP-13869 rev.2. under item 78.

WCAP to the staff for its review and approval. Has this WCAP been reviewed by the staff. If not then provide the TVA to provide date copy of WCAP for staff review. when information will be docketed.

176 7.1 7.1 6/28/2010 Responder: Craig/Webb 168. Y Closed Closed EICB RAI EICB (Garg)

ML102910008 Placeholder: The staff has identified questions regarding Setpoint methodology questions are addressed in the to OI 154 Item#54 instrument setpoints. The staff will keep the instrument setpoint revised response to letter item 3 (I&C Matrix Item 154).

methodology issue open until TVA provides additional information TVA to provide date regarding RIS 2006-17 and single sided correction factor for when information will uncertainty determination. be docketed 177 7.5.2. 7.5.1 7/15/2010 Responder: Clark 169. Y Closed Closed N/A TVA Letter dated RAI not required EICB (Marcus) 1 10/5/10 FSAR Amendment 99 Section 7.5.1.2 states: "Type A Variables The type A variables are the same in Unit 1 and Unit 2. See Response provided in letter dated 09/16/10 Those variables that provide primary information to the MCR calculation WBNOSG4047 Rev. 4 (Attachment ) 10/5/10 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 August 19, 2010 - TVA to submit Chapter 15 design basis events. Primary information is information calculation.

that is essential for the direct accomplishment of specified safety functions." Review of Unit 2 FSAR confirms Unit 1 and Unit 2 Type A variables

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Clarify whether Unit 2 has the same Type A variables as Unit 1. are the same.

Not necessary to docket WBNOSG4047.

178 7.5.2. 7.5.1 7/15/2010 Responder: Clark 170. Y Closed Closed N/A TVA Letter dated RAI not required EICB (Marcus) 1 10/5/10 Please provide WBN-OSG4-047, "PAM Type A Variable See response to item 177 above. Response provided in letter dated 09/16/10 Determination." 10/5/10 August 19, 2010 - TVA to submit calculation.

Review of Unit 2 FSAR confirms Unit 1 and Unit 2 Type A variables are the same.

Not necessary to docket WBOSG4047.

179 An emphasis is placed on traceability in System Requirements Responder: WEC 171. Y Closed Closed N/A - Closed to NA EICB (Carte)

Specifications in the SRP, in the unmodified IEEE std 830-1993, Item No. 142 and even more so given the modifications to the standard listed in Steve Clark to look at how to combine traceability items.

Regulatory Guide 1.172, which breaks with typical NRC use of the word should regarding backwards traceability to say Each Was addressed to during the 9/15 meeting and 9/20 - 9/21 identifiable requirement in an SRS must be traceable backwards to audit.

the system requirements and the design bases or regulatory requirements that is satisfies Closed to Item 142.

Discuss how TVA has ensured that there 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.

180 The SRP, BTP 7-14, Section B.3.3.1 states that Regulatory Guide Responder: WEC 172. Y Closed Closed N/A - Closed to NA EICB (Carte) 1.172 endorses, with a few noted exceptions, IEEE Std 830-1993. Item No. 142 IEEE Recommended Practices for Software Requirements Steve Clark to look at how to combine traceability items. TVA to provide date Specifications. when information will Will be addressed to during the 9/15 meeting and 9/20 - 9/21 be docketed Clarify whether the WBU2 Post Accident Monitoring Systems audit.

Software Requirements Specification adheres to IEEE std 830-1993 as modified by Regulatory Guide 1.172? Closed to Item 142.

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

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N corresponding SRP acceptance criteria.

181 An emphasis is placed on traceability in System Requirements Responder: WEC 173. Y Closed Closed N/A - Closed to NA EICB (Carte)

Specifications in the SRP, in the unmodified IEEE std 830-1993, Item No. 142 and even more so given the modifications to the standard listed in Steve Clark to look at how to combine traceability items.

Regulatory Guide 1.172, which breaks with typical NRC use of the word should to say Each identifiable requirement in an SRS must Will be addressed to during the 9/15 meeting and 9/20 - 9/21 be traceable backwards to the system requirements and the design audit.

bases or regulatory requirements that is satisfies Closed to Item 142.

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 Requirements Specification, what directed the author to include the requirement there?

182 Characteristics that the SRP states that a Software Requirements Responder: WEC 174. Y Closed Closed N/A - Closed to NA EICB (Carte)

Specifications should have include unambiguity, verifiability, and Item No. 142 style, part of the latter is that Each requirement should be uniquely Steve Clark to look at how to combine traceability items.

and completely defined in a single location in the SRS.

Will be addressed to during the 9/15 meeting and 9/20 - 9/21 Clarify whether the unnumbered paragraphs in the Post Accident audit.

Monitoring Systems Software Requirements Specification, such as in the section headings, or are all such sections simply considered Closed to Item 142.

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.]

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 7/15/2010 Responder: WEC 15. Y Open Open-NRC Review EICB RAI TVA Letter dated EICB (Carte)

ML102980066 Item 10/21/10 An emphasis is placed on traceability in System Requirements The generic Software Requirements Specification applies Pending Submittal of Revision 3 of Due 3/29/11 No. 9 Enclosure 1 Item Specifications in the SRP, in the unmodified IEEE std 830-1993, except as modified by the WBN Unit 2 System Requirements the Licensing Technical Report due No. 4 and even more so given the modifications to the standard listed in Specification. 3/29/11. NNC 11/18/10: The Regulatory Guide 1.172, which breaks with typical NRC use of the point behind this open word should to say Each identifiable requirement in an SRS must TVA Response to Follow-up NRC Request: item was that TVA must be traceable backwards to the system requirements and the design Revised response included in letter demonstrate that the bases or regulatory requirements that is satisfies Please see the response to RAI item 12 in letter dated dated 12/22/10. origin of each 12/22/10, NRC Matrix Item 144. requirement in the On page 1-2 of the Post Accident Monitoring Systems Software WEC requirements Requirements Specification in the background section, is the TVA Response to Second Follow-up NRC Request: Response provided in letter dated specification is known sentence Those sections of the above references that require 10/21/10 and documented. TVA modification from the generic PAMS are defined in the document This item was addressed by updating the Contract stated that this referring purely to the changes from WNA-DS-01617-WBT Post Compliance Matrix and adding Section 13, Origin Tracing of information would be in Accident Monitoring System-System Requirements Specification WBN2 PAMS System Requirements Specification to the CQ PAMS LTR Rev. 2.

or is it saying that there are additional changes beyond those and Licensing Technical Report Revision 3 to address this

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N that the SRS defines them? concern. Attachment 2 contains WNA-LI-00058-WBT-P, NNC 2/3/11: CQ PMS Post-Accident Monitoring System (PAMS) Licensing LTR Rev. 2 Sections 11 If there are additional changes, what is their origin? Technical Report, Revision 3, dated March 2011 & 12 do not prove this (proprietary). information. TVA to proive a plan to address requested information.

184 7/15/2010 Responder: WEC 175. Y Closed Closed N/A - Closed to N/A EICB (Carte)

Item No. 142 The NRC considers that a System Requirements Specification is Steve Clark to look at how to combine traceability items.

the complete set of requirements used for the design of the software, whether it is contained within one document or many. In Will be addressed to during the 9/15 meeting and 9/20 - 9/21 order to evaluate an SRS against the guidance in the SRP the staff audit.

needs access to all the requirements.

Closed to Item 142.

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?

185 7/15/2010 Responder: WEC 16. N Open Open-NRC Review EICB RAI EICB (Carte)

ML102980066 Item An emphasis is placed on the traceability of requirements in Steve Clark to look at how to combine traceability items. Response included in letter dated NNC 11/18/10: (1)The No. 17 Software Requirements Specifications in the SRP, in the 12/22/10. point behind this open unmodified IEEE std 830-1993, and even more so given the Was addressed to during the 9/15 meeting and 9/20 - 9/21 item was that TVA must modifications to the standard listed in Regulatory Guide 1.172, audit. demonstrate that the which breaks with typical NRC use of the word should to say origin of each Each identifiable requirement in an SRS must be traceable TVA Response to Follow-up NRC Request: requirement in the backwards to the system requirements and the design bases or (1) See NRC Matrix Item 144 WEC requirements regulatory requirements that is satisfies Also the NRC considers (2) There is no RTM for development of the individual specification is known that the SRS is the complete set of requirements used for the reusable software elements. As listed in item 15 of and documented. TVA design of the software, whether it is contained within one document Table 6-1 Document Requirements of WNA-LI-00058- stated that this or many. In order to evaluate an SRS against the guidance in the WT-P, Revision 2, Post-Accident Monitoring System information would be in SRP the staff needs access to all the requirements. (PAMS) Licensing Technical Report submitted in TVA CQ PAMS LTR Rev. 2.

Letter to NRC, dated December 3, 2010, a RTM for (2) TVA also said it References 12, 27, 29, and 31-44 in the Post Accident Monitoring implementation of the RSEDs (WNA-VR-00280-WBT) would provide a RTM Systems Software Requirements Specification are various types of for the WBN Unit 2 Common Q PAMS has been for the RSED Reusable Software Element. developed. This document is available for NRC audit at the Westinghouse Rockville office. NNC 2/3/11: To be These references are used in the body of the SRS, for example: addressed during next audit.

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

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

[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?

186 7.7.8 7.7.1.12 7/15/2010 Responder: Perkins/Clark 176. Y Closed Closed EICB RAI No.6 TVA Letter dated EICB (Darbali)

ML102910017, 10/5/10 Along with Amendment 96, TVA submitted a list of Bechtel No. The previous wording reflected operation of the Response included in letter dated 10/19/10 changes for each section. Change number 45 addresses a change computer based AMSAC system. The change reflects the 10/29/10 TVA Letter dated to section 7.7.1.12, AMSAC, however, the Justification column operation of the relay logic based system that replaced the 10/29/10 states This change is not included. EDCR 52408 installs the original computer based system in Unit 1. Unit 2 is installing Enclosure 1 Item AMSAC in Unit 2. It does not have a trouble alarms. The existing a similar relay logic based system, so the change to the Unit Response is satisfactory. No. 14 words better reflect the operation of the system. 1 wording is applicable to Unit 2.

Follow-up NRC Request:

Even thought this change was not included in Amendment 96, will EDCR 52408 Summary it be included in a future amendment? TVA to state that no further FSAR A Purchase Order was issued to Nutherm International to changes are planned.

Also, please submit a summary of EDCR 52408. 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.

In the Main Control Room, three cables will be installed for the AMSAC handswitch on 2-M-3 and AMSAC NOT ARMED and AMSAC ACTUATED annunciator windows.

In the Turbine Building, two pressure transmitters will be installed in two local panels to sense turbine pressure.

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.

In the Control Building, three cables will be routed to separation relays which will provide the start signal for the Motor Driven Auxiliary Feedwater Pumps, Turbine Driven Auxiliary Feedwater Pump, and initiate a Turbine Trip.

Additionally, a cable will be routed to Unit 2 ICS for AMSAC NOT ARMED and AMSAC ACTUATED log points.

This EDCR is intended to configure Unit 2 AMSAC like Unit 1 when possible.

TVA Revised Response:

No further changes to the FSAR associated with AMSAC are planned.

187 By letter dated June 18, 2010, TVA docketed responses to NRC Responder: Merten 177. N Closed Closed ML101970033, Item TVA Letter dated Are these connections already EICB (Carte) requests for information. No. 1 & 2 10/5/10 docketed?

1) Please refer to the revised response to letter dated Revised response included in letter

1) Enclosure 1, Item No. 33 of the TVA letter dated June 18, 2010, 10/5/10 Item 18 (RAI Matrix item 115). dated 12/22/10.

did not identify any connection from the PAMS Operator Modules (OMs) to the plant computer and printers; however, Figure 2.1-1 of Partial Response provided in letter the PAMS System Requirements Specification (WNA-DS-01617- dated 10/5/10 WBT Rev. 1 - ML101680578) shows a TCP connection from the OMs to the plant computer and printer. Please explain. NNC 8/25/10: Why did TVA not catch this on the review of the

2) Please clarify whether any digital safety-related systems or 2) This is a duplicate of closed RAI Matrix Item 45. PAMS SysRS or SRS? Does TVA

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N components have a digital communications path to non-safety- check that the CQ PAMS system related systems or with safety related systems in another division. meets the requirements in its If so, NRC staff will need these paths identified on the docket. purchase specifications?

TVA Response to Follow-up NRC Request:

A review of the following documents determined that the connection between the OM and the plant computer has been changed to a connection to a printer:

1. WNA-DS-01617-WBT-P, Revision 3, Post Accident Monitoring System - System Requirements Specification, dated November 2010

2. WNA-DS-01667-WBT-P, Revision 3, Post Accident Monitoring System - System Design Specification, dated November 2010

3. WNA-LI-00058-WBT-P, Revision 2, Post-Accident Monitoring System (PAMS) Licensing Technical Report, dated November 2010, submitted in TVA to NRC letter December 3, 2010 Review of the newly released Common Q PAMS documents listed below confirmed they correctly show a connection from the OM to a printer and not the plant computer. None of the other newly released documents contain a figure of the Common Q PAMS system showing the connection from the OM. The exception is WCAP-17351 which was created to allow a non-proprietary version of a generic Common Q document to be submitted on the docket and was not intended to reflect the WBN Unit 2 configuration.

Note: The OM printer connection is only used for maintenance. A printer is not normally connected to the OM. To use the OM printer connection, the FE keyswitch must installed and be in the ENABLE position.

(1) WNA-TP-02988-WBT, Revision 0, Post Accident Monitoring System Channel Integration Test/Factory Acceptance Test, dated November 2010, submitted in TVA to NRC letter December 3, 2010 (Reference 1)

(2) WNA-AR-00180-WBT-P, Revision 0, Failure Modes and Effects Analysis (FMEA) for the Post Accident Monitoring System, dated October 2010, submitted in TVA to NRC letter November 5, 2010 (Reference 12) 188 By letter dated June 30, 2010, TVA docketed, Tennessee Valley Responder: Clark 178. Y Closed Closed ML101970033, Item TVA Letter dated EICB (Carte)

Authority (TVA) Watts Bar Unit 2 (WBN2) - Post-Accident No. 3 & 4 10/5/10 Monitoring System (PAMS) Licensing Technical Report, 1) The original design was to allow printing from both the Response provided in letter dated to Open Item 187 (Document Number WNA-LI-00058-WBT- P, Revision 0, June Operator Module (OM) and Maintenance and Test Panel 10/5/10 2010) (Westinghouse Proprietary Class 2). (MTP) via the plant computer. This required both to be connected to the plant computer. Westinghouse did not NNC 08/25/10: See Open Item No.

1) Figure 2.2-1 of the PAMS Licensing Topical Report does not perceive this as an issue, because the standard Common Q 187.

show any connection between the Operators Modules and the PAMS design includes both the flat panel displays and plant computer or printer; however, Figure 2.1-1 of the PAMS individual control panel indicators. The Westinghouse System Requirements Specification (WNA-DS-01617-WBT Rev. 1 Common Q team did not realize that WBN does not use the

- ML101680578) shows a TCP connection from the OMs to the individual control panel indicators. As a result, the original plant computer and printer. Please explain. design documents provided by Westinghouse included the connection from the OM to the plant computer.

2) Section 5.3, Response to individual criteria in DI&C-ISG-04, of the PAMS Licensing Topical Report does not address the TCP The TVA team did not realize that the Westinghouse design connection between the OM and non-safety components depicted relied on the OM and MTP to be qualified isolation devices in Figure 2.1-1 of the PAMS System Requirements Specification that protected the AC160 functions and individual control

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N (WNA-DS-01617-WBT Rev. 1 - ML101680578). Please explain. panel indicators from interference from the plant computer.

It was not until a meeting was held to discuss the design of the OM that the issues came to light. That was when Westinghouse understood that the OM was the PAMS display and WBN did not use individual control panel indicators and TVA understood that the OM was being credited as the qualified isolation device. It became apparent at the meeting to both TVA and Westinghouse that the original design was not acceptable. The team then agreed to delete the OM connection to the plant computer.

2) This is a duplicate of closed RAI Matrix Item 45.

189 7.6.7 7/20/2010 Responder: Clark 179. Y Closed Closed RAI No. 3 TVA Letter dated EICB (Singh)

ML102980005 10/5/10 FSAR Section 7.6.7States: Conformance with Regulatory Guide This is a typographical error. The correct reference is Table Response provided in letter dated By FSAR Amendment 10/26/2010 1.133, Revision 1 is discussed in Table 7.1-7. FSAR Chapter 7 7.1-1. The reference will be corrected in FSAR Amendment 10/5/10 100, page 7.6-4.

does not contain any such numbered table. Please explain. 100.

NNC 8/25/10: Acceptable response.

190 7.9 FSAR Table 7.1-1 states: Regulatory Guide 1.133, May 1981 Responder: Clark 180. Y Closed Closed RAI No. 4 TVA Letter dated Closed to OI-331.

EICB (Singh)

Loose-Part Detection Program for the Primary System of Light- ML102980005 10/5/10 Water Cooled Reactors, Revision 1 (See Note 12)Note 12 1) TSR 3.3.6.3 specifies 18 months as the calibration Response provided in letter dated to Open Item 331. 10/26/2010 Conforms except as noted belowPositi[o]ns C.3.a.(3) and C.5.c. frequency. 10/5/10 recommend a channel calibration be performed at least once pe[r] TVA letter of 10/5/2010, 18 months. In lieu of this recommendation, the DMIMS will be 2) Per the Technical Requirements Manual (TRM) Bases Item 55 provided the calibrated at the frequency stated in subsection TSR 3.3.6.3 of TR 3.3.6 (Attachment 9) the surveillance requirements and response.

3.3.6 (Loose-Part Detection System). frequency are provided in Regulatory Guide 1.133, "Loose-Part Detection Program for the Primary System of Light- FSAR conformance

1) Clarify what frequency is specified in TSR 3.3.6.3. Water-Cooled Reactors." claims open items addressed in OI No.

2) Please explain why the stated calibration frequency is adequate 3) TRM section 3.3.6 and its bases are contained in 331 .

for meeting regulatory requirements. Attachment 9 to the 10/5/10 response letter.

3) Please provide sufficient documentation for the NRC to independently evaluate the conformance claims stated in the FSAR.

191 7.9 NUREG-0800 Chapter 7, Section 7.9, "Data Communication Responder: Jimmie Perkins 181. Y Closed Closed ML10197016, Item TVA Letter dated EICB (Carte)

Systems" contains review criteria for data communication systems. Nos. 1-3 10/5/10 The WBN2 FSAR did not include any description of data WBN Unit 2 is in compliance with the regulatory Response provided in letter dated communications systems. requirements for data communications systems as described 10/5/10

1) Please identify all data communications systems. in Attachment 34 (Data Communications Systems

2) Please describe each data communications system identified Description and Regulatory Compliance Analysis). NNC 8/25/10: Information received, above. and read.

3) Please provide a regulatory evaluation of each data communications system against the applicable regulatory criteria.

192 7.5.1. 7.5.2 The NRC Staff is using SRP (NUREG-0800) Chapter 7 Section Responder: Clark 182. Y Closed Closed Item No. 1 sent to TVA Letter dated EICB RAI ML1028618855 sent to EICB (Marcus) 1 7.5, Instrumentation Systems Important to Safety, to review the DORL 7/20/2010 10/5/10 DORL.

WBU2 FSAR Section 7.5, Instrumentation Systems Important to 1. At WBN Unit 1 and 2, there is a single computer system Response provided in letter dated NRC to issue formal ML102010034.

Safety. The following requests are for information that the SRP named the Integrated Computer System or ICS. That 10/5/10 RAI to TVA. EICB RAI directs the reviewers to evaluate. system is sometimes described as the Plant Computer ML102861885 Item System, the Process Computer, the Technical Support August 19, 2010 - NRC to review No. 1 The role of the EICB Technical reviewer is to determine if there is Center Data System (TSCDS) or the Emergency Response TVA response.

reasonable assurance that the equipment will perform the required Facility Data System (ERFDS). At one time, the TSCDS functions. The WBU2 FSAR, Section 7.5.2, Plant Computer and ERFDS were separate computers on Unit 1 but their TVA letter dated10/5/10 Response System, does not contain any description of the equipment that functions were all incorporated into the ICS when it was 57 provided information.

performs the functions described in the section. Enclosure 1 Item installed.

3 of letter dated March 12, 2010, TVA stated that the platform of

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N the Process Computer was, Hewlett Packard RX2660 and Dell 2. The Watts Nuclear Plant ICS is a non-safety related Poweredge R200 servers with RTP Corp 8707 I/O. In addition system, is designed as a single, large-scale nuclear plant TVA provided (a) two pages of marketing literature by DELL on the computer system which integrates balance of plant (BOP)

Poweredge R200 Server, (b) the HP Integrity rx2660 Server Unser monitoring with extensive nuclear steam supply system Service Guide, and (c) the Integrated Computer System Network (NSSS) application software into a comprehensive computer Configuration Connection Diagram (2-45W2697-1-1 dated based tool for plant operations. The system is comprised of 8/27/09). This provided information is not sufficient for evaluating the following major components:

whether the equipment will, with reasonable assurance, perform

• Remote multiplexers in the Computer Room, Auxiliary the functions described in the FSAR. Instrument Room and 480V Board rooms.

• Redundant Central Processing Units (CPUs)

1) Is the Plant Computer System another name for the Process

• Data Storage Devices Computer?

• Man-Machine Interfaces (MMI) - Satellite Display Stations (SDS) terminals in the Main Control Room (MCR), Technical

2) Please provide an architectural description of the Plant Support Center (TSC) and Computer Room.

Computer System.

• Networking equipment including switches, firewalls and terminal servers

3) Please describe the relationship between the Plant Computer

• Printers System and the Integrated Computer System.

• 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 Areva Beacon core monitoring systems o Multi-pen recorders o Landis & Gyr switchyard monitoring system o Computer Enhanced Rod Position Indication (CERPI) o Eagle 21 o Ronan Annunciator o Leading Edge Flow Meter (LEFM) o Bentley-Nevada vibration monitoring system o Inadequate Core Cooling Monitor (ICCM) (unit 1 only) o Common Q (unit 2 only) o WINCISE (unit 2) o Plant Engineering Data System (PEDS)

In support of normal plant operations, each units ICS:

• Scans and converts analog and digital plant process inputs to engineering units for displaying, alarming and reporting.

• Receives analog and digital inputs as pre-processed values from other digital systems for displaying, alarming, archiving, and reporting.

• Performs data validity checking.

• Performs calculations to obtain parameters such as difference, flows, and rates.

• Displays alarms when data point value exceeds predefined set points.

• Displays alarms received from the digital Annunciator system.

• Generates periodic station logs and pre-selected special logs.

• Performs BOP and NSSS related calculations.

• Provides graphical and digital trending displays of plant data.

• Provides graphical P&ID type displays of plant data.

In support of emergency plant operations each units ICS:

• Provides plant emergency support with the Safety Parameter Display System (SPDS) functions based upon the Westinghouse Owners Group CSF status trees and

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N historical data collection, storage, and retrieval functions required to support NUREG-0737 and NUREG-0737, Supplement 1 category 1 variables (except for containment isolation).

• Provides SPDS and Emergency Response Data System (ERDS) data to the Emergency Offsite Facilities via PEDS.

• Provides BISI functions (not including operating and trip bypasses of RPS and ESFAS).

• Provides continuous monitoring of RHR system performance when RHR is in use.

ICS is not required to be safety-related and is not required to meet IEEE single-failure criteria for Class 1E equipment.

3. The Plant Computer System and the Integrated Computer System are the same system.

193 7.5.1. 7.5.2 The WBU2 FSAR, Section 7.5.2, Plant Computer System, Responder: Clark 183. Y Closed Closed Item No. 2 sent to TVA Letter dated EICB RAI ML1028618855 sent to EICB (Marcus) 1 contains three subsections, DORL 7/20/2010 10/5/10 DORL.

7.5.2.1, Safety Parameter Display System There is a single set of hardware that incorporates the Response provided in letter dated NRC to issue formal ML102010034 7.5.2.2, Bypassed and Inoperable Status Indication System (BISI) functionality of Safety Parameter Display System (SPDS), 10/5/10 RAI to TVA. EICB RAI 7.5.2.3, Technical Support Center and Nuclear Data Links Bypass and Inoperable Status Indication System (BISI) and ML102861885 Item the Technical Support Center (TSC). TVA letter dated 10/5/10 No. 2 Are there three separate sets of hardware that implement these Responses 58 and 67 provided functions, or are these three functions that are implemented on a Also refer to the response to item 59 (RAI Matrix Item 193). information.

single set of hardware?

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 the Plant Engineering Data System (PEDS). That data is then available to be sent from the CECC to the NRC.

194 7.5.1. 7.5.2.1 The WBU2 FSAR Section 7.5.2.1, Safety Parameter Display Responder: Costley/Norman 184. Y Closed Closed Item No. 3 sent to TVA Letter dated EICB RAI ML1028618855 sent to EICB (Marcus) 1.1 System, contains a description of the Safety Parameter Display DORL 7/20/2010 10/5/10 DORL.

System. The principal purpose and function of the SPDS is to aid Response provided in letter dated NRC to issue formal ML102010034 control room personnel during abnormal and emergency 10/5/10 RAI to TVA. EICB RAI SRP Section 7.5, Subsection II, Acceptance Criteria states: conditions in determining the safety status of the plant and in ML102861885 Item Requirements applicable to the review of SPDS10 CFR assessing if abnormal conditions require corrective action by TVA letter dated 10/5/10 Response No. 3 50.55a(a)(1), Quality Standards. the operators to avoid a degraded core. It also operates 59 provided information.

during normal operations, continuously displaying Please provide a description of how SPDS meets this regulatory information from which the plant safety status can be readily requirement. 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.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 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.

• All documentation related to the SPDS software changes are QA records.

• The software source code is kept in a physically secure, environmentally controlled space to prevent inadvertent changes.

• Cyber security considerations are also considered in the storage environment.

The data goes through several validation steps before being presented to the operators. When redundant sensors are used, the data received by the computer can be processed by software to determine if the quality of one or more points is questionable.

195 7.5.1. 7.5.2.2 Bypassed and Inoperable Status Indication (BISI) Responder: Costley/Norman 185. Y Closed Closed Item No. 4 sent to TVA Letter dated EICB RAI ML1028618855 sent to EICB (Marcus) 1.2 DORL 7/20/2010 10/5/10 DORL.

The WBU2 FSAR Section 7.5.2.2, Bypassed and Inoperable The BISI system is a computer based system that provides Response provided in letter dated NRC to issue formal ML102010034 Status Indication System (BISI), contains a description of the automatic indication and annunciation of the abnormal status 10/5/10 RAI to TVA. EICB RAI Bypassed Inoperable Status Indication System (BISI). of each ESFAS actuated component of each redundant ML102861885 Item portion of a system that performs a safety-related function. TVA letter dated 10/5/10 Response No. 4 SRP Section 7.5, Subsection II, Acceptance Criteria states: 60 provided information.

Requirements applicable to bypassed and inoperable status To ensure quality, the design, testing, and inspection of the indication 10 CFR 50.55a(a)(1), Quality Standards. BISI system is controlled by qualified personnel and by using TVA procedure SPP-2.6, Computer Software Control. The Please provide a description of how BISI meets this regulatory procedure details controls and processes required for the requirement. 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

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 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.

196 7.5.1. 7.5.2.2 Bypassed and Inoperable Status Indication (BISI) Responder: Costley/Norman 186. Y Closed Closed Item No. 5 sent to TVA Letter dated EICB RAI ML1028618855 sent to EICB (Marcus) 1.2 DORL 7/20/2010 10/5/10 DORL.

The NRC staff is performing its review in accordance with LIC-110, Section C of the Regulatory Guide lists the following six Response provided in letter dated NRC to issue formal ML102010034 Rev. 1, Watts Bar Unit 2 License Application Review. LIC-110 regulatory positions for guidance to satisfy the NRC 10/5/10 RAI to TVA EICB RAI directs the staff to review systems unique to Unit 2 in accordance requirements with respect to the bypassed and inoperable ML102861885 Item with current staff guidance. Regulatory Guide (RG) 1.47 Revision status indication(BISI) for nuclear power plant safety TVA letter dated 10/5/10 Response No. 5 1, Bypassed and Inoperable Status indication for Nuclear Power systems: 61 provided information.

Plant Safety Systems, is the current regulatory guidance for BISI.

Please provide a regulatory evaluation of BISI against the current 1. Administrative procedures should be supplemented by an RG. 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

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

• Safety Injection

• Residual Heat Removal

• Containment Spray

• 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.

The system level display or indicating lights indicate NORMAL status when a previously bypassed system returns to normal operational status. The Operations staff will determine the impact of each alarm on the process flow path indication during plant modes of operation. The final decision of system operability is left up to the Operations staff to determine per Technical Specifications.

2. The indicating system for BISI should also be activated automatically by the bypassing or the deliberately induced inoperability of any auxiliary or supporting system that effectively bypasses or renders inoperable a safety function and the systems actuated or controlled by the safety function.

Response: The Integrated Computer System(ICS) obtains real-time plant parameter information system by continuously scanning pre-assigned analog, pulse, and contact sensors located throughout the plant to provide status information to the BISI system and automatically displays that information on the BISI terminals in the Main Control Room. Alarms are also initiated to gain the Operations staffs attention.

3. Annunciating functions for system failure and automatic actions based on the self-test or self-diagnostic capabilities of digital computer-based I&C safety systems should be consistent with Positions 1 and 2.

Response: The data goes through several validation steps before being presented to the operators. When redundant sensors are used, the data received by the computer can be processed by software to determine if the quality of one or more points is questionable.

4. The bypass and inoperable status indication system should include a capability for ensuring its operable status during normal plant operation to the extent that the indicating and annunciating functions can be verified.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Response: The BISI system is designed to operate during all normal plant modes of operations including startup, shutdown, standby, refueling, and power operation. The ICS is designed to provide a very high degree of reliability and the accuracy of the displayed data is not significantly less than the accuracy of comparable data displayed in the Main Control Room.

5. Bypass and inoperable status indicators should be arranged such that the operator can determine whether continued reactor operation is permissible. The control room of all affected units should receive an indication of the bypass of shared system safety functions.

Response: A system level display via the BISI display or indicating lights is provided to the operators to indicate the status of the systems being monitored as well as any support systems. If an alarm condition exists, additional detailed information is provided to the operations staff so as to allow determination of the abnormal condition. The information provided will identify to the Operations staff the exact nature of the initiating condition for the abnormal alarm. Each BISI system point will allow the user to access a detailed system screen.

These indicators and alarms will provide critical information to help the operations staff determine whether continued reactor operation is/is not permissible. As stated previously, the final decision of system operability/inoperability is left to the Operations staff to determine per Technical Specifications.

6. Bypass and inoperable status indicators should be designed and installed in a manner that precludes the possibility of adverse effects on plant safety systems. The indication system should not be used to perform functions that are essential to safety, unless it is designed in conformance with criteria established for safety systems.

Response: The BISI system is not designed to safety system criteria and therefore is not to be used to perform functions essential to the health and safety of the public, nor are operator actions based solely on BISI indications.

Appropriate electrical and physical isolation from safety-related equipment to the non-safety system is provided to meet the requirements identified in the FSAR. The ICS is independent of existing sensors and equipment in safety-related systems. Independence is achieved through qualified safety-related Class 1E isolators. The ICS is also isolated to preclude electrical or electronic interference with existing safety systems.

Inputs and outputs are isolated from the plant inputs such that normal faults on the plant side of the loops will have no adverse impact on the ICS other than loss of the one circuit with the fault. The inputs/outputs meet the isolation requirements of Watts Bar Design Criteria WB-DC-30-4,

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Separation/Isolation, which defines the design requirements for electrical separation/isolation of the distribution equipment and wiring for Class 1E electrical systems and components in the plant.

197 X Open Item 197 was never issued. 187. Y Closed Closed 198 7.5.1. 7.5.2.2 SRP Section 7.5, Subsection III, Review Procedures states: Responder: Costley/Norman 188. Y Closed Closed Item No. 6 sent to TVA Letter dated EICB RAI ML1028618855 sent to EICB (Marcus) 1.2 Recommended review emphasis for BISI DORL 7/20/2010 10/5/10 DORL.

F. Scope of BISI indications - As a minimum, BISI should be F. The scope of the WBN BISI indications are based on Response provided in letter dated NRC to issue formal ML102010034 provided for the following systems: engineering calculation WBPEVAR8807025 Rev. 7 10/5/10 RAI to TVA EICB RAI

- Reactor trip system (RTS) and engineered safety features (Attachment 10). This calculation has not been updated for ML102861885 Item actuation system (ESFAS) - See SRP Appendix 7.1-B subsection Unit 2. The calculation does include Common and Unit 2 TVA letter dated 10/5/10 Response No. 6 4.13, Indication of Bypasses, and SRP Appendix 7.1-C equipment required to support Unit 1 operation. 62 and Attachments 10 and 35 subsection 5.8.3, Indication of Bypasses. G. Compliance to Regulatory Guide 1.47 is described in provided information.

- Interlocks for isolation of low-pressure systems from the reactor design criteria document WB-DC-30-29 Rev. 8, Integrated coolant system - See SRP BTP 7-1. Computer System (submitted under TVA letter dated August

- ECCS accumulator isolation valves - See SRP BTP 7-2. 11, 2010 (Reference 1)) which is a design input to

- Controls for changeover of residual heat removal from injection to calculation WBPEVAR8807025 Rev. 7.

recirculation mode - See SRP BTP 7-6. H. Design criteria document WB-DC-30-29 Rev. 8, G. Conformance with Regulatory Guide 1.47, Bypassed and Integrated Computer System submitted under TVA letter Inoperable Status Indication for Nuclear Power Plant Safety dated August 11, 2010 (Reference 1)) section 3.4.1, BISI Systems. Design and Operation states: The BISI shall not be H. Independence - See SRP Appendix 7.1-B subsection 4.7, designed to safety related system criteria and therefore is Control and Protection System Interaction, and SRP Appendix not to be used to perform functions essential to the health 7.1-C subsections 5.6, Independence, and 6.3, Interaction and safety of the public. Class 1E isolation is required, Between the Sense and Command Features and Other Systems. however, to maintain the independence of safety related The indication system should be designed and installed in a equipment and systems.

manner that precludes the possibility of adverse effects on plant I. Development of the Bypassed and Inoperable Status safety systems. Failure or bypass of a protective function should Indication (BISI) application of the Integrated Computer not be a credible consequence of failures occurring in the System (ICS) is performed in accordance with NPG SPP 2.6, indication equipment, and the bypass indication should not reduce Computer Software Control, Rev. 12 (Attachment 35). The the required independence between redundant safety systems. development process starts with classifying the application I. Use of digital systems - See SRP Appendix 7.0-A and Appendix depending on how the output of the software will be used.

7.1-D. BISI software is currently classified as category C in accordance with . Appendix B which defines Category C Please provide a description of how BISI meets each item above, as:

or provide appropriate justification for not doing so.

Application Software Categories Category Description C Software and data which are an integral part of a quality-related but not safety-related plant system or component and are essential to the performance of that function.

Software, portions of software, and data essential to the implementation of quality-related programs listed in Section 5.1.B of the Nuclear Quality Assurance Plan, including software used to implement regulatory physical security requirements.

Software and data which implements NQAP requirements but not specifically identified as an augmented quality-related program as defined in Section 5.1.B of the NQAP.

Software, not associated with a specific plant system, which stores, maintains, controls, distributes or manages data which can be used without further verification in activities which affect safety- or quality- related plant structures, systems, and components.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Software, portions of software, and data which are an integral part of a non safety-related, non-quality related plant system or component whose failure would significantly impact plant operations.

Software used in the design of non quality-related, non safety-related plant structures, systems, and components Based on category C classification, SPP 2.6, Annex C defines the documentation that is required for the software..

For BISI, a Software Requirements Specification (SRS) based on the engineering calculation will be generated along with a Software Design Description. A Software Verification and Validation Report (SVVR) consisting of a Validation Test and results and an Operability Test and results will be prepared. User documentation for BISI will be incorporated into the overall ICS user documents.

Future changes to BISI will be driven foremost by changes to the engineering calculation that defines the overall functionality of the system. Any changes to the engineering calculation will cause a Software Services Request (SSR) to be generated. Depending on the scope of the change, the various documents (SRS, SDD, SVVR and user documentation) will be updated or re-issued.

199 7.5.1. 7.5.2.3 The WBU2 FSAR Section 7.5.2.3, Technical Support Center and Responder: Costley/Norman 189. Y Closed Closed Item No. 7 sent to TVA Letter dated Related SE Section 7.5.5.3 EICB RAI EICB (Marcus) 1.3 Nuclear Data Links, contains a description of the Technical DORL 7/20/2010 10/5/10 ML1028618855 sent to DORL.

Support Center and Nuclear Data Links. The Technical Support Center is intended to be an accident Response provided in letter dated NRC to issue formal ML102010034 mitigation support center and provides Satellite Display 10/5/10 RAI to TVA EICB RAI SRP Section 7.5, Subsection II, Acceptance Criteria states: Stations (SDS) capable of displaying information on plant ML102861885 Item Requirements applicable to the review ofERF information systems for Unit 1, Unit 2 or the Simulator. Stations in the TVA letter dated 10/5/10 Response No. 7 systems, and ERDS information systems 10 CFR 50.55a(a)(1), TSC receive data from the plant Integrated Computer 63 provided information.

Quality Standards. System (ICS) over the ICS network. Separate PCs receive data from the simulator computer over the WBN site network Please provide a description of how the nuclear data links meets to support drills and training exercises. Those PCs can also this regulatory requirement. 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.

200 7.2 (

C 7/21/2010 Responder: Clark 190. Y Closed Closed EICB RAI TVA Letter dated 7.3 The statement in SER Section 7.5.1 is supported by the ML102980066 Item 10/5/10 7.5 Amendment 99 of the Watts Bar Unit 2 FSAR Section 7.5, following: No. 2 7.7 Instrumentation Systems Important to Safety, does not include I&C Systems for Normal Operation FSAR Section Amendment 101

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N any description of instrumentation for normal operation; therefore, Eagle 21 7.2 Submitted Section 7.5 of the FSAR does not support statements made in the Neutron Monitoring 7.2 10/29/10.

SER Section 7.5; compare SER (ML072060490) Section 7.5.1 and Foxboro Spec 200 7.3 (List of other sections in FSAR Amendment 99 Section 7.5. Please identify where, in the attachment 34) docketed material, information exists to support the statements in Foxboro I/A 7.7.11 (new section will be added by the SER Section 7.5.1. amendment 101) (other sections have been previously provided)

Plant Computer 7.5.2 Rod Control 7.7.1.2 CERPI 7.7.1.2 Control Rod Drive 7.7.1.1 Incore Neutron Monitoring 7.7.1.9 Lose Part Detection/Monitoring 7.6.7 Vibration Monitoring RCP 5.5.1.2 Control Boards 7.1.1.10 RVLIS 7.5, 5.6 201 7.7.1. 7.7.11 7/21/2010 Responder: Webb 191. Y Closed Closed EICB RAI TVA Letter dated EICB (Carte) 1.1 ML102980066 Item 10/5/10 Amendment 99, FSAR Section 7.7.1.1.1, "Reactor Control Input These functions are within the scope of the Foxboro I/A No. 3 Signals (Unit 2 Only)," contains a description of functions system. Section 7.7.11 will be added to the FSAR in Amendment 101 performed uniquely for Unit 2. Please describe the equipment that amendment 101 to provide a discussion of the DCS. Submitted performs this function (in sufficient detail to support a regulatory 10/29/10.

evaluation), and evaluate this equipment against the appropriate regulatory criteria.

202 7.5.2 7/22/2010 Responder: WEC 17. N Open Open-NRC Review EICB RAI TVA Letter dated NNC 1/5/11: See Also Open Item No.

EICB (Carte)

ML102980066 Item 10/5/10 81 and 86.

The letter (ML0003740165) which transmitted the Safety Revision 1 of the Licensing Technical Report will provide Pending Submittal of Revision 3 of Due 2/25/11 & No. 4 Evaluation for the Common Q topical report to Westinghouse more detailed information on the changes to the platform. the Licensing Technical Report due 3/29/11 stated: "Should our criteria or regulations change so that our 3/29/11.

conclusions as to the acceptability of the report are invalidated, CE to provide information Nuclear Power and/or the applicant referencing the topical report Rev. 2 of the Licensing Technical Report will include the Response included in letter dated requested.

will be expected to revise and resubmit their respective applicability of guidance. 12/22/10 documentation, or submit justification for continued applicability of Due TBD the topical report without revision of the respective documentation." TVA Response to Follow-up NRC Request: Partial Response provided in letter Question No 81 identified many criteria changes; please revise the WNA-LI-00058-WBT-P, Revision 2, Post-Accident dated 10/5/10 respective documentation or submit justification for continued Monitoring System (PAMS) Licensing Technical Report applicability of the topical report. (LTR) submitted in TVA Letter to NRC dated December 3, NNC 1/5/11: Summary provided in 2010, contains the following change to address the NRC Licensing Technical Report R2 has request: been reviewed and found to be unacceptable.

Section 9, Compliance Evaluation of the Watts Bar 2 PAMS Software Requirements Specification to IEEE Standard 830- LTR Section 9 evaluates the 1998 and Regulatory Guide 1.172 to show the origin of the compliance of the SRS to IEEE requirements has been added. 830-1998. There are two issues with this evaluation:

The descriptions and commitments in the Topical Report (1) IEEE 830-1998 is not the current (TR) still apply. The LTR provides compliance evidence to SRP acceptance criteria. IEEE the new ISG-04 criteria. The statement in the SE means that 830-1998 has not been formally the TR can be evaluated against later NRC criteria when it endorsed by a regulatory guide.

appears. (2) Westinghouse committed to evaluate the SRS against 830 when Source: E-mail from Westinghouse (Matthew A. Shakun) to the NRC identified several Bechtel (Mark S. Clark), RE: December 22 letter review, inconsistencies.

dated December 17, 2010 Yes ISG-4 is one new criteria, and Partial TVA Response to Follow-up NRC Request: an evaluation against it has been

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N provided.

Attachment 4 contains the results of the TVA analysis of standards and regulatory guides applicable to the Common In addition, LTR Rev. 2 Section 13 Q PAMS. Based on the results of the analysis, the Common states: The applicable NRC Q PAMS design is acceptable. regulatory guides, IEEE and EPRI industry standards fo the common The final response is pending submittal of the Licensing Q PAMS are shown below.

Technical Report Revision 3 scheduled for March 29, 2011. Compliance to these codes and standards are stated in Section 4 of TVA Response to Follow-up NRC Request: Reference 1. Reference 1 is the common Q topical report.

(1) As discussed on page 9-1 of the Licensing Technical Report (Attachment 2) a comparison of IEEE 830-1993 and IEEE 830-1998 was performed and it was determined that the 1998 version enveloped all the requirements of the 1993 version which is endorsed by Regulatory Guide 1.172. Therefore the use of IEEE 830-1998 is acceptable.

(2) Table 9.1 IEEE Std 830-1998 Compliance of the Licensing Technical Report (Attachment 2) evaluates the Software Requirements Specification against the requirements of IEEE 830-1998.

(3) See TVA to NRC letter Watts Bar Nuclear Plant (WBN)

Unit 2 - Instrumentation And Controls Staff Information Requests, dated February 25, 2011 Attachment 4 Common Q PAMS Regulatory Guide and IEEE Standard Analysis.

(4) This section of the Licensing Technical Report (Attachment 2) has been relocated to section 15. The comment has been addressed by adding Reference 40 to TVA to NRC letter dated February 25, 2011, Attachment 4 which is the Common Q PAMS Regulatory Guide and IEEE Standard Analysis.

203 7.5.1. 7.5.2 7/26/2010 Responder: Clark 192. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL EICB (Marcus) 1 ML102861885 Item 10/5/10 By letter dated April 27, 2010 (ML101230248), TVA stated The plant computer system is one set of hardware. The Response provided in letter dated NRC to issue formal No. 9 (Enclosure Item No.19): "The WBN Unit 2 Integrated Computer Safety Parameter Display System, Bypassed and 10/5/10 RAI to TVA System(ICS) modification merges the ERFDS and plant computer Inoperable Status Indication System (BISI), Technical into a single computer network." Support Center and Nuclear Data Links are all functions of TVA letter dated 10/5/10 Response the Plant Computer System. Historically the Westinghouse 67 provided information.

FSAR Section 7.5.2, "Plant Computer System," has three P2500 Plant Process Computer and Emergency Response subsections: Facilities Data System (ERFDS) were individual systems but 7.5.2.1, "Safety Parameter Display System" were merged together with the implementation of DCN 7.5.2.2, "Bypassed and Inoperable Status Indication System (BISI)" 39911-A, implemented for WBN Unit 1 in December 1998, to 7.5.2.3, "Technical Support Center and Nuclear Data Links" become the Plant Integrated Computer System (ICS). A This arrangement implies that the each of these function are part of similar system is being installed for WBN Unit 2 based on the the plant computer, and not a separate sets of equipment. Please same software with more modern hardware.

describe the equipment for each function and identify any equipment common to more than one function. 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

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 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.

204 7.5.1. 7.5.2 7/26/2010 Responder: Costley/Norman 193. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL EICB (Marcus) 1 NRC to issue formal ML102861885 Item 10/5/10 By letter dated March 12, 2010 (ML101680577) TVA provided 1. Three data diodes. Response provided in letter dated RAI to TVA No. 10 drawing No. 2-45W2697-1-1, "Integrated Computer System 2. Two provide an interface between train A and B of 10/5/10 Network Configuration Connection Diagram," that depicts three Common Q.

"Data Diodes. Please provide a detailed description of the a. These are identical systems consisting of the following: 10/5/10 TVA letter Response 68 equipment, software, and configurations of each "Data Diode". i. Dual DELL R200 computers provided information.

ii. Red Hat Enterprise Linux software that is locked down by CTI Response is acceptable.

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.

205 7/26/2010 Responder: Clark 194. Y Closed Closed EICB RAI TVA Letter dated Question B related to prior NRC EICB (Garg)

ML102910008 10/5/10 approval of this system or 50.59 Regarding the Foxboro Spec 200 system installed at Unit 2: As discussed at the August 3 and 4 meeting in Knoxville Response provided in letter dated TVA to respond or Item#22 information. This question will be between TVA and the NRC, the Foxboro Spec 200 is not a 10/5/10 provide proposed date addressed in the August plant visit.

a- Is it similar to Unit 1? If not, identify the differences and system. The Foxboro Spec 200 analog hardware is used to of response.

evaluation of the acceptability of these differences. replace the existing obsolete hardware with the same 10/14 functions. There are no interconnections between the

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N b- deleted analog loops unless such interconnections existed prior to the replacement. This is strictly an analog to analog upgrade c- For each system which is discussed in the FSAR and utilizes the due to equipment obsolescence. The Foxboro hardware is Spec 200 system, please provide the instrument logic diagram, installed in existing cabinets which require modifications to loop/block diagram with reference to where the system is accept the Foxboro hardware racks.

discussed in the FSAR.

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.

206 7.5.1. 7.5.2 7/27/2010 Responder: Clark 195. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL EICB (Marcus) 1 ML102861885 Item 10/5/10 The NRC Requested a description of the plant computer and TVA (1) The Plant Computer is not just a computer but is a Response provided in letter dated NRC to issue formal No. 11 provided: system and is designated the Integrated Computer System 10/5/10 RAI to TVA (1) Dell marketing literature for Dell Poweredge R200 Server, or ICS. The ICS is composed of multiple computer CPUs, which can be found on the internet LCD displays, RTP Multiplexer Assemblies, network fiber WB-DC-30-29 Rev. 8 is Enclosure 1 (http://www.dell.com/downloads/global/products/pedge/en/pe_R20 optic panels, fiber optic converters, Ethernet switches and of TVA letter dated August 11, 2010 0_spec_sheet_new.pdf), and network taps previously described in items 71, 81 and 82 (ML102240382 letter and (2) HP Integrity rx2660 Server User Service guide (edition 6), above. For a detailed discussion of the ICS functions refer ML102240383 Enclosure 1).

which has not yet been found on the internet, but many other to design criteria document WB-DC-30-29 Rev. 8, Integrated editions have been found. Computer System submitted under TVA letter dated August 10/5/10 TVA letter Response 70 This information is not adequate for answering the question. (Note: 11, 2010. provided information.

TVA also provided a network configuration connection diagram, which is necessary but not sufficient.) (2) As previously discussed in item 82, there is no unique set Response is acceptable of hardware for any specific function.

Please provide a description of the plant computer:

(1) Please include sufficient detail so that an evaluation can be made against the SRP acceptance criteria in SRP Section 7.7.

(2) Please identify the equipment (hardware and software) that performs each function described in the FSAR.

207 EICB July 27, 2010 Date: 196. Y Closed Closed (Carte Responder:

)

Deleted by DORL 208 7.5.2. 7.5.1 7/27/2010 Responder: Clark 197. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL EICB (Marcus) 1 ML102861885 Item 10/5/10 By letter dated June 18, 2010 (ML101940236), TVA responded to The notes provided with the table include the change to the Response provided in letter dated NRC to issue formal No. 12 See Item 302 which requests more an NRC request for additional information. Enclosure 1 Item No. 6 variable under 10 CFR 50.59. For ease of review, the other 10/5/10 RAI to TVA detailed information on this topic of this letter identified, for each PAM variable whether the variable note references have been deleted for these variables and was: (1) implemented identically to Unit 1 and reviewed by the only the note dealing with the Unit 1 change has been 10/5/10 TVA letter Response 71 NRC, (2) implemented identically to Unit 1 but modified under 10 retained in the Notes column of the table excerpt. The provided information.

CFR 50.59 after it was reviewed by the NRC, and (3) implemented applicable notes are highlighted in the notes list.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 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.

209 7.5.2. 7.5.1 7/27/2010 Responder: Clark 198. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL EICB (Marcus) 1 ML102861885 Item 10/5/10 By letter dated June 18, 2010 (ML101940236), TVA responded to The first eight variables in question are primary chemistry Response provided in letter dated NRC to issue formal No. 13 an NRC request for additional information. Enclosure 1 Item No. 6 parameter. The parameters are the same for both units, but 10/5/10 RAI to TVA of this letter identified, for each PAM variable whether the variable in Unit 1, the sample is obtained via the post accident was: (1) implemented identically to Unit 1 and reviewed by the sampling system, while in Unit 2 the sample is obtained !0 /5/10 TVA letter Response 72 NRC, (2) implemented identically to Unit 1 but modified under 10 using a grab sample via the normal sample system. provided information.

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 The last variable was somewhat difficult to characterize. The were identified as both Unique to Unit 2 and identical to what was method of detection and the hardware manufacturer is the reviewed and approved on Unit 1. Please explain. 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.

210 7.5.2. 7.5.1 7/27/2010 Responder: Clark 199. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL EICB (Marcus) 1 ML102861885 Item 10/5/10 By letter dated June 18, 2010 (ML101940236), TVA responded to The design basis for Unit 2 is to match Unit 1 as closely as 10/5/10 TVA letter Response 73 NRC to issue formal No. 14 See Item 302 which requests more an NRC request for additional information. Enclosure 1 Item No. 6 possible. This includes incorporating changes made to Unit provided information. RAI to TVA detailed information on this topic of this letter identified, for each PAM variable whether the variable 1 after licensing under 10 CFR 50.59. The changes in was: (1) implemented identically to Unit 1 and reviewed by the question fall into this category and are described in the Response provided in letter dated NRC, (2) implemented identically to Unit 1 but modified under 10 Notes for each variable in the original submittal. 10/5/10 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.

211 7.5.1. 7/27/2010 Responder: Clark 200. Y Closed Closed EICB RAI TVA Letter dated Relates to SE Sections:

EICB (Carte) 1 ML102980066 Item 10/5/10 7.5.5, Plant Computer 7.5.2 FSA Table 7.1-1 shows: "The extent to which the The WBN 2 FSAR Section 7.5 defines the following systems No. 5 7.6.10, Loose Part Monitoring 7.6.1 recommendations of the applicable NRC regulatory guides and as important to safety Amendment 101 7.7.1, Control System Description 7.7.1 IEEE standards are followed for the Class 1E instrumentation and Submitted 7.7.2, Safety System Status Monitoring 7.7.2 control systems is shown below. The symbol (F) indicates full 1. Post Accident Monitoring including: 10/29/10. System 7.7.4 compliance. Those which are not fully implemented are discussed a. Common Q Post Accident Monitoring System (Safety- 7.7.4, PZR & SG Overfill 7.9 in the referenced sections of the FSAR and in the footnotes as Related) 7.9, Data Communications indicated." i. Reactor Vessel Level ii. Core Exit Thermocouples Please describe how systems that are important to safety, but not iii. Subcooling Margin Monitor 1E, comply with 10 CFR 50.55a(a)1: "Structures, systems, and b. Eagle 21 indications (Safety-Related) components must be designed, fabricated, erected, constructed, c. Foxboro Spec 200 indications (Safety-Related) tested, and inspected to quality standards commensurate with the d. Neutron Monitoring (Source and Intermediate Range) importance of the safety function to be performed." (Safety-Related)

e. Radiation Monitors (Safety-Related)

f. Unit 1 and Common shared indications (Safety-Related)

g. Foxboro I/A indications (Non-Safety-Related)

h. Radiation Monitors (Non-Safety-Related)

i. CERPI (Non-Safety-Related)

j. Integrated Computer System (Non-Safety-Related)

k. Unit 1 and Common shared indications (Non-Safety-Related)

Post Accident Monitoring Instrumentation Design Criteria, WB-DC-30-7, Rev. 22, Appendix A provides the minimum quality requirements for each Category (1, 2 or 3) of variable.

By definition, no Category 1 variable can be non-safety-related. Therefore, non-safety-related variables and the source equipment are limited to category 2 or 3. Since some

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N variables are designated as having more than 1 category, the requirements of the highest category apply. Additional design criteria information for specific systems is contained in:

g. Foxboro I/A - Site-Specific Engineering Specification WBN Unit 2 NSSS and BOP Controls Upgrade Specification Rev. 1 (Attachment 23)

h. CERPI - Rod Control System Description, N3-85-4003, Rev. 12 Section 2.2, Design Requirements

i. Radiation Monitors - Design Criteria Document WB-DC-40-24, Radiation Monitoring - (Unit 1 / Unit 2), Rev. 21

j. Integrated Computer System - Design Criteria Document WB-DC-30-29 Plant Integrated Computer System (ICS),

Rev. 8 (Submitted under TVA to NRC letter dated August __,

2010)

2. Plant Computer (Integrated Computer System) - See Item j above.

The WBN 2 FSAR Section 7.6, defines the following non-safety-related systems as other systems required for safety

1. Foxboro I/A - While not specifically described, functions performed by the system are described in this section. The qualify requirements are described above.

2. Lose Part Monitoring System - Design Criteria Document WB-DC-30-31, Loose Parts Monitoring System, Rev. 4, provides the quality requirements for this system. A description of the distributed control system will be added as FSAR section 7.7.1.11 in FSAR Amendment 101.

Installation is performed in accordance with the quality requirements of either the Bechtel or TVA work order processes based on the quality classification of the equipment being installed. Vendor testing is performed in accordance with procurement specification requirements which are based on the type and quality classification of the equipment. Preoperational testing is performed in accordance with Chapter 14 of the FSAR.

212 7.5.2 7/27/2010 Responder: WEC 18. N Open Open-NRC Review EICB RAI EICB (Carte)

ML102980066 Item By letter dated June 18, 2010 (ML101940236) TVA stated Application specific requirements for testing. This cannot be Partial Response included in letter No. 10 (Enclosure 1, Attachment 3, Item No. 3) that the PAMS system addressed in a topical report. Evaluation of how the dated 03/16/11 design specification and software requirements specification hardware meets the regulatory requirements.

contain information to address the "Design Report on Computer Final response due 3/29/11 Integrity, Test and Calibration..." The staff has reviewed these WEC to provide the information and determine where the documents, and it is not clear how this is the case. information will be located.

(1) Please describe how the information provided demonstrates compliance with IEEE 603-1991 Clauses 5.5, 5.7, 5.10, & 6.5. IEEE-603 1991:

(2) Please describe how the information provided demonstrates 5.5 System Integrity. The safety systems shall be NNC 2/17/2011: IEEE conformance with IEEE 7-4.3.2-2003 Clauses 5.5 & 57. designed to accomplish their safety functions under the 603 Clause 5.5 full range of applicable conditions enumerated in the basically states that design basis. conditions identified in IEEE 603 Clauses 4.7 TVA Response: The applicable conditions and & 4.8 must be Common Q PAMS system compliance are contained in addressed in the

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N WNA-LI-00058-WBT-P, Rev. 2, Post-Accident design. Energy supply Monitoring System (PAMS) Licensing Technical conditions have not Report submitted in TVA Letter to NRC dated been identified, or December 3, 2010, Section 11, Contract Compliance explicitly addressed.

Matrix items:

87 and 88 Seismic 89, 90, 91, 92 and 185 EMI/RFI 300, 301 and 302 Environmental Seismic qualification of the equipment to meet the design basis requirements NNC 2/18/11: Clause 5.7 Capability for Test and Calibration. Capability for 5.7 is acceptably testing and calibration of safety system equipment addressed.

shall be provided while retaining the capability of the safety systems to accomplish their safety functions.

The capability for testing and calibration of safety system equipment shall be provided during power operation and shall duplicate, as closely as practicable, performance of the safety function. Testing of Class 1E systems shall be in accordance with the requirements of IEEE Std 338-1987. Exceptions to testing and calibration during power operation are allowed where this capability cannot be provided without adversely affecting the safety or operability of the generating station. In this case:

(1) appropriate justification shall be provided (for example, demonstration that no practical design exists),

(2) acceptable reliability of equipment operation shall be otherwise demonstrated, and (3) the capability shall be provided while the generating station is shut down.

TVA Response: The requirements for test and calibration and Common Q PAMS system compliance, are contained in WNA-LI-00058-WBT-P, Rev. 2, Post-Accident Monitoring System (PAMS) Licensing Technical Report Section 11, TVA Contract Compliance Matrix items:

202 self test 350 Maintenance Bypass NNC 2/18/2011: WNA-351 Loop Tuning Parameters, AR-00189-WBT Rev. 0 400 and 401 3.7.2 Testing, Calibration, and Table 5-2 shows a Verification MTTR of 7.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. It 402, 403 and 404, 3.7.3 Channel Bypass or is not clear how this Removal from Operation satisfies the contractual item No.

5.10 Repair. The safety systems shall be designed to 179.

facilitate timely recognition, location, replacement, repair, and adjustment of malfunctioning equipment. The Contract Compliance Matrix Item TVA Response: The requirements for repair and 179 in Revision 3 of the Common Q PAMS system compliance are contained in LTR has been revised WNA-LI-00058-WBT-P, Rev. 2, Post-Accident to show this item as a Monitoring System (PAMS) Licensing Technical deviaition and to reflect Report Section 11, TVA Contract Compliance Matrix TVAs acceptance of items: the 7.2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> MTTR

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 179 Mean time to repair value. Attachment 2 202 self test contains WNA-LI-398 3.7 Maintenance 00058-WBT-P, Post-399 3.7.1 Troubleshooting Accident Monitoring System (PAMS) 6.5 Capability for Testing and Calibration Licensing Technical Report, Revision 3, 6.5.1 Means shall be provided for checking, with a high dated March 2011 degree of confidence, the operational availability of (proprietary).

each sense and command feature input sensor required for a safety function during reactor operation.

This may be accomplished in various ways; for example:

(1) by perturbing the monitored variable, (2) within the constraints of 6.6, by introducing and varying, as appropriate, a substitute input to the sensor of the same nature as the measured variable, or (3) by cross-checking between channels that bear a known relationship to each other and that have readouts available.

6.5.2 One of the following means shall be provided for assuring the operational availability of each sense and command feature required during the post-accident period:

(1) Checking the operational availability of sensors by use of the methods described in 6.5.1.

(2) Specifying equipment that is stable and retains its calibration during the post-accident time period.

TVA Response: The requirements for sense and command feature testing and Common Q PAMS system compliance are contained in WNA-LI-00058-WBT-P, Revision 2, Post-Accident Monitoring System (PAMS) Licensing Technical Report Section 11 TVA Contract Compliance Matrix items:

10, display of sensor diagnostic information 202 self test 205 self diagnostics and watchdog timer 264 through 271, system self checks 311 system status displays, 341 alarms, 344 on-line diagnostics IEEE 7-4.3.2-2003 5.5 System integrity In addition to the system integrity criteria provided by IEEE Std 603-1998, the following are necessary to achieve system integrity in digital equipment for use in safety systems:

Design for computer integrity Design for test and calibration Fault detection and self-diagnostics 5.5.1 Design for computer integrity The computer shall be designed to perform its safety function when subjected to conditions, external or

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N internal, that have significant potential for defeating the safety function. For example, input and output processing failures, precision or round off problems, improper recovery actions, electrical input voltage and frequency fluctuations, and maximum credible number of coincident signal changes.

If the system requirements identify a safety system preferred failure mode, failures of the computer shall not preclude the safety system from being placed in that mode. Performance of computer system restart operations shall not result in the safety system being inhibited from performing its function.

TVA Response: Common Q PAMS system reliability and failure modes are described in:

WNA-AR-00180-WBT, Revision 0, Failure Modes and Effects Analysis (FMEA) for the Post Accident Monitoring System WNA-AR-00189-WBT, Revision 0 Post Accident Monitoring System Reliability Analysis The requirements for mean time between failure and Common Q PAMS system compliance are contained in WNA-LI-00058-WBT-P, Revision 2, Post-Accident Monitoring System (PAMS) Licensing Technical Report, Section 11 TVA Contract Compliance Matrix item 178.

5.5.2 Design for test and calibration Test and calibration functions shall not adversely affect the ability of the computer to perform its safety function. Appropriate bypass of one redundant channel is not considered an adverse effect in this context. It shall be verified that the test and calibration functions do not affect computer functions that are not included in a calibration change (e.g., setpoint change).

V&V, configuration management, and QA shall be required for test and calibration functions on separate computers (e.g., test and calibration computer) that provide the sole verification of test and calibration data.

V&V, configuration management, and QA shall be required when the test and calibration function is inherent to the computer that is part of the safety system.

V&V, configuration management, and QA are not required when the test and calibration function is resident on a separate computer and does not provide the sole verification of test and calibration data for the computer that is part of the safety system.

TVA Response: The requirements for test and calibration and Common Q PAMS system compliance are contained in WNA-LI-00058-WBT-P, Revision 2, Post-Accident Monitoring System (PAMS) Licensing

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Technical Report Section 11 TVA Contract Compliance Matrix items:

202 self test 350 Maintenance Bypass 351 Loop Tuning Parameters, 400 and 401 3.7.2 Testing, Calibration, and Verification 402, 403 and 404, 3.7.3 Channel Bypass or Removal from Operation 5.5.3 Fault detection and self-diagnostics Computer systems can experience partial failures that can degrade the capabilities of the computer system, but may not be immediately detectable by the system.

Self-diagnostics are one means that can be used to assist in detecting these failures. Fault detection and self-diagnostics requirements are addressed in this sub-clause.

The reliability requirements of the safety system shall be used to establish the need for self-diagnostics. Self diagnostics are not required for systems in which failures can be detected by alternate means in a timely manner. If self-diagnostics are incorporated into the system requirements, these functions shall be subject to the same V&V processes as the safety system functions.

If reliability requirements warrant self-diagnostics, then computer programs shall incorporate functions to detect and report computer system faults and failures in a timely manner. Conversely, self-diagnostic functions shall not adversely affect the ability of the computer system to perform its safety function, or cause spurious actuations of the safety function. A typical set of self-diagnostic functions includes the following:

Memory functionality and integrity tests (e.g.,

PROM checksum and RAM tests)

Computer system instruction set (e.g., calculation tests)

Computer peripheral hardware tests (e.g.,

watchdog timers and keyboards)

Computer architecture support hardware (e.g.,

address lines and shared memory interfaces)

Communication link diagnostics (e.g., CRC checks)

Infrequent communication link failures that do not result in a system failure or a lack of system functionality do not require reporting.

When self-diagnostics are applied, the following self-diagnostic features shall be incorporated into the system design:

a) Self-diagnostics during computer system startup b) Periodic self-diagnostics while the computer system is operating

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N c) Self-diagnostic test failure reporting TVA Response: The requirements for fault detection and self diagnostics and Common Q PAMS system compliance are contained in WNA-LI-00058-WBT-P, Rev. 2, Post-Accident Monitoring System (PAMS)

Licensing Technical Report Section 11 TVA Contract Compliance Matrix items:

107 error free download 202 self test 205 self diagnostics and watchdog timer 263 primary and backup communication 264 through 271, continuous on-line self checks 311 system status displays, 341 alarms, 344 on-line diagnostics 5.7 Capability for test and calibration No requirements beyond IEEE Std 603-1998 are necessary.

TVA Response: No response required.

Concurrence: E-mail from Westinghouse (Andrew P. Drake) to Bechtel (Mark S. Clark), RE: RAI 212 Response - Errors in the Contract Compliance Matrix, dated December 17, 2010 (a) Energy Supply conditions are specified in WNA-DS-01617-WBT-P, System Requirements Specification Rev.

4, Requirement 4.1-1 which requires 120Vac +/-10% and 60+/-3Hz. Power to the Common Q PAMS is provided from the 120Vac vital power system. Per WBN Unit 2 FSAR section 8.3.1.1 the vital 120 volt ac system specifications are 120Vac +/-2% and 60+/-0.5Hz. Based on this, the power provided meets the system requirements.

Electromagnetic compatibility, seismic and environmental qualification of the equipment to meet the design basis requirements is documented in EQ-QR WBT-P, Revision 0 Qualification Summary Report for Post-Accident Monitoring System (PAMS)" (Proprietary)

(Attachment 4). Attachment 5 contains EQ-QR WBT-NP, Revision 0 Qualification Summary Report for Post-Accident Monitoring System (PAMS)" (non-proprietary). Attachment 6 contains CWA-11-3118, Application for Withholding Proprietary Information from Public Disclosure, EQ-QR-68-WBT-P, Revision 0 Qualification Summary Report for Post-Accident Monitoring System (PAMS), (Proprietary), dated February 28, 2011.

(b) The Contract Compliance Matrix Item 179 in Revision 3 of the Licensing Technical Report will be revised to show this item as a deviation and to reflect TVAs acceptance of the 7.2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> MTTR value. WNA-LI-00058-WBT-P, Post-Accident Monitoring System (PAMS) Licensing Technical Report, Revision 3,

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N (proprietary) dated March 2011, will be submitted no later than March 29, 2011.

213 7.5.2 7/27/2010 Responder: WEC 19. N Open Open-NRC Review EICB RAI EICB (Carte)

ML102980066 Item By letter dated June 18, 2010 (ML101940236) TVA stated Conformance with IEEE 603 is documented in the revised Pending Submittal of Revision 3 of Due 3/29/11 No. 18 (Enclosure 1, Attachment 3, Item No. 3) that the PAMS system Common Q PAMS Licensing Technical Report and the the Licensing Technical Report due design specification and software requirements specification Common Q PAMS System Design Specification. 3/29/11. NNC 2/3/11: The contain information to address the "Theory of Operation identified Description." The staff has reviewed these documents, and it is not Attachment 1 contains the proprietary version of Response is included in letter dated documentation does clear how this is the case. The docketed material does not appear Westinghouse document Tennessee Valley Authority 10/25/10 not include the design to contain the design basis information that is required to evaluate (TVA), Watts Bar Unit 2 (WBN2), Post-Accident Monitoring bases. Please provide compliance with the Clause of IEEE 603. System (PAMS), Licensing Technical Report, Revision 1, NNC to review and revise this schedule for providing (1) Please provide the design basis (as described in IEEE 604 WNA-LI-00058-WBT-P, Dated October 2010 question after LTR R2 is received. the requested Clause 4) of the Common Q PAMS. information.

(2) Please provide a regulatory evaluation of how the PAMs Attachment 8 contains the proprietary version of complies with the applicable regulatory requirements for the theory Westinghouse document Nuclear Automation Watts Bar 2 of operation. NSSS Completion Program I&C Projects Post Accident For example: Regarding IEEE 603 Clause 5.8.4 (1) What are the Monitoring System - System Design Specification, WNA-manually controlled protective actions? (2) How do the documents DS-01667-WBT, Rev. 2 dated September 2010.

identified demonstrate compliance with this clause?

TVA Response to Follow-up NRC Request:

The Regulatory Guide 1.97 classification of the Common Q PAMS variables is documented in TVA Design Criteria WB-DC-30-7 Post Accident Monitoring Instrumentation which was submitted as Attachment 5 on TVA to NRC letter Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests dated June 18, 2010 (Reference 1)

The hardware design bases for the Common Q PAMS is described in the WBN Unit 2 FSAR section 7.5.1.8 Post Accident Monitoring System (PAMS).

The Common Q PAMS indications are used to support operator response to events described in chapter 15 of the WBN Unit 2 FSAR such as:

RCCA/RCCA Bank dropped/misaligned Steam Generator Tube Rupture Inadvertent Loading of a Fuel Assembly Into an Improper Position Loss of Shutdown Power Major Reactor Coolant System Pipe Ruptures (Loss Of Coolant Accident)

Major Secondary System Pipe Rupture 214 7/27/2010 Responder: WEC 201. Y Closed Closed EICB RAI TVA Letter dated EICB (Carte)

ML102980066 Item 10/5/10 By letter dated June 18, 2010 (ML101940236) TVA stated According to "The Software Program Manual for Common Q No. 11 (Enclosure 1, Attachment 3, Item No. 10) that the approved Systems," WCAP-16096-NP-1A, the Software Safety Plan Common Q Topical Report contains information to address the only applies to Protection class software and PAMS is "Safety Analysis." The Common Q SPM however states that a classified as Important-to-safety. Exhibit 4-1 of the SPM Preliminary Hazards Analysis Report and the V&V reports shows that PAMS is classified as Important-to-Safety document the software hazards analysis. Please Provide these documents.

215 O RL 7/29/2010 Responder: WEC 202. Y Closed Closed (Pl

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N By letter dated June 18, 2010, TVA provided a table showing the Close this item 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.

216 7.5.1. 7.5.2 7/29/2010 Responder: Clark 203. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL EICB (Marcus) 1 ML102861885 Item 10/5/10 By letter dated March 12, 2010 (ML101680577), TVA stated that it 1) EDCR 52322 is contained in Attachment 7. Response provided in letter dated NRC to issue formal No. 15 would provide five documents to describe the Process computer: 5) The design change referred to is the addition of a data 10/5/10 RAI to TVA.

(1) EDCR 52322 Rev. A excerpts, (2) HP RX2660 Users Guide diode. This has not been incorporated into the drawing.

AB419-9002C-ed6, (3) Dell Poweredge R200 Server sheet Please see the response to letter item 88 (RAI Matrix Item 10/5/10 TVA letter Response 76 November 2007, (4) RTP Corp 8707 I/O Brochure RTP 8707-02, 224). and Attachment 7 provided 2004, and (5) Integrated Computer System Drawing. information.

217 7/6/2010 Responder: Clark 204. Y Close Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 7/30/10 Provide copies excerpts of the EDCRs and DCNs that provide the Attachment 7 contains excerpts of the following change Item#55 block and logic diagrams for the Foxboro Spec 200 documents:

implementation.

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 and as such are implemented under 10CFR50.59.

EDCR 52343 EDCR 52427 218 7/6/2010 Responder: Clark 205. Y Closed Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 7/30/10 Provide copies excerpts of the EDCRs and DCNs that provide the The excerpt of work order WO 08-813412-000 provided with Attachment 8 contains the required Item#56 block and logic diagrams for the Foxboro Spec 200 the June 18 letter did not contain the information showing correct work order excerpt.

implementation. 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.

219 8/4/2010 Responder: TVA Licensing 206. Y Closed Closed EICB RAI EICB (Garg)

ML102910008 Transmit copy of February 8, 2008 FSAR Red-Line for Unit 2 letter A copy was hand carried by Mr. W. Crouch and delivered to Check what sent by Terry missing Item#57 with attachments [CD]. Stewart Bailey at the August 17 meeting at NRC attachments.

headquarters.

TVA Revised Response:

Attachment 6 contains the redline FSAR with attachments.

220 8/4/2010 Responder: Ayala 207. Y Closed Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 10/5/10 For Safety Related SSPS, submit letter justifying delta between U1 The Westinghouse ARLA latch attachment is obsolete. In Response provided in letter dated TVA to respond or Item#23

[utilizing ARs] & U2 [utilizing ARs and MDRs]. [Requires TS order to provide a latching relay for Unit 2 Solid State 10/5/10 provide proposed date change ???] Protection System (SSPS), a MDR latching relay must be of response.

used. MDR relays are currently in use and shown to be Are there any open issues? Docket reliable as SSPS Slave Relays in other Westinghouse plant specific responses to the plants. individual.

The Technical Specification (TS) Bases was updated in Amendment B to indicate acceptability of testing MDR

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 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.

221 7.7.1. 7.7.1.3 8/4/2010 Responder: Trelease 208. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL EICB (Marcus) 2 ML102861885 Item 10/5/10 Submit EDCR Technical Evaluation for the source and The EDCR 52421 Source and Intermediate Range, Scope Response provided in letter dated NRC to issue formal No. 16 intermediate range updated electronics for Unit 2 and Intent, Unit Difference and Technical Evaluations are 10/5/10 RAI to TVA.

contained in Attachment 31 to 10/5 letter.

10/5/10 TVA letter Response 78 and Attachment 31 provided information.

222 8/4/2010 Responder: Clark 209. Y Close Closed EICB RAI TVA Letter dated EICB ML102910008 10/5/10 (Garg)

Submit updated list for Foxboro Spec 200 [replacement of Bailey The updated listing of Foxboro Spec 200 loop functions is Response provided in letter dated Item#24 and Robert-Shaw electronics contained in Attachment 33. 10/5/10 223 8/4/2010 Responder: Clark 210. Y Closed Closed EICB RAI EICB (Garg)

ML102910008 Submit EDCR Technical Evaluation for Foxboro I/A replacing Duplicate of item 233. Item#58 obsolete non-safety related Foxboro H-Line analog electronics with a digital CDS. [selected single point failures being addressed in design]

224 7.5.1. 7.5.2 8/4/2010 Responder: Norman (TVA CEG) 211. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL EICB (Marcus) 1 ML102861885 Item 10/5/10 Mike Norman [TVA Computer Eng. Group] will check status of The Data diode to isolate the WBN Unit 1 and Unit 2 ICS Response provided in letter dated NRC to issue formal No. 17 DCN/50.59 for Integrated Computer System upgrade that will computers from the WBN PEDS computers will be installed 10/5/10 RAI to TVA.

install the data diode between the WBN PEDS and the Unit 1 and in PIC 56278 as part of DCN 54971. This DCN is scheduled Unit 2 ICS. for implementation in Spring 2011. This date was included in 10/5/10 TVA letter Response 80 the Cyber Security Plan Implementation Schedules provided information.

submitted to the NRC on July 23.

225 8/4/2010 Responder: Scansen 212. Y Close Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 10/5/10 Provide EDCR Technical Evaluation Justify/explain updated The requested information is contained in the Scope and Response provided in letter dated Item#25 hardware [functionally equivalent to Unit 1] for the RCP and Intent, Unit Difference and Technical Evaluations for EDCRs 10/5/10 Turbine Generator vibration monitoring equipment. 52420 (Attachment 11) and 53559 (Attachment 12) 226 8/4/2010 Responder: TVA Licensing 213. Y Closed Closed N/A - Information TVA Letter dated See also Open Item Nos. 41 & 270.

EICB (Carte) requested under 8/11/10 Submit the Foxboro I/A segmentation analysis and ICS Design These documents were submitted under TVA letter dated NNC 8/25/10: Segmentation another open item.

Criteria documents on an expedited separate letter. Provide a date August 11, 2010. analysis has been received and when the Segmentation analysis will be revised based on read. Please describe why a failure discussions at the meeting. or error will not propagate over the -

peer-to-peer network, and cause more than one segment to fail.

227 CB (G 8/4/2010 Responder: Clark 214. Y Close Closed EICB RAI TVA Letter dated ar ML102910008 10/5/10

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Provide copies of 50.59s for the following Unit 1 changes A. CERPI, initial installation DCN 51072 and 2009 Response provided in letter dated Item#26 upgrade DCN 52957 (Attachment Upgrade of RCP, TG 10/5/10

a. CERPI (initial installation and 2009 upgrade) and FW pumps vibration monitoring to Bentley-Nevada

b. Vibration monitoring (RCP, TG and FW pumps to Bentley- 3300, DCN 39242, DCN 39506, DCN 39548, and DCN Nevada 3300) 50750 (Attachment )

c. Containment Sump Level Transmitter replacement B. Containment Sump Level Transmitter replacement,

d. Turbine Servo Control Valve Card replacement DCN 39608 (Attachment )

e. Pressurizer Heater deletion of Backup Heaters on for PZR High C. Turbine Servo Control Valve Card replacement, DCN Level 38993 (Attachment )

f. AMSAC D. Pressurizer Heater deletion of Backup Heaters on for

g. Significant ESFAS changes PZR High Level, DCN 51102 (Attachment )

E. AMSAC DCN 50475 (Attachment )

F. Significant ESFAS changes

i. Relocate containment isolation valve function and relocate the 6.9KV Shutdown Boards Emergency Feeder Breaker Trip function from K626 and K602, respectively, to minimize disruption on plant operation. DCN 38238 (Attachment )

ii. Revise OTT and OPT turbine runback setpoints, DCN 38842 (Attachment )

iii. Install Integrated Computer System (ICS)

Stages 4 and 5, DCN 50301 (Attachment )

228 8/4/2010 Responder: Clark 215. Y Closed Closed EICB RAI TVA Letter dated EICB ML102980066 Item 10/5/10 (Carte) Submit rod control system description N3-85-4003 The Rod Control System Description N3-85-4003 is Response provided in letter dated No. 6 contained in Attachment 21. 10/5/10 229 8/4/2010 Responder: Clark 216. Y Closed Closed EICB RAI TVA Letter dated EICB ML102980066 Item 10/5/10 (Carte) Submit Annunciator system description/design criteria Condition Status/Alarm Design Criteria Document WB-DC- Response provided in letter dated No. 7 30-21 is contained in Attachment 22. 10/5/10 230 8/4/2010 Responder: Webb 217. Y Closed Closed EICB RAI TVA Letter dated EICB ML102980066 Item 10/5/10 (Carte) Submit Foxboro I/A Procurement Specification excerpts that The requested Foxboro I/A Procurement Specification is Response provided in letter dated No. 8 provide system description information contained in Attachment 23. 10/5/10 231 8/4/2010 Responder: Clark 218. Y Closed Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 10/5/10 Update FSAR Amendment 100 Section 7.1.1.2 markup based on FSAR section 7.1.1.2 is revised in FSAR Amendment 100 Response provided in letter dated FSAR AMD 100 Item#27 discussion with Hukam Garg. submitted to the NRC on TVA letter to the NRC dated 10/5/10 September 1, 2010 includes the requested clarifications.

232 8/4/2010 Responder: Clark 219. Y Closed Closed RAI No. 5 TVA Letter dated EICB (Singh)

ML102980005 10/5/10 Submit EDCR Technical Evaluation for LPMS EDCR The EDCR 52418 Lose Part Monitoring Scope and Intent, TVA provided 10/26/2010 Unit Difference and Technical Evaluations are contained in information in Att. 24 of Attachment 24 to 10/5 letter. 10/5 letter.

233 8/4/2010 Responder: Clark 220. Y Closed Closed EICB RAI TVA Letter dated EICB ML102980066 Item 10/5/10 (Carte) Submit EDCR Technical Evaluation for Foxboro I/A EDCR Foxboro I/A EDCRs 52378 and 52671 Scope and Intent, Unit Response provided in letter dated No. 12 Difference and Technical Evaluations are contained in 10/5/10 Attachment 25 to the 10/5 letter.

221. Y

(

234 C 8/4/2010 Responder: Closed Closed N/A - Duplicate N/A

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Item Bechtel to perform D3 analysis for Common Q PAMS which will be Duplicate of Item 64 incorporated into Westinghouse Licensing Technical Report.

235 8/4/2010 Responder: TVA Licensing 222. Y Closed Closed N/A N/A EICB (Garg)

TVA to ensure Stewart Bailey is on cc: for all Chapter 7 RAI Stewart Bailey has been added to the standard response response letters. letter template used for Chapter 7 responses.

236 8/4/2010 Responder: Clark 223. Y Close Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 10/5/10 Submit EDCR Technical Evaluation for Foxboro Spec 200 EDCRs Foxboro Spec 200 EDCRs 52343, 52427 and 52641, Scope Response provided in letter dated Item#28 and Intent, Unit Difference and Technical Evaluations are 10/5/10 contained in Attachment 26 to 10/5 letter.

237 8/4/2010 Responder: Clark 224. Y Closed Closed EICB RAI TVA Letter dated EICB ML102980066 Item 10/5/10 (Carte) Submit EDCR Technical Evaluation for Annunciator EDCR The Annunciator EDCR 52315 Scope and Intent, Unit Response provided in letter dated No. 13 Difference and Technical Evaluations are contained in 10/5/10 Attachment 27 to 10/5 letter.

238 8/4/2010 Responder: Webb/Hilmes 225. Y Closed Closed N/A - Duplicate N/A EICB Item (Carte) Discuss with TVA adding a description of the Foxboro I/A system to Duplicate of item 201 chapter 7 of the FSAR.

239 8/4/2010 Responder: Hilmes 226. Y Closed Closed N/A - Meeting N/A EICB request (Carte) Plan a meeting with TVA the NRC and Westinghouse to review meeting held 8/17/10 Common Q PAMS documentation.

240 8/4/2010 Responder: Clark 227. Y Close Closed Ml102910008 TVA Letter dated EICB (Garg)

Item#29 10/5/10 Submit EDCR Technical Evaluation for Vibration Monitoring The Scope and Intent, Unit Difference and Technical Response provided in letter dated EDCR(s) Evaluations for EDCRs 53559 and 52420 are contained in 10/5/10 Attachment 28 of 10/5 letter.

241 8/4/2010 Responder: Davies 228. Y Closed Closed RAI No. 10 TVA Letter dated EICB (Singh)

ML102980005 10/5/10 Review CERPI WCAPs for system description information to be CERPI was designed after Westinghouse stopped using Response provided in letter dated TVA provided 10/26/2010 submitted to the NRC. WCAPs. The document that provides the most detailed 10/5/10 information in Att. 29 of information is the CERPI System Requirements Specification 10/5 letter.

WN-DS-00001-WBT Rev. 2. The proprietary version of this document and the affidavit for withholding are contained in Attachment 29.

242 8/4/2010 Responder: Hilmes 229. Y Close Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 10/5/10 TVA to make firm decision on date of transfer (before or after initial The Unit 2 loops in service for Unit that are scheduled to be Response provided in letter dated Item#30 startup) of Unit 2 loops in service for Unit 1 to new Foxboro Spec transferred to the Foxboro Spec 200 hardware will be 10/5/10 200 hardware transferred prior to Unit 2 fuel load.

243 8/3/2010 Responder: WEC 230. Y Closed Closed N/A - Closed to N/A EICB (Carte)

Item No. 142 Section 8.2.1 of the Common Q SPM (ML050350234) states that WEC to address at the 9/15 meeting the System Requirements Specification (SysRS) includes the system design basis. Section 1.2, "System Scope," of the WBN2 Closed to Item 142 PAM SysRS (ML101680578) includes a description of the PAMS design bases that does not meet the requirements of IEEE 603-199 Clause 4. Please provide a description of the PAMs design

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N bases that conforms to the requirements of IEEE 603-1991 Clause 4.

244 8/3/2010 Responder: WEC 20. N Open Open-NRC Review EICB RAI Response is LIC-101 Rev. 3 Appendix B Section 4, EICB (Carte)

ML102980066 Item provided in letter "Safety Evaluation" states: "the Section 8.2.2 of the Common Q SPM (ML050350234) states that The process related requirements have been removed from Revised response is included in Due 2/25/11 Document No. 14 dated 10/25/10. information relied upon in the SE must the Software Requirements Specification (SRS) shall be developed revision 2 of the Software Requirements Specification (SRS). letter dated 12/22/10 revisions be docketed correspondence."

using IEEE 830 and RE 1.172. Clause 4.8, "Embedding project requirements in the SRS," of the IEEE 830 states that an SRS Attachment 3 of letter dated 10/25/10 contains the Response is provided in letter dated NNC 2/2/11: Issues LIC-101 Rev. 3 states: "The safety should address the software product, not the process of producing proprietary version of Westinghouse document Nuclear 10/25/10. with Common Q TR & analysis that supports the change the software. In addition Section 4.3.2.1 of the SPM states "Any Automation, Watts Bar 2 NSSS Completion Program, I&C SPM compliance were requested should include technical alternatives to the SPM processes or additional project specific Projects, Software Requirements Specification for the Post NNC 11/18/10: SysRS Rev. 2 also discussed in the weekly information in sufficient detail to enable information for the ...SCMP...shall be specified in the PQP. Accident Monitoring System, WNA-SD-00239-WBT, contains process requirements that public meetings. the NRC staff to make an independent Revision 2, Dated September 2010. are more appropriately incorporated Westinghouse to assessment regarding the acceptability Contrary to these two statements in the SPM, the WBN2 PAMS into process documentation. perform Common Q TR of the proposal in terms of regulatory SRS (ML101050202) contains many process related requirements, & SPM compliance self requirements and the protection of for example all seventeen requirements in Section 2.3.2, TVA Response to Follow-up NRC Request: assessment; this will be public health and safety."

"Configuration Control," address process requirements for As shown is the listed documents, process related discussed in detail on configuration control. requirements have been deleted from the SRS and SysRS in the next audit.

Revision 3:

Please explain how the above meets the intent of the approved SPM. Attachment 1 contains proprietary version of WNA-DS-01617-WBT-P, Revision 3, Post Accident Monitoring System-System Requirements Specification, dated December 2010.

Attachment 7 contains the proprietary version of WNA-SD-00239-WBT-P, Revision 3, Software Requirements Specification for the Post Accident Monitoring System, dated December 2010.

Source: E-mail from Westinghouse (Andrew P. Drake) to Bechtel (Mark S. Clark), RE: Common Q RAI concerns, dated December 8, 2010 (Reference 17)

TVA Response to Follow-up NRC Request:

The documents discussed in Item 3 have been revised to address compliance with the Topical Report (TR) and the Software Program Manual (SPM).

245 8/3/2010 Responder: WEC 21. N Open Open-NRC Review EICB RAI LIC-101 Rev. 3 Appendix B Section 4, EICB (Carte)

ML102980066 Item "Safety Evaluation" states: "the Section 5.8 of the Common Q SPM (ML050350234) identifies the Relates to the commitment to provide the test plan and the Pending Submittal of the Test Due 3/29/11 No. 119 information relied upon in the SE must required test documentation for systems developed using the SPM compliance matrix Summary Report due 3/29/11 be docketed correspondence."

Common Q SPM. Please provide sufficient information for the NNC 2/2/11: Issues NRC staff to independently assess whether the test plan for WBN2 Attachment 9 contains the Westinghouse document Post Response included in letter dated with the Common Q TR LIC-101 Rev. 3 states: "The safety PAMS, is as described in the SPM (e.g., Section 5.8.1). Accident Monitoring System Test Plan, WNA-PT-00138- 12/3/10 & SPM were discussed analysis that supports the change WBT, Revision 0, dated November 2010. Attachment 10 in the weekly public requested should include technical contains the Westinghouse Application for Withholding for Common Q PAMS Test Summary meetings. information in sufficient detail to enable the Post Accident Monitoring System Test Plan, WNA-PT- Report scheduled to be submitted Westinghouse to the NRC staff to make an independent 00138-WBT, Revision 0, dated November 2010. March 29, 2011. perform Common Q TR assessment regarding the acceptability

& SPM compliance self of the proposal in terms of regulatory TVA Response to Follow-up NRC Request: assessment requirements and the protection of public health and safety."

The results of the self assessment were reviewed by Westinghouse with the NRC on February 2, 2011 and were further reviewed by TVA during the NRC Common Q PAMS audit during the week of February 28 to March 4, 2011.

Corrections to WNA-TR-02451-WBT, Test Summary Report

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N for the Post Accident Monitoring System and the self assessment were made as a result of the TVA review to ensure this comment was fully addressed.

By agreement between TVA, WEC and the NRC, the Post Accident Monitoring System Test Plan, WNA-PT-00138-WBT, Revision 0 will not be revised. Instead a non-proprietary Common Q PAMS Test Summary Report will be developed and submitted to address the issues with TR and SPM compliance. Attachment 1 contains non-proprietary WNA-TR-02451-WBT, Revision 0, Test Summary Report for the Post Accident Monitoring System, dated March 2011.

246 8/3/2010 Responder: WEC 22. N Open Open-NRC Review EICB RAI Response is LIC-101 Rev. 3 Appendix B Section 4, EICB (Carte)

ML102980066 Item provided in letter "Safety Evaluation" states: "the Section 4.3.2.1, "Initiation Phase" of the Common Q SPM As agreed ISG6 does not apply to the Common Q PAMS Pending Submittal of Revision 3 of Due 3/29/11 No. 15 dated 10/25/10 information relied upon in the SE must (ML050350234) requires that a Project Quality Plan (PQP) be platform. The information required to address this question the Licensing Technical Report due be docketed correspondence."

developed. Many other section of the SPM identify that this PQP concerning the PQP and SPM has been added to 3/29/11. PQP provided for audit the NNC 2/2/11: Issues should contain information required by ISG6. Please provide the compliance matrix in revision 1 of the Licensing Technical week of 2/28/11. with the Common Q TR LIC-101 Rev. 3 states: "The safety PQP. If "PQP" is not the name of the documentation produced, Report. & SPM implementation analysis that supports the change please describe the documentation produced and provide the Response is provided in letter dated were discussed in the requested should include technical information that the SPM states should be in the PQP. Attachment 1 of letter dated 10/25/10 contains the 10/25/10 weekly public meetings. information in sufficient detail to enable proprietary version of Westinghouse document Tennessee Westinghouse to the NRC staff to make an independent Valley Authority (TVA), Watts Bar Unit 2 (WBN2), Post- NNC 11/18/10: PQP has not been perform Common Q TR assessment regarding the acceptability Accident Monitoring System (PAMS), Licensing Technical provided and CQ PAMS LTR Rev. 1 & SPM compliance self of the proposal in terms of regulatory Report, Revision 1, WNA-LI-00058-WBT-P, Dated October does not contain comparable assessment requirements and the protection of 2010 information. public health and safety."

TVA Response to Follow-up NRC Request:

The results of the Common Q TR and SPM self assessment were reviewed by Westinghouse with the NRC on February 2, 2011.

The Westinghouse Watts Bar Unit 2 NSSS Completion I&C Projects Project Quality Plan, WNA-PQ-00220-WBT, Revision 1 is available for NRC audit at the Westinghouse Rockville Office and was available for review during the NRC Common Q PAMS audit during the week of February 28 to March 4, 2011. During the audit, the Westinghouse Quality Assurance in process audit of the Common Q PAMS project was reviewed by the NRC inspector with no issues identified.

247 8/8/2010 Responder: WEC 231. Y Closed Closed EICB RAI Response is LIC-101 Rev. 3 Appendix B Section 4, EICB (Carte)

ML102980066 Item provided in letter "Safety Evaluation" states: "the As part of the Common Q topical report development effort, The implementation documents required by the SPM are No. 16 dated 10/25/10 information relied upon in the SE must Westinghouse developed the Software Program Manual for identified in the compliance matrix in revision 1 of the be docketed correspondence."

Common Q Systems (ML050350234) to address software planning Licensing Technical Report.

documentation. The NRC reviewed the SPM and concluded: the LIC-101 Rev. 3 states: "The safety SPM specifies plans that will provide a quality software life cycle Attachment 1 of letter dated 10/25/10 contains the analysis that supports the change process, and that these plans commit to documentation of life cycle proprietary version of Westinghouse document Tennessee requested should include technical activities that will permit the staff or others to evaluate the quality of Valley Authority (TVA), Watts Bar Unit 2 (WBN2), Post- information in sufficient detail to enable the design features upon which the safety determination will be Accident Monitoring System (PAMS), Licensing Technical the NRC staff to make an independent based. The staff will review the Implementation of the life cycle Report, Revision 1, WNA-LI-00058-WBT-P, Dated October assessment regarding the acceptability process and the software life cycle process design outputs for 2010 of the proposal in terms of regulatory specific applications on a plant-specific basis. Please identify the requirements and the protection of implementation documentation produced as a result of following public health and safety."

the SPM, and state what information will be docketed.

232. Y

(

248 C 8/8/2010 Responder: WEC Closed Closed Response is LIC-101 Rev. 3 Appendix B Section 4,

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N provided in letter "Safety Evaluation" states: "the As part of the Common Q topical report development effort, The documents are identified in the compliance matrix in dated 10/25/10 information relied upon in the SE must Westinghouse developed the Software Program Manual for revision 1 of the Licensing Technical Report be docketed correspondence."

Common Q Systems (ML050350234) to address software planning documentation. The NRC reviewed the SPM and concluded: the Attachment 1 of the letter dated 10/25/10 contains the LIC-101 Rev. 3 states: "The safety SPM specifies plans that will provide a quality software life cycle proprietary version of Westinghouse document Tennessee analysis that supports the change process, and that these plans commit to documentation of life cycle Valley Authority (TVA), Watts Bar Unit 2 (WBN2), Post- requested should include technical activities that will permit the staff or others to evaluate the quality of Accident Monitoring System (PAMS), Licensing Technical information in sufficient detail to enable the design features upon which the safety determination will be Report, Revision 1, WNA-LI-00058-WBT-P, Dated October the NRC staff to make an independent based. The staff will review the Implementation of the life cycle 2010 assessment regarding the acceptability process and the software life cycle process design outputs for of the proposal in terms of regulatory specific applications on a plant-specific basis. Please identify the requirements and the protection of design outputs produced as a result of following the SPM, and public health and safety."

state when what information will be docketed.

249 8/8/2010 Responder: WEC 233. Y Closed Closed LIC-101 Rev. 3 Appendix B Section 4, EICB (Carte)

"Safety Evaluation" states: "the The SVVP in the SPM describes the V&V implementation tasks Close to previous items to provide the V&V Reports. information relied upon in the SE must that are to be carried out. The acceptance criterion for software be docketed correspondence."

V&V implementation is that the tasks in the SVVP have been carried out in their entirety. Documentation should exist that shows LIC-101 Rev. 3 states: "The safety that the V&V tasks have been successfully accomplished for each analysis that supports the change life cycle activity group. Please provide information that shows that requested should include technical the V&V tasks have been successfully accomplished for each life information in sufficient detail to enable cycle activity group. 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."

250 8/8/2010 Responder: WEC 23. N Open Open-NRC Review LIC-101 Rev. 3 Appendix B Section 4, EICB (Carte)

"Safety Evaluation" states: "the The SPM describes the software and documents that will be Westinghouse develops Software Release Reports/Records Revised response included in letter NNC 2/2/11: To be information relied upon in the SE must created and placed under configuration control. The SCMP (e.g., and a Configuration Management Release Report. Describe dated 12/22/10 addressed during the be docketed correspondence."

SPM Section 6, Software Configuration Management Plan) the documents and when they will be produced. Summarize next audit.

describes the implementation tasks that are to be carried out. The guidance on how to produce these records, focus on project Response included in letter dated LIC-101 Rev. 3 states: "The safety acceptance criterion for software CM implementation is that the specific requirements in SPM etc. 10/25/10. analysis that supports the change tasks in the SCMP have been carried out in their entirety. requested should include technical Documentation should exist that shows that the configuration TVA Response to Follow-up NRC Request: information in sufficient detail to enable management tasks for that activity group have been successfully the NRC staff to make an independent accomplished. Please provide information that shows that the CM The following documentation shows that the configuration assessment regarding the acceptability tasks have been successfully accomplished for each life cycle management tasks for that activity group have been of the proposal in terms of regulatory activity group. successfully accomplished. requirements and the protection of public health and safety."

1. WNA-LI-00058-WT-P, Revision 2, Post-Accident Monitoring System (PAMS) Licensing Technical Report submitted in TVA Letter to NRC dated December 3, 2010, (Reference 1) contains the following changes to address the NRC requests:

a. Section 2.2.1 Hardware/Software Change Process has been added to describe the process of how changes are evaluated.

b. Section 2.2.2, Software has been expanded to include a table detailing evolutionary software changes that have occurred since the initial submittal and the change evaluation of the life cycle.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

2. WNA-PT-00138-WBT, Revision 0, Nuclear Automation Watts Bar 2 NSSS Completion Program I&C Projects, Post Accident Monitoring System Test Plan, (Proprietary), dated November 2010 submitted in TVA Letter to NRC, dated December 3, 2010 (Reference 1).

251 8/8/2010 Responder: WEC 24. N Open Open-NRC Review LIC-101 Rev. 3 Appendix B Section 4, EICB (Carte)

"Safety Evaluation" states: "the The SPM describes the software testing and documents that will be The software testing performed and documents created are Pending Submittal of the Test Due 3/29/11 information relied upon in the SE must created. The SPM also describes the testing tasks that are to be addressed by the SPM Compliance matrix contained in Summary Report due 3/29/11 be docketed correspondence."

carried out. The acceptance criterion for software test Revision 1 of the Licensing Technical Report. NNC 2/2/11: Issues implementation is that the tasks in the SPM have been carried out Revised response included in letter with the Common Q TR LIC-101 Rev. 3 states: "The safety in their entirety. Please provide information that shows that Attachment 1 of the letter dated 10/25/10 contains the dated 12/22/10 & SPM were discussed analysis that supports the change testing been successfully accomplished. Proprietary version of Westinghouses document titled: in the weekly public requested should include technical Tennessee Valley Authority (TVA), Watts Bar Unit 2 Partial response is provided in letter meetings. information in sufficient detail to enable (WBN2), Post-Accident Monitoring System (PAMS), dated 10/25/10 Westinghouse to the NRC staff to make an independent Licensing Technical Report, Revision 1, WNA-LI-00058- perform Common Q TR assessment regarding the acceptability WBT-P, Dated October 2010 & SPM compliance self of the proposal in terms of regulatory assessment requirements and the protection of TVA Response to Follow-up NRC Request: public health and safety."

Please see the response to RAI item 21 in letter dated 12/22/10, NRC Matrix Item 250.

TVA Response to second Follow-up NRC Request:

The results of the Common Q TR and SPM self assessment were reviewed by Westinghouse with the NRC on February 2, 2011.

By agreement between TVA, WEC and the NRC, the Post Accident Monitoring System Test Plan, WNA-PT-00138-WBT, Revision 0 will not be revised. Instead a non-proprietary Common Q PAMS Test Summary Report will be developed and submitted to address the issues with TR and SPM compliance. Attachment 1 contains non-proprietary WNA-TR-02451-WBT, Revision 0, Test Summary Report for the Post Accident Monitoring System, dated March 2011.

252 8/8/2010 Responder: WEC 25. N Open Open-NRC Review LIC-101 Rev. 3 Appendix B Section 4, EICB (Carte)

"Safety Evaluation" states: "the The SPM contain requirements for software requirements Explain response to AP1000 audit report. Response included in letter dated Due 2/25/11 (document information relied upon in the SE must traceability analysis and associated documentation (see Section RTM docketed NRC awaiting V&V evaluation of RTM. 12/22/10 submittals) be docketed correspondence."

5.4.5.3, Requirements Traceability Analysis). Please provide information that demonstrates that requirements traceability The following responses are based on WBN Unit 2 Common Read ML091560352 NNC 2/2/11: Updated LIC-101 Rev. 3 states: "The safety analysis has been successfully accomplished. Q PAMS traceability: RTMs and analysis that supports the change specifications to be requested should include technical Software requirements traceability analysis is described in provided. information in sufficient detail to enable the following documents: the NRC staff to make an independent Requirements assessment regarding the acceptability

1. WNA-LI-00058-WBT-P, Revision 2, Post-Accident traceability to be of the proposal in terms of regulatory Monitoring System (PAMS) Licensing Technical addressed during he requirements and the protection of Report submitted in TVA Letter to NRC dated next audit. public health and safety."

December 3, 2010, (Reference 1) Section 11, TVA Contract Compliance Matrix

2. WNA-VR-00279-WBT, Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System (available for NRC audit at the Westinghouse Rockville

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N office)

3. WNA-VR-00280-WBT, Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Reactor Vessel Level Indication System (RVLIS) Custom PC Elements (available for NRC audit at the Westinghouse Rockville office) This document addresses the RSEDs used in the WBN Unit 2 Common Q PAMS.

The V&V evaluation of the RTM is documented in section 2.2.2 of the following documents:

1. The Independent Verification & Validation (IV&V) report covering the Concept and Definition phases (Nuclear Automation Watts Bar Unit 2 NSSS Completion Program I&C Projects, IV&V Summary Report for the Post Accident Monitoring System, (Proprietary), WNA-VR-00283-WBT, Revision 1, dated November 2010), submitted in TVA Letter to NRC dated December 3, 2010 (Reference 1).

2. The Independent Verification &Validation (IV&V) report covering the Design and Implementation phases (Nuclear Automation Watts Bar Unit 2 NSSS Completion Program I&C Projects, IV&V Summary Report for the Post Accident Monitoring System, (Proprietary), WNA-VR-00283-WBT, Revision 2, dated November 2010), submitted in TVA Letter to NRC dated December 3, 2010 (Reference 1).

3. The integration phase is covered in Attachment 10, the proprietary version of IV&V Summary Report for the Post Accident Monitoring System, WNA-VR-00283-WBT-P, Revision 3, dated December 2010.

Attachment 11 contains the non-proprietary version of IV&V Summary Report for the Post Accident Monitoring System, WNA-VR-00283-WBT-NP, Revision 3, dated December 2010. Attachment 12 contains the Application For Withholding Proprietary Information From Public Disclosure WNA-VR-00283-WBT-P, Revision 3, IV &V Summary Report for the Post Accident Monitoring System (Proprietary), dated December 2010.

TVA Response to Follow-up NRC Request:

See Response to item 3 (Matrix Item Number 142) 253 8/8/2010 Responder: Clark 234. Y Closed Closed TVA Letter dated Related to Open Item no. 83.

EICB (Carte) 10/5/10 TVA provided information by letter dated July 30, 2010 All AC160 modules used for the Common Q PAMS have Response provided in letter dated TVA to respond or LIC-110 Rev. 1 Section 6.2.2 states:

(ML102160349) - See Enclosure 1 Item No. 8 - that some AC160 been previously approved. The original response listed all 10/5/10 provide proposed date "Design features and administrative module contain FPGAs. For those modules that have not been FPGAs when the request was only for components that had of response. programs that are unique to Unit 2 previously approved, please provide information to address not been previously approved. should then be reviewed in accordance regulatory criteria for FPGAs. with current staff positions" LIC-101 Rev. 3 Appendix B Section 4, "Safety Evaluation" states: "the

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N information relied upon in the SE must be docketed correspondence."

254 8/10/2010 Responder: WEC 235. Y Closed Closed N/A - Request to TVA Letter dated EICB (Carte) make documents 10/21/10 Please make the following available in Westinghouse's Rockville Documents are available for review in the Westinghouse Response provided in letter dated available for audit. Enclosure 1 Item office. Rockville office per WEC letter WBT-D-2268, NRC Access to 10/21/10 No. 5 Common Q Documents at the Westinghouse Rockville WNA-PD-00056-WBT, Rev 1 Watts Bar Unit 2 NSSS Completion Office, dated 8/16/10 (Reference 2).

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.

255 8/10/2010 Responder: WEC 236. Y Closed Closed N/A - Request to TVA Letter dated EICB (Carte) make documents 10/21/10 Please make the following available in Westinghouse's Rockville Documents are available for review in the Westinghouse Response provided in letter dated available for audit. Enclosure 1 Item office. Rockville office per WEC letter WBT-D-2268, NRC Access to 10/21/10 No. 6 The Reusable Software Elements Documents. These contain Common Q Documents at the Westinghouse Rockville requirements for the software. Office, dated 8/16/10 (Reference 2).

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. 5 256 8/10/2010 Responder: WEC 237. Y Closed Closed N/A - Request to TVA Letter dated EICB (Carte) make documents 10/21/10 Please make the following available in Westinghouse's Rockville Documents are available for review in the Westinghouse Response provided in letter dated available for audit. Enclosure 1 Item office. Rockville office per WEC letter WBT-D-2268, NRC Access to 10/21/10 No. 7 Common Q Documents at the Westinghouse Rockville The following are documents that contain requirements used in the Office, dated 8/16/10 (Reference 2).

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

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 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, 257 8/10/2010 Responder: WEC 238. Y Closed Closed N/A - Request to N/A EICB (Carte) make documents Please make the following available in Westinghouse's Rockville WEC Reviewing to ensure all documents are available in available for audit.

office. 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, WBT-D-2268, 8/16/2010 Software Design Description for the Common Q Generic Flat-Panel Display Software, 00000-ICE-30157, Rev. 16, WEC still needs to make/confirm this document is available.

Westinghouse Electric Company LLC.

System Requirements Specification for the Common Q Post WBT-D-2024, 6/9/2010 Accident Monitoring System, 0000-ICE-30156, Rev. 06, Westinghouse Electric Company LLC.

Software Requirements Specification for the Common Q Post WBT-D-2024, 6/9/2010 Accident Monitoring System 00000-ICE-3238, Rev. 5, Westinghouse Electric Company LLC.

Commercial Dedication Report for QNX 4.25G for Common Q WBT-D-2268, 8/16/2010 Applications, WNA-CD-00018-GEN, Rev. 3, Westinghouse Electric Company LLC, Generic Common Q Software Installation Procedure, WNA-IP- WBT-D-2268, 8/16/2010 00152-GEN, Rev. 7, Westinghouse Electric Company LLC.

258 8/10/2010 Responder: WEC 239. Y Closed Closed N/A - Request to N/A EICB (Carte) make documents Please make the following available in Westinghouse's Rockville WEC Reviewing to ensure all documents are available in available for audit.

office. 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

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

-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 259 8/10/2010 Responder: WEC 240. Y Closed Closed N/A - Request to TVA Letter dated EICB (Carte) make documents 10/21/10 Please make the following available in Westinghouse's Rockville Documents are available for review in the Westinghouse Response provided in letter dated available for audit. Enclosure 1 Item office. Rockville office per WEC letter WBT-D-2268, NRC Access to 10/21/10 No. 8 Common Q Documents at the Westinghouse Rockville As they may demonstrate that a number of issues raised by, or that Office, dated 8/16/10 (Reference 2).

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.

260 8/10/2010 Responder: WEC 241. Y Closed Closed N/A - Request to N/A EICB (Carte) make documents Please make the following available in Westinghouse's Rockville WEC Reviewing to ensure all documents are available in available for audit.

office. Rockville office.

The Source level documents for the requirements WBT-D-2268, 8/16/2010 WBT-TVA-0070 Safety Related Digital Logic Cards Circuitry and Related Instrument Racks Restrictions WBT-D-0088 Transmittal Westinghouse comments on TVA WBT-D-2268, 8/16/2010 specification EDSR 52451 Contract Number 65717 Tennessee Valley Authority Watts Bar WBT-D-2268, 8/16/2010 Nuclear Plant Unit 2 NSSS Completion Project WEST-WBT-2008-25 TVA Contract Word Authorization Hilmes to determine if this document can be provided.

261 8/10/2010 Responder: WEC 242. Y Closed Closed N/A - Closed to TVA Letter dated LIC-110 Rev. 1 Section 6.2.2 states:

EICB (Carte)

Item No. 142 8/20/10 "Design features and administrative Please provide the Requirements Traceability Matrix for generic WEC to make available in Rockville ASAP. May require later programs that are unique to Unit 2 PAMS and/or any other RTMs applicable to WBN2 PAMS. Some submittal per 9/15 meeting. TVA Letter dated should then be reviewed in accordance requirements in the Software Requirements Specification are 9/2/10 with current staff positions" simply not present in the Watts Bar 2 PAMS specific RTM (WNA- Closed to Item 142 VR-00279-WBT). LIC-101 Rev. 3 Appendix B Section 4, "Safety Evaluation" states: "the information relied upon in the SE must be docketed correspondence."

262 8/10/2010 Responder: WEC 243. Y Closed Closed N/A - Request to N/A EICB (Carte) make documents In order to facilitate visits to the Rockville office, please make the WEC Reviewing to ensure all documents are available in available for audit.

following documents available at the Rockville office. Rockville office.

Watts Bar 2 PAMS licensing technical report 00000-ICE-37722 Rev. 0 (ML003733136) WBT-D-1526, 01/28/10; WBT-D-2268, 8/16/10 Common Q Software Programming manual (ML050350234)

Common Q topical report. (ML031830959) 263 8/11/2010 Responder: WEC 244. Y Closed Closed ML101650255, Item EICB (Carte)

Based on an examination of document available at the No. 2 Westinghouse Rockville offices (i.e., NA 7.4, WEC 7.2, WEC 7.3, Addressed in 9/20 - 9/21 audit.

CDI-3803, & CDI-3722) a CDI appears to identify the verification activities for each critical characteristic. These activities appear to Combine with item 138 after audit.

be documented on the associated dedication data sheets;

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N therefore, it appears that the Westinghouse Commercial Grade Dedication Plan is called a CDI and the completed CDI data sheets are the commercial grade dedication Report. If so, please provide the CDI for each new (not previously approved) component and the associated completed dedication data sheets.

264 8/11/2010 Responder: WEC 245. Y Closed Closed ML101650255, Item EICB No. 2 (Carte) Please provide a copy of the commercial grade survey(s) After the 9/20 - 9/21 audit.

applicable to each new (not previously approved) Common Q component. Combine with item 138 after audit.

265 8/11/2010 Responder: WEC 246. Y Closed Closed ML101650255, Item EICB No. 2 (Carte) Please provide: After the 9/20 - 9/21 audit.

WNA-CD-00018-GEN Rev. 3 00000-ICE-35444 Rev. 1 Combine with item 138 after audit.

266 8/11/2010 Responder: Webb/Webber 247. Y Closed Closed TVA Letter dated EICB (Carte) 10/21/10 Please provide a high level description of the Foxboro IA FSAR section 7.7.1.11 will be added in Amendment 101. In Enclosure 1 Item equipment used at WBN2. This description should be more discussions with the NRC reviewer on October 4, 2010 it No. 9 detailed than a brochure on the product line (or available on the was agreed that the new FSAR section along with previously web), and less detailed than a technical manual on each field submitted documents should be sufficient to address this replaceable unit. It is expected that such literature already exists. request. The NRC reviewer will notify TVA if additional documentation is required.

267 8/11/2010 Responder: WEC 248. Y Closed Closed EICB (Carte)

By letter dated June 18, 2010 (ML101940236) TVA stated that the This is addressed in the Licensing Technical Report, software safety plan (SSP) was not applicable to PAMS Revision 1, WNA-LI-00058-WBT-P.

applications (see Watts Bar 2 - Common Q PAMS ISG-6 Compliance matrix Item No. 10); however, reference No. 30 of the Attachment 1 of the letter dated 10/25/10 SRS (ML101050202) is: 00000-ICE-37727, Rev. 0, "Post Accident contains the Proprietary version of Westinghouses Monitoring System Software Preliminary Hazard Analysis for the document titled: Tennessee Valley Authority (TVA), Watts Common Q PAMS Project." A Preliminary Hazard Analysis is Bar Unit 2 (WBN2), Post-Accident Monitoring System required by the SSP. Please explain. (PAMS), Licensing Technical Report, Revision 1, WNA-LI-00058-WBT-P, Dated October 2010 268 8/19/2010 Responder: WEC 249. N Closed Closed EICB (Carte)

By letter dated March 12, 2010 (ML101680577), TVA stated that 11/18/10 Warren Odess-Gillett took action to discuss with Response included in letter dated the application specific hardware and software architecture Design Engineering to generate a non-prop figure 12/3/10 descriptions are addressed in the WBN2 PAMS System Design Specification (ML101680579, ML102040481, & ML102040482) and Attachment 18 contains the non-proprietary version of the Software Requirements Specification (ML101050202, Westinghouse document Watts Bar 2 Common Q PAMS ML102040486, & ML1022040487). Block Diagram.

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.

269 8/20/2010 Responder: NRC 250. Y Closed Closed N/A N/A DORL (Poole)

DORL to send the Eagle-21 Audit Report to TVA. Audit Report sent to TVA. Letter dated 11/2/2010 (ML102240630) 270 CB (C 8/23/2010 Responder: Clark 251. Y Closed Closed See also Open Item Nod. 41 & 245.

art

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N By letter dated June 18, 2009 (ML091560352) the NRC informed Close to items 41 and 245 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.

271 8/23/2010 Responder: WEC 252. Y Closed Closed N/A - Closed to NA EICB (Carte)

Item No. 142 By letter dated August 20, 2010 TVA docketed a Requirements 9/15 meeting and 9/20 audit Traceability Matrix for the Common Q PAMS (Requirements Phase).This document does not identify the source of each Closed to Item 142 requirement. The Common 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.

272 7.5.2. 7.5.1 8/26/2010 Responder: Clark 253. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL EICB (Marcus) 1 ML102861885 Item 10/21/10 In WBN2 FSAR Table 7.5-2, "Regulatory Guide 1.97 Variable List The variable number will be changed to 19 in FSAR Response provided in letter dated NRC to issue formal No. 19 Enclosure 1 Item (Deviation and Justification for Deviations)," (WBNP-96) for Amendment 101 as shown below: 10/21/10 RAI to TVA. No. 10 Variable 19, "Containment Hydrogen Concentration," Deviation 2 (page 19 of 41), the variable number is listed as 15. The variable Table 7.5-2 TVA formal response number should be listed as 19. due 10/31/10 DEVIATION 2 VARIABLE (1519)

Containment Hydrogen Concentration 273 7.5.2. 7.5.1 8/26/2010 Responder: Clark 254. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL EICB (Marcus) 1 ML102861885 Item 10/5/10 In WBN2 FSAR Table 7.5-2, "Regulatory Guide 1.97 Variable List Post accident samples will be obtained from the normal Response provided in letter dated NRC to issue formal No. 18 (Deviation and Justification for Deviations)," (WBNP-96) for sample system. 10/5/10 RAI to TVA Variable 97g, "Reactor Coolant Sample Activity," Deviation 5 (page 21 of 41), the last two sentences of the Justification read, "TVA 10/5/10 TVA letter Response 95 meets the intent of RG 1.97 recommended range by monitoring provided information.

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.

274. 7.5.2. 7.5.1 8/26/2010 Responder: Clark 255. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL EICB (Marcus) a 1 ML102861885 Item 10/21/10 In WBN2 FSAR Table 7.5-2, "Regulatory Guide 1.97 Variable List The SC in the last sentence will be changed to SG in FSAR Response provided in letter dated NRC to issue formal No. 21 Enclosure 1 Item (Deviation and Justification for Deviations)," (WBNP-96) for Amendment 101 as shown below: 10/21/10 RAI to TVA. No. 11 Variable 82, "Steam Generator Level Wide Range," Deviation 10 (page 24 of 41), in the last sentence, of the Justification, SC should SG wide range level indication is utilized as a diverse TVA formal response be SG. variable to auxiliary feedwater (AFW) flow for gross due 10/31/10 indication of flow to the SGs. The WBN AFW monitors are Types A1 and D2. WBN's position is that since SC SG wide range level is only used as a backup to redundant AFW flow monitors, it does not require redundancy 274. 8/26/2010 Responder: Stockton 256. Y Closed Closed RAI No. 6 TVA Letter dated b EICB ML102980005 10/21/10 (Singh) Loose Parts Monitoring System: TR 3.3 refers to section 4.4.6 of The reference will be changed to FSAR section 7.6.7 Loose Response provided in letter dated Due __________ 10/26/2010 Enclosure 1 Item the FSAR for description of the loose parts monitoring system. Part Monitoring System (LPMS) System Description in next 10/21/10 No. 12

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N However, this section of the FSAR is not available. TVA to check revision of the Technical Requirements Manual as shown Pending TRM the reference and respond. below: TRM Change Package submitted to amendment submittal.

TVA Licensing.

1. Watts Bar FSAR, Section 7.6.7, Lose Part Monitoring Response acceptable.

System. TVA to complete stated action.

275 8/27/2010 Responder: Clark 257. Y Closed Closed Not Required N/A EICB (Singh)

Answer exists in Loose Parts Monitoring System: RG 1.133, sections C.1.a and TRM 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.

276 7.6 7.6 8/27/2010 Responder: Webb 258. Y Closed Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 10/21/10 In order for the staff to review the effects of multi control systems Revised response provided in letter Due 11/24/10 Item#60 Enclosure 1 Item failure, provide the summary of the analyses documenting the The NRC reviewer confirmed this question applies to non- dated 12/22/10 No. 13 effect on the plant based on the following events: (1) loss of power safety systems. TVA to provide to all control systems powered by a single power supply; (2) failure Response provided in letter dated justification for non-of each instrument sensor which provides signal to two or more The Distributed Control System (DCS) implemented using 10/21/10 safety system other control systems; (3) Break of any sensor impulse line which is Foxboro I/A hardware, replaces most of the non-safety than DCS.

used for sensors providing signals to two or more control systems; related control systems for WBN Unit 2. The other non- Revised response provided in letter and (4) failure of digital system based on the common cause safety-related control systems within the scope of this dated 11/24/10 The statement that software failure affecting two or more control systems. For each of question are: failure of sense line these events, confirm that the consequences of these events will Response Acceptable. 11/17/10 where more than one not be outside chapter 15 analyses or beyond the capability of a. Rod Control - Failures of this system are addressed in transmitter is connected operators or safety systems. FSAR Chapter 15. would be bounded by

b. Main Turbine Electro-Hydraulic Control System TVA changed the response in the the failure of a single latest writeup. The scope of the transmitter does not The following provides the requested summaries for the four question applies to all non safety make sense.

events listed: related control systems and is not limited to just three system listed by TVA needs to make a (1) The (DCS) segmentation analysis submitted on TVA the TVA. TVA could use to statement that all non-letter to NRC dated August 11, 2010, Enclosure 2 envelope other control systems by safety control systems (Reference 7) demonstrates that the loss of any single Unit 1 analysis if they applies to Unit have been evaluated power source does not result in a loss of any DCS 2 systems also. against these criteria function. The other systems within the scope of this and have determined question are configured in the same manner as Unit 1, that their failure does with redundant power sources such that the failure of a not have consequences single power source does not cause a loss of function. which will put the plant outside chapter 15 (2) Signals shared by more than one control function analyses.

within the DCS are addressed in the DCS segmentation analysis submitted on TVA letter to NRC dated August 11, 2010, Enclosure 2 (Reference 7) which demonstrates that the loss of a single signal does not cause a failure of any critical control function.

The impact of a loss of signal to the other systems within the scope of this question is bounded by the loss of that signal to the individual system and has the same effect as for Unit 1.

(3) Where feasible, the Unit 2 design includes separate sense lines for redundant transmitters, thereby eliminating multiple single point failures which are present in Unit 1. A review of the transmitter sense line database was performed to identify multiple sensors on

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N a single sense line that had control functions (transmitters and switches). Attachment 9 provides the results of the review and an analysis of the functions impacted by a sense line failure.

There are no transmitters on shared sense lines, such that a sense line failure would impact any combination of the DCS, Rod Control or Main Turbine Electro-Hydraulic Control Systems.

(4) Limiting DCS failures were addressed in the segmentation analysis, supplemented by Fault Handling in the I/A Series System, Revision 1, submitted on TVA letter to NRC dated October 5, 2010, Attachment 42 (Reference 1). The other systems within the scope of this question are analog and therefore this question is not applicable.

All non-safety control systems have been evaluated against these criteria and TVA has determined that their failure does not have consequences which will put the plant outside chapter 15 analyses.

TVA Response to Follow-up NRC Request:

All non-safety related control systems were reviewed in the context of this question. The review found that failures of non-safety related control systems based on the scenarios in this RAI, do not have consequences which will put the plant outside the Chapter 15 analyses.

277 7.6 7.6.3 8/27/2010 Responder: Clark 259. Y Close Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 10/29/10 NUREG 0847, "Safety evaluation report Related to the operation of Removal of the Upper Head Injection System was reviewed Response is included in letter dated Item#61 Enclosure 1 Item Watts Bar Nuclear Plant, Units 1 and 2." has section 7.6.3 which as part of the WBN Unit 1 original and was reviewed by the 10/29/10 No. 15 discusses the, "Upper Head Injection Manual Control" system but staff in SER Supplement 6:

has been removed from the FSAR. Please provide the information regarding when this system was removed, and the justification for 1.7 Summary of Outstanding Issues - PAGE 1-3 the removal of the system and if the NRC staff has previously "Supplement 7" reviewed and accepted the removal of the system provide the reference to the staff's SE. (22) Removal of upper head injection system Opened (SSER 7) 6.3.1 (TAC 77195)

When the removal of UHI System was evaluated by the NRC, this should be applied to both sections 6.3.1 and 7.6.3, since the UHI Control System has no function once the UHI System has been removed.

278 7.6 7.6.6 8/27/2010 Responder: Trelease 260. Y Close Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 10/21/10 For FSAR Section 7.6.6, provide the justification for adding valves UFSAR section 7.6.6 does not identify control valves FCV- Response provided in letter dated TVA to Docket in 10/20 Item#62 Enclosure 1 Item FCV 63-8 and FCV 63-11, which require that power to be removed 63-8 and -11 as part of a list of valves that are required to 10/21/10 letter No. 14 and will be administratively controlled prior to use of RHR system have their motive power removed during specific operating for plant cooldown. Provide the P & ID and block diagram showing modes. The Unit 1 General operating instructions GO-1 and the operation of these valves. GO-6 (which will be used as a guideline for unit 2) provide administrative instructions to remove power and restore power to these valves in mode 3. Also, U1 Emergency operating procedures (e.g ES-1.3) do not address the restoration of power to the valves as part of post LOCA Mitigation activities.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Attachment 8 contains the control and logic diagrams, along with the applicable design changes to verify that the control schemes are similar to unit 1.

279 7.6 7.6.6 8/27/2010 Responder: Mather 261. Y Close Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 10/21/10 For FSAR Section 7.6.6, provide the justification for the exception The FSAR change to include the valves as exceptions to the Response provided in letter dated TVA to docket in 10/20 Item#63 Enclosure 1 Item to install protective covers which operator has to remove before he use of protective covers was made to match Unit 1 UFSAR 10/21/10 letter No. 15 can have access to control switch to operate two additional valves change Pkg. No. 1547 Safety Assessment Item 8. The FCV62-98 and FCV62-99. change package identified FCV-62-98 and 99 as exceptions to the use of protective covers. This change was based on WBPER980417 which removed the power from the valves and had them locked open. TVA will incorporate the same changes in Unit 2 as Unit 1. The Unit 1 changes are described in References 3 and 4.

280 7.6 7.6.6 8/27/2010 Responder: Trelease 262. Y Closed Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 10/21/10 For FSAR Section 7.6.6, provide the justification for the Historical DCN 38661 removes the requirement that power Response is acceptable. Item#64 Enclosure 1 Item acceptability of removing FCV 63-5 from the list of valves which be removed from FCV-63-5 during normal operations, and TVA to issue by 10/20 No. 16 has operating instructions specifying the removal of power during notes that the valve does not have a shunt breaker to allow Response provided in letter dated specific modes of plant operation. MCR position indication with power removed. The Unit 2 10/21/10 system description has been updated to reflect the Unit 1 change to the system description, and the update of section 7.6.6 to remove the requirement of FCV-63-5 from the list of valves which has operating instructions specifying the removal of power during normal operations. This is supported by the failure modes and effects analysis for the safety injection system calculation EMP-SNM-043029 (which has been revised to be applicable to Unit 2), as well as the Unit 2 FSAR Table 6.3-8 both which state that spurious closure of FCV-63-5 is not credible. Spurious closure of FCV-63-5 is not credible because the MCR hand switch is provided with a protective cover to prevent operator error. In addition, the hand switch is wired with contacts on both sides of the motor contactor to prevent a single failure within the switch gear from spuriously closing the valve. These features eliminate the need to remove power from FCV-63-5.

Attachment 10 contains the documentation associated with this response.

281 7.6 7.6.8 8/27/2010 Responder: Webb 263. Closed Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 10/29/10 For FSAR Section 7.6.8 in amendment 96, redline version has Attachment 5 contains the WBN Unit 2 FSAR markup for Response provided in letter dated Due 11/24/10 Item#65 Enclosure 1 Item completely rewritten this section of the FSAR, however, the staff is Section 7.6.8, Interlocks for RCS Pressure Control During 10/29/10 No. 16 not able to determine any changes made to the section. Explain Low Temperature Operation, showing what was changed Provide the basis for what changes have been made to this FSAR Section. between Amendments 95 and 96. the changes. Look at FSAR Amendment 101 did not Foxboro I/A impact.

TVA Response to Follow-up NRC Request: reflect the changes in 7.6.8 associated with implementation of The interlock for the RCS Pressure Control for Unit 2 is the DCS. Provide the basis for implemented differently than Unit 1 implementation. There acceptance to use Foxboro I/A DCS are no differences between Unit 1 and Unit 2 interlocks, inplace of analog instrumentation operation of interlocks and operator interface for operation of and relays.

the RCS Pressure Control. Primary sensing elements and final control elements are identical and operations of these Additional clarification provided devices are identical. For Unit 2, once signals are processed during 1/20 telecom. Question is by the Eagle 21 system, interlock implementation is by how does the system conform to

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N software modules in the Foxboro I/A Distributed Control IEEE 279 as described in 7.6.8.1.

System (DCS). Hardware outputs, generated in the DCS, operate the PORVs. The Unit 2 DCS is implemented via EDCRs 52378 and 54504. Section 7.6.8 in Amendment 101 of the WBN Unit 2 FSAR reflects the Unit 2 changes associated with implementation of the DCS.

TVA Response to Second Follow-up NRC Request:

The underlined text from FSAR Amendment 101 Section 7.6.8 reflects the installation of the Foxboro DCS.

7.6.8 Text from FSAR Amendment 101 The wide range temperature signals, as inputs to the Protection Sets I and II, continuously monitor RCS temperature conditions. In Protection Set I, the existing RCS wide range temperature channels on RCS loops 1 and 2 provide inputs to the Eagle 21 digital process protection system. Eagle 21 provides isolated analog signals to the digital process control system. An auctioneer function selects the lowest temperature signal which is then used to calculate an acceptable reference pressure limit (PORV setpoint) considering the plants allowable pressure and temperature Protection Set III. The calculated reference pressure is compared to the actual RCS pressure monitored by the wide range pressure channel. The auctioneered temperature signal will annunciate a main control room (MCR) alarm whenever the measured temperature approaches, within a predetermined amount, the reference temperature for arming the system. Similarly, whenever the measured pressure approaches within a predetermined amount of the programmed setpoint, another MCR alarm will be generated.

When the measured RCS pressure is equal to or above the programmed setpoint (nominal values), a PORV open signal is initiated and a MCR alarm is actuated. A manually armed permissive allows this actuation signal to control the Train A PORV (PCV-68-340A). The manually armed permissive also serves to block a spurious PORV opening due to potential instrument failure whenever the RCS temperature is above the arming reference temperature.

The monitored generating station variables that generate the actuation signal for the Train B PORV (PCV-68-334) are processed in a similar manner. The RCS loops 3 and 4 wide range temperature signals and the RCS pressure signal are provided from Protection Set II. Therefore, the generating station variables used for the Train B PORV are derived from a protection set that is independent of the sets from which generating station variables used for the Train A PORV are derived. The wide range temperature auctioneer function and the programmed pressure setpoint calculation for the Train B PORV are performed in a different group of the digital process control system than those for the Train A PORV. Each of these control groups has a fault tolerant, redundant processor pair and redundant power supplies with different power sources.

FSAR Section 7.6.8.1 Analysis of Interlock describes the

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N system conformance to IEEE-279. The design of the COMS as implemented in the Foxboro I/A system fully complies with FSAR section 7.6.8.1. Items (1) and (2) are implemented as part of the Eagle 21 modification. Item (3) is addressed by each processor pair having redundant power supplies with both being battery backed and ultimately backed by an ESF diesel generator.

282 7.6 7.6.9 8/27/2010 Responder: Trelease 264. Y Close Closed EICB RAI TVA Letter dated EICB (Garg)

Response is acceptable ML102910008 10/21/10 For FSAR Section 7.6.9 which discusses the switch over from The re-write for section 7.6.9 was to provide a more concise TVA to issue by 10/20 Item#66 Enclosure 1 Item injection to recirculation, and is a ESF system, the compliance with description of the instrumentation and controls. The section Response provided in letter dated No. 17 IEEE 279 has been removed from the FSAR. Justify this deletion. was too wordy, and several topics were duplicated in section 10/21/10 7.3. Wording is now more closely aligned to system description.

Compliance with IEEE 279 is not intended to be removed, merely the reference to the standard in that particular section. A statement is added that The automatic switchover of the RHR pumps from the injection to the recirculation Mode is part of the Engineered Safety Features Actuation System (ESFAS) discussed in chapter 7.3.

Chapter 7.3 includes a reference to IEEE Standard 279-1979. The reference in 7.6.9 was therefore considered unnecessary, and therefore removed.

Attachment 9 contains FSAR excerpts required to support this response.

283 7.7.5 XX 8/27/2010 Responder: Clark 265. Y Closed Closed EICB RAI No.13 TVA Letter dated This item is a follow-up question to item EICB (Darbali)

ML102910017, 10/29/10 96.

Follow-up to item 96 1. Steam generator power operated relief valve control Response is included in letter dated Due 10/31/10 10/19/10 Enclosure 1 Item system 10/29/10 No. 17 On Open Item 96, regarding the implementation of IEN 79-22, part of TVAs response was: The potential scenario for this event is addressed in 15.2.13, Accidental Depressurization of the Main The non-safety-related device/systems within the scope of IEN 79- Steam System.

22 are:

1. Steam generator power operated relief valve control system 2. Pressurizer power operated relief valve control system

2. Pressurizer power operated relief valve control system

3. Main feedwater control system The potential scenario for this event is depressurization

4. Automatic rod control system. of the reactor coolant system due to a relief valve failing open. This is addressed in 15.2.12, Accidental Failure of these systems/devices due to a high energy line break is Depressurization of the Reactor Coolant System and fully addressed in Chapter 15, Accident Analysis of the WBN Unit 15.3.1, Loss Of Reactor Coolant From Small Ruptured 2 FSAR. Pipes Or From Cracks In Large Pipes Which Actuate The Emergency Core Cooling System.

Please identify the sections of FSAR Chapter 15 that address the failures of these systems. 3. Main feedwater control system The potential scenarios for this event are:

a. A loss of feedwater due a feedwater isolation valve failing closed. This is addressed in 15.2.8, Loss of Normal Feedwater.

b. A feedwater regulating valve failing open. This is addressed in 15.2.10, Excessive heat removal due to feedwater system malfunctions.

4. Automatic rod control system

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N The potential scenarios are uncontrolled rod withdrawal events that are addressed in 15.2.1, Uncontrolled Rod Cluster Control Assembly Bank Withdrawal From A Subcritical Condition, 15.2.2, Uncontrolled Rod Cluster Control Assembly Bank Withdrawal At Power, and 15.2.3, Rod Cluster Control Assembly Misalignment.

284 7.7.3 7.4.1 8/27/2010 Responder: Webber 266. Y Closed Closed EICB RAI No.14 TVA Letter dated This item is a follow-up question to item EICB (Darbali)

ML102910017, 10/21/10 123 Follow-up to item 123 Attachment 2 to the 10/20 letter contains the electrical logic 10/19/10 Enclosure 1 Item diagrams and required Drawing Change Authorizations No. 18, Please provide a readable electrical logic diagram of the Volume (DRAs). Attachment 7 Control Tank Level Control System.

285 7.3.3 7.3 8/27/2010 Responder: McNeil 267. Y Closed Closed EICB RAI No.15 TVA Letter dated This item is a follow-up question to item EICB (Darbali)

ML102910017, 10/29/10 22 Follow-up to item 22 The Foxboro SPEC 200 components are physically arranged Response is included in letter dated 10/19/10 Enclosure 1 Item in the racks to meet the requirements of IEEE-279 and Watts 10/29/10 No. 18 Do the control loops meet the requirements of IEEE-279? If not Bar Design Criteria WB-DC-30-4, Separation/Isolation.

are they isolated from the circuit which meets the requirements of 279. Foxboro (Invensys) uses two IE analog modules to isolate IE to Non-IE signals. These are Contact Output Isolator (Model Number 2A0-L2C-R Relay Output) and Voltage-to-Current Converter (Model Number 2A0-VAI), both of which have the Input and Output signals isolated.

286 7.7.3 9.3.4.2.4 8/27/2010 Responder: Webber 268. Y Closed Closed EICB RAI No.16 TVA Letter dated EICB (Darbali)

ML102910017, 10/21/10 Item No.

SE 7.7.3, Volume Control Tank Level Control System Low alarm is correct - the setpoint is above the low-low Response is satisfactory. 10/19/10 19 interlock that opens the isolation valve, mentioned earlier in In FSAR section 9.3.4.2.4 a change was made to the last the paragraph. Response provided in letter dated paragraph of the Volume Control Tank description (page 9.3-31 of Editorial change to correct a typo. 10/21/10 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.

287 7.3 7.3-1 8/27/2010 Responder: Elton 269. Y Closed Closed ML102390538, Item Response EICB (Darbali)

No. 1, 9/10/10 and received in 11 In Amendment 95 of FSAR section 7.3.2.3 Further Unit 2 FSAR Section 7.3 addresses Engineered Safety EICB RAI No.17 10 TVA letter, item Considerations, the list of signals that would start the auxiliary Features (ESF) Actuation System. AMSAC is non-safety, ML102910017, 7.3-1 feedwater motor driven and turbine driven pumps was moved to and thus non-ESF. Therefore, it was correct to not include 10/19/10 table 7.3-1 item 3, Auxiliary Feedwater. However, item (6) AMSAC when the initiating signals were relocated from Unit AMSAC was not included in table 7.3-1. 2 FSAR Section 7.3.2.3 to Table 7.3-1.

Please explain this omission or state your commitment to correct this in a future amendment.

288 7.3 9/2/2010 Responder: McNeil 270. Y Closed Closed EICB RAI EICB (Garg)

ML102910008 (1) Can we add a section to chapter 7 giving a brief overview of the (1) and (2) The following new section and reference will be Due 11/24/10 Item#67 Foxboro Spec 200 in Section 7.3? added to the WBN Unit 2 FSAR as part of Amendment 102: TVA committed to adding a description of the Foxboro Spec TVA should include the Additional Clarification provided by the NRC 7.3.1.1.3 Analog Instrumentation 200 hardware at the 10/12 NRC list of all the functions Public Meeting. where Spec 200 is (2) TVA should include the list of all the functions where Spec 200 The miscellaneous safety-related analog process control used and discuss is used and discuss differences between unit 1 and unit 2. (3) This and indication loops are made up of discrete analog differences between discussion should also include loops which are currently used for modules that have been tested and qualified for use in unit 1 and unit2. This

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Unit 1 operation (4) If Spec 200 components have also been safety related systems. The various components have discussion should also qualified to RG 1.209, it should be stated and if not why not. been qualified to IEEE Standard 323-1983 (R-1996) IEEE include loop which are Standard for Qualifying Class IE Equipment for Nuclear currently used for Unit 1 Power Generating Stations, IEEE Standard 344-1987 (R- operation If Spec 200 1993) IEEE Standard Recommended Practices for components have also Seismic Qualification of Class IE Equipment for Nuclear been qualified to RG Power Generating Stations, and IEEE Standard 384-1984 1.209, it should be (R-1992) IEEE Standard Criteria for Independence of stated and if not why Class IE Equipment and Circuits. The modules are not.

arranged in instrument loops to provide the safety functions listed below:

Turbine driven AFW Pump Flow Control Motor driven AFW pump differential pressure indication and recirculation valve control Steam generator AFW flow and level indication and control Containment Pressure indication Upper and Lower Compartment Containment Ambient Temperature indication RHR Heat Exchanger CCS Supply Header Flow Sample Heat Exchanger Header CCS Differential Flow ERCW Strainer Differential Pressure, Backwash and Flush Control CCS Heat Exchanger B Inlet Pressure CCS Surge Tank Level Control CCS Heat Exchanger B Outlet Temperature Reactor Vessel Head Vent Throttle Manual Loading Station (Unit 2 Only)

EGTS Annulus Differential Pressure Control The components are physically arranged in the racks to meet the requirements of IEEE-279 and Watts Bar Design Criteria WB-DC-30-4, Separation/Isolation. (Unit 2 Only) Two IE analog modules are used to isolate IE to Non-IE signals. These are the Contact Output Isolator and Voltage-to-Current Converter, both of which have the Input and Output signals isolated.

EMI testing and acceptance by TVA of the Foxboro Spec 200 hardware is documented in Reference [8].

References:

(8) Invensys Process Systems Document No. 800063-1830, Electromagnetic Compatibility Test Reports, dated August 21, 2008, Rev. 0.

(2) As agreed to by TVA and the NRC reviewer, the level of detail necessary to describe the differences between Unit 1 and Unit 2 is down to the specific hardware manufacturer.

This level of detail was agreed to not be appropriate in Chapter 7 which discusses the functions and design requirements for the plant control systems. The hardware manufacturer level of detail is addressed in Chapter 3.10 which describes the qualification of the specific hardware for

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N safety related functions.

(3) While not specifically identified as such, loops in service for Unit 1 (Essential Raw Cooling Water etc.) are described in the FSAR chapters describing the systems the loops serve.

(4) Reg. Guide 1.209, Guidelines for Environmental Qualification of Safety-Related Computer-Based Instrumentation and Control Systems in Nuclear Power Plants, is not applicable to the analog Foxboro Spec 200 hardware.

289 9/2/2010 Responder: Faulkner 271. Y Closed Closed RAI No. 24 TVA Letter dated EICB (Singh)

- Response acceptable. ML102980005 10/21/10 There are 4 Containment High Range Radiation Monitors Response provided in letter dated 10/26/2010 Enclosure 1 Item Provide an ISG 2 diversity analysis for the containment high range (HRRMs) for WBN2, a pair in upper containment and a pair 10/21/10 Please refer to No. 20 accident monitors RM-1000. in lower containment. Each pair completely meets the highlighted sections of requirements for safety related equipment including response that address separation, independence, electrical isolation, seismic NRC comments 1) and qualification, quality requirements, etc. Each monitor 2).

channel is a standalone instrument loop with traditional individual panel readout. They are not a part of a Highly Staff has the following Integrated Control Room (HICR) and there is no diversity comments on the question relating to the HRRMs and any HICR infrastructure. proposed TVA Therefore, the response to this RAI will address the response per the functional uses of the HRRMs and the alternate and diverse 10/21/submittal:

instrumentation that could be used for those functions should a common mode software issue render both trains of 1) Response HRRMs non-functional. addresses upscale failure. Please The Containment HRRMs have no automatic actuation explain how function. They only provide indication as required by RG downscale failure of 1.97R2. They are used at WBN for 2 functions. They are all HRRM channels used by the operators in Emergency Operating Instructions is detected and (EOI) as one of the indications of abnormal containment appropriate actions conditions indicative of a Loss of Coolant Accident (LOCA) taken.

after a Reactor Trip and Safety Injection and they are used in Emergency Plan Implementing Procedures (EPIP) to assist 2) Please confirm that with event classification for events which involve fuel the location for cladding degradation. obtaining the RCS sample is In the EOI procedures, there are several diverse indications accessible after an of containment conditions that are used to detect a LOCA accident.

and they are Containment Pressure, Containment Temperature, and Containment Sump Level. All of these Otherwise, the instrument channels are diverse to the HRRMs in that they response is acceptable.

do not share a software platform or any integrated information or control system features. The HRRMs Due 10/31/10 functional through individual, self contained, microprocessor based instrument loops. Containment Pressure and Sump Level indications are provided through Eagle 21 equipment which is completely diverse from the HRRMs. Containment Temperature is provided through Foxboro Spec 200 instrument channels which are completely diverse from the HRRMs. All of these readouts are through traditional panel meters and are not part of any HICR infrastructure.

In the EPIPs, the HRRMs are used to indicate loss of fuel

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N clad barrier and the potential loss of a containment barrier.

Potential fuel clad damage can also be determined from samples taken from the Reactor Coolant System and from Incore Thermocouple readings. RCS sampling does not rely on plant instrumentation systems and the Incore Thermocouple System uses a Common Q software platform which is diverse from the HRRMs. 2) The accessibility required to obtain post accident samples of RCS has been demonstrated to be a viable post accident action at WBN.

Should all 4 channels of HRRMs fail upscale, Annunciator Response Instructions would be followed and they call for evacuation of containment, sampling of RCS, checking other non-accident Radiation Monitors, notification of Radiological Control personnel to investigate, potential transition to Abnormal Operating procedures for management of potential radioactive material release, and evaluation under the Emergency Plan Implementing Procedures for event classification. All of these actions are conservative actions.

1) Should all 4 channels of the HRRMs fail downscale, the operators would turn to diverse indications as noted above before taking any further action.

Therefore, there are diverse methods and equipment sets that can be used for any functions provided by the HRRMs should both channels become nonfunctional.

290 7.7 9/7/2010 Responder: Clark 272. Y Closed Closed N/A N/A This item is a duplicate of item 291.

EICB (Carte)

The equation at the bottom of Amendment 99 page 7.7-3 is wrong. This item is a duplicate of item 291.

There are two ways that this equation is inconsistent with the text above it.

291 7.7 9/7/2010 Responder: Clark 273. Y Closed Closed TVA Letter dated EICB (Carte) 10/21/10 The equation at the bottom of Amendment 100 page 7.7-3 is The errors in the terms within the equation for total rod Enclosure 1 Item wrong. There are two ways that this equation is inconsistent with speed error [TE] will be corrected in FSAR Amendment 101 No. 21 the text above it. as shown below:

1 1 1 1 1 1

292 7.2.5 7.2 9/7/2010 Responder: Craig 274. Y Closed Closed EICB RAI TVA Letter dated EICB (Garg)

ML102910008 10/21/10 FSAR Section 7.2, Steam Generator Reference Leg: By letter The SG level transmitter reference legs are not insulated on Response provided in letter dated Due 10/31/10 Item#68 Enclosure 1 Item dated July 27, 1994, TVA had withdrawn its commitment on Unit 1 Unit 1 and will not be insulated on Unit 2. The analysis 10/21/10 No. 22 to insulate SG reference leg. TVA had provided an analysis to provided for Unit 1 is also applicable to Unit 2. FSAR justify this action which was accepted by the staff. Confirm Section 7.2.1.1.2 (5) indicates that the Low-Low steam whether SG reference leg in Unit 2 are insulated and if not then generator water level trip protects the reactor from loss of confirm that the analysis which was submitted for Unit 1 is also heat sink in the event of a loss of feedwater to one or more applicable to Unit 2. steam generators or a major feedwater line rupture outside containment. For a feedwater line rupture inside containment the TVA analysis credits the high containment

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N pressure Safety Injection signal. FSAR Section 15.4.2.2 has been revised accordingly.

Reference:

1. Watts Bar Unit 1 SER NUREG-0847, Supplement 14.

2. Westinghouse WCAP 13462, Revision 2 293 7.7.4 7.2.2.3.5 9/8/2010 Responder: Craig 275. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL EICB (Marcus)

ML102861885 Item 10/29/10 FSAR Amendment 100, Section 7.2.2.3.5 discusses Steam Steam Generator Overfill Response is acceptable NRC to issue formal No. 22 Enclosure 1 Item Generator Water Level and protection against low water level. FSAR Section 7.2 discusses reactor trip functions. Section RAI to TVA. No. 19 However, this section does not discuss protection against Steam 7.2.2.3.5 describes the Low-Low steam generator level Response is included in letter dated Generator overfill. Additionally, FSAR Section 7.2.2.3.4 discusses reactor trip. The steam generator High-High level interlock 10/29/10 TVA to provide formal Pressurizer Water Level and provides minimal information (P-14) protects against steam generator overfill by initiating response to RAI concerning Pressurizer overfill. Please provide a discussion of feedwater isolation and a turbine trip. Reactor trip occurs protection against Pressurizer and Steam Generator overfill. indirectly as a result of the turbine trip if power is above 50%,

the P-9 interlock. This function is identified as ESFAS interlock P-14 in FSAR Section 7.3, Table 7.3-3. The High-High level interlock is also discussed in FSAR Section 10.4.7.3. Section 15.2.10 analyzes the feedwater malfunction event which causes one or more feedwater control valves to fail to the fully open position.

Pressurizer Overfill The High pressurizer water level reactor trip protects against pressurizer overfill. This trip is described in FSAR Section 7.2.1.1.2 (3). Section 7.2.2.3.4 discusses specific control and protection interactions related to pressurizer level control. The high water level trip setpoint provides sufficient margin such that the undesirable condition of discharging liquid coolant through the safety valves is avoided.

Pressurizer level is modeled in various Chapter 15 events to ensure that critical protection functions will function as required.

294 7.3 7.3.1.1.1 9/9/2010 Responder: Elton 276. Y Closed Closed ML102390538, Item Response EICB (Darbali)

No. 2, 9/10/10 received in 11 In Amendment 95 of FSAR section 7.3.1.1.1 Function Initiation, The information provided in Unit 2 FSAR Section 7.3.1.1 is 10 TVA letter, item item (13) was arranged into paragraph form from what used to be a not meant to describe the specific function of each item in 7.3-2 listing of items (a), (b) and (c). detail; the descriptions provided are a summary listing. The omitted information provided information beyond the level of The second bullet under item (c) was omitted in the new detail provided for the other items in this section.

paragraph.

The level of detail contained in item (13) of Unit 2 FSAR Initiates Phase B containment isolation of the following: Section 7.3.1.1 is consistent with that contained in item 13.

Closure of the main steam isolation valves (MSIV) to limit of Unit 1 UFSAR Section 7.3.1.1.

reactor coolant system cooldown for breaks downstream of the MSIVs.

Please explain this omission or state your commitment to correct this in a future amendment.

295 7.3 7.3.1.1.2 9/9/2010 Responder: Elton 277. Y Closed Closed ML102390538, Item Response EICB (Darbali)

No. 3, 9/10/10 received in 11 In Amendment 95 of FSAR section 7.3.1.1.2 Process Protection The level of detail is sufficient for this section without the two 10 TVA letter, item Circuitry, item (3), references to sections 7.6 and 7.7 were removed references to other Sections. 7.3-3 removed.

The level of detail contained in item (3) of Unit 2 FSAR Please explain the reason for removal. Section 7.3.1.1.2 is consistent with that contained in item 3.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N of Unit 1 UFSAR Section 7.3.1.1.2.

296 7.3 7.3.1.2.1 9/9/2010 Responder: Elton 278. Y Closed Closed ML102390538, Item Response EICB (Darbali)

No. 4, 9/10/10 received in 11 In Amendment 95 of FSAR section 7.3.1.2.1 Generating Station The information provided in Unit 2 FSAR Section 7.3.1.2.1 is 10 TVA letter, item Conditions, the new paragraph was arranged from what used to be not meant to provide detailed information describing what 7.3-4 a listing of items (1.b), (1.c), and (2.b), leaving out items (1.a) and each condition includes. Deletion of the breaks described in (2.a). Even if the paragraph contains the word include, the breaks Items (1.a) and (2.a) is justified because they are in items (1.a) and (2.a) should be listed. encompassed by the operating conditions primary system breaks and secondary system breaks, respectively.

Please explain this omission or state your commitment to correct this in a future amendment. The level of detail contained in Unit 2 FSAR Section 7.3.1.2.1 is consistent with that contained in Unit 1 UFSAR Section 7.3.1.2.1.

297 7.3 7.3.1.2.2 9/9/2010 Responder: Elton 279. Y Closed Closed ML102390538, Item Response EICB (Darbali)

No. 5, 9/10/10 received in 11 In Amendment 95 of FSAR section 7.3.1.2.2 Generating Station Unit 2 FSAR Section 7.3 addresses Engineered Safety 10 TVA letter, item Variables, the following sentence was erased: Features (ESF) Actuation System. Post accident monitoring 7.3-5 is not an ESF; thus, a reference to it is not required in Post accident monitoring requirements and variables are given in 7.3.1.2.2.

Tables 7.5-1 and 7.5-2.

Please explain the reason for removal.

298 7.3 XX 9/9/2010 Responder: Clark 280. Y Closed Closed ML102390538, Item Response EICB (Darbali)

No. 6, 9/10/10 received in 11 IE Bulletin 80-06 calls for review of engineered safety features with A review of the schematic diagrams for the WBN Unit 2 10 TVA letter, item the objective of ensuring that no device will change position solely valves listed in SER 3 found the following: 7.3-6 because of the reset action.

(1) For feedwater isolation valves (FCV-3-33, FCV-3-47, In Supplement 3 of NUREG-0847, section 7.3.5, the staff approved FCV-3-87, and FCV-3-100), feedwater check valve the design modifications proposed by the applicant that would bypass valves (FCV-3-185, FCV-3-186, FCV-3-187, allow certain devices to remain unchanged upon an ESF reset. and FCV-3-188), and upper tap main feedwater The staff also found acceptable the applicants justification for isolation valves (FCV 3-236, FCV-3-239, FCV-3-242, some safety-related equipment that does not remain in its and FCV-3-245), the Unit 2 equivalent reset switch emergency mode after an ESF reset. and a relay have been added for each steam generator loop. When the engineered safety feature Please confirm whether or not the equipment that was determined (ESF) signal is reset, the individual valve will not in NUREG-0847 and its supplements to remain unchanged upon change state until both the loop and the ESF train an ESF reset will still remain unchanged in Unit 2. reset switches have been reset.

(2) For steam generator blowdown isolation valves (FCV-43-54D, FCV-43-56D, FCV-43-59D, FCV 63D, FCV-43-55, FCV-43-58, FCV-43-61, and FCV-43-64), the ESF signal is sealed in by means of a seal in relay. The individual valve will not change state until a hand switch in the sample room is used to reopen the individual valve.

(3) For residual heat removal heat exchanger outlet flow control valves (FCV-74-16 and FCV-74-28), the ESF signal is sealed in by the limit switch. The Unit 2 equivalent reset switch has been added at the control room control board. When the ESF signal is reset, the individual valve will not change state until the individual reset switch has been reset.

299 EICB Provide Common Q Software Requirements Specification Post Attachment 41 of the 10/5 letter contains the Common Q 281. Y Closed Closed TVA Letter dated (Carte Accident Monitoring System 00000-ICE-3238 Rev. 5 Software Requirements Specification Post Accident 10/5/10

)

Monitoring System 00000-ICE-3238 Rev. 5 and the affidavit Response provided in letter dated

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N for withholding. 10/5/10 300 Need Radiation Monitoring System Description/Design Criteria Responder: Temples/Mather 282. Y Closed Closed RAI No. 25 TVA Letter ML102980005 11/24/10, item 4, Are detectors different from Unit 1. Describe any differences. (1) The Radiation Monitoring Design Criteria Document, Response is included in letter dated Due 11/24/10 10/26/2010 and TVA letter WB-DC-40-24, Revision 21 is contained in Attachment 10/29/10 10/29/10 Are there any commercially dedicated parts in the RM-1000? If so, 6 to letter dated October 31, 2010. TVA to address the Enclosure 1 Item how are they dedicated? Revised response Included in letter following comments: No. 20 (2) Attachment 7 contains the General Atomics detector dated 11/24/10 Please confirm that digital communication ports available in RM- differences report. The containment high range (1) Is it Att. 5 or Att.

1000 are not used. radiation monitors are loops 271-274. 6?

(2) Pl. confirm that (3) For safety-related applications, General Atomics HRRMs are loops Electronic Systems, Inc. supplies the RM-1000 module 271-274.

assembly as a Basic Component. This assembly does (3) TVA to clarify that contain component parts that are Safety-Related GA has a Commercial Grade Items (SRCGI). Because these commercial EICB (Singh)

SRCGI components are assembled into the delivered dedication Basic Component, they are dedicated to the assembly program in place by virtue of the acceptance test of the full RM-1000 and that GA is an assembly. Safety-related commercial grade items are approved dedicated in accordance with General Atomics 10CFR50, App. B approved 10 CFR 50 Appendix B program. supplier.

App B does not (4) The digital communications ports on the safety-related address RM-1000 radiation monitors are not used. commercial grade dedication .

TVA Response to Follow-up NRC Request:

Revised response General Atomics Electronics Systems, Inc. is an approved is acceptable.

10 CFR 50 Appendix B supplier. They have a commercial Please submit grade dedication program. response.

(4) Response acceptable.

301 1.TVA is requested to address the consequences of software Responder: WEC/Davies/Clark 283. Y Closed Closed RAI No. 11 TVA Letter dated Note 1:

common cause failure including all potential resulting failures (i.e. ML102980005 10/29/10 (Encl 1, total loss of CERPI, system fail as-is). TVA Partial Response: Revised response included in letter Due 12/22/10 10/26/2010 Item 21) and letter Effects of common cause software dated 12/22/10. dated 12-22-10 failure are addressed in DI&C-ISG-02

2. In addition, address how the actions stipulated in the plant For all accidents analyzed in WBN Unit 2 FSAR, Chapter 15, 1) Please address (Encl 1, item 25) (ML091590268) Section 4 on pages 8 Technical Specifications will be taken when the CERPI system no credit is taken for the rod position indication system. For Revised response included in letter how fail-as-is is and 9. This document is publically indications are lost. Information notice IN 2010-10 (ML100080281) all continuous rod withdrawal accidents analyzed in WBN dated 11/24/10. detected i.e. available. Some excerpts are as addresses the need to consider software failures and the actions Unit 2 FSAR, Chapter 15, no credit is taken for any rod alarms, rod follows:

required to assure that the plant will stay within its licensing basis. stop/block. Partial response in 10/29 letter. position deviation alarms, etc. For example, a failure to trip might EICB (Singh)

3. Provide FMEA in support of your response. (1) Technical Specification 3.1.8, Rod Position Indication, 2) Response not be as limiting as a partial does not have an action for total loss of indication; acceptable. actuation of an emergency core

4. FSAR Table 7.7-1, Plant Control System Interlocks lists interlock therefore, a total loss of CERPI puts the plant into LCO 3) Response cooling system, with digital indications of a successful actuation.

C-11 to block automatic rod withdrawal when 1/1 Control Bank D 3.0.3 which states: acceptable. In cases such as this, it may take an rod position is above setpoint. This interlock capability would be 4) a. Response operator longer to evaluate and lost in case of total loss of CERPI. How is the rod block assured When an LCO is not met and the associated ACTIONS acceptable. correct the safety system failure than for this event? are not met, an associated ACTION is not provided, or if b. Pl. address it would if there was a total failure to directed by the associated ACTIONS the unit shall be failure mode on send any actuation signal. For this

5. How is automatic rod withdrawal affected in case of total loss of placed in a MODE or other specified condition in which fail-as-is. reason, the evaluation of failure signals from the CERPI to the ICS? Is this interlock fail safe? the LCO is not applicable. Action shall be initiated within 5) Response modes as a result of software CCF 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in: acceptable. should include the possibility of 6.FSAR chapter 15, Section 2.3.2.1states that the resolution of the 6) Response partial actuation and failure to actuate with false indications, as well rod position indicator channel is 5% of span (7.2 inches). The MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />; acceptable.

as a total failure to actuate.

CERPI system accuracy specified in the CERPI System MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N requirements Specification, WNDS-DS-00001_WBT, Rev. 2 is 12 MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />. TVA to address steps or 5.19%. The specified system accuracy seems to be common cause failure The primary concern is that an greater than the accuracy assumed in the FSAR Chapter 15. as stated under undetected failure within the digital Please clarify this anomaly. Exceptions to this Specification are stated in the response item 2. system could prevent proper system operation. A failure or fault that is individual Specifications. Where corrective measures detected can be addressed; are completed that permit operation in accordance with Please explain how however, failures that are non-the LCO or ACTIONS, completion of the actions various alarms will detectable may prevent a system required by LCO 3.0.3 is not required. continue to annunciate actuation when required.

on software lockup? Consequently, non-detectable faults (2) CERPI common mode software failure Need better are of concern.

explanation to Description of the CERPI systems installed at Watts understand the Bar (Unit 1 & 2): rationale behind the response.

Each Programmable Logic Controller (PLC),

Maintenance Test Panel (MTP), and Operators Module Further response (OM) is isolated within its own Train, A or B. Rod required to address position information is provided to the OMs in the main CCF:

control room via redundant data links. Each train (PLC, MTP, and OM) is electrically isolated from the other Total failure of train. software and lock-up alone would normally Communications within a CERPI train (PLC, MTP, and be detected. Staff is OM) are continuously monitored. If communication is also concerned by interrupted, this condition is annunciated to the operator undetected failure in the control room. The MTP and OM display screens within the digital have rotating cursors in the upper right-hand corner of system that could the display to indicate that the system is operating. prevent proper system operation. A failure or History of CERPI: fault that is detected can be addressed; The basic PLC software associated with the CERPI however, failures that system has been in use for over ten years. The first are non-detectable plant to utilize the CERPI PLC software was Beaver may prevent a system Valley. In 2003, the CERPI software was deployed with actuation when interfaces to the Common Q MTP and OM interfaces required or may result within the systems for Surry Units 1 & 2, and Watts Bar in a partial actuation.

Unit 1. In 2009, the Watts Bar Unit 1 CERPI system Please address the was modified to allow for two independent trains of consequences of an CERPI. The Watts Bar Unit 2 CERPI system is based undetected failures on on the Unit 1 design. Only the detectors and the system operation and detector interface boards are not redundant within the alarms and interlocks Watts Bar CERPI systems. including control bank D interlock. (See note CERPI Software Failure Analysis 1 in the Comments column of this open With regard to the CERPI system software: item for reference)

The software used on PLC-A is identical to that used on PLC-B.

The software used on MTP-A is identical to that used on MTP-B The software used on OM-A is identical to that used on OM-B.

A common cause failure affecting the software of one CERPI train would affect the other train as well.

Common cause problems associated with the CERPI

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N software were mitigated by the Westinghouse software development process, factory acceptance testing, and site acceptance testing. There is no "fail as-is" scenario. Any failure of a hardware/software component (resulting in processor lock-up) would be immediately annunciated (Main Control Room alarm).

A loss of communication to the MTP, or OM would be annunciated, and the data values on the flat panel display would be displayed in magenta (indicating failure). A hardware/software failure in the PLC (resulting in processor lock-up) would result in an annunciator because of the watchdog alarm circuit associated with the PLC processor module.

A total loss of CERPI indication (e.g., loss of both AC power sources to the rod position cabinets) is possible, but this condition would be immediately annunciated. A complete loss of CERPI indication would lead to entering Technical Specification LCO 3.0.3. A more likely scenario would be loss of a single train of CERPI due to a hardware failure; in which case, there are no technical specification conditions to enter because a single train is capable of providing all rod indications needed for control.

(3) There is no FMEA for the CERPI system.

(4) Control Bank D Automatic Rod Withdrawal Limit would be assured by Operations and control circuitry by the following 2 methods:

a. A simultaneous failure of all indications of the Rod Position Indication System places the plant in LCO 3.0.3, since it would prevent compliance with actions in LCO 3.1.8.

b. CERPI cabinet relays A-KX-18 and B-KX-18 are the PLC controlled components of Rod Withdrawal Limit. The relays are active low requiring power to activate the contacts in the control circuit. Total loss of CERPI will open the contacts and block Automatic Rod Withdrawal.

Additionally, Annunciator window 64F will annunciate to show C-11 BANK D AUTO WITHDRAWAL BLOCKED.

(5) The CERPI Maintenance and Test Panels are used to set the Rod Withdrawal Limit with output signal to ICS as a parallel path. As stated above, the relays are the controlling functions and loss of signal to ICS will not affect the capability of the control circuit to disable the Automatic Rod Withdrawal function. The C-11 interlock is fail safe with regards to loss of power.

(6) The cycle-specific analyses for the static rod misalignment assume full misalignment of an individual rod from the bank position indicator(s). Such a misalignment exceeds that which is possible during plant operations when accounting for the most adverse

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N combination of the rod deviation alarm and uncertainty of the rod position indicator (both 12 steps). For consistency of parameter (and units) with the deviation alarm and position indicator uncertainty, the WBN Unit 2 FSAR Chapter 15, Section 2.3.1 will be revised in Amendment 102 to read:

The resolution of the rod position indicator channel is +/-

12 steps. Deviation of any RCCA from its group by twice this distance (24 steps) will not cause power distributions worse than the design limits. The deviation alarm alerts the operator to rod deviation with respect to group demand position in excess of 12 steps. If the rod deviation alarm is not operable, the operator is required to take action as required by the Technical Specifications.

This change is consistent with FSAR section 4.3.2.2.5, Limiting Power Distributions Page 4.3-13, which states the maximum deviation assumed is 12 steps.

TVA Response to Follow-up NRC Request:

1. The following response is based on the information contained in Westinghouse letter WBT-D-2722 Response To Question On CERPI RAI #301, dated December 6, 2010 (Reference Error! Reference source not found.).

TVA believes the follow-up question is related to the statement found in the response to question 2 of NRC Matrix Item 301, submitted on TVA Letter to NRC Watts Bar Nuclear Plant (WBN) Unit 2 -

Instrumentation and Controls Staff Information Requests, dated November 24, 2010, (Reference Error! Reference source not found.) Any failure of a hardware/software component (resulting in processor lock-up) would be immediately annunciated (Main Control Room alarm)

The CERPI system will not annunciate various system alarms if the software is in a lockup condition.

However, the system will annunciate an alarm based on the PLC watchdog relay dropping out because the software has locked up the processor. So, even if the PLC locks up, an alarm is generated to alert the operators in the Main Control Room (MCR).

The CERPI system alarms (that connect to the plant annunciator system) are wired to specific alarm relays within the CERPI system. With the exception of the watchdog alarm relay, the alarm relay coils are actuated by the PLC Digital Output Module. The plant annunciator wiring connects to either the Normally Open (NO) or the Normally Closed (NC) contacts of the associated alarm relay. The watchdog relay is configured such that when a timeout condition occurs (the PLC locks up), the watchdog relay de-energizes, and a CERPI System

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Trouble alarm is annunciated in the MCR.

2. As previously stated;

a. For all accidents analyzed in WBN Unit 2 FSAR, Chapter 15, no credit is taken for the rod position indication system. For all continuous rod withdrawal accidents analyzed in WBN Unit 2 FSAR, Chapter 15, no credit is taken for any rod stop/block. Based on this, an undetected failure of the CERPI would not have any impact on the WBN Unit 2 accident analysis.

b. Concerning the impact on Bank D, CERPI cabinet relays A-KX-18 and B-KX-18 are the PLC controlled components of Rod Withdrawal Limit.

The relays are active low requiring power to activate the contacts in the control circuit. Total loss of CERPI will open the contacts and block Automatic Rod Withdrawal. Additionally, Annunciator window 64F will annunciate to show C-11 BANK D AUTO WITHDRAWAL BLOCKED.

Therefore, this would not result in an undetected failure. In the event of an undetected failure that kept relays A-KX-18 and B-KX-18 energized, the worst case scenario would be a continuous rod withdrawal event. This event is already addressed in the Chapter 15 accident continuous rod withdrawal accident analysis which takes no credit for rod stops/blocks.

302 7.5.2. 7.5.1 09/17/2010 Responder: Tindell 284. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 1 ML102861885 Item 10/29/10 Item 208 requested a description of the changes that were Attachment 8 contains the requested 50.59 evaluations and Response is acceptable NRC to issue formal No. 23 Enclosure 1 Item See Item 332 performed under 10 CFR 50.59 for 16 Unit 1 PAM variables that the variable table cross referencing the variable to the RAI to TVA No. 22 were identified in Enclosure 1 Item No.6 of the letter dated June appropriate DCN. There are two changes to the original Response is included in letter dated EICB (Marcus) 18, 2010 (ML101940236). Please identify the specific 10 CFR table. Variable 9, RCS Pressurizer Level and 10, RCS 10/29/10 TVA to provide formal 50.59 documentation that applies to each of these 16 variables. Pressure Wide Range have been changed from 50.59 Y to response to RAI N. The original response showed these variables as changed under 10 CFR 50.59. The response was based on the plan to replace all paper recorders in Unit 1. The assumption was that these recorders would be replaced prior to Unit 2 startup. While this may still occur, the recorders have not been replaced at this time.

303 7.5.2. 7.5.1 09/17/2010 Responder: Tindell 285. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 1 ML102861885 Item 10/29/10 Enclosure 1 Item 6 of the letter dated June 18, 2010 included a Attachment 9 contains the cross reference between the Unit Response is acceptable NRC to issue formal No. 24 Enclosure 1 Item See Item 333 column to indicate the Unit 2 variable source for each PAM variable 2 and Unit 1 variable sources for the unique WBN Unit 2 RAI to TVA No. 23 and also if the variable was unique to Unit 2. For each variable variables within the scope of the Foxboro Spec 200, Corrected response is included in EICB (Marcus) that was indicated as unique to Unit 2 and the Unit 2 variable Common Q PAMS and Foxboro I/A changes. letter dated 10/29/10 TVA to provide formal source is (1) Foxboro Spec 200, (2) Common Q PAMS, or (3) response to RAI Foxboro IA, identify the Unit 1 variable source. NOTE: An error was identified during preparation of this response. Variable 37 CCS Surge Tank Level was incorrectly identified as being within the scope of the Foxboro I/A system in TVA to NRC letter dated June 18, 2010. Variable 37 will be provided by the Foxboro Spec 200 system for Unit 2.

(

304 7.5.2. 7.5.1 09/17/2010 Responder: Tindell 286. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL M

a

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 1 ML102861885 Item 10/29/10 Enclosure 1 Item 6 of the letter dated June 18, 2010 indicated that The source for the Unit 1 variables is the Eagle 21 System. Response is included in letter dated NRC to issue formal No. 25 Enclosure 1 Item the Unit 2 variable source for 14 PAM variables is Eagle 21. 10/29/10 RAI to TVA No. 24 Please confirm that for each of these 14 variables the Unit 1 variable source is also the Eagle 21. Response is acceptable TVA to provide formal response to RAI 305 7.5.2. 7.5.1 09/17/2010 Responder: Tindell 287. Y Closed Closed EICB RAI TVA Letter dated EICB RAI ML102861885 sent to DORL 1 ML102861885 Item 10/29/10 EICB (Marcus)

Enclosure 1 Item 6 of the letter dated June 18, 2010 indicated that The source for the Unit 1 variables is the Integrated Response is included in letter dated NRC to issue formal No. 26 Enclosure 1 Item the Unit 2 variable source for 2 PAM variables is the Integrated Computer System. 10/29/10 RAI to TVA No. 25 Computer System. Please confirm that for these 2 variables the Unit 1 variable source was the Unit 1 plant computer system. Response is acceptable TVA to provide formal response to RAI 306 7.1 7.1 FSAR amendment 100, page 7.1-12 provides the definition of Responder: Hilmes 288. Y Closed Closed EICB RAI TVA Letter dated Allowable value which is not consistent with TSTF-493 as ML102910008 10/29/10 EICB (Garg) allowable value is the value beyond which instrument channel is The FSAR Allowable Value definition will be revised to be Response is included in letter dated Due 12/17/10 Item#69 Enclosure 1 Item declared inoperable. consistent with the TSTF-493 in FSAR Amendment 102. 10/29/10 No. 26 Attachment 3 contains the revised FSAR section 7.1.2.1.9 Pending FSAR that will be included in FSAR Amendment 102 that reflects Amendment 102 this change. submittal 307 7.1 7.1 (1) FSAR amendment 100, Section 7.1, page 7.1-12, definition of Responder: Hilmes 289. Y Closed Closed EICB RAI TVA Letter dated Acceptable as found tolerance is not in accordance with TSTF-493 ML102910008 10/29/10 as AAF is the limit beyond which the instrument channel is (1) The Acceptable As Found (AAF) definition will be Response is included in letter dated Due 12/17/10 Item#70 Enclosure 1 Item degraded but may be operable and its operability must be revised to be consistent with TSTF-493 in FSAR 10/29/10 No. 27 evaluated. (2) Also it states that AAF is based on measurable Amendment 102. Attachment 3 contains the revised Pending FSAR instrument channel uncertainties, such as drift, expected during the FSAR section 7.1.2.1.9 that will be included in FSAR Amendment 102 surveillance interval. These wording should be revised to agree Amendment 102 that reflects this change. submittal with the wording given in RIS2006-17 as these wordings are very vague. (3) Also it states that RPS functions use double sided (2) Additional detail on the AAF methodology was provided tolerance limits for the AAF. Since AAF is a band it will always be in sections 7.1.2.1.9.1, Westinghouse Setpoint double sided and therefore, this clarification does not mean Methodology, and 7.1.2.1.9.2, TVA Setpoint anything and it clouds the issue. Methodology. These sections will be revised to clarify EICB (Garg) the AAF calculations in FSAR Amendment 102.

Attachment 3 contains the revised FSAR section 7.1.2.1.9 that will be included in FSAR Amendment 102 that reflects this change.

(3) The statement about double sided limits addresses a TSTF requirement that the AAF tolerance consider errors in both the conservative and non-conservative directions and ensures that an as-found value which exceeds these limits, even in the conservative direction (away from the safety limit), will be evaluated.

Attachment 3 contains the revised FSAR section 7.1.2.1.9 that will be included in FSAR Amendment 102 that reflects this change.

308 7.1 7.1 (1) FSAR Amendment 100, Section 7.1, page 7.1-13, definition of Responder: Hilmes 290. Y Closed Closed EICB RAI TVA Letter dated Acceptable as left tolerance is not in accordance with TSTF-493 as ML102910008 10/29/10 it states that this may take calibration history into consideration. (1) The statement about using calibration history to Response is included in letter dated Item#71 Enclosure 1 Item EICB (Garg)

This is very vague and ambiguous. (2) Also it states that RPS determine the Acceptable As Left (AAL) will be deleted 10/29/10 Due 12/17/10 No. 28 functions use double sided tolerance limits. Since ALF is a band it in FSAR Amendment 102. Attachment 3 contains the Pending FSAR will always be double sided and therefore, this clarification does not revised FSAR section 7.1.2.1.9 that will be included in Amendment 102 mean anything and clouds the issue. FSAR Amendment 102 that reflects this change. submittal (2) See response to letter item 27 (NRC Matrix Item 307).

(

309 7.1 7.1.2.1.9 G (1) FSAR amendment 100, Page 7.1-14, Westinghouse setpoint Responder: Hilmes 291. Y Closed Closed EICB RAI TVA Letter dated

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

.1 methodology, states that AAF is the algebraic sum of the .. This ML102910008 10/29/10 is not acceptable. As algebraic sum is non conservative compared (1) The AAF calculation for Westinghouse setpoint Response is included in letter dated Due 12/17/10 Item#72 Enclosure 1 Item to the SRSS method and will mask the operability of the instrument methodology calculations in TI-28 for TSTF-493 will be 10/29/10 No. 29 channel and therefore, it is not acceptable to the staff. (2) It also revised to use the Square Root Sum of the Squares Pending FSAR make the statement that ALT may take calibration history into (SRSS) method. Amendment 102 consideration which is vague and ambiguous. submittal (2) AAF definition will be revised to be consistent with TSTF-493 as discussed with the NRC Staff, in FSAR Amendment 102. Attachment 3 contains the revised FSAR Amendment 102 Change Markup that reflects this change.

310 7.1 7.1.2.1.9 (1) FSAR amendment 100, Page 7.1-14, TVA setpoint Responder: Hilmes 292. Y Closed Closed EICB RAI TVA Letter dated

.2 methodology, states that for AAF .and other measurable ML102910008 10/29/10 uncertainties as appropriate (i.e., those present during TVA Response: Response is included in letter dated Due 12/17/10 Item#73 Enclosure 1 Item calibration.) should be changed to present during normal 10/29/10 No. 30 operation (2) Also on page 7.1-15, states that ALT may take (1) The AAF definition will be revised in FSAR Amendment Pending FSAR calibration history into consideration which is vague and 102 to read: Amendment 102 ambiguous. submittal A tolerance band on either side of the NTSP which defines the limits of acceptable instrument performance, beyond which the channel may be considered degraded and must be evaluated for operability prior to returning it to service. Channels which exceed the AAF will be entered into the Corrective Action Program for further evaluation and trending. The Acceptable As Found tolerance is the SRSS combination of drift, maintenance and test equipment (M&TE) accuracy and readability, and calibration/reference accuracy. Other uncertainties may be included in the AAF if applicable.

EICB (Garg)

This revision eliminates the concern regarding uncertainties. Attachment 3 contained in the October 29, 2010 letter provided the revised FSAR Section 7.1.2.1.9 that will be included in FSAR Amendment 102 that reflects this change.

(2) The AAL definition will be revised in FSAR Amendment 102 to read:

A tolerance band on either side of the NTSP within which an instrument or instrument loop is left after calibration or setpoint verification. The Acceptable As Left tolerance is equal to or less than the SRSS combination of reference accuracy, M&TE accuracy and M&TE readability. Other uncertainties may be included in the AAL if applicable.

This revision eliminates the concern regarding calibration history. Attachment 3 contained in the October 29, 2010 letter provided the revised FSAR Section 7.1.2.1.9 that will be included in FSAR Amendment 102 that reflects this change.

311 7.1 7.1 Both Westinghouse and TVA setpoint methodology do not have Responder: Hilmes 293. Y Closed Closed EICB RAI TVA Letter dated EICB (Garg) any discussion on single sided calculation. Please confirm that ML102910008 10/29/10 single sided calculation has not been used for all setpoints with A statement that single-sided corrections are not used for Response is included in letter dated Due 12/17/10 Item#74 Enclosure 1 Item TSTF-493 and provide a statement to that effect in the FSAR. TSTF-493 setpoints will be included in FSAR Amendment 10/29/10 No. 31 102. Attachment 3 contains the revised FSAR section Pending FSAR

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 7.1.2.1.9 that will be included in FSAR Amendment 102 that Amendment 102 reflects this change. submittal 312 7.0 By letter dated September 10,2010, TVA provided the summary Responder: Stockton 294. Y Close Closed EICB RAI TVA Letter dated evaluation of 50.59 reports which were related to FSAR Chapter ML102910008 10/21/10 EICB (Garg) 7.0. However, these evaluation only covers Amendments 0 thru 8. Amendment 8 is the current version of Unit 1 UFSAR. Response provided in letter dated Due 10/31/10 Item#75 Enclosure 1 Item Provide all other evaluation which have been done since these 10/21/10 No. 23 amendments and which forms the basis for FSAR Chapter 7.0 systems.

313 7.7.8 7.7.1.12 EDCR 52408 (installation of AMSAC in Unit 2) states that Design Responder: Ayala 295. Y Closed Closed EICB RAI No.18 TVA Letter dated Criteria WB-DC-40-57 needs to be modified to reflect AMSAC in ML102910017, 10/29/10 Unit 2. (1) The review of WB-DC-40-57 for Unit 2 applicability has Response is included in letter dated 10/19/10 Enclosure 1 Item been completed and included in Revision 4 of the 10/29/10 No. 32

1. Has WB-DC-40-57 been completed for Unit 2? If so, please document. Attachment 10 contains TVA design submit. criteria WB-DC-40-57, Revision 4, Anticipated Transients Without Scram Mitigation System Actuation

2. If WB-DC-40-57 has not been completed for Unit 2, please Circuitry (AMSAC).

EICB (Darbali) give an estimated date of completion and submittal.

(2) The revision for Unit 2 is complete with open items as

3. Please submit WB-DC-40-57 for Unit 1 and identify any identified in item (3) below.

changes to the Unit 2 version.

Attachment 10 contains TVA design criteria WB-DC-40-57, Revision 4, Anticipated Transients Without Scram Mitigation System Actuation Circuitry (AMSAC) which is applicable to both WBN Unit 1 and Unit 2. There are 17 open Watts Bar Nuclear Plant Unit 2 Startup Integration Task Equipment List (WITEL) punch list items associated with Revision 4 that require resolution. A list of the punch list items is contained in Attachment 10.

314 7.3 7.3 The following 50.59 changes were listed in the March 12 RAI Responder: Stockton 296. Y Closed Closed EICB RAI No. 19 TVA Letter dated Related to OI 10 response letter (item 10) but were not included in the September 9 ML102910017, 10/21/10 submittal of 50.59 safety evaluations. Please submit the 50.59 Attachment 8 contains the requested safety evaluations. Response provided in TVA letter 10/19/10 Enclosure 1 Item safety evaluations for the following changes: dated 10/21/10. No. 24 EICB (Darbali)

DCN 38842 (Revise OTT and OPT turbine runback setpoints)

DCN 50991 (Install Test Points)

DCN 51124 (Eliminate spurious ICS alarms associated with the SSPS 315 7.5.3 7.5.3 IE Bulletin 79-27 required that emergency operating procedures to Responder: S. Smith (TVA Operations) 297. Y Close Closed EICB RAI TVA Letter dated be used by control room operators to attain safe shutdown upon ML102910008 10/21/10 loss of any Class IE or non Class IE bus are adequate. WBN1 has While the WBN Unit 2 Emergency Operating Procedures Response provided in letter dated Due 10/31/10 Item#76 Enclosure 1 Item EICB (Garg) performed the review and documented their conclusion. Confirm (EOPs) have not been written, they will be written the same 10/21/10 No. 25 that WBN2 emergency procedures are adequate to achieve safe as the Unit 1 EOPs. WBN Unit 1 personnel will perform shutdown in the event of loss of any Class IE or non-Class IE bus. validations to ensure that WBN Unit 2 EOPs will perform the required actions. The WBN Unit 2 EOPs will be written and validated prior to Unit 2 fuel load.

316 7.5.2. 7.5 TVA has provided various documents in support of RM-1000 high Responder: Temples/Mather 298. Y Closed Closed RAI No. 26 3 range monitors for WBN2. ML102980005 EICB (Singh)

Please clarify the following: The Sequoyah RM-1000 v1.1 Software Verification Report Response provided in letter dated Response acceptable 10/26/2010 RM-1000 v1.1 Software Verification Report 04508006 (Sequoyah) 04508006 and RM-1000 v1.2 Software Verification Report 10/21/10 per TVA letter of RM-1000 v1.2 Software Verification Report 04508006 (Sequoyah) 04508006 are applicable to WBN Unit 2. 10/21/10, Enclosure 1, RM-1000 System Verification Test Results (Sequoyah) Item 26.

The RM-1000 System Verification Test Results report is not These documents were prepared for the Sequoyah plant. IS the applicable to WBN Unit 2. This document was for the non-

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N version provided applicable to WBN2? Please confirm and explain safety related software and was superseded by the if these documents are applicable to WBN 2 as provided or with 04508006 v1.1 and v1.2 reports for the safety-related differences? software.

317 7.5.2. 7.5 TVA has provided a proprietary and a non-proprietary version of Responder: Temples 299. Y Closed Closed RAI No. 27 TVA Letter dated 3 Technical Manual for RM-1000 Digital Radiation Processor under ML102980005 10/29/10 ML101680582 and ML101680587). i. These documents are applicable to WBN Unit 2. Response is included in letter dated Proposed response is 10/26/2010 Enclosure 1 Item ii. This was an error in document preparation that 10/29/10 acceptable. No. 33 (i) Are these documents applicable to WBN2 as provided occurred when attachments were assembled for a EICB (Singh)

(October 2003 version). previous letter. Due 10/31/10 (ii) Why is DCN38993-A attached at the back of the iii. The Technical Manual is not intended to include proprietary version? It is for WBN1 Turbine Governor equipment requirements. Requirements would be Control Valve. found in the applicable TVA Specifications for the (iii) This document does not state the requirements for RM- contract. (iii) Staff is looking for high level 1000 units. Please provide a document that states the requirements for RM-1000 requirements for the RM-1000 radiation monitors for Attachment 11 contains the Material Requisition monitors. Pl. provide appropriate WBN2. Specification Revisions 1 and 4 which contain the requested documents.

information.

318 7.5.2. 7.5 TVA has provided the following documents for RM-1000 Responder: Temples 300. Y Closed Closed RAI No. 28 TVA Letter dated 3 equipment qualification: ML102980005 10/29/10, Encl 1 Response provided in letter dated Response acceptable 10/26/2010 Item 34, and TVA (i) Qualification Test Report for RM-1000 Processor Module 10/21/10 per TVA letter of letter 11/24/10, and Current-To-Frequency Converter 04508905-QR (i) Applicable to WBN Unit 2. 04508905-1QR is 10/21/10, Enclosure 1, Att. 2.

(January 2001) applicable only in regards to the RM-1000, with the Revised response is included in Item 26.

(ii) Qualification Test Report Supplement, RM-1000 Upgrades exception of re-qualification of certain RM-1000 letter dated 12/22/10.

04508905-1SP (June 2006) equipment differences covered in the -1SP report. Due 2/25/11 (iii) Qualification Test Report Supplement, RM-1000 Upgrades The Current-to-Frequency (I-F) converter module Note check 04508905-1QR or QR.

04508905-2SP (June 2008) qualifications in the base report and the -1SP report Staff version is QR only. Response update (iv) Qualification Test Report Supplement, RM-1000 Upgrades are not applicable to the RM-1000s, and will be used required. It is clear that 04508905-3SP (May 2008) later as references in the WBN Unit 2 specific Response is included in letter dated 04508903-2SP and -

qualification reports. 10/29/10 3SP are not applicable.

Please clarify whether all of these are fully applicable to WBN2 or The response for are they applicable with exceptions? If with exceptions, then (ii) Applicable to WBN Unit 2. applicability of please clarify what those are. 04508905-QR and -

(iii) Not applicable to WBN Unit 2 1SP to RM-1000 and IF Supplement 3 was issued one month prior to supplement 2. (iv) Not applicable to WBN Unit 2 converter is not clear.

Please explain the reason for the same.

EICB (Singh)

The 04508905-3SP report was prepared for another TVA Check page numbers of plant, as a monitor system-level report, where the system Appendix F included equipment mostly based on the base report (missing/duplicate equipment items. These two -2SP and -3SP supplement pages).

reports were essentially worked concurrently, but the -2SP Check applicability of document review/release process resulted in the release Appendix C to RM1000 time difference. instead of RM2300?

See items 336 and 337.

TVA Response to Follow-up NRC Request:

All equipment NOTE: The response for the current to frequency (I to F) qualification reports converter in item 1 below is a reversal of the including supplements response previously provided in TVA to NRC letter 2SP and 3SP have dated October 29, 2010 (Reference 22). General been reviewed as Atomics Electronic Systems Inc. (GA-ESI) notified vendor drawings for TVA of this change on December 8, 2010 WBN-2. Please explain (Reference 20). the reason for applicability of one (1) The applicability of the qualification reports from GA- report and not the ESI e-mail dated December 10, 2010 (Reference 19) is other.

as follows:

Further all TVA/Bechtel

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

a. 04508905-QR Qualification Test Report for RM- reviews seems to be 1000 Processor Module and Current-to- dispositioned as Code Frequency Converter is applicable to the WBN 4, Review not required.

Unit 2 RM-1000 and I to F converter modules. Work may proceed.

The applicable reports

b. 04508905-1SP Supplement to Qualification Test should have been Report for RM-1000 Processor Module and reviewed prior to Current-to-Frequency Converter is applicable to dispositioning them.

the WBN Unit 2 RM-1000 module. Please explain the apparent lack of review

c. 04508905-1SP is not applicable to the WBN Unit of WBN-2 applicable 2 I to F converter module. documents. Was appropriate review

d. 04508905-2SP Qualification Test Report guidance used?

Supplement, I-F Converter Upgrades is applicable to the WBN Unit 2 I to F converter Further update required module.

Provide model GA-ESI provided two other reports required to support number/part number for qualification of the containment high range radiation the RM-1000 and I/F monitors. The report descriptions are from GA-ESI e-converter used for mail on December 8, 2010 (Reference 20). The WBN-2. This reports are:

information is needed

e. GA-ESI report 04038903-QSR, Qualification to verify that the model Summary Report for Watts Bar Nuclear Plant Unit or part number used is 2 Replacement Radiation Monitors: The report is the equipment that has the principle report and the starting point for all been qualified for WBN-the radiation monitors provided as part of the 2.

replacement contract. The report describes each monitor; referenced to the technical manual for Provide qualification the physical and functional description and lists reports 04038903-QSR the major components of the monitor system. and 04038903-7SP by Report section 3 identifies the TVA Watts Bar Unit the dues date of 2 Environmental, Seismic, Electromagnetic 1/22/11.

Compatibility (EMC), and software requirements for each monitor. In section 4 a brief description Submit a copy of any of GA-ESI generic qualification programs for all other relevant reviewed radiation monitoring equipment in each of the four versions of the above areas is provided. The qualification basis qualification reports.

for each monitor is provided in a separate supplement to the principle report and is identified Submit copies of the in section 5. reviewed reports for 04508905-QR,

f. GA-ESI report 04038903-7SP, Qualification 04508905-1SP, Basis for 04034101-001 (2-RE-90-271, -272, - 04508905-2SP.

273, & -274) [TVA Note: These are the containment post accident high range radiation Clarification of monitors.]: GA-ESI report 04038903-7SP is applicability of existing divided into subsections to address the reports is acceptable.

Environmental, Seismic, EMC, and Software qualification basis for the High Range Area Monitors. Within each subsection, the HRAM is compared to a tested or analyzed article to demonstrate similarity and/or evaluate differences, the tests that were performed, and evaluation to demonstrate qualification. In most cases, the qualification basis references other documents. In addition to qualification, a section

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N is provided that lists the life of those replaceable components that have life expectancy less than 40 years.

(2) This is addressed by response to RAI Question 336 in TVA to NRC letter dated November 24, 2010 (Reference 8)

(3) This is addressed by response to RAI Question 337 in TVA to NRC letter dated November 24, 2010 (Reference 8)

(4) The 04508905-3SP Qualification Test Report Supplement, RM-1000 Upgrades is not applicable to WBN Unit 2 (Reference 19).

Please see Item 1, above, for applicability of the other reports.

(5) TVA provided the proprietary versions of the reports by letter dated March 12, 2010 (Reference 10). By letter dated July 15, 2010 (Reference 23), TVA provided the non-proprietary version of the reports and included a copy of the proprietary report which had been erroneously marked as having not been reviewed.

04508905-QR report has been reviewed by TVA. The review of the remaining reports is ongoing.

(6) See item 5.

TVA Response to Follow-up NRC Request:

The following documents are the qualification documents associated with the RM-1000 radiation monitors:

Attachment 5 contains the approved proprietary version of General Atomics Electronic Systems 04508905-1SP, Qualification Test Report Supplement, RM-1000 Upgrade.

Attachment 6 contains the approved proprietary version of General Atomics Electronic Systems 04508905-2SP, Qualification Test Report Supplement, I-F Converter Upgrades.

Attachment 7 contains the approved proprietary version of General Atomics Electronic Systems 04038903-7SP, Qualification Basis for 04034101 (2-RE-90-271, 272, 273 & 274).

Attachment 8 contains the proprietary version of General Atomics Electronic Systems 04038903-QSR, Qualification Summary Report for Watts Bar Nuclear Plant Unit 2 Replacement Radiation Monitors. In order to meet the NRC submittal schedule, the engineering review of this document was limited to the RM-1000. The document has been accepted for the RM-1000 monitors. Engineering approval will not occur until full review for all covered monitors is complete.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Attachment 23 contains the approved proprietary version of General Atomics Electronic Systems 04508905-QR, Qualification Test Report for RM-1000 Processor Module and Current-To-Frequency Converter.

319 7.5.2. 7.5 TVA provided System Verification Test Results 04507007-1TR Responder: Temples 301. Y Closed Closed RAI No. 29 TVA Letter dated 3 (July 1999) for Sequoyah to support test verification. However, the -Response Acceptable ML102980005 10/29/10 document states (page v) that it is not applicable for high range See TVA letter to the NRC dated October 21, 2010, item 26 Response is included in letter dated 10/26/2010 Enclosure 1 Item monitors with an action noted for fixing a problem with the high (RAI Matrix Item 316) for non-applicability of 04507007-1TR. 10/29/10 No. 35 EICB (Singh) range RM-1000 monitors on page vi. TVA to respond to the The recorded anomaly was later resolved through the Due 10/31/10 following clarifications: verification of software version 1.2, reported in RM-1000 v1.2 Software Verification Report 04508006. Response acceptable.

Has the anomaly noted on page vi been resolved for the high TVA to issue letter and range monitors? The high range verification documents are the Sequoyah confirm stated (future)

RM-1000 v1.1 Software Verification Report 04508006 and dates Provide the high range verification document for WBN2. RM-1000 v1.2 Software Verification Report 04508006.

320 Per Westinghouse letter WBT-D-2340, TENNESSEE VALLEY Responder: Clark 302. Y Closed Closed N/A N/A Duplicate of item 156 AUTHORITY WATTS BAR NUCLEAR PLANT UNIT 2 FSAR Markups Units 1 and 2 118% vs 121 % and Correction to RAI This item is not required It was entered as a tracking Response SNPB 4.3.2-7, (Reference 17) the 118% value should commitment from the 10/5 letter to issue FSAR Amendment EICB (Garg) be 121%. Depending on the use in the FSAR either 118% or 121% 101 which includes the described change. Amendment 101 is the correct value. As a result of the question, Westinghouse will be issued no later than 10/29.

reviewed all locations where either 118% or 121% are used and the context of use and provided a FSAR markup to reflect the correct value at the specific location. These changes will be incorporated in FSAR Amendment 101 321 For the purposes of measuring reactor coolant flow for Reactor Responder: Clark 303. Y Closed Closed N/A N/A Duplicate of OI# 157 Protection functions, elbow taps are used for both Unit 1 and 2.

The discussion and equation are valid for establishing the nominal This item is not required It was entered as a tracking full power flow which is used to establish the Reactor Protection commitment from the 10/5 letter to issue FSAR Amendment System low flow trip setpoint. However the method used to verify 101 which includes the described change. Amendment 101 reactor coolant flow, as required by the Technical Specifications, is will be issued no later than 10/29.

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 FSAR Reference 17, WCAP-16067, Rev 0, RCS Flow Measurement EICB (Garg)

Using Elbow Tap Methodology at Watts Bar Unit 1. The plan is for Unit 2 to transition to this method after sufficient data is obtained.

Pending this transition, 7.2.2.1.2 will be revised to read as follows:

Nominal full power flow is established at the beginning of each fuel cycle by either elbow tap methodology or, performance of the RCS calorimetric flow measurement. Unit 1 utilizes elbow tap methodology Reference [17]. Unit 2 utilizes the RCS calorimetric flow measurement. The results are used to normalize the RCS flow indicators and provide a reference point for the low flow reactor trip setpoint.

This change will be incorporated in FSAR Amendment 101 322 7.7.1.11 Section 7.7.1.11 will be added to FSAR Amendment 101 to provide Responder: Clark 304. Y Closed Closed EICB (Carte) a discussion of the Distributed Control System This item is not required It was entered as a tracking commitment from the 10/5 letter to issue FSAR Amendment 101 which includes the described change. Amendment 101 will be issued no later than 10/29.

323 CB (G WCAP-13869 revision 1 was previously reviewed under WBN Unit Responder: Hilmes/Unit 1 1. Y Open Open-TVA/Bechtel TVA Letter dated ar 1 SER SSER 13 (Reference 8). Unit 2 references revision 2. An 10/29/10

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N analysis of the differences and their acceptability will be submitted Attachment 12 contains the WCAP 13869 Revision 1 to Due 3/29/11 Due: Enclosure 1 Item to the NRC by November 15, 2010 Revision 2 Change Analysis. No. 36 Revised Response is included in Need to provide TVA Response to Follow-up NRC Request letter dated 10/29/10 additional info on why A FSAR change will be submitted in a future FSAR Rev. 1 is acceptable for amendment to change the revision level back to 1. The staff is confused with the both units.

response since both units have TVA Response to Second Follow-up NRC Request reference leg not insulated Rev 2 3/10/11 should apply to Unit 1 also and Staff does not agree The differences between the Revision 1 and Revision 2 there should be no difference with the statement that WCAPs is documented in Attachment 12, WCAP 13869 between Unit 1 and 2 there is no technical Revision 1 to Revision 2 Change Analysis, to TVA to NRC differences between letter dated October 29, 2010 (Reference 2). The design WCAP-13869 rev.1 and bases for the response to feedwater break inside rev2., but staff agree containment, as documented in Chapter 15 of the WBN Unit that rev1 and change 2 FSAR, is the same for WBN Unit 1. Since WBN Unit 2 is analysis could be basis required to match the WBN Unit 1 licensing basis to the for acceptance for both extent practical, the decision was made to revise the WBN Watts Bar units.

Unit 2 FSAR to agree with the WBN Unit 1 FSAR which uses Revision 1. 4/6/11 TVA response is acceptable, however this item remains open until TVA makes changes to FSAR.

324 EICB Per the NRC reviewer, the BISI calculation is not required to be 305. Y Closed Closed (Marc submitted.

us) 325 The Unit 2 loops in service for Unit 1 that are scheduled to be Responder: TVA Startup Olson 306. Y Closed Closed Closed to open item ?

transferred to the Foxboro Spec 200 hardware will be transferred prior to Unit 2 fuel load EICB(Garg) 326 TVA uses double-sided methodology for as-found and as-left Responder: Webb 307. Y Closed Closed TVA Letter dated Reactor Trip and ESFAS instrument setpoint values. The FSAR 10/29/10 EICB(Garg) will be revised in a future amendment to reflect this methodology Attachment 3 contains the revised FSAR section 7.1.2.1.9 Response is included in letter dated Due 12/17/10 Enclosure 1 Item that will be included in FSAR Amendment 102 that reflects 10/29/10 No. 37 this change. Pending FSAR Amendment 102 submittal 327 Attachment 36 contains Foxboro proprietary drawings 08F802403- Responder: Webber 26. Y Open Open-NRC Review SC-2001 sheets 1 through 6. An affidavit for withholding and non-DORL (Poole) proprietary versions of the drawings will be submitted by January In accordance with correspondence from Foxboro, there is Response Included in letter dated Due 11/24/10 31, 2011. no proprietary information contained in the 08F802403-SC- 11/24/10 2001 drawings. Based on this, no affidavit for withholding is required. Attachment 1 contains versions of the drawings with the proprietary information block removed.

328 7.5.2. 7.5 Provide the model number for the four containment high range Responder: Temples 308. Y Closed Closed RAI No. 30 TVA Letter dated 3 EICB area monitors, RM-1000 and identify how the software V&V and -Response Acceptable ML102980005 10/29/10 (Singh) qualification documents apply to them. If there is no specific model The Containment High Range Radiation Monitors are model Response is included in letter dated 10/26/2010 Enclosure 1 Item number then how is it ensured that the correct radiation monitor is RM-1000. The monitors are uniquely identified by serial 10/29/10 No. 38

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N received at the site and subsequently installed? numbers which are assigned when the equipment is assembled. The applicability of V&V reports and quality documentation for the RM-1000 model is in accordance with manufacturers approved 10 CFR 50 Appendix B Quality Program and the requirements of the purchase order.

329 7.6.1 7.6.7 Section 7.6.7 of the FSAR (Amendment 100) states that, The Responder: Clark 309. Y Closed Closed RAI No. 1 TVA Letter dated EICB (Singh)

DMIMS-DX' audio and visual alarm capability will remain ML102980005 10/29/10 functional after an Operating Basis Earthquake (OBE). All of the The title of FSAR Section 3.10 is Seismic Design of Response is included in letter dated 10/26/2010 Enclosure 1 Item DMIMS-DX' components are qualified for structural integrity Category I Instrumentation and Electrical Equipment. Since 10/29/10 Due 12/17/10 No. 39 and FSAR during a Safe Shutdown Earthquake (SSE) and will not the Loose Part Monitoring System is not a Category 1 Amendment 102.

mechanically impact any safety-related equipment. system, it is not included in the scope of 3.10. FSAR Section Pending FSAR 7.6.7, Loose Parts Monitoring System (LPMS) System Amendment 102 TVA to clarify the seismic qualification of the loose parts monitoring Description, identifies basic system seismic design criteria submittal.

system and include the appropriate information in Table 3.10 (or which are consistent with the requirements of TVA Design another suitable section) of the FSAR. Criteria, WB-DC-30-31, Loose Parts Monitoring System. As TVA to confirm that the identified in FSAR Table 7.1-1, Watts Bar Nuclear Plant NRC equipment has been Regulatory Guide Conformance, the system conforms to seismically qualified as Reg. Guide 1.133 as modified by Note 12. Reg. Guide 1.133 required and that TVA identifies the seismic requirements and Note 12 does not reviewed and found the contain any exception to the Regulatory Guide seismic report acceptable.

requirements.

TVA response does not The Westinghouse LPMS seismic report, EQ-QR-33-WBT, list the seismic test Revision 0, Seismic Evaluation of the Digital Metal Impact document and its Monitoring System (DMIMS-DXTM) for Watts Bar Unit 2, will acceptance by TVA.

be added as Reference 7 to FSAR section 7.6 in amendment FSAR should reference 102. the test document as the source document for tracking conformance.

330 7.3 7.3 Related to Item 298 Responder: Hilmes/Faulkner 310. Y Closed Closed EICB RAI No.20 Item 7, TVA letter ML102910017, dated November IE Bulletin 80-06 calls for review of engineered safety features with The original response to IE Bulletin 80-06 for both WBN Unit 10/19/10 24, 2010 the objective of ensuring that no device will change position solely 1 and 2 was provided on TVA letter to NRC dated March 11, because of the reset action. 1982 (ML073530129) (Reference 4). Subsequent design changes have impacted the original response such that In Supplement 3 of NUREG-0847, section 7.3.5, the staff approved some equipment that originally changed state no longer does the design modifications proposed by the applicant that would so and some equipment has been deleted. There are no allow certain devices to remain unchanged upon an ESF reset. additions to the list originally provided in TVA letter to NRC The staff also found acceptable the applicants justification for dated March 11, 1982 (ML073530129) (Reference 4). The some safety-related equipment that does not remain in its following is the current list of equipment that does not remain emergency mode after an ESF reset. in its emergency mode after an ESF reset:

EICB (Darbali)

Please list for Unit 1 and Unit 2 the safety-related equipment 1. Unit 1 and 2 Equipment (prefix 1- (Unit 1) or 2- (Unit 2) that does not remain in its emergency mode after an ESF reset. a. Auxiliary Feedwater Pump Turbine Speed Control Valve, FCV-1-52

b. Auxiliary Feedwater (AFW) Level Control Valves as listed below:

i.LCV-3-172 - SG3 - Level Control Valve ii.LCV-3-173 - SG2 - Level Control Valve iii.LCV-3-174 - SG1 - Level Control Valve iv. LCV-3-175 - SG4 - Level Control Valve

v. LIC-3-172 - SG3 - Level Indicating Controller vi. LIC-3-173 - SG2 - Level Indicating

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Controller vii. LIC-3-174 - SG1 - Level Indicating Controller viii. LIC-3-175 - SG4 - Level Indicating Controller ix. LCV-3-148 - SG3 - Level Valve

x. LCV-3-156 - SG2 - Level Valve xi. LCV-3-164 - SG1 - Level Valve xii. LCV-3-171 - SG4 - Level Valve xiii. LCV-3-148A - SG3 - Level Bypass Control Valve xiv. LCV-3-156A - SG2 - Level Bypass Control Valve xv. LCV-3-164A - SG1 - Level Bypass Control Valve xvi. LCV-3-171A - SG4 - Level Bypass Control Valve xvii. LIC-3-148 - SG3 - Controller xviii. LIC-3-156 - SG2 - Controller xix. LIC-3-164 - SG1 - Controller xx. LIC-3-171 - SG4 - Controller

c. Lower and Upper Compartment Cooler Fans and Control Rod Drive Mechanism Cooler Fan

d. Penetration Room Cooler Fans Elevations 737, 692 and 713

e. Pipe Chase Cooler Fans

2. Common Equipment

a. Shutdown Board Room A Pressurizing Fans

b. Control Building Ventilation Dampers as listed below:

i. 0-FCO-31-9 - Spreading Room Supply Fan Damper ii. 0-FCO-31 Spreading Room Supply Fan Damper iii. 0-FCO-31 Toilet a Locker Room Exhaust Fan Exhaust Damper iv. 0-FCO-31 Toilet a Locker Room Exhaust Fan Exhaust Damper

v. 0-FCO-31-3 - Main Control Room Isolation Damper vi. 0-FCO-31-4 - Main Control Room Isolation Damper vii. 0-FCO-31 Spreading Room Fresh Air Supply Damper viii. 0-FCO-31 Spreading Room Fresh Air Supply Damper

c. Cask Loading Exhaust Dampers as listed

i. 0-FCO-30-122 - Cask Loading Area Exhaust Damper ii. 0-FCO-30-123 -Cask Loading Area Exhaust

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Damper

d. Auxiliary Building General Supply Exhaust Fans Elevation 737

e. CCW and AFT Pump Space Cooler Fans

f. Spent Fuel Pit Pumps Space Coolers

g. EGTS Room Coolers

h. Turbine Driven AFW and Boric Acid Space Coolers 331 7.6.1 7.6.7 As a follow up of OI 190, Staff has reviewed the proprietary version Responder: WEC/Harless/Clark 311. Y Closed Closed RAI No. 8 TVA Letter dated Follow-up of OI-190.

of the DMIMS-DX system description to verify the conformance ML102980005 10/29/10 claims in the FSAR. Staff has noted the following insufficiencies TVA Partial Response: Response included in letter dated TVA letter 12/22/10, 10/26/2010 Enclosure 1 Item and discrepancies between the FSAR and the proprietary version 12/22/10 Encl 1, Item 27. No. 40 of the system description for loose parts monitoring system 1) The source of the information is the DMIMS-DXTM provided by TVA. Operations and Maintenance Manual, TS3176, Revision Due 12/22/10 0, dated August 2010. Attachment 14 contains the

1) FSAR, Amendment 100, page 7.6-5 states, During baseline revised system description, Westinghouse DIMMS- Pending FSAR testing, the reactor vessel and steam generator are impacted DXTM Loose Part Detection System Description, Amendment 102 three feet from each sensor with a force of 0.5 ft-lb. Loose Revision 1. The Westinghouse DIMMS-DXTM Loose submittal parts detection is accomplished at a frequency of 1 kHz to 20 Part Detection System Description, Revision 1 will be kHz, where background signals from the RCS are acceptable. added as Reference 9 to section 7.6 in FSAR TVA to reference the Spurious alarming from control rod stepping is prevented by a Amendment 102. DMIMS-DXTM module that detects CRDM motion commands and Operations Manual in automatically inhibits alarms during control rod stepping. 2) The source of the information is the DMIMS-DXTM the FSAR as the source seismic qualification report, Westinghouse report EQ- document The online sensitivity of the DMIMS-DX' is such that the QR-33-WBT, Revision 0, Seismic Evaluation of the system will detect a loose part that weighs from 0.25 to 30 Ib Digital Metal Impact Monitoring System (DMIMS-DXTM) TVA to reference the and impacts with a kinetic energy of 0.5 ft-lb on the inside for Watts Bar Unit 2. Attachment 14 contains the source document for surface of the RCS pressure boundary within 3 ft of a sensor. revised system description, Westinghouse DIMMS- item# 4 per the DXTM Loose Part Detection System Description, response.

The source of this information is not cited nor is it described in Revision 1.

the system description. TVA to provide the source of the information and update the system description as needed. 3) The entries for the following items in FSAR Section 7.6.7 will be modified in Amendment 102 as shown in

2) Regulatory Guide (RG) 1.133, rev.1, regulatory position C.1.g Attachment 3 for draft revision to WBN Unit 2 FSAR states that, Operability for Seismic and Environmental Section 7.6.7, Loose Part Monitoring System (LPMS)

Conditions. Components of the loose-part detection system System Description.

within containment should be designed and installed to perform their function following all seismic events that do not Sensors (In Containment) require plant shutdown, i.e., up to and including the Operating Softline Cable (In Containment)

Basis Earthquake (OBE). Recording equipment need not Preamplifier (In Containment) function without maintenance following the specified seismic event provided the audio or visual alarm capability remains Attachment 3 contains the FSAR Amendment 102 functional. The system should also be shown to be adequate Change Markups that reflect these changes.

by analysis, test, or combined analysis and test for the normal operating radiation, vibration, temperature, and humidity 4) The source of the information is Westinghouse Letter environment. WBT-D-2580, Tennessee Valley Authority Watts Bar Nuclear Plant Unit 2 Response to NRC RAIs on LPMS FSAR, Amendment 100, page 7.6-5 states, The DMIMS- (Reference 5). Attachment 14 contains Westinghouse DX' audio and visual alarm capability will remain functional DIMMS-DXTM Loose Part Detection System EICB (Singh) after an Operating Basis Earthquake (OBE). All of the Description, Revision 1.

DMIMS-DX' components are qualified for structural integrity during a Safe Shutdown Earthquake (SSE) and will not In responding to Item 4, conflicting information was mechanically impact any safety-related equipment. found between the Westinghouse-prepared FSAR

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Paragraphs 4.c and 4.d of the system description are not section and various Westinghouse technical consistent with the seismic qualifications described in the documents. To fully respond to this item, a change to FSAR. TVA to provide the source of the information the FSAR is required to change the minimum flat sensor contained in the FSAR and update the system description as frequency response from 5 Hz to 10 Hz. Attachment 3 needed. contains the FSAR Amendment 102 Change Markups that reflect the revised frequency response of the

3) The system description clearly describes the In-containment sensor.

equipment and DIMMS-DX Cabinet equipment. The FSAR should be updated to reflect the equipment locations for Westinghouse document 1TS3182, Revision 0, Watts clarification purposes. Bar Unit 2 DMIMS-DXTM System Validation Data Package, dated July 2010 has been added as reference

4) The information regarding frequency ranges of the sensors is 8 to FSAR Section 7.6 in amendment 102. Per included on page 7.6-6 of Amendment 100 of the FSAR but Westinghouse letter WBT-D-2580, this document will be the system description does not contain this information. revised to reflect the 10Hz minimum frequency and Please provide the source of this information and update the provide the basis for the frequency response values in system description to reflect the appropriate information. the FSAR.

5) Please provide information as to how the in-containment 5) In-containment component qualification for vibration as components are qualified for vibration as addressed in addressed in regulatory position C.1.g of RG 1.133, will regulatory position C.1.g of RG 1.133. be addressed in a future RAI response letter.

TVA Partial Response:

Items 1) through 4) were addressed in the partial response provided in TVA to NRC letter dated October 29, 2010. Item 5 is addressed as follows:

TVA has reviewed the information provided by Westinghouse describing how the Loose Part Monitoring System (LPMS) sensor is qualified for normal operating conditions provided in Westinghouse letter WBT-D-2782, dated December 17, 2010 (Reference 11) as addressed in regulatory position C.1.g of Reg. Guide 1.133 and found it acceptable. Vibration qualification is not applicable to the softline cable. Due to the installation location (junction boxes mounted to the shield or fan room walls) and previous seismic qualification, vibration qualification of the charge converter/preamplifier is not required. This completes the response to this item.

332 7.5.2. 7.5.1 10/26/2010 312. Y Closed Closed ML103000105 Item TBD EICB RAI ML103000105 sent to DORL EICB (Marcus) 1 No. 1 Related to 302 TVA included DCN 52389 in the 10/29/10 letter. Response is acceptable NRC to issue formal RAI to TVA In response to Open Item 302 TVA provided a diskette that This item was corrected prior to transmittal of the response Response is included in TVA letter included a draft of Attachment 8 to the proposed 10/29/2010 letter. to OI 302 in the 10/29/10 TVA letter. dated 10/29/10 TVA to provide formal Attachment 8 included 14 of the 15, 50.59 documents listed in the, response to RAI RG 1.97 50.59 Listing. DCN 52389 was not included on the diskette. Identify the document and date that officially transmitted or will transmit, DCN 52389 to the NRC. If DCN 52389 has not been previously transmitted to NRC please transmit the document to the NRC.

333 7.5.2. 7.5.1 10/27/2010 313. Y Closed Closed ML103000105 Item TBD EICB RAI ML103000105 sent to DORL EICB (Marcus) 1 No. 2 Related to 44 and 303 TVA included the correct information in the 10/29/10 letter. Response is acceptable NRC to use formal RAI to TVA In response to Open Item 303, TVA provided a diskette that This item was corrected prior to transmittal of the response Response is included in TVA letter included a draft of Attachment 9 to the proposed October 29, 2010 to OI 303 in the 10/29/10 TVA letter. dated 10/29/10 TVA to provide formal letter. In Attachment 9, the Unit 2 variable source for RG 1.97 response to RAI

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N variable 37, CCS Sample Tank Level, was listed as Foxboro Spec 200. However, in response to Open Item 44, in Enclosure 1 to TVA letter dated June 18, 2010 (ML101940236), the Unit 2 variable source for RG 1.97 variable 37 was listed as Foxboro I/A.

Determine which is correct and formally issue a correction.

334 7 7 FSAR Figure 7A-3 Mechanical Flow and Control Diagram Responder: Stockton 314. Y Closed Closed RAI not required. N/A RAI not required because the figure is Symbols doesnt show the symbols for the first column of valves. not part of any SE section.

EICB (Darbali)

Please correct this in a future FSAR amendment. Figure was corrected in FSAR Amendment 103.

Update:

Please fix symbols for Gate Valve, Globe Valve and Float operated valve.

335 7.6.1 7.6.7 LPMS: Reference to OI-331, sub item 2. Responder: WEC 315. Y Closed Closed RAI# 1, EICB letter TVA letter, dated We need to confirm when MEEB when 11/22/2010 3/31/2011, Item they will complete their review of the Provide analysis, test, or combined analysis and test for normal TVA has reviewed the information provided by Partial Response included in letter Submit qual report by 15. seismic qualification report.

operating radiation, temperature, and humidity environment per Westinghouse describing how the Loose Part Monitoring dated 12/22/10 3/11/11 as stated in The report regulatory position C.1.g of RG 1.133. As an alternate TVA may System (LPMS) sensor is qualified for normal operating TVA letter of 12/22/10, addresses this open confirm that the required equipment has been qualified for the conditions provided in Westinghouse letter WBT-D-2782, As of 3/24/2011: Encl 1, Item 28. item, however, the environments stated in RG 1.133, position C.1.g and that TVA has dated December 17, 2010 (Reference 11) as addressed in The staff reviewed the proprietary maximum Rx reviewed the test report and found it acceptable. regulatory position C.1.g of Reg. Guide 1.133 and found it version of EQ-EV-71-WBT-P, Due 12/22/10 Containment acceptable. The qualification information on the softline Revision 1, Environmental Temperature is not cable and charge converter/preamplifier is being assembled Evaluation and Operating History of addressed within and will be submitted by March 11, 2011. the Westinghouse DMIMS-DX the report and the Preamplifier and Softline Cable staff needs this Used at Watts Bar 2 dated information to Partial Response included in TVA to NRC letter dated February 2011 (Proprietary). approved the December 22, 2010 (Reference 1). maximum temperature Attachment 18 contains the proprietary version of EQ-EV qualification of 70o WBT-P, Revision 1, Environmental Evaluation and C for the EICB (Singh)

Operating History of the Westinghouse DMIMS-DX preamplifier cable Preamplifier and Softline Cable Used at Watts Bar 2 dated (Microdot February 2011 (Proprietary). Attachment 19 contains the Connector) end.

non-proprietary version EQ-EV-71-WBT-NP, Revision 1, TVA stated that Environmental Evaluation and Operating History of the they will provide the Westinghouse DMIMS-DX Preamplifier and Softline Cable Containment Used at Watts Bar 2, dated February 2011. Attachment 20 maximum temp.

contains the Application for Withholding Proprietary and reference the Information from Public Disclosure, EQ-EV-71-WBT-P, environmental Revision 1, Environmental Evaluation and Operating History report which this of the Westinghouse DMIMS-DX Preamplifier and Softline data is taken from Cable Used at Watts Bar 2, (Proprietary) dated February 18, in their next letter, 2011. which is expected on Tuesday TVA Response to Follow-up NRC Request: 3/29/2011.

The maximum WBN Unit 2 containment upper compartment normal operating temperature of 110 °F (43.3 °C) is shown on TVA environmental drawing 2-47E235-41 Revision 0.

The maximum WBN Unit 2 containment lower compartment normal operating temperature of 150 °F ( 65.6 °C) is shown on TVA environmental drawing 2-47E235-42 Revision 0.

336 7.5.2. 7.5 Re: RM-1000 Report 04508905-QR Responder: GA 316. Y Closed Closed 3

EICB Please check the page numbering in Appendix F, Closed General Atomics was not able to determine where the Response Included in letter dated Response acceptable.

(Singh) Nonconforming Material Reports. Pages 1 and 6 are missing and duplicate page 2 originated. The master document does not 11/24/10 Please submit page 2 is included multiple times. Also identify which page number contain any duplicate pages. Due a clerical error during response.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N is the last page number. document development, the master document starts at page 2 and ends at page 9, for a total of 8 pages. In May of this year, the NRC discovered that the master document was missing page 6. The master document was revised and re-submitted. Attachment 2 contains the missing page 6.

The Nonconforming Material (NCM) reports found on Appendix F are complete.

337 7.5.2. 7.5 Re: RM-1000 Report 04508905-QR Responder: GA 317. Y Closed Closed 3

Appendix C is titled as Seismic Test Fixture for RM2300, See The test fixture listed on Appendix C is applicable to the RM- Response Included in letter dated Response acceptable.

Drawing 04619028. Please verify whether or not it applies to RM- 1000, as indicated in the second and third paragraph of 11/24/10 Please submit EICB (Singh) 1000? If applicable, then please identify how it is applicable. section 4.3.1, of the 04508905-QR report. The RM-1000s response.

and the I/F converters are mounted on a standard 19 inch NIM-Bin, and this test rack is configured to simulate the field installation of a standard 19 inch rack.

This seismic test fixture was originally built for the seismic testing of the RM2300s which are also mounted on a standard 19 in NIM-Bin.

338 7.5.2. 7.5 In page 3-15 and appendix B of Qualification Test Report 04508905-QR, Qualification Test Report for RM-1000 318. Y Closed Closed RAI #4 letter dated FSAR amend 103 Note: Item to be added to Section 3.10 3 04508905-QR, licensee described the selection of seismic Processor Module and Current-To-Frequency Converter, November 22, 10 issued (3/15/11) of the FSAR for seismic quals.

required response spectra (RRS) and indicated Figure 3-2 (page (Attachment 23) documents the original baseline testing of Due: and RM-1000 3-17), Figure 3-3 (page 3-18) are the RRSs used. The RRS the RM-1000 and current-to-frequency converter. The Will be closed on included in FSAR curves used for actual testing are lower than the RRS curves that document has been revised to discuss the actual test issuance of FSAR amend.

are shown on Figures 3-2 and 3-3. The RRS curves used for spectra versus the required WBN response spectra used in amendment 103. SE testing are shown in Figure 4-5, 4-6, 4-7, 4-8, 4-11, 4-12, 4-13, the tests (see Attachment 22). 04508905-QR serves as a for Seismic qualification EICB (Singh) and 4-14 (pages 4-25, 4-26, 4-28, 4-29, 4-37, 4-38, 4-40, 4-41). reference document for the WBN Unit 2 specific seismic will be addressed in Please clarify and justify why the RRS curves used in actual tests qualification of the RM-1000 radiation monitors and current- section 3.10 of the are lower than the RRS curves determined in Figures 3-2 and 3-3. to-frequency converters documented in 04038903-7SP, FSAR.

Qualification Basis for 04034101 (2-RE-90-271, 272, 273 &

In addition please justify that the RRS used for testing envelopes 274), (Attachment 7) and 04038903-QSR, Qualification Amendment 103 the RRS required for WBN-2 application specific seismic Summary Report for Watts Bar Nuclear Plant Unit 2 issued. NRC action to conditions. Replacement Radiation Monitors, (Attachment 8). review and close item.

04038903-7SP makes the comparison of the actual test response spectra used in 04508905-QR and the WBN required response spectra (see Attachment 22).

339 7.5.2. 7.5 In the Qualification Test Report 04508905-QR, the licensee As agreed to with the reviewer, Attachment 1 contains the 319. Y Closed Closed RAI #5 letter dated FSAR amend 103 Note: Item to be added to Section 3.10 3 provided only eight Safe Shutdown Earthquake (SSE) Test applicable ARS plots for Elevation 755 where the TRS does November 22, 10 issued (3/15/11) of the FSAR for seismic quals.

Response Spectra (TRS) as mentioned in the previous open item not envelope the RRS. Attachment 2 contains the applicable Due: 2/25/11 and RM-1000 EICB (Singh)

(OI-338). Please provide all SSE and Operating Basis Earthquake Wyle Test Report 41991 SSE TRS plots. Will be closed on included in FSAR (OBE) TRS plots for NRC review. issuance of FSAR amend.

amendment 103. SE for Seismic qualification will be addressed in section 3.10 of the FSAR.

340 7.5.2. 7.5 Provide test result curves for all EMI/RFI tests listed in Table 3.2.3 Responder: GA 27. N Open Open-NRC Review 3 (page 3-8) of the Qualification Test Report 04508905-QR. In Due 4/30/11 addition, please provide the standards or the guidance documents The following responses are based on e-mail: GA-ESI to Provide the qual reports EICB (Singh) used as the source for ENV 50140, ENV 55011 Class A, and EN Bechtel, dated December 8, 2010 (Reference 20), Response included in letter dated by 1/28/11 per TVA 55022 Class B. 12/22/10. letter of 12/22/10.

(1) The EMI/RFI tests described in Table 3-2 are based on GA-ESI report 04509050 and are summarized in GA- Due: 2/25/11 ESI report 04508905-QR. The independent laboratory Clarification Needed:

report, with curves, is part of GA-ESI report 04509050. Per 2/25/11 response Subsequent to issuing GA-ESI report 04508905-QR TVA document SS-

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N additional EMC testing was performed in accordance E18.14.01, Rev. 3 is with TVA specific requirements. The results of the the source document subsequent EMC testing are reported in GA-ESI report for all testing. Please 04038800. GA-ESI report 04038800 includes the test provide this document curves and the report is used as the basis for EMC for staff review. In qualification of the Upper and Lower Inside addition British Containment Post Accident Radiation Monitors (2-RE- Standards (e.g. ENV 90-271 through -274). The results of the testing and 50140) have been cited the acceptability of the RM-1000 monitors for use at in testing which are not WBN Unit 2 are addressed in GA-ESI report per RG 1.180, R1. TVA 04038903-7SP. This report will be submitted no later to describe compliance than January 28, 2010. of SS-E18-14.01 to RG 1.180 with justification (2) ENV 50140, EN 55011, and EN 55022 are British for deviations. No test Standard Institution (BSI) publications concerning curves have been equipment electromagnetic and radio frequency provided in any of the performance. The standard titles are shown below: reports. As a minimum

a. ENV 50140 - Electromagnetic Compatibility - TVA to provide a few Basic Immunity Standard - Radiated Radio- sample test curves or Frequency Electromagnetic Field - Immunity Test justify not supplying

b. EN 55011 - Industrial, scientific and medical them.

equipment - Radio-frequency disturbance characteristics - Limits and methods of No EMI/RFI curves measurement have been provided as

c. EN 55022 - Information technology equipment - yet. TVA to provide Radio disturbance characteristics - Limits and representative curves.

methods of measurement NRC review proceeding TVA Response to Follow-up NRC Request: in parallel.

The total EMI/RFI testing of the RM-1000 and current-to- NRC current review frequency converter is documented in the following reports: guidance is based on compliance with RG Attachment 5 contains the proprietary version of 1.180 or equal with General Atomics Electronic Systems 04508905-1SP, justification for Qualification Test Report Supplement, RM-1000 variations. TVA is Upgrade. See sections 5.1.1, 5.1.2 and 5.1.4 for requested to provide EMI/RFI. the roadmap for Attachment 7 contains the proprietary version of compliance to RG General Atomics Electronic Systems 04038903-7SP, 1.180 with justifications Qualification Basis for 04034101 (2-RE-90-271, 272, for any deviations.

273 & 274). See section 5 for EMC qualification basis. Simply following TVA Attachment 8 contains the proprietary version of standard specification General Atomics Electronic Systems 04038903-QSR, SS E18.14.01, Rev. 3 is Qualification Summary Report for Watts Bar Nuclear not sufficient.

Plant Unit 2 Replacement Radiation Monitors. See section 3.4 for electromagnetic compatibility qualification requirements.

Attachment 23 contains the proprietary version of General Atomics Electronic Systems 04508905-QR, Qualification Test Report for RM-1000 Processor Module and Current-To-Frequency Converter. See sections 3.2.1 through 3.2.5 and 6.2 for EMI/RFI.

Attachments 7 and 8 document the EMI/RFI testing specific to the WBN Unit 2 RM-1000 monitors and current-to-frequency converters.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N TVA Response to Second Follow-up NRC Request:

GA-ESI qualification report 04038903-7SP, Qualification Basis for 04034101 (2-RE-90-271, 272, 273 & 274) Revision C dated February 22, 2011(Proprietary), submitted on TVA to NRC letter dated February 25, 2011 (Reference 2),

section 5.1 states:

GA-ESI has performed the tests on a 2 channel RM-1000 radiation monitoring system the configuration of which is shown in GA-ESI drawing 04509000 System Installation Configuration, RFI/EMI Test, RM-1000 the results of which are issued in GA-ESI report 04038800, RM-1000 EMC Test Report, TVA and 04509050, RM-1000 EMC Test Report.

The equipment tested used an RM-1000 microprocessor radiation monitor Display/Control NIM Bin Assembly, an I-F Converter, line filter, and an RD-23 detector. The monitor system being qualified is the same as the monitor system tested and includes ECO-17656 modifications to ensure EMC compliance.

Attachment 1 contains the TVA Browns Ferry High Range Radiation Monitor which contains the requested EMI test curves. We have confirmed that the GA-ESI reports (04509050, RM-1000 EMC Test Report, dated 4/22/03 and 04038800, RM-1000 EMC Test Report, dated 11/11/99) included in the TVA report are applicable to the WBN Unit 2 RM-1000 monitors. The non-proprietary versions and affidavit for withholding of GA-ESI reports (04509050 and 04038800) will be submitted within two weeks of receipt from GA-ESI.

GA-ESI qualification report 04038903-7SP, section 5, provides a detailed discussion of the test results in GA-ESi report 04509050.

TVA Response to Follow-up NRC Request Attachment 1 provides a comparision of the TVA EMC specification SS E18.14.01, Revision 3 requirements to RG 1.180 requirements.

341 7.5.2. 7.5 FSAR Tables 3.10 list seismically qualified equipment. However, A review of WBN Unit 2 FSAR amendment 102 chapters 320. Y Closed Closed RAI #1 letter dated FSAR amend 103 3 these tables do not list the containment high range radiation 3.10, 11 and 12 was performed. The reviewer was unable to January 14, 2011. issued (3/15/11) monitors. Please add them to the appropriate FSAR table(s) or locate seismic qualification information for the radiation FSAR section 3.10 will be updated Will be closed on and RM-1000 justify why they should not be included in the FSAR 3.10 series of monitoring system in those chapters. A review of chapter update of FSAR 3.10 included in FSAR in Amendment 103.

EICB (Singh) tables. 3.11 confirmed that radiation monitoring is included in the series tables. amend.

environmentally qualified systems.

Amendment 103 It appears that seismic qualification of the radiation issued. NRC action to monitoring equipment was unintentionally omitted from review and close item.

FSAR chapter 3.10. FSAR chapter 3.10 will be updated to include the qualified radiation monitoring equipment in FSAR amendment 103.

342 7.5.2. 7.5 Please confirm that RM-1000 monitors and the associated The RM-1000 containment high range radiation monitors are 321. Y Closed Closed 3 EICB equipment is supplied power from redundant battery backed class powered from 2-RM-90-271 & 2-RM-90-273 - Vital Power (Singh) 1E power sources. Board 2-III Breaker 45 Train A and 2-RM-90-272 & 2-RM See TVA letter 274 - Vital Power Board 2-IV Breaker 47 Train B. The vital 12/22/10, encl 1, item

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N power boards are battery backed. 31.

343 7.5.2. 7.5 Seismic RRS in the 04508905-QR report Figures 3-2 and 3-3 (1) The cause of the difference between the RRS and TRS 322. Y Closed Closed 3 show Required Response Spectra (RRS) to be greater than 20 was a test equipment failure at the test facility. When gs. The Test Response Spectra (TRS) in Figures 4-11 and 4-12 the test equipment failed, the facility was unable to use See TVA letter appears to be limited to about 15 g maximum. Please explain this the table capable of 20gs. Rather than delay testing 12/22/10, encl 1, item EICB (Singh) apparent lack of consistency between the RRS and the TRS. Will for six months, the facility proposed and GA-ESI 32.

this document be revised to take care of this inconsistency? agreed to use a smaller table with a lower capability.

The justification was that the resulting TRS would still envelope the majority of US nuclear plants RRS.

(2) To TVAs knowledge GA-ESI does not plan to revise this report. This is a baseline report that is used as a basis for producing individual plant specific reports.

344 7.6.6  ? Unit 1 SE discussed in Section 7.6.5, Valve Power Lockout. (a) In accordance with0PDP-6, Locked Valve/Breaker 323. Y Close Closed Close based on TVA letter dated There is no section in FSAR which provides discussion on this Program, Revision 1 (Attachment 25), valves locked by 3/29/11 subject. SE section discusses compliance with PSB-18. Provide design are shown on design output documents (flow Due 3/29/11 a discussion which can be used by the staff to determine similar diagrams, system descriptions, etc.). As documented in conclusion as Unit 1 and if the design is similar to Unit 1 then 0PDP-6, valves are locked for multiple reasons. It is ICSB-18 provides guidance on make a statement to that effect. Also provide the list of the anticipated that many of the valves that were locked to application of the single failure valves where power lockout during normal reactor operation is provide positive isolation between Unit 1 and Unit 2 will criterion to manually controlled utilized for valves whose inadvertent operation could affect plant not be locked when Unit 2 becomes operational and will electrically operated valves..

safety. be removed from the locked valve program. At the According to this BTP, electrically same time, Unit 1 valves locked for operated valves includes MOV, How do we meet the PSB? operational/Appendix R/Single Failure criteria will result SOV and those valves operated in the corresponding Unit 2 valves being locked. indirectly by an electrical device, e.g.an air operated valves whose air (b) The list of valves locked by design is contained in 0-PI- supply is controlled by an electrical OPS-17.0, 18 Month Locked Valve Verification, solenoid valves. FSAR Section Revision 44 (Attachment 21). Valves locked out by 7.6.6 addresses only MOVs. If TVA opening the associated circuit breaker are listed in 0-PI- has done an analysis to OPS-17.1, 18 Month Locked Breaker Verification, demonstrate compliance with the Revision 14 (Attachment 24). guidance of this BTP for Unit 1 and this analysis does not change for TVA Response to Follow Up NRC Question Unit 2 for other valves than TVA Eicg(Garg) shouls make a statement to that SER Supplement 0, Section 8.3.1.8 states: effect. If there are changes to the analysis then justify those changes 8.3.1.8 Application of the Single Failure Criterion to Manually based on this BTP.

Controlled Electrically Operated Valves - page 8-9 With regard to safety-related manually controlled, electrically operated valves, the staff asked the applicant to provide (1) an evaluation of all safety-related fluid systems to identify all such valves whose failure (that is, failure to operate on demand or undesired spurious operation) could result in the loss of capability to perform a system safety function (2) a description of the means provided to meet the single-failure criterion in safety-related fluid systems where it is identified that a single failure, as defined above, would result in the loss of capability to perform the system safety function In response, the applicant identified 17 such valves and documented in Section 7.6.6 of the FSAR that the design for these valves consists of modified control circuits. The

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N modified circuit utilizes redundant contacts which are wired before and after each opening and closing coil. Based on its review of the information provided by the applicant, the staff concluded that the above provisions are in accordance with BTP ICSB 18 of SRP Appendix 8-A, with the exception of redundant valve position indication.

Subsequently, the applicant stated that the method of locking out power with the required redundant instrumentation is shown on electrical drawing 45W760-63-2 Based on this drawing, the staff concludes that the design meets the staff's position and is acceptable.

SER Supplement 5 states:

6.3.2 Evaluation, Page 6-3, Supplement 5 In the SER, the staff stated that the applicant will lock out power from certain valves in the emergency core cooling system (ECCS) whose misalignment might affect ECCS effectiveness. Some of these valves would be required to operate following a LOCA, and the manual restoration of power would add to post-accident operational complexity.

By letters dated September 15, 1982, and April 10, 1985, the applicant stated Watts Bar would use modified control circuits for these valves to ensure that no single failure would be able to energize the opening or closing coils of the valve operators. The design uses redundant contacts that are wired before and after each opening and closing coil. In addition, clear protective covers will be attached to the main control board over each respective control switch to prevent inadvertent actuation. As discussed in SER Sections 7.6.4 and 8.3.1.8, the staff found this design acceptable.

Accordingly, power will not be locked out from the following valves during operation:

(1) hot-leg injection line valves (2) valves from residual heat removal (RHR) discharge to safety injection (SI) and charging pump suction (3) RHR suction valves from containment sump (4) RHR discharge valves (5) SI pump suction valve from refueling water storage tank (6) SI miniflow valve In addition, the applicant evaluated other valves that may be used for SI miniflow, RHR to SI cross-connect, and SI injection, but for which the consequences of single failure would be acceptable. Power will also not be locked out from these valves. This revision is acceptable to the staff. This review was tracked under TAC 63630.

The design of WBN Unit 2 mirrors the design WBN Unit 1.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N As a result, the locked valves for PSB-18 are the same for WBN Unit 2 as for WBN Unit 1 and the list in the Unit 2 FSAR Section 7.6.6 is accurate for Unit 2.

345 7.5.2. 7.5 Provide the normal temperatures and expected periods of high/low RM-1000 in a NIM Bin was Tested at 39°F for 72 Hrs and 324. Y Closed Closed Response 3 temperature excursions to assess aging requirements. TVA to Tested at 131°F for 72 Hrs per Section 4.2.6 of 04508905- provided by TVA further clarify if 86ºF for 40 years was used as the qualification QR. This is stated in document 04038903-7SP, Section 2.1. Due: 2/25/11 letter dated requirement for aging tests. This has been stated in some of the The ambient temperature used for aging was 86°F(30°C). 3/31/2011 in Item subsections under section 4.2 of the 04508905-QR report but the The NIM Bin has perforated holes in top and bottom covers Clarification Required: # 17.

rationale for using 86ºF (includes an internal temperature rise of and has an average internal temperature rise of Regulatory Guide1.209 18ºF) for 40 years has not been justified in the 04508905-QR approximately 18 °F due to natural air convection. So the endorses with the report or the supplement reports. TVA to provide the rationale for average internal temperature used for aging was 104°F exceptions IEEE 323-this acceptance criteria for WBN-2. (40°C) 2003. One of these exceptions is that the Check on verification of the 40 year life of the rad monitors. How is In accordance with Attachment 8, 04038903-QSR, documentation this explained. Qualification Summary Report for Watts Bar Nuclear Plant applicable to Unit 2 Replacement Radiation Monitors Section 3.2, the qualification in a mild aging is to an ambient equivalent condition of 104°F which is environment should be based on an 86°F average ambient temperature of the consistent with the environment and an enclosure temperature rise of 18°F. guidance given in IEEE Std 1205-2000, Table D.8 shows that the upper Section 7.2 for the bounding temperature is 104°F for all plant areas except the harsh environment.

reactor building. The intent in qualifying the part for 40 years is to identify each components failure mechanisms and to TVA has provided determine whether 40 years1 of aging has a significant effect synopsis of test of these failure mechanisms. information in support of environmental 1The design life goal for most Class 1E equipment is 40 qualification in the years, but for most electronic assemblies 20 years, or less, is 2/25/2011 letter. TVA more realistic. Because of rapidly changing technologies, to describe compliance EICB (Singh) replacement components sometimes become unavailable in to the guidance of a relatively short period of time. Section 7.2 of IEEE 323.

TVA Response to Follow-up NRC Request:

Please explain the (1) After review, GA-ESI report 04038903-7SP, basis for stating that the Qualification Basis for 04034101-001 (2-RE-90-271, - radiation monitors are 272, -273 & -274), submitted on TVA to NRC letter qualified for 40 years.

dated February 25, 2011 (Reference 3) follows the Please note that applicable guidance of Reg. Guide 1.209 for IEEE 323 qualification section 7.2 documentation. The information is either requirements of the contained in or referenced in the report. The computer based I&C documents are part of the GA-ESI permanent records equipment needs to and the appropriate GA-ESI records are part of the follow the guidance in permanent TVA WBN Unit 2 quality records. RG 1.209.

(2) The following IEEE 323 section 7.2 documentation requirements for equipment located in a harsh environment are not applicable for equipment located in a mild environment:

k. Aging mechanisms are not required by Reg. Guide 1.209

l. Qualified life determination is not required by Reg.

Guide 1.209

m. Age conditioning test results are not required by Reg. Guide 1.209 The remaining documentation requirements are

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N applicable in whole or in part to the RM-1000 radiation monitors. As described in item 1 above, GA-ESI report 04038903-7SP, Qualification Basis for 04034101-001 (2-RE-90-271, -272, -273 & -274), either contains or references the required documentation.

(3) As stated in Regulatory Guide 1.209, there is no need to establish a qualified life. This is addressed in the next to the last sentence of the second paragraph on page 2 which states: In addition, because of ready accessibility for monitoring and maintenance in mild environments, the need to establish a qualified life does not apply. It is further discussed in the last paragraph on page 6 which states: This guide does not intend to imply that a qualified life should be established for I&C systems in mild environments. Therefore, for the purposes of this guide, qualification is a validation of design to demonstrate that a safety-related computer-based I&C system is capable of performing its safety function under the specified environmental and operational stresses.

346 7.5.2. 7.5 TVA has previously stated in response to open item 319 that RM- Document 04507007-1TR is the RM-1000 System 28. N Open Open-NRC Reviewl 3 1000 System Verification Test Results report, 04507007-1TR is not Verification Test Results. 04038903-QSR, Qualification Due 4/15/11 applicable to WBN-2. However, TVA has not provided a WBN-2 Summary Report for Watts Bar Nuclear Plant Unit 2 Due: 2/25/11 specific test results report. Please identify and provide the Replacement Radiation Monitors (Attachment 8) and and appropriate test results reports to complete the review. 04038903-7SP, Qualification Basis for 04034101 (2-RE The proposed response 271, 272, 273 & 274) (Attachment 7) are the Watts Bar Unit appears to be 2 equipment specific qualification reports. conflicting with the proposed response for TVA Response to Follow up NRC Request: OI-351 regarding not submitting the Report 04507007-1TR RM-1000 System Verification Test 04508905-QR report.

Results is applicable to the WBN Unit 2 monitors. The TVA to re-assess applicability is that 04507007-1TR includes all test cases proposed response for called out in the 04507006 RM-1000 System Test both OIs.

Procedure Specification and contains evidence that the V&V tests were performed with version 1.0 software code. The TVA to re-evaluate verification report for version 1.1 software is document previous responses to EICB (Singh) 04508005 RM-1000 Software Version 1.1 Software OI-316 and OI-319 Verification Report. Document 04508006 RM-1000 Version which have conflicting 1.2 Software Verification and Validation Report shows that responses regarding the required test was completed to validated version 1.2 the applicability of code for the RM-1000. 04507007-1TR.

The Engineering reviewed and approved proprietary versions NRC Follow-up of 04507007-1TR, 04508005 and 04508006 will be question submitted within two weeks of receipt from GA-ESI. The unreviewed proprietary versions, non-proprietary versions Report 04507007-1TR, and affidavit for withholding were submitted on TVA to NRC 1999 states in the Test letter July 15, 2010 (Reference 3). Summary that Initially the testing was done TVA Response to Follow up NRC Request using the SE safety related production GA-ESI has a single process for buying material, assembling modules that had and testing modules. The same process is used for any part undergone software number, safety related or not so they can avoid having to V&V testing. The store the same part number in two different locations and majority of the testing avoid the possibility of mixing them up. Therefore, the was done by using two

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Sorrento Electronics safety-related production modules and of the Sequoyah non-the Sequoyah non-safety-related modules are physically safety related identical. Based on the above the report is acceptable. production modules for the TVA contract, substituted for the SE modules. Since the report is based on primarily non safety related components TVA to clarify and justify why NRC should accept this test report for safety related V&V testing.

347 7.5.2. 7.5 Qualification report 04508905-1SP does not address EMI/RFI Qualification report 04038903-7SP, Qualification Basis for 325. Y Closed Closed 3 qualification for the new RM-1000 modules. TVA to provide the 04034101-001 (2-RE-90-271, -272, -273, & -274)

EICB (Singh) updated qualification or explain the basis for not addressing the (Attachment 7), addresses the EMI/RFI qualifications for the Item 19 of TVA letter EMI/RFI qualification. entire loop including the RM-1000 and current to frequency dated 2/25/11 provided (I/F) converter. This report references 04038800, RM-1000 satisfactory response to EMC Test Report, TVA, and the results are summarized in close the item.

04038903-7SP.

348 7.5.2. 7.5 Qualification report 04508905-2SP does not address EMI/RFI Qualification report 04038903-7SP, Qualification Basis for 326. Y Closed Closed EICB (Singh) 3 qualification for the new I/F converters. TVA to provide the 04034101-001 (2-RE-90-271, -272, -273, & -274),

updated qualification or explain the basis for not addressing the (Attachment 7) addresses the EMI/RFI qualifications for the Item 20 of TVA letter EMI/RFI qualification. entire loop including the RM-1000 & I/F converter. This dated 2/25/11 provided report references 04038800, RM-1000 EMC Test Report, satisfactory response to TVA, and the results are summarized in 04038903-7SP. close the item.

349 7.5.2. 7.5 Radiation testing was not considered in any of the test reports as The design criteria provides the criteria for determining what 1. Y Open Open-Mech Eng to 3 all the equipment has been assumed to be located in nuclear is a mild environment at WBN Unit 2. Calculation revise calculation power plant areas with mild environments and radiation dosages WBNAPS4004 Summary of Mild Environment Conditions for less than 1 x 103 rads for total integrated dose (TID). However, Watts Bar Nuclear Plant provides the actual values for each Due: 2/25/11 the radiation monitors and the I/F converters are located in the area of the plant. In accordance with Table 1, the Control main control room which is defined as mild environment. For Room has a 40 year maximum TID of 3.5x102 RAD and a TVA to provide the WBN-2 mild environment is defined as room or building zone maximum integrated accident dose of 710.5 RAD for a assessment document where (1) the temperature, pressure, or relative humidity resulting maximum TID of 1060.5 RAD. or a summary of the from the direct effects of a design basis event (DBE) (e.g., document with the temperature rise due to steam release) are no more severe than The accident dose of 710.5 RAD is the dose for a 100 day reference to the those which would occur during an abnormal plant operational LOCA at the surface of the HEPA filter in the Mechanical appropriate condition, (2) the temperature will not exceed 130ºF due to indirect Equipment Room. This is documented in TVA calculation document/documents.

effects of a DBE, (3) the event radiation dose is less than or equal WBNTSR-005, Dose Due to the Control Building EICB (Singh) to 1 x 104 rads, and (4) the total event plus the 40 year TID (total Emergency Air Cleanup Filters Revision 3. However, on February 25, 2011 integrated dose) is less than or equal to 5 x 104 rads (reference page 25 of WBNTSR-005, the shine from this source into the response is acceptable.

WB-DC-40-54). TVA to address lack of radiation qualification for control room is negligible and is not considered in the dose Item will be tracked as WBN-2. calculation for the control room. a confirmatory item in the SE. TVA to provide Calculation WBNAPS3-126, EQ Dose in the U1/U2 Auxiliary calculation or summary Instrument Rooms and the Computer Room in the Control of calculation when Building Revision 0 documents the environmental complete.

qualification (EQ) radiation dose in the control building. A review of this document by the TVA radiation protection engineer determined that the TID including the normal and accident dose values for the control room is less than 1x103 RAD. Calculation WBNAPS3-126, will be revised to include the control room by July 1, 2011. Since the control room TID has been determined to be less than 1x103 RAD, radiation qualification of the RM-1000.

350 7.5.2. 7.5 The seismic required response spectra (RRS) is shown in Figures The RM-1000 was seismically tested in a NIM Bin and the 327. Y Closed Closed RAI # 9, letter FSAR amend 103 Note: Item to be added to Section 3.10

(

S i

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 3 3-1 of 04508905-1SP and Figure 3-1 of 0458905-2SP report. The actual test response spectra fully envelopes the RRS of TVA dated January 14, issued (3/15/11) of the FSAR for seismic quals.

actual test response spectra are shown in Figures 4-5 and 4-6 of Standard Specification CEB-SS-5.10 For Seismic Due: 2/25/11 2011. and RM-1000 04508905-QR report. The actual test response spectra does not Qualification of Electrical, Mechanical and I&C Devices included in FSAR seem to fully envelope the RRS. However, this statement is based Revision 3, (Attachment 3) Figure 3-1 as shown in Section Will be closed on amend. See OI-on visual reading of unidentified numbers. TVA to provide 3.0, Figures 3-4 and 3-5 of 04038903-7SP, Qualification issuance of FSAR 358 for further clarification to the values at the inflection point of all lines on the Basis for 04034101 (2-RE-90-271, 272, 273 & 274) amendment 103. SE details of RRS RRS and the actual test response spectra. The seismic (Attachment 7). Seismic qualification of the WBN Unit 2 RM- for Seismic qualification max values.

qualification issue is open till further clarification is received from 1000 monitors is summarized in 04038903-QSR, will be addressed in TVA. Qualification Summary Report for Watts Bar Nuclear Plant section 3.10 of the Unit 2 Replacement Radiation Monitors (Attachment 8). FSAR.

Amendment 103 issued. NRC action to review and close item.

351 7.5.2. 7.5 The replacement schedule for the components that have a The replacement schedules stated in 04508905-1SP, 328. Y Closed Closed 3 qualified life of less than 40 years is noted in Table 6-1 of the Qualification Test Report Supplement, RM-1000 Upgrade supplemental qualification report 04508905-1SP. It is not clear if (Attachment 5) and 04508905-2SP, Qualification Test Due: 2/25/11 the components identified for replacement in this report are the Report Supplement, I-F Converter Upgrades (Attachment 6)

EICB (Singh) only components or if the components which are in addition to the should be used. 04508905-2SP states in Section 6: None Reports 04508905-1SP components previously identified in qualification report 04508905- of the Current-to-Frequency converter modules qualified by and -2SP both refer to QR. this supplement contain parts that have significant age 04508905-QR as the related failure mechanisms. parent document in Are there any age sensitive components for the I/F converter used section 4.1. Also see for WBN-2? (Note: Report 04508905-2SP does not state any age staff comment on OI-sensitive components that require replacement during the qualified 346.

life).

352 7.5.2. 7.5 Please clarify how many RM-1000 radiation monitors are being The total number of RM-1000 units procured under MR 329. Y Closed Closed 3 procured for WBN-2, is the quantity 2 or four. MR 25402-011- 25402-011-MRA-HARA-00002 is four. The MR on line item EICB (Singh)

MRA-HARA-00002, R4 under Item 1.6 indicates that the quantity is 1.6 is stating the purchase of 2 sets of 2 RM-1000s & I/F Due: 2/25/11

2. If so, is WBN-2 using dual channel indication on each RM-1000 Converters making a total of 4 for each type of component.

unit. TVA to clarify. Will close on receipt of Each monitor utilizes a single channel display for the 2-RM- formal response.90-271 - 274 monitors.

353 7.5.2. 7.5 Please provide a summary of the [manufacturers] commercial GA-ESI submitted their commercial grade dedication 29. N Open Open-NRC Review 3 dedication plan for radiation monitors with references to the procedure (OP-7.3-240, Safety-Related Commercial Grade Due 4/15/11 guidance document that it follows. Also please include different Item Parts Acceptance, Revision H) to engineering for TVA to note that staff facets (e.g. receiving, inspection, testing etc.) of the plan. review. Engineering review of the procedure found that the has written a safety procedure, Section 5, did not require multiple dedication evaluation and methods for complex CGI or CGI used in digital safety accepted EPRI TR-systems. As a result, it was determined that the GA-ESI 106439 (1996) as an program did not meet the requirements of NUREG-800, acceptable method of Section 7.0A, Revision 5. addressing commercial dedication. EPRI NP-EICB (Singh)

A discussion with GA-ESI found that while not required by 5652 must be used in procedure, GA-ESI does perform vendor surveys as required conjunction with the by Method 2 of NP-5652. The surveys are done based on additional guidance in prudent business practices. Based on this discussion, GA- EPRI TR-106439 for ESI agreed to review the CGI used in the WBN Unit 2 digital commercial dedication safety-related monitors to determine if they had been processes e.g. EPRI dedicated by more than one method. NP-6404, EPRI TR-102260, GL 89-02, and The review of the CGI used in the WBN Unit 2 digital safety- GL-91-05 per Section related monitors determined that all CGI had been dedicated 3.3 of EPRI TR-using Method 1 of EPRI guideline NP-5652. However, in the 106439.

sample of items reviewed, there were CGI that were dedicated using a single method. Based on the results of the Follow-up

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N engineering procedure review and the results of the GA-ESI clarification:

CGI review, Service Request 346896 was initiated to document the condition and to place the monitors in TVA to review and Conditional Release status. satisfy itself with the procedure and provide Based on the results of the previous reviews, GA-ESI agreed NRC a copy of the to the following plan of action to resolve the CGD issue: procedure for review.

In addition, TVA and

1. GA-ESI shall revise its commercial grade dedication GA to provide procedure (OP-7.3-240) to require multiple dedication information as to what methods be utilized for complex commercial grade additional measures items and commercial grade items for digital safety were taken by GA with class systems. The evidence that this has been available completed will be provided to TVA by April 15, 2011. documentation to prove that more than one Specifically, Method 1 and at least one additional method was followed method from the list below will be used to ensure that for commercial the CGD procedure complies with the current SRP. dedication.

Method 1 - Special Tests and Inspections Method 2 - Commercial Grade Survey of Supplier Method 3 - Source Verification Method 4 - Acceptable Supplier/Item Performance Record

2. GA-ESI shall take actions consistent with the revised operating procedure to address the CGls used in the WBN Unit 2 safety-related digital monitors. Evidence that those actions have been completed will be provided no later than September 1, 2011.

Based on the above action plan, TVA will resolve the issues with the GA-ESI CGD of CGI used in the WBN Unit 2 monitors and submit documentation of the resolution to the NRC by:

GA-ESI procedure OP-7.3-240 revision: April 30, 2011 Resolution of CGD of CGI used in WBN Unit 2 RM-1000 monitors: September 15, 2011 TVA Response to Follow up NRC Request (1) TVA has reviewed the revised GA-ESI procedure and determined that changes bring the CGD program into conformance with the requirements of NUREG-800, Section 7.0A, Revision 5 EPRI topical report TR-106439 and EPRI guideline NP-5652. Attachment 2 contains GA-ESI procedure OP-7.3-240 Safety-Related Commercial Grade Item Parts Acceptance, Revision I.

(2) As stated in TVA to NRC letter dated April 15, 2011(Reference 1), Attachment 4, List of New Commitment Items, item 2, the due date for resolution of this issue is September 15, 2011.

354 7.5.2. 7.5 RG 1.180 endorsed the guidance of IEEE-1050-1996 with (1) The WBN Unit 2 grounding system design is in 330. Y Closed Closed The grounding specification used by 3 EICB clarifications regarding Instrumentation and Control Equipment accordance with WB-DC-30-32, Revision 3, Design Due 3/29/11 TVA does not meet IEEE 1050-1996 (Singh) Grounding to minimize the effects of EMI/RFI and power surge Criteria For Grounding (Attachment 5). I&C equipment and therefore additional steps must be related effects on the safety-related I&C systems. (1)TVA to grounding is described in Section 2.2.3C.1 I&C taken to assure that the radiation

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N describe the grounding of the I&C equipment and (2)to state Grounding System (page 15). The design is based on monitors are not susceptible to EMI/RFI whether or not it follows the guidance of IEEE Std 1050-1996. IEEE 80-1986 IEEE Guide for Safety in AC Substation interference when portable radio Grounding. devices are sued in the control room.

TVA has agreed to do the survey after (2) The design of the WBN grounding system predates the radiation monitors are installed.

IEEE 1050. As a result WBN Units 1 and 2 do not follow the guidance of IEEE 1050 or Regulatory Guide Will be tracked for survey committment 1.180. under OI-355.

355 7.5.2. 7.5 Staff has not found the stated exclusion zone for EMI/RFI Cautions and distance limitations for WBN Unit 1 legacy 331. Y Closed Closed 3 interfering devices (e.g. hand-held radio devices) in the submitted equipment are documented in TVA procedure TI-134, Due 4/15/11 documents. TVA to provide the distance for the exclusion zones if Revision 0, Control of Portable Two-Way Radios, TVA letter dated April not provided already. If it is already a submitted information then (Attachment 7) Appendix B. Where WBN Unit 2 uses the 15, 2011, Item No. 4.

please point the source of the information. same legacy equipment, the same cautions and distance TVA committed to do limitations apply. EMI/RFI survey.

New equipment is procured and tested to TVA Standard TVA to provide Specification SS E18.14.01, Revision 3, Electromagnetic commitment that an Interference (EMI) Testing Requirements for Electronic EMI/RFI survey will be Devices (Attachment 6). The TVA specification is conducted after the conservative with respect to Regulatory Guide 1.180, installation of the Revision 1. The specification requires that equipment not be equipment to confirm susceptible to external interference or create external the non-susceptibility EICB (Singh) interference. New equipment is either tested by the when using portable manufacturer or tested in the TVA EMI test facility to ensure radio-frequency it meets the specification. If issues are found, the equipment sources such as hand-is modified and installation documents are revised to held radios or other eliminate the issue(s). This is true for the RM-1000 radiation authorized devices that monitors which were tested prior to installation in Browns may be used in the Ferry at 10v/meter (Browns Ferry High Range Radiation control room.

Monitor dated December 8, 2006). Based on this, no Summary of the results exclusion zone for radio use is required for the RM-1000 to be submitted to NRC radiation monitors in WBN Unit 2. to close this item.

Survey results are to be TVA Response to Follow-up NRC Request: available for audit by NRC.

TVA will perform an EMI survey of the containment high range radiation monitors after installation in WBN Unit 2 and submit the results to the NRC within two weeks of the survey being completed.

356 7.5.2. 7.5 The attachment number refers to your February 25, 2011 letter. The loss of the RM-3 output (current to frequency (I/F) 332. Y Closed Closed Closed by TVA 3 RM-1000 Qualification Test Report 04508905-QR (Attachment 23); converter output) was determined to be a result of a defect in letter of 3/31/11.

page 4-27 in Table 4-22 shows that RM-3 output failed during the the shaker table (described in section 4.3.6 page 4-23) which OBE and SSE tests. The justification for failure of this RM-3 output exposed the test articles to unexpected high Gs. This is not explained in the report or any of the appendices in the report. caused a failure in the RM-1000 high voltage power supply Please provide the resolution for this failure. Please note that a output. The RM-1000 used in the I/F converter test setup similar failure was reported in the test in Table 4-21 which was (as shown in Figure 2-6 on page 2-9) was not included in the EICB (Singh) resolved in Appendix F, Closed Nonconforming Material Reports. equipment set being qualified. Rather it was being used as a piece of test equipment to power the I/F converter and provide outputs to monitor I/F converter performance during the test. The resolution was to retest the I/F converter using a functional RM-1000 module at a later time (December).

The balance of the components (non-failed) were tested to completion during the original testing runs in the November time frame.

357 7.5.2. 7.5 In Attachment 5, Qualification Test Report Supplement, RM-1000 Attachment 8 contains GA-ESI qualification report 333. Y Closed Closed Closed by TVA

(

S i

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 3 (04508905-1SP), Attachment 6, Qualification Test Report 04508903-1TR Seismic Qualification Test Results RM-1000 submittal of Supplement, I-F Converter Upgrade (04508905-2SP), and and Current-to Frequency (I/F) Converter original release, 3/31/2011, Att. 8.

Attachment 23, Qualification Test Report for RM-1000 Processor dated April 1999.

Module and Current-To-Frequency Converter (04508905-QR), the applicant made a statement that the results for these tests are provided in SE document 04508903-1TR. Please provide SE document 04508903-1TR for the staff to review. IF this report has been submitted earlier then please advise us the letter number and date by which it was submitted.

358 7.5.2. 7.5 The attachment numbers refer to your February 25, 2011 letter. In An incomplete response was inadvertently submitted in TVA 334. Y Closed Closed Closed by TVA 3 Attachment 2, Wyle Test Report 41991 Safety Shutdown to NRC letter dated March 31, 2011 (Reference 1). The Due 4/15/11 letter dated Earthquake (SSE) Test Response Spectra (TRS) Plots all five (5) following response supersedes the previous response in its 4/15/2011, Item 5.

pages, in Attachment 5, General Atomics Electronic Systems entirety.

04508905-1SP, page 5-5, Figure 5-2, and in Attachment 23, Qualification Test Report for RM-1000 Processor Module and 1. Attachment 2, Wyle Test Report 41991 Safety Current-To-Frequency Converter (04508905-QR), page 4-25, Shutdown Earthquake (SSE) Test Response Spectra Figure 4-5 X-Axis SSE Test Response Spectra (TRS) versus (TRS) Plots all five (5) pages. These five Test Required Response Spectra (RRS), it shows that the TRS were Response Spectra (TRS) Plots versus Required below the RRS at various frequency (5% Damping). Please provide Response Spectra (RRS) show that the TRS were an explanation regarding why this is acceptable. below the RRS at various frequency (5% Damping).

Please provide an explanation regarding why this is acceptable.

Attachment 2 of this letter provides five pages from the first seismic test (Wyle Test report 41991) from GA-ESI report 04508903-1TR, submitted in response to OI-357 on TVA to NRC letter dated March 31, 2011 (Reference 1). The following discussion refers to these pages.

Wyle test report 41991 provided the seismic test results for two RM-1000 monitors (one area monitor and one process monitor) and one I/F converter. During the test, EICB (Singh) the RM-1000 monitor configured as an area monitor was damaged due to the test table impacting its mechanical stop (see page 4 of Wyle Test Report 41991 attached).

This first test was completed for the RM-1000 monitor configured as a process monitor and the I/F converter.

A second seismic test for the RM-1000 monitor configured as an area monitor and two I/F converters (Wyle Test Report 41991-1) is also included in 04508903-1TR. The RM-1000 monitor used in this second test was the same RM-1000 process monitor used in the first seismic test reconfigured (switch in application type 1 mode) as an area monitor. One of the I/F converters tested was the same I/F converter tested in the first seismic test. This second test was performed to complete the testing which could not be performed during the first seismic test due to the damage to the RM-1000 area monitor and the loss of the high voltage power supply to the I/F converter that occurred during the first seismic test. None of the TRS plots in this second seismic test report 41991-1 were below the RRS.

General Atomics Qualification Test Report for RM-1000 Processor Module and Current-To-Frequency Converter (04508905-QR) refers to both Wyle Reports

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N 41991 and 41991-1 included in report 04508903-1TR. It is recognized that the five TRS Plots versus the RRS where the TRS were below the RRS is an exceedance that must be justified. From Wyle report 41991 it can be determined that these five TRS versus RRS plots are for the seismic response in the front to back panel direction.

The RRS used in the Wyle test reports envelopes the TVA standard RRS shown in Fig 3.1 of TVA Standard Specification CEB-SS-5.10, For Seismic Qualification of Electrical, Mechanical and I&C Devices, submitted on TVA to NRC letter dated February 25, 2011, (Reference

2) below 33 Hz. This TVA standard RRS conservatively envelopes the in panel seismic demand for most TVA applications. For specific cases when required the actual in panel RRS can be developed. Calculation WCG-ACQ-0766, In-Cabinet Required Response Spectra for RM-1000 Radiation Monitors in MCR Panel 2-M-30, Revision 0, (Attachment 3) has been issued to generate the 5% RRS for these safety related RM-1000 monitors, I/F converters and NIM bins for the WBN2 panel (2-M-30) where they will be installed. As can be seen from the RRS plots in calculation WCG-ACQ-0766 the front to back 5% RRS broad band peak is 9.76 g which is lower than the front to back 5% TRS shown in the subject five (5) plots.

2. Attachment 5, General Atomics Electronic Systems 04508905-1SP, page 5-5, Figure 5-2. The Figure 5-2 Test Response Spectra (TRS) Plots versus Required Response Spectra (RRS) shows the TRS to be below the RRS at various frequency (5% Damping). Please provide an explanation regarding why this is acceptable.

The display module for the RM-1000 monitors procured for WBN2 differs from that used in previous RM-1000 qualification tests. The seismic qualification basis for the WBN2 display module is established by similarity to the display module used in RM-2000 monitor qualification tests shown on page 5-4 and 5-5 of 04508905-1SP (pages attached). The basis for the similarity discussion is provided on pages 5-2 and 5-3 of 04508905-1SP. The TRS non-exceedance at approximately 6-7 Hz shown on page 5-5 is not applicable to WBN2 since the RRS shown on that figure is not used for WBN2 qualification. The correct comparison for WBN2 would be the TVA standard RRS shown in Fig 3.1 of CEB-SS-5.10 for 5% damping. The TRS shown on page 5-5 meets or exceeds all points of the TVA standard RRS. Therefore, the seismic qualification of the WBN2 display module is provided by pages 5-4 and 5-5 for which the TRS completely envelopes the TVA standard RRS shown in Fig 3.1 of CEB-SS-5.10. Additionally, as previously stated, Calculation WCG-ACQ-0766 was issued to generate the 5% RRS for the WBN2 panel (2-M-30) where the safety related RM-1000 monitors will be installed. The vertical 5% RRS plot in calculation WCG-ACQ-0766 broad band peak is 4.2 g which is lower than the 5% TRS shown in 04508905-1SP, page 5-5, Figure 5-2.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

3. Attachment 23, Qualification Test Report for RM-1000 Processor Module and Current-To-Frequency Converter (04508905-QR), page 4-25, Figure 4-5 X-Axis SSE Test Response Spectra (TRS) versus Required Response Spectra (RRS) shows the TRS to be below the RRS at various frequency (5% Damping). Please provide an explanation regarding why this is acceptable.

This Figure 4-5 is one of the same figures identified in item 1. See item 1. for the appropriate discussion.

359 7.7.1. Was the CERPI system developed under a 10 CFR 50 Appendix B CERPI is a non-safety related system. Therefore, 10 CFR 30. Open Open-NRC Review 1 EICB compliant program? 50 Appendix B is not applicable. Due 4/15/11 (Carte) 360 In order for staff to review the acceptability of the Incore (a) The Watts Bar Unit 2 In-core Instrumentation System 31. Open Open-NRC Review Instrumentation System (IIS): (IIS) replaces all of the functionality provided by the Due 4/15/11 Movable Incore Detector System (MIDS) used at Watts (a) Provide a brief system description of IIS and its regulatory Bar Unit 1. The IIS to be used at Watts Bar Unit 2 is a compliance. In your discussion include the discussion of Westinghouse IN-Core Information, Surveillance, and WINCISE and BEACON system which are part of the IIS. Engineering (WINCISE) System that is functionally Also provide the differences between the system used at described in Section 7.7.1.9 of the Watts Bar Unit 2 WBN Unit vs. at Unit 2, e.g. Movable vs. fixed IIS. For Final Safety Analysis Report (FSAR). The WINCISE-WINCISE provide the basis for acceptance. style IIS used at Watts Bar Unit 2 is essentially the same as the in-core power distribution measurement systems (b) If this system has been accepted by the staff previously at used at most Combustion Engineering style of operating some other plant then provide the reference to that SE. reactors that use a type of in-core neutron sensors Identify the document that describes the functionally of the IIS commonly called "Fixed In-core Detectors (FID)." The that is identical to the IIS used in the Westinghouse AP1000 Watts Bar Unit 2 IIS is functionally identical to the IIS reactor design. used in the Westinghouse 1AP1000' reactor design.

The Watts Bar Unit 2 IIS includes the FIDs, Core Exit (c) If this has not been evaluated by the staff previously, then Thermocouples (CET), FID and CET signal cables, the provide the effect of CCF of this system and its effect on FID signal processing hardware, and the FID signal safety system or chapter 15 analysis. processing software. This hardware and software is EICB (Garg) required to provide the measured signals to the (d) Does this have any interconnection with safety system?

associated BEACON System to periodically determine (e) For BEACON provide the acceptability of this system. I whether the reactor is operating within design core believe that this system was accepted at WBN Unit 1. If that peaking factor limits. A detailed description of the Watts is the case then provide the reference to that review. Also Bar Unit 2 IIS hardware is provided in the document provide any differences of this system to the one at WBN Unit titled, Westinghouse Incore Information Surveillance &

1 system. Engineering (WINCISE) System Technical Manual, NO-WBT-002, Revision 0 supplied by Westinghouse to TVA (f) Please provide detailed information about the In-core in September of 2010.

Instrumentation System (IIS) to be installed in Watts Bar Unit

2. This information should indicate how the system meets the The qualification for the BEACON System to perform the requirements established in the Standard Review Plan, core power distribution measurement function using the including system concept, system requirements, system Watts Bar Unit 2 WINCISE style IIS instrumentation is design, and system development, as well as the regulatory documented in the generic NRC Safety Evaluation requirements identified for Watts Bar Unit 2. Reports (SER) provided with WCAP-12472-P-A, BEACON Core Monitoring and Operations Support (g) Please provide a description on how the system will meet the System, Addendum I-A and Addendum 2-A.

regulatory requirements identified in Table 7.1-1 of the SRP, applicable to the IIS. (b) The WINCISE style IIS used at Watts Bar Unit 2 is essentially the same as the in-core power distribution (h) Provide detailed description about the connection and measurement systems used at all Combustion Engineering style of operating reactors that use a type 1

AP-1000 is a registered trademark of the Westinghouse Electric Company LLC

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N communication for the signals to be transmitted from the Core of in-core neutron sensors commonly called "Fixed In-Exit Thermocouples to the Common Q Post Accident core Detectors (FID)." The Watts Bar Unit 2 IIS is Monitoring System (PAMS). Also, describe how this functionally identical to the IIS described in the communication will meet the NRC communications regulatory Westinghouse AP1000 design documents and approved requirements. in the Westinghouse AP1000 SER section 7.5.7 as documented in Westinghouse Letter WBT-D-____ ,

(i) Please provide the following Westinghouse document: NO- title, dated April 14, 2011 (Attachment 7)

WBT-002, Westinghouse Incore Information Surveillance &

Engineering (WINCISE') System Technical Manual. (c) The digital in-core flux monitoring portion of the IIS is non-safety-related. As such, CCF analysis is not (j) Provide the failure modes and effects analyses for the IIS, required by NUREG-800 section 7.0-A. The IIS has no documented in calculation WBNOSG4220 WB Incore impact on any Safety Analysis documented in Chapter Instrumentation System Failure Modes and Effects Analyses, 15 of the Watts Bar Unit 2 FSAR.

and demonstrate how these potential failures do not adversely affect reactor safety. (d) The IIS includes the 1E qualified CET and CET analog signal cables required to allow the CETs to be directly connected to the Common Q Post Accident Monitoring System (PAMS). There is no other interface to safety systems. The CET signals are electrically isolated from signals output from the non-1E FID signals and signal processing electronics.

(e) The qualification for the BEACON System to perform the core power distribution measurement function using the Watts Bar Unit 2 WINCISE style IIS instrumentation is documented in the generic NRC Safety Evaluation Reports (SER) provided with WCAP-12472-P-A. This WCAP generically approves the BEACON System for use at PWR reactors including those using Movable In-core Detector Systems (MIDS) like Watts Bar Unit 1 and, through Addendum I-A and 2-A, those like Watts Bar Unit 2 using a WINCISE type fixed in-core instrumentation system.

The specific differences between the Unit 1 and Unit 2 core power distribution measurement systems are too numerous to simply list. A detailed description of the Watts Bar Unit 2 IIS hardware is provided in section 2 of the WINCISE System Technical Manual NO-WBT-002 (Attachment 5).

(f) NUREG-800 section 7.0-A, Table 7.0-A-1. Review Topics for Various Systems, requires only a limited review for non-safety related system discussed in NUREG-800 section 7.7 Control. WINCISE is a non-safety-related, indication only system within the scope of NUREG-800 section 7.7. The limited review required is:

Control systems receive a limited review as necessary to confirm that control system failures cannot have an adverse effect on safety system functions and will not pose frequent challenges to the safety systems. The only WINCISE interface with a safety-related system is the CET in the IITA which is hardwired to the Common Q PAMS system. See item (g) below for a description of the qualification process that demonstrates that failures in the balance of the WINCISE system do not impact the performance of the safety-related CET function.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N (g) With the exception of the IITA hardware, WINCISE is a non-safety-related indication system. The IITA assemblies meet the following criteria:

i. R.G. 1.26 Rev. 3 Quality Group Classification and Standards for Water, Steam and Radioactive Waste Components of Nuclear Power Plants ii. R.G. 1.38 Rev. 2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling of Items for Water-Cooled Nuclear Power Plants iii. R.G. 1.71 Rev. 0 Welder Qualification for Areas of Limited Accessibility iv. R.G. 8.8 Rev. 3 Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power Stations will be As Low As Reasonably Achievable

v. R.G. 8.19 Rev. 1 Occupational Radiation Dose Assessment in Light-Water Reactor Plants Design State Man-Rem Estimates vi. R.G. 1.84 Rev. 27 Design and Fabrication Code Case Acceptability - ASME Section III, Division 1R.G. 1.85 Rev. 27 Material Code Case Acceptability - ASME Section III, Division 1 1.1.4 The design, materials, fabrication, inspection, and testing of the IITA shall be in accordance with the ASME Boiler and Pressure Vessel Code,Section III Class 3, and all applicable Code Cases as proposed by the supplier and approved by Westinghouse. Materials shall be in accordance with this specification.

1.1.5 Component Classification - The IITA is classified as an instrument tube, so it is not under the jurisdiction of the ASME per NCA-1130(c). However, the design, primary pressure boundary materials, and NDE Requirements are per ASME Section III, Class 3 and the IITA is classified as Safety Class 2.

The non-safety-related WINCISE Signal Processing System Cabinets are located inside containment and are therefore required to not impact the function of any safety-related equipment. To meet this requirement the cabinets were tested and passed based on the following criteria:

i. In accordance with WB-DC-40-31.2, Watts Bar Nuclear Plant Seismic Qualification of Category 1 Fluid System Components and Electrical or Mechanical Equipment, Revision 8, November 2000 and U.S. N.R.C. Regulatory Guide 1.100, Seismic

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Qualification of Electrical and Mechanical Equipment for Nuclear Power Plants, Revision 2, June 1988, the equipment must withstand five OBEs and one SSE without creating missiles. Testing was done in accordance with:

(1) IEEE Std 344-1975, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations, Institute of Electrical and Electronics Engineers, Inc., 1975 (2) IEEE Std 344-1987, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations, Institute of Electrical and Electronics Engineers, Inc., 1987 ii. In accordance with U.S NRC Regulatory Guide 1.180 Guidelines for Evaluating Electromagnetic and Radio-Frequency Interference in Safety-Related Instrumentation and Control Systems, Revision 1, October 2003 and IEEE 323-1983 IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generator Stations, Institute of Electrical and Electronics Engineers, Inc., 1983, the equipment must not generate spurious electromagnetic emissions or suffer some common mode failure due to its operating environment that could directly or indirectly impact the operation of safety-related equipment (1) IEC 61000-6-2, Electromagnetic compatibility (EMC). Generic Standards. Immunity for Industrial Environments, 2005 (2) MIL-STD-461E, Requirements for the control of Electromagnetic interference Characteristics of Subsystems and Equipment, August 1999 (3) IEC 61000-4-4, Electromagnetic compatibility (EMC) - Part 4-4: Testing and Measurement Techniques - Electrical Fast Transient/Burst Immunity Test, 1995 (4) IEC 61000-4-12, Electromagnetic Compatibility (EMC) - Part 4: Testing and Measurement Techniques, Section 12:

Oscillatory Waves Immunity Tests, 1996 iii. In order to demonstrate that a maximum expected surge of 600 volts on the power input to the cabinets would not propagate and damage the CET cables in the IITA, the cabinets were surge tested in accordance with IEC 61000-4-5, Electromagnetic compatibility (EMC) - Part 4-5: Testing and Measurement Techniques - Surge Immunity Test, 1995.

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Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N (h) The cables for the CETs separate from the FID cables at the seal table. The CETs are connected directly to the Common Q PAMS cabinet. The FIDs are connected directly to the in-containment signal processing system cabinets.

(i) Attachment 5 is the proprietary section 2 Equipment Description of NO-WBT-002, Westinghouse Incore Information Surveillance & Engineering (WINCISE')

System Technical Manual. This is strictly a proprietary document and a non-proprietary version will not be submitted. An affidavit for withholding will be submitted within two weeks of receipt from Westinghouse.

(j) Attachment 6 is the proprietary WINCISE FMEA. A non-proprietary version and affidavit for withholding will be provided within two weeks of receipt from Westinghouse.

Westinghouse is available to discuss any specific questions on the methodology and hardware used in the Watts Bar Unit 2 IIS that the NRC believes are not well defined in the documents listed above.

361 7.7.1. Was the Foxboro IA system developed under a 10 CFR 50 Foxboro I/A is a non-safety related system. Therefore, 10 32. Open Open-NRC Review 1 EICB Appendix B compliant program? CFR 50 Appendix B is not applicable. Due 4/15/11 (Carte) 362 7.6.1 7.6.7 OI #331 requested TVA to provide information regarding how the TVA committed to provide a letter on the docket (targeted is 2. Open-TVA Open-Loose Parts Monitoring System (LPMS) in-containment for 4/30/2011) stating why the the in-containment equipment TVA/Bechtel/NRC components (e.g., Accelerometer ( including the integral insulated has been qualified for vibration per RG 1.133, Rev. 1. NRC Update (WEK)--On March 27, Review of Partial hardline cable), Softline cable, and Remote Charge Preamplifiers) 2011 TVA provided a document Response.

were qualified for vibration as addressed in regulatory position (1) Attachment 4 contains Westinghouse document WBT WBT-D-2782 in response to this C.1.g of RG 1.133, Rev. 1. TVA responded by stating that TVA DMIMS-DX' Seismic Evaluation of the Digital Metal OI. This document provides the in-has reviewed the information provided by Westinghouse describing Impact Monitoring System (DMIMS-DX') for Watts Bar containment LPMS equipment how the Loose Part Monitoring System (LPMS) sensor is qualified Unit 2, EQ-QR-33-WBT, Revision 0 (proprietary). The qualification specification(s) and for normal operating conditions provided in Westinghouse letter non-proprietary version and affidavit for withholding will indicates that the normal WBT-D-2782, dated December 17, 2010 (Reference 11) as be submitted within two weeks of receipt from environmental conditions for a addressed in regulatory position C.1.g of Reg. Guide 1.133 and Westinghouse. Westinghouse containment are found it acceptable. Vibration qualification is not applicable to the reported in Tables 6-1 and 6-2 from EICB ( Kemper & Singh) softline cable. Due to the installation location (junction boxes Attachment 5 contains Westinghouse non-proprietary WCAP 8587 Rev. 6, "Methodology mounted to the shield or fan room walls) and previous seismic white paper WBT-D-2782, Westinghouse DMIMS-DX for Qualifying Westinghouse WRD qualification, vibration qualification of the charge In-Containment equipment environmental specifications Supplied NSSS Safety Related converter/preamplifier is not required. This completes the Electrical Equipment". These tables response to this item. EQ-EV-71-WBT-P, Revision 1, Environmental are attached.

Evaluation and Operating History of the Westinghouse The EQ specifications are included However, the staff still desires further clarification on this DMIMS-DX Preamplifier and Softline Cable Used at in the document, however, the response. Specifically, please provide a documented basis that Watts Bar 2 dated February 2011 was submitted on documented basis that demonstrates the LPMS in-containment equipment is qualified for TVA to NRC letter dated Februay 25, 2011 (Reference demonstrates the in-containment normal operating conditions (e.g., test results compared to the 4). equipment has been successfully equipment qualification specification), including vibration tested to meet or exceed its EQ qualification. Also, provide justification for why vibration While no specific vibration testing of the accelerometers specification is not included.

qualification if the Remote Charge Preamplifier is not required. was performed, Westinghouse has over 40 years Please include the in-experience in loose parts monitoring technologies. Since containment EQ test results.

1970, Westinghouse has installed over 40 metal impact monitoring systems, many of which use the same in- 5/5/2011 Update (WEK): TVA containment equipment that has been supplied to Watts committed to provide an Bar Unit 2. Table 1 lists a selection of plants in which a analysis, tests, of combined

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Loose Parts Monitoring System is installed using the analysis and tests for the LPMS same accelerometers as those for Watts Bar Unit 2 in-containment equipment demonstrating the long term operability of the subject to vibration.

accelerometers in environments similar to Watts Bar Unit 2.

(2) The Remote Charge Preamplifiers are mounted in junction boxes inside containment. The junction boxes are hard mounted either to the crane wall or to a fan room wall. The crane wall and fan room walls are subject to any significant vibration during normal operation.

TVA Partial Response to NRC Request Attachment 1 contains Westinghouse non-proprietary document EQ-QR-79, Revision 0, Summary Test Report Vibration Testing of the Westinghouse Digital Metal Impact Monitoring System (DMIMS-DX) In-Containment Sensor and Integral Hardline Cable 5357C52G01, dated May 2011.

363 7.5.1. 7.5.2 OI#199 requested TVA to provide information concerning how TVA TVA Procedure SPP-2.6 Computer Software Control has 33. Due 4/30/11 Open-NRC Review 1.3 plans to meet regulatory criteria for Quality (10 CFR 50.55a(a)(1)) been superseded by TVA Procedure NPG-SPP-12.7, and associated with the Technical Support Center and Nuclear Data Computer Software Control, Revision 0, dated December 7.9.1 Link. TVA responded in Letter Dated October 5, 2010, Item 63; 17, 2010 (Attachment 3).

however, TVAs response does not address the quality aspects of these system features. A similar question had been asked for To ensure quality, the design, testing, and inspection of all Quality Criteria adherence for the SPDS and the BISI functions of Integrated Computer System (ICS) software including a) the Integrated Computer System. In response to that request SPDS, b) BISI and c) Technical Support Center (TSC) and (same letter) TVA provided a description of TVA procedures, BISI Nuclear Data Link (NDL) functionality is controlled by software development procedures, and various management qualified personnel in accordance with TVA procedure NPG-measures that will be taken to assure high quality in the design, SPP-12.7. The TSC and NDL functions are provided and operation, and maintenance of the SPDS and BISI functions of the performed by the ICS and, in the case of NDL, the Central ICS. Since the TSC and Nuclear Data Link information originates Emergency Control Center (CECC) computers in in the SPDS function of the ICS, are there any aspects of the Chattanooga.

quality measures that apply to the TSC and NDL features developed as part of quality processes for the ICS that are Any changes to ICS software must be documented and EICB (Rahn and Mossman) applicable to the data communications features? controlled using TVA procedure NPG-SPP-12.7. This includes the a) SPDS, b) BISI and c) TSC and NDL Specifically, what is the scope of TVA Procedure SPP-2.6 functions. The procedure details controls and processes Computer Software Control? How does it apply to the ICS required for the development, modification, and configuration functions of a) SPDS, b) BISI, and c) TSC and NDL functions? management of computer software used to support the Wouldnt there be aspects of the quality procedures that apply to design, operation, modification, and maintenance of TVAs the development, maintenance, and operations of the software nuclear power plants consistent with the Nuclear Quality needed to support the data communications features. Also, what Assurance Plan.

quality measures will be applied to develop, maintain, and operate the hardware that accomplishes the TSC and NDL functions to Controls in NPG-SPP-12.7 guide the development and ensure that these features will be reliable and available when testing of the software changes. Other controls established needed? by this procedure to further maintain quality standards are:

The application custodian implements controls to prevent unauthorized changes to the software.

Changes are made in a non-production environment, and validation testing takes place before the change is installed on the ICS when possible.

Once validation testing begins, the source code is placed under configuration control.

When the modifications are installed on the ICS, an operability test is performed to demonstrate that the software is installed correctly and is functioning correctly in its operating environment.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Documentation related to ICS software changes are QA records.

The software source code is kept in a physically secure, environmentally controlled space to prevent inadvertent changes.

Cyber security considerations are also considered in the storage environment.

The data goes through several validation steps before being presented to the operators.

When redundant sensors are used, the data received by the computer can be processed by software to determine if the quality of one or more points is questionable.

The hardware involved in the TSC and NDL functionality is verified to be operable on a periodic basis.

In the case of the NDL functionality, the ICS transmits the required data to the CECC on a continuous basis. The CECC monitors the status of the ICS data communications and alarms are generated when the link is not active. The Emergency Plan (EP) staff conducts a quarterly test that verifies that NDL data is successfully transmitted from each unit to the NRC.

364 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an TVA Partial Response to NRC Request 1. N Open Open-TVA/WEC/NRC NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff Due 5/15/11 Review of Partial 81.

position. 2. Table 7.1-1 will be updated to reference IEEE Std 603- Response 1991 for the Common Q PAMS.

By letter dated 2/25/11 (ML110620219), TVA docketed a response:

TVA performed an analysis and concluded that the Common Q TVA has reviewed the requirements of IEEE Std 603-PAMS equipment does not need to meet either IEEE 279-1971 or 1991 for the Sorrento Containment High Range IEEE 603-1991 and so no analysis was performed or provided. Radiation Monitors and determined that IEEE Std 603-1991 is not applicable. IEEE 603-1991 is applicable to However, SRP (NUREG-0800 Rev. 2 dated March 2007) Section actuation systems. While TVA lists the containment 7.7, Information System Important to Safety, specifically identifies high range radiation monitors as RG 1.97 Revision 2 IEEE Std 603-1991 as being applicable to accident monitoring Typa A variables, the classification is not based on the instrumentation. Based upon the review of this item, the staff finds RG 1.97 requirements which states:

the following open items:

1 TVA to demonstrate that the Common Q PAMS meets the Type A, those variables that provide primary EICB (Carte) applicable regulatory requirements in IEEE Std 603-1991. information needed to permit the control room operating 2 TVA to updated FSAR (Amendment 103) Table 7.1-1 to personnel to take the specified manually controlled reference IEEE Std 603-1991 for WBN2 Common Q PAMS actions for which no automatic control is provided and and Sorento Containment High Radiation Monitors. that are required for safety systems to accomplish their safety functions for design basis accident event.

TVA calculation WBN0SG4047, PAM Type "A NNC 5/4/2011: Please explain why the Variables Determination uses a broader definition. TVA calculation WBN0SG4047, PAM The calculation definition is: Type "A Variables Determination uses a broader definition for Type A The type "A variables will be divided into three groups variables than is in the FSAR based on the parameter's purpose. The groups are: (1) (Amendment 103). Why is this event identification, (2) event recovery to plant definition not in the FSAR?

stabilization, and (3) maintaining the stabilized conditions from event recovery to hot standby.

Following a reactor trip, the termination point for transients at WBNP is considered a stabilized condition at hot standby per chapter 15 of the WBN FSAR. Event recovery actions are those manual actions taken to

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N mitigate a design basis accident to a stabilized condition. The plant can be considered stabilized when the plant parameters vary slowly and automatic systems are not being initiated. The diagnostic process consciously performed by the operator via the plant variables to interpret an event indication will be considered as a safety-related operator action regardless of the lack of manual manipulation of equipment. This diagnostic process is necessary to enable the operator to distinguish the "type" of transient and take the correct mitigating actions.

A review of TVA calculation WBN0SG4047 and the associated Emergency Instructions found that there are NNC 5/4/2011: Will the FSAR no operator actions that are meet the RG 1.97 Revision (Amaendment 103) Table 7.5-2 Var No.

2 definition for a Type A variable which are based on 4, Contaimnment Radiation be the containment high range radiation monitors. Based updated to change the variable type on this review, IEEE 603 is not applicable to the designation? Will this variable still be containment high range radiation monitors. Qualification Category No. 1?

365 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an The Common Q PAMS panel internals meets the 34. Y Open Open-NRC Review NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff requirements of Regulatory Guide of 1.75 and IEEE Std 384 Due 5/15/11 81.

position. 1992. The external Common Q PAMs cables are routed as 1E, 10 CFR 50.49, trained cables in accordance with Watts By letter dated 2/25/11 (ML110620219), TVA docketed a response: Bar Design Criteria WB-DC-30-4, which is not in that WBN2 is not committed in complying with Reg. Guide conformance with Regulatory Guide 1.75 Revision 3 or IEEE 1.75Since WBN2 is not committed to RG 1.75 or IEEE-384, no Std 384-1992.

comparison is required As noted in WBN Unit 2 FSAR section 8.1.5.3 Compliance However, WBN2 is committed to RG 1.75 Rev. 2, Physical to Regulatory Guides and IEEE Standards note 2 Independence of Electric Systems. RG 1.75 Rev. 3 and IEEE Std. Regulatory Guide 1.75 was issued after the Watts Bar EICB (Carte) 384-1992 are used, in part, to address IEEE Std 603-1991 Clause design was complete. Separations criteria for WBNP are 5.6.1. The current NRC staff position for RG 1.75 is documented in given in Section 8.3.1.4.2.

Rev. 3. Based upon the review of this item, the staff finds the following open item: FSAR section 8.3.1.4.2 provides a detailed discussion of the 1 TVA to updated FSAR (Amendment 103) Table 7.1-1 to WBN Unit 2 separation requirements and compensatory include RG 1.75 Rev. 3 for WBN2 Common Q PAMS and the actions. To ensure that non-1E cables do not degrade 1E Sorento Containment High Radiation monitor. cables, non-1E routed in a Class 1 structures are evaluated to ensure that they are adequately protected to prevent The Common Q PAMS was designed to meet the requirements of propagation of damage from the non 1E cables to 1E cables.

RG 1.75 Rev. 2. WBN2 did not perform an analysis to RG 1.75 Rev. 3. Based upon the review of this item, the staff finds the The NRC reviewed TVAs separation criteria as following open item: supplemented by a breaker testing program in SSER 16 and 2 TVA to evaluate Common Q PAMS and the Sorento found it to be acceptable. The same criteria and breaker Containment High Radiation monitor for conformance with RG testing program are applicable to WBN Unit 2.

1.75 Rev. 3.

366 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an The Common Q PAMS and RM-1000 radiation monitors 35. Y Open Open-NRC Review NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff comply with IEEE 344-2004 and with Reg. Guide 1.100 Due 5/15/11 81.

position. Revision 3 with the exception of testing above 30Hz. Table 7.1-1 will be updated to reflect conformance.

By letter dated 2/25/11 (ML110620219), TVA docketed a response:

EICB (Carte)

TVA stated that the Common Q PAMS equipment fully meets the RG 1.100 Rev. 0 and is compliant with Rev. 3, with exception of testing above 33 Hz, which is not applicable to Watts Bar.

The WBN2 FSAR (Amendment 103) references Regulatory Guide 1.100 Rev. 1 Seismic Qualification of Electrical Equipment for Nuclear Power Plants. The Common Q PAMS was designed to meet the requirements of RG 1.100 Rev. 2. RG 1.100 Rev. 3 is the

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N current revision of this guide and is endorsed by the NRC. RG 1.100 Rev. 3 endorses IEEE 344-2004.

Based upon the review of this item, the staff finds the following open item:

1 TVA to updated FSAR (Amendment 103) Table 7.1-1 to include RG 1.100 Rev. 3 for WBN2 Common Q PAMS and the Sorento Containment High Radiation monitor.

or 2 TVA to evaluate Common Q PAMS for conformance with RG 1.100 Rev. 1.

367 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an Common Q PAMS complies with Regulatory Guide 1.153 36. Y Open Open-NRC Review NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff Revision 1. The response in Attachment 4 to TVA to NRC Due 5/15/11 81.

position. letter dated February 25, 2011 (Reference 3) was in error.

By letter dated 2/25/11 (ML110620219), TVA docketed a response.

The WBN2 FSAR (Amendment 103) references RG 1.153 Rev. 0, Criteria for Safety Systems. The Common Q PAMS is designed to meet the requirements of RG 1.153 Rev. 1. By letter dated February 25, 2010 (ML110620219), TVA stated:

The subject Regulatory Guides [RG 1.153 Rev. 0 & 1]

endorse and reference other standards. Common Q PAMS has been evaluated to comply with the requirements of these EICB (Carte) other endorsed standards ([Comparison report in this letter titled IEEE-279-1971 to IEEE-603-1991 Comparison]).

Therefore no additional analysis needs to be performed and no further action is necessary.

However, the Comparison report in this letter titled IEEE-279-1971 to IEEE-603-1991 Comparison, stated:

The first of the two standards, IEEE-279, is part of the design basis of WBN2 but is not relevant to Common Q PAMS. The second standard, IEEE-603-1991 is not part of the design basis for the Common Q PAMS forWBN2.

Based on the reasoning quoted above, WBN2 did not evaluate the Common Q PAMS against the criteria of RG 1.153 Rev. 1; therefore, the staff finds the following open item (see also Open Items No. 1 & 2 above.):

1 TVA to evaluate Common Q PAMS for conformance with RG 1.153 Rev. 1.

368 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an Attachment 6 contains the evaluation for Common Q PAMS 37. Y Open Open-NRC Review NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff for conformance with RG 1.152 Revision 2 Due 5/15/11 81.

position.

By letter dated 2/25/11 (ML110620219), TVA docketed a response.

EICB (Carte)

The WBN2 FSAR (Amendment 103) references RG 1.152 Rev. 0, Criteria for Digital Computers in Safety Systems of Nuclear Power Plants. The Common Q PAMS was designed to meet the requirements of RG 1.152 Rev. 1. RG 1.152 Rev. 2 is the current revision of this guide and is endorsed by the NRC. By letter dated February 25, 2010 (ML110620219), TVA stated:

RG 1.152 rev 2 endorses ANSI/IEEE-ANS-7-4.3.2-2003, but also provides extra regulatory guidance concerning computer based cyber security. Since this revision was not part of the design basis of WBN2 or Common Q PAMS, the project

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N makes no commitment to the compliance of RG 1.152 rev 2.

Based upon the review of this item, the staff finds the following open item:

1 TVA to evaluate Common Q PAMS for conformance with RG 1.152 Rev. 2.

369 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an 2. N Open Open-TVA/WEC NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff Due 5/15/11 81.

position.

By letter dated 2/25/11 (ML110620219), TVA docketed a response.

The WBN2 FSAR (Amendment 103) references IEEE 7-4.3.2-1982, "IEEE Standard Criteria for Digital Computers in Safety EICB (Carte)

Systems of Nuclear Power Generating Stations" as endorsed by Regulatory Guide (RG) 1.152, "Criteria for Use of Computers in Safety Systems of Nuclear Power Plants," Revision 0 for the Eagle 21 system. The current regulatory position is documented in RG 1.152 Rev. 2 which endorses IEEE Std 7-4.3.2-2003 as an acceptable method for using digital computers to meet IEEE Std 603-1991. Based upon the review of this item, the staff finds the following open item:

1 WBN2 to updated FSAR Table 7.1-1 to reference IEEE 7-4.3.2-2003 as being applicable to WBN2 Common Q PAMS and the Sorento Containment High Radiation monitor.

370 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an TVA Partial Response to NRC Request: 3. Y Open Open-TVA/WEC/NRC NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff Due 5/15/11 Review of Partial 81.

position. Common Q PAMS is designed in accordance with Response Regulatory Guide 1.168, Revision 1, IEEE 1012-1998 and By letter dated 2/25/11 (ML110620219), TVA docketed a response. IEEE 1028-1997. These references will be added to FSAR Table 7.1-1.

The WBN2 FSAR (Amendment 103) does not reference RG 1.168, EICB (Carte)

IEEE 1012, or IEEE 1028. IEEE Std 7-4.3.2-2003 indentifies IEEE Std 1012-1998 as normative. RG 1.168 Rev. 1 endorses, with clarifications, IEEE 1012-1998. The current staff positions are documented in RG 1.168 Rev. 1, IEEE 1012-1998, and IEEE 1020-1997. Based upon the review of this item, the staff finds the following open item:

1 WBN2 to updated FSAR Table 7.1-1 to reference RG 1.168 Rev. 1, IEEE 1012-1998, and IEEE 1020-1997 as being applicable to WBN2 Common Q PAMS and the Sorento Containment High Radiation monitor.

371 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an 4. N Open Open-TVA/WEC NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff Due 5/15/11 81.

position.

By letter dated 2/25/11 (ML110620219), TVA docketed a response.

EICB (Carte)

The WBN2 FSAR (Amendment 103) does not reference Regulatory Guide 1.209, Guidelines for Environmental Qualification of Safety-Related Computer-Based Instrumentation and Control Systems in Nuclear Power Plants. Based upon the review of this item, the staff finds the following open item:

1 WBN2 to updated FSAR Table 7.1-1 to reference RG 1.209 and IEEE Std. 323-2003 as being applicable to WBN2 Common Q PAMS and the Sorento Containment High Radiation monitor.

TVA did not docket an evaluation against the criteria in RG 1.209.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Based upon the review of this item, the staff finds the following open item:

2 WBN2 to evaluate Common Q PAMS for conformance with RG 1.209 and IEEE Std. 323-2003.

372 7.5.2. 7.5 On 5/6/2010 (See Open Item No. 81) the NRC Staff requested an TVA Partial Response to NRC Request: 5. Y Open Open-TVA/WEC/NRC NNC 4/125/2011: See Open Item No.

2 evaluation of the Common Q PAMS against the current staff Due 5/15/11 Review of Partial 81.

position. 1. Attachment 7 contains the evaluation for how the Response Common Q PAMS SysRS and SRS implement the By letter dated 2/25/11 (ML110620219), TVA docketed a response. design basis requirements of IEEE 603-1991 Clause 4.

The requirements in the SysRS and SRS are not traceable back to 2. This item is the result of a request made by the NRC the design basis (e.g., IEEE Std 603-1991 Section 4) for the staff on the Watts Bar 2 PAMS project conducted at the system. The SRS does not include any documented evidence that Westinghouse facility in Warrendale, PA the week of it was ever independently reviewed in accordance with the February 28, 2011:

10CFR50 Appendix B Criterion III, Design Control. (Note: It appears that the only Common Q or WBN2 PAMS document that "For the WB N2 PAMS project, Westinghouse will was independently reviewed in accordance with 10 CFR 50 provide documentation in their Rockville MD offices Appendix B requirements is the SysRS.) demonstrating that each document requiring Based upon the review of the SysRS and SRS, the staff finds that independent review was in fact independently reviewed there is reasonable assurance that the systems fully conform to the CAPs No. 11-061-M047 will contain a commitment to applicable guidelines, except for the following open items: provided documented evidence of appropriate 1 TVA to produce an acceptable description of how the SysRS independent reviews. "

and SRS implement the design basis requirements of IEEE 603-1991 Clause 4. The referenced CAPS issue has been closed. To 2 TVA to produce a final SRS that is independently reviewed in summarize the CAPS disposition:

accordance with 10CFR50Appendix B, Criterion III Design Control, requirements. All revisions of the Watts Bar NSSS Completion Program I&C Projects Post Accident Monitoring System "System Design Specification (WNA-DS-O1 667-WBT-EICB (Carte)

PINP, Revision 0 to Revision 4)", "Software Requirements Specification (WNA-SD-00239-WBT-PINP Revision 0 to Revision 4)", "Software Design Description for the AC 160 Software (WNA-SD-00250-WBT, Revision 0 to Revision 3)", and "Software Design Description for the FPDS Software (WNA-SD-00248-WBT, Revision 0 to Revision 3)" documents have been independently reviewed (verified) per WEC 6.1. Please note that according to NSNP 3.3.3, the independent review is considered as an acceptable method of verification.

The above documents, for all revisions, include a verifier (an independent reviewer) who is a competent individual other than the document author to verify that the document is technically correct and satisfactorily meets the intended requirements.

The front page of each document lists the author, the independent reviewer (the first reviewer listed; second reviewer listed is the Project Manager verifying document's compliance to the program rules). The second page lists any contributors to the document. It is important to note that the document's independent reviewer (verifier) is NOT included within the list of contributors indicating their independence from the original work.

In summary, according to WEC 6.1 the Responsible

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Manager (also listed on the front page) must 1) approve the document for issuance, 2) ensure that the verification method and design methodology are demonstrated appropriately, and; 3) ensure that the qualifications of the originator and verifier are adequate.

The manager(s) listed on the document attests to the fact that he or she has completed these responsibilities.

Moreover, the manager has ensured that 1) the verifier is competent to perform the independent review, 2) did not perform the original work even though they may be from the same organization or group, and 3) assigned to verify that the document is technically correct and satisfactorily meets the intended requirements.

373 7.5.2. 7.5 The SDDs do not include any documented evidence that they were 1. See the response to Letter Item 4 (NRC Matrix Item 6. N Open Open-TVA/WEC 2 independently reviewed in accordance with the 10CFR50 Appendix Number 372) response to question 2. Due 5/15/11 EICB (Carte)

B Criterion III, Design Control.

Based upon the review of the SDDs, the staff the following open item:

1 TVA to produce final SDDs that are independently reviewed in accordance with 10 CFR50 Appendix B Criterion III, Design Control, requirements.

374 7.5.2. 7.5 By letter dated October 29, 2010 (ML103120711), TVA docketed a 1. The Technical Specification Changes required by 38. N Open Open-NRC Review 2 draft technical evaluation associated with an engineering design implementation of the Common Q PAMS were made in Due 5/15/11 change (ML103120712) that states the Common Q PAMS will Revision B of the Technical Specifications which were EICB (Carte) require changes in the technical specifications. The technical submitted on TVA to NRC letter dated February 2, 2010, specifications (TS) have not be received yet for review. The TS will Watts Bar Nuclear Plant (WBN) - Unit 2 -

be reviewed once they are received. Developmental Revision B of the Technical 1 Confirm/Verify Technical Specification changes associated Specifications (TS), TS Bases, Technical Requirements with Common Q PAMS are acceptable. Manual (TRM), TRM Bases; and Pressure and Temperature Limits Report (PTLR) ADAMS ascension number ML100550326 (Reference 2).

375 7.7.9 1. During the conference call held on 4/12, the staff requested TVA Partial Response to NRC Request: 7. N NRC Update (Alvarado) - Based on Open-TVA/WEC TVA to provide a description of the differences in hardware the presentation material and and/or software design and implementation of the Incore 1. System differences are described in EDCR 52321-1 discussions with TVA and WEC, we Instrumentation System instrumentation between WBN2 and Excerpts (Attachment 4 to TVA to NRC letter dated have revised the questions for this WBN1. This information was not included in the 4/15 letter. April 15, 2011 (Reference 1) pages 2 and 3, 7 through open item as follows:

When will this be provided? 9, and 60 through 113.

1. Request now identifed in item

2. The response for item g provided by TVA does not describe 2. Please see response to the following question for EQ #384.

how the regulatory requirements were met. It only listed the reports. Only the safety related portion of IITA 2. The only thing missing from this criteria and stated that it passed the test. Also, the criteria for (namely the CETs and CET cable assemblies) are response is the equipment IITA does not list criteria for environmental qualifications of safety significant and fall under the cited regulatory qualification for the MI cable, EICB (Alvarado) safety-related equipment (e.g., RG 1.29, Environmental guide. IITA, and SPS cabinet, as well Equipment Qualifications). Please provide summary test as analysis to show compliance reports. 3. Please refer to Westinghouse report DAR-ME-09-10, with IEEE-384. These requests Revision 0, Qualification Summary Report for the are now identified in Items #381,

3. Attachment 4 of the TVA letter 4/15 states that the CET and WINCISE Cable and Connector Upgrade at Watts Bar 382, 383, 385, and 387.

CET cable assembly, as well as mineral insulated cables and Unit 2 (proprietary) (TVA Document Number: 25402- 3. See comment above. These IITA connectors, are EQ and class 1E qualified. Please 011-V1A-MG00-01949-001-WBT-D-1464) (Attachment requests are now identified in provide the qualification summary test report for these 8) for qualification of the associated cable assemblies. Items #381, 382, 383, 385, and components. The non-proprietary version of DAR-ME-09-10, 387.

Revision 0, Qualification Summary Report for the 4. Request now identifed in item

4. Attachment 5 of the TVA letter 4/15 provides the hardware WINCISE Cable and Connector Upgrade at Watts Bar #380.

description for the WINCISE (WEC document NO-WBT-002). Unit 2 and the affidavit for withholding will be 5. Closed.

Does this document include a section for Software submitted within two weeks of receipt from 6. Closed Description? If so, please provide a copy. Westinghouse. 7. Closed

4. 8. Closed

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

5. Attachment 7 of the TVA letter 4/15 describes the functionality 9. This item still requires a of the IIS for Watts Bar unit 2 and the IIS used in AP-1000. The qualification report for the IITAs has not been response from TVA.

The description provided only describes the similarity for the completed. The proprietary, non-proprietary versions 10. Closed.

core exit thermocouple (CET) and the PAMS system. and the affidavit for withholding will be submitted within 11. Request now identifed in items However, this document does not describe the other two weeks of receipt from Westinghouse. #381 and 387.

components of the IIS (e.g. IITAs). Please clarify if the only 12. Closed.

similarity between Watts Bar unit 2 and AP-1000 is for the 5. There is no software description in the reference (NO- 13. Closed.

CETs and PAMS, and that there is not similar for the IITAs. WBT-002). The functionality of the software for the IIS 14. Please provide updated FMEA is described in the reference. Note that the BEACON that discusses the failure modes

6. The WCAP-12472-P-A for the BEACON system describes System software is not part of safety related portion of of the MI insulated cable - only that the system has three operational levels: on line IITA. The non-safety IIS provides input to the for the part of the system that is monitoring, tech spec monitor (TSM), and direct margin BEACON System. 1E.

monitor. For Unit 1, TVA requested approval of the Beacon 15. Closed TSM to be only used as a tech spec monitor for present 6. The IITA are composed of the CET and the self- 16. This item still requires a peaking factor limits. Please confirm that the functionality to powered neutron detectors (SPDs). The Watts Bar response from TVA.

be implemented in Unit 2 is the same than the one requested Unit 2 and AP1000 IITAs have the same function, but 17. This item still requires a and approved for unit 1. Note Attachment 5 states that the are a slightly different design. These differences are response from TVA.

Beacon servers run the Beacon TSM, but it is not clear that necessary because the Watts Bar IITAs are bottom 18. This item still requires a this is the only level operating for the IIS. mounted and the AP1000 IITAs are top mounted. response from TVA.

Additionally, the IITA are sized appropriately for Watts 19. Request now identifed in items

7. The SE for use of the Beacon System in Unit 1 states that the Bar and AP1000 because the fuel assemblies are #380 and 386.

BEACON system will be used when thermal power is greater different sizes. The Watts Bar IITA design includes 5 20. Request now identifed in item than 25% RTP. Page 129 of Attachment 4 states that the self powered neutron detectors (SPDs) of sequentially #386.

WINCISE system will be capable of performing its required increasing length, up to a maximum length of 12 feet. 21. Request now identifed in items core monitoring functions at or above 20%RTP. Please clarify The AP1000 IITA design includes 7 SPDs of #380.

what the intent is for the Beacon system in Unit 2. sequentially increasing length, up to a maximum of 14 22. Closed.

feet. 23. Closed.

8. The technical evaluation provided for the Beacon System for unit 1 states that the movable incore detectors (MIDs) are 7. Unit 2 has only been provided with the BEACON TSM used for periodic calibration of the PDMS when thermal power function.

is greater than 25% RTP. Additionally, the MIDs are used whenever the PDMS is inoperable or whenever power 8. The BEACON topical report states that BEACON distribution is below 25%. Please explain how this function PDMS will be inoperable below 25% RTP. The will be performed with the fix incore detectors and the Beacon electrical equipment operability requirements are set system for unit 2. below the core power distribution monitoring requirements to ensure that the electronics are

9. In the NRC SE for WCAP-12472-P-A for the BEACON operable when needed to support core monitoring.

system, the staff accepted this system but subject to three conditions. In the TVA submittal for use of the Beacon system 9. Periodic flux maps using the MIDs (Unit 1) have been in unit 1, TVA described how they met these conditions for replaced by continuous analysis of the permanently Unit 1. Please describe how TVA will meet these conditions installed fixed incore detectors (Unit 2). Data from for Unit 2. these fixed incore detectors will periodically be used to generate a set of calibration factors for the BEACON

10. Please clarify the following statement provided in Attachment PDMS. The following description was provided in 4, Page 25: During certain accident scenarios, it is possible response to a RAI for addendum 1 of the BEACON for the CETs to see temperatures up to 20 deg F different topical report:

from Unit 1.

The basic concepts and methodologies used for

11. Attachment 4 and 5 explained that the Mineral Insulation cable determining the detector uncertainties and limitations allows the isolation of the core exit thermocouples (1E) and are the same between a BEACON system for a typical self-powered neutron detector (non-1E) signals. Please Westinghouse plant and a plant that is using SPDs.

provide the analysis that evaluated this separation, as well as However, since the basic hardware is different, the the evaluation that show that failure of the non-1E signal wont actual uncertainties, limitations and restrictions affect the 1E signal. associated with fixed incore detectors are different from the corresponding values associated with the use of

12. Page 129 of Attachment 4 states that a minimum of three incore movable detectors. The prime purpose of the thermocouples are operable in each quadrant. Table 7.5-2 of BEACON system is to continuously measure the core the SSER (R.G. 1.97) states that 4 thermocouples should be peaking factors with high accuracy. In the standard operable in each quadrant. Please explain if TVA is deviating Westinghouse BEACON plant, the incore movable

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N from the requirements in R.G 1.97, and how this is justified. detectors provide periodic (180 EFPD) calibration input to the BEACON System with thermocouple and excore

13. Please provide information regarding the effects of a software detector readings providing data for continuous power common cause failure (SWCCF) on the IIS. distribution monitoring. The plant specific analysis used to determine the uncertainties in this

14. The FMEA provided by TVA on 4/15 has not been updated measurement are described in Section 5 of WCAP-(see email from Steve Clark on 4/11). Also, the FMEA 12742-P-A. The fixed incore detector functionality provided focus on failures during installation and replaces the functionality of the core exit commissioning and it does not identify measures for failures thermocouples, excore detector axial power shape during operation. Last, this FMEA does not address software information, and periodic incore movable detector failures, only component failures and installation failures. inputs used by the BEACON System continuous Please provide an updated and complete version of the FMEA monitoring process in Westinghouse design plants.

The fixed incore detector uncertainties are analyzed for

15. Attachment 4, TVA document Incore Instrumentation System a specific plant detector configuration using the describes the system requirements. Therefore, provide a methodology described in Section 5.0 of Addendum 1 complete system description of the IIS for the staff to evaluate to WCAP-12472-P-A.

the IIS to be installed in Watts Bar Unit 2.

Also, the description for the incore thermocouple system in Generally speaking, the more fixed incore detectors this TVA document is inconsistent with the description are installed, and the higher each detectors provided in Westinghouse WINCISE Hardware Description measurement accuracy is (smaller measurement (Attachment 5). For example, Section 1.2 of the TVA variability), the smaller the measured core power document states that there are 65 incore thermocouples and peaking factor uncertainty becomes. As described in Section 2.2.9 describes that the incore thermocouples provide response to Question 8, the SPD detector design and an input signal to the Inadequate Core Cooling Monitor. layout are different for the different NSSS vendors.

Furthermore, there are some basic differences in the

16. TVA attachment 4 of the 4/15 letter show modifications to the application of the SPD and moveable detector DBE design criteria. Please provide detailed explanation systems. These include:

about these modifications.

As plant operation continues, neutron irradiation

17. Please explain if new penetration and routing were required depletes the detector sensor material and for IIS signals. If new penetrations are required, explain how increases the measurement variability. The these were qualified. Also, explain the criteria used to route measurement variability of the incore movable the power/control cables. detectors effectively does not change during operation because the movable detector

18. Questions on Technical Specification: measurements are not present in the core for (1) The TVA package states that TS 3.1 and TS Bases 3.1 sufficiently long times to undergo any appreciable were modified due to WINCISE. Please provide detailed depletion of the detector material.

information to evaluate the modifications to the TS.

(2) The TVA mark up does not define the operating limits in Some of the fixed incore detectors may fail during the TS for the reactor power distribution. Please provide operation, which requires that the power detailed information on how the IIS may impact the Technical distribution measurement uncertainty be adjusted Specification. during plant operation. If an individual incore movable detector fails, the core locations

19. Redundancies are designed and built into the signal measured by the failed detector can be accessed processing system to avoid impacting operation in the event of using one of the other movable detectors, so no the loss of some SPD signals. The master signal processing uncertainty adjustment is required.

rack data interface card provides the output data stream to the Application server. Each cabinet master signal processor rack If an incore movable detector location access contains redundant data interface cards. Loss of one data thimble becomes blocked, then the power interface card will not result in a loss of data output from the distribution measurement uncertainty associated cabinet. Provide detailed description on how this works (e.g., with the BEACON calibration data generated from is the switchover software based?) the incore movable detector input is automatically adjusted by the BEACON System. Should the

20. The Application Servers receive information from Signal thimble become usable at a later time, BEACON Processing System (SPS Cabinets), Integrated Computer automatically adjusts to this situation. If a FID System (ICS), and BEACON. The WINCISE IP Switches string cannot be inserted into the thimble during provide the main hub for traffic flow from the SPS cabinets, the refueling, the entire string is left out of the core BEACON servers, Application Servers, and ICS. Provide and the uncertainty is adjusted accordingly for the detailed description of the communication among the

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Integrated Computer System (ICS) and the Beacon System entire cycle.

and the Wincises Application servers.

The BEACON power distribution uncertainty

21. Attachment 4, TVA document Incore Instrumentation System methodology is designed to determining the power describes that the WINCISE system includes a Domain peaking factor measurement uncertainty for a wide server, which provides a supportive function and is not range of the SPD detector operating conditions. The required for the PDMS to receive needed information from the measure peaking factor uncertainty is defined as a Application Server. However, the domain server provides an function of the fraction of inoperable detectors and the environment for the development and maintenance of detector measurement variability as given by Equation application and system software. Please explain how this 3 and Equation 4 of Addendum 1 to WCAP-12472-P-A.

domain server will be configured and used for WINCISE in The methodology of the power peaking factor WBN2. Note that the domain server is not part of the uncertainty determination is described in Section 5 of Westinghouse WINCISE Hardware Description (Attachment 5) Addendum 1 to WCAP-12472-P-A.

22. Page 52 of Attachment 4, question 1.5 was answered yes, but The constants, variabilities, and coefficients used in the the I&C calculation to be provided in Sections 4 and 5 is not equations described in Section 5 of Addendum 1 to included. Please explain if this calculation was performed, and WCAP-12472-P-A are specific for a given reactor core if so provide a description. geometry, detector configuration, and installation layout, and can be obtained as described in Section 5.

23. Page 52 of Attachment 4, Section 6 does not include the block The equations are applicable for a wide range of diagram of the proposed modification to WBN2. Please detector conditions anticipated during the reactor provide a block diagram if the system, including power operation.

sources.

The behavior of the measured peaking factor uncertainties as a function of the incore detector variability and composite random detector loss levels are shown in Figure 4 and Figure 5 of Addendum 1 to WCAP-12472-P-A for a representative plant. It is seen that the higher the SPD measurement variability and fraction of inoperable detector are, the higher the peaking factor measurement uncertainty becomes.

In most cases, the upper bound of the SPD measurement variability and fraction will be determined for a specified peaking factor measurement uncertainty. Alternatively, the BEACON methodology can be used to support an existing or requested availability requirement for a specific plant.

10. The CETs are included in the IITA at Unit 2. This means that the Unit 2 CETs are physically located in different areas (radically and axially) than the Unit 1 thermocouples. In other words, this statement points out that a direct comparison of CET readings from Unit 1 and Unit 2 will be of little value. The Unit 2 CETs are located at the top of the active fuel inside the fuel assembly instrument thimble, instead of at the bottom of the upper core plate, so differences in temperature are to be expected between the units.

Please note that these differences have been specifically considered in the applicable post-accident monitoring procedures.

11. The attached documents provide the assessment of potential interactions between the core exit thermocouples and the self powered detectors of the AP1000 Incore Instrumentation System. Note that APP-IIS-J0R-002 (ML102390521) is a non-proprietary version of APP-IIS-J0R-001.

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N

12. To clarify, page 129 states that the WINCISE system shall support two divisions of CET with a minimum of three thermocouples provided in each core quadrant for each division. In other words, there are at least three thermocouples per train per quadrant, or a minimum of six thermocouples per quadrant.

13. The IIS software functions are non-safety-related and have no impact on any safety function. Therefore software common mode failure analysis is not required.

15. There are two design changes that impact this system description. The responsible engineers agreed that the WINCISE change package (EDCR 52321) would address everything except the CETs and that the Common Q PAMS change package (EDCR 52351) would address the changes related to the CETS. As previously committed, the Common Q PAMS EDCR 52351-B will be submitted after the package is issued.

Currently the package is scheduled to be issued May 12, 2011.

16. The changes are based on the installation of WINCISE in WBN Unit 2 as shown on page 115 of the attachment in the Revision No. 13 Description of Revision and in the Description of Change on pages 2 and 3 of the attachment.

376 7.7.9 DCI-CVIB Input: TVA does not agree with this recommendation. The IITA 8. Response on Hold based on May Open-TVA/WEC Related to OI 360 assemblies cannot be inspected for wall thinning using 12 Rockville Public Meeting ReferenceEDCR # 52321, Revision AEDCR Unit Difference internal eddy current methods as can a thimble tube. In Form --- Bechtel Document addition, after the IITAs are irradiated, inspection using external ultrasonic measurements as are done for pipe Page 2 -Maintenance Difference inspections would result in excessive personnel exposure.

While visual inspection is possible, it cannot detect wall The proposed In-Core Instrument Thimble Assemblies (IITAs) thinning.

which will replace Movable In-Core Detectable Systems (MIDs) have the following features: As documented in Westinghouse to TVA letter WBT-D-3072 WINCISE Vibration Induced Wear Calculation Conclusion, (1) IITAs are not fully extracted and they are held in a dated April 6, 2011 (Reference 8) calculation CN-PO-09-15, EICB (Alvarado) movable frame assembly. "Westinghouse Incore Information Surveillance and Engineering (WINCISE) Incore Instrument Thimble Assembly (2) IITAs exert lower vibration amplitude and therefore, aging (IITA) Vibration Analysis for Watts Bar Unit 2", M. J. Reho, degradation due to wear does not occur. September 22, 2010, demonstrates that the assemblies are not subject to vibration induced wear. Based on the above (3) Loss of reactor coolant system pressure boundary due to and the fact that the outer wall of the IITA is not a RCS breach of IITA outer sheath does not occur. pressure boundary, TVA does not agree to include an IITA inspection program in the plant maintenance program. The Question: referenced proprietary letter and calculation are available for The staff believes that the licensee should provide an review at the Westinghouse Rockville office.

inspection program to confirm that the aforementioned attributes associated with IITAs are valid and this inspection program can be a part of a routine maintenance program.

Replacement of 58 CETs for the current 65 CETs -to be addressed by the fuels division.

377 7.7.9 CB (Al 1. (a) 9. Response on Hold based on May Open-TVA/WEC Further explanation is required for the sentence in EDCR 52321 12 Rockville Public Meeting var d

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N Rev A Page 2, During certain accident scenarios, it is possible for the CETs to see temperatures up to 20 degree F different from Unit 1.

(b) Which accident scenarios the above statements refer to?

(c) Compare the accuracy for flux mapping with movable detectors (MIDS) and fixed detectors such as SPDs.

2. Explain how the linear heat generation rate is monitored using the new IITA system.

3. (a) Page 26 of the EDCR 52321-A states that certain SPS electronics cannot withstand the increased pressure during an Integrated Leak Rate Testing (ILRT). As a result, these SPS electronics need to be removed prior to starting the ILRT. If SPS electronics does not survive an ILRT, what will be their status during a design basis accident, such as, loss of coolant accident?

(b) Page 129 of EDCR 52321-A Item Number 7 CET Requirements states that The CET must be operable before, during, and after a design basis accident without loss of safety function, and for the time required to perform the safety function.

Does this CET requirement conflict with the scenario in Part (a) above, such that the malfunction of the electronics during high pressure during the design basis accident?

4. BEACON Power Distribution Monitoring System (PDMS) with WINCSE seems to be functioning different from old conventional BEACON monitoring system. Explain the differences between the new and old system and the advantages, if any, of the new system over the old one.

5. EDCR 52321-A Page 129 (WBN2-94-4003 Rev 0000 Page 18 of 41) WINCISE Requirements Sections 1 and 2 specify minimum requirements for inputs from SPDs such that the WINCISE system shall not require input from 75% (50% for Section

2) of the instrumented locations, with at least five operable SPD associated with the top half of the active core and at least five operable SPD associated with bottom half of the active core per quadrant,. Section 3 states that The WINCISE System will be capable of performing its required core monitoring functions at or above 20% RTP. Provide documents supported by analyses that will show that the incore monitoring systems and the CET system will be fully capable of performing the intended functions under the circumstances prescribed in Sections 1, 2 and 3 of WINCISE Requirements.

6. Section 6.0 of WCAP-12472-P-A Addendum 2-A stipulates that in addition to maintaining power distribution Technical Specification that require surveillance of parameters related to hot rod power and local power density, it will be necessary for the licensees to include a BEACON Operability specification in the Technical Requirements Manual (TRM) associated with either the NUREG-1430 or NUREG-1432 format TS. Are the minimum requirements (50% and 75% of the instrument locations input) and functions of WINCISE and CET systems specified in Sections 1 through 6 of WINSCISE Requirements included in the WBN-2 Technical Specifications? If the answer is no, explain why. Also,

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N please provide the agency with a copy of the Technical Requirements Manual for the WINCISE system proposed for WBN-2

7. NRC Staffs search for references listed in Section 7 of EDCR 52321-A resulted in lack of any specific reference to Westinghouse Topical Report in the EDCR 52321-A.

(a) Please specify which of the Addendums for WCAP 12472 Topical Report or any other Westinghouse TR is the basis for the planned WINCISE system to be installed at Watts Bar -2.

(b) Provide the Agency with all relevant calculations and analyses supporting the proposed WINCISE system for Watts Bar 2.

378 Make the following WEC proprietary documents available for NRC Per Westinghouse letter WBT-D-3201 (Reference 1), the 10. Due 5/24/11 Open-TVA/WEC review at the Westinghouse Rockville office: documents are available for NRC review at the Westinghouse Rockville office.

WINCISE Functional Specification for Watts Bar Unit 2, 420A90, Rev. 2 BEACON Data Processing Application Program Software Requirements Specification, WNA-DS-02196-WBT, Rev. 1 Standard Fixed In-Core Detector Data Processing (PRLQFDO.2) Function Block Specification, WNA-DS-01400-EICB (Alvarado)

GEN, Rev. 0 Standard Vanadium Detector Filter (FBM.SPDO.2) Function Block Specification, WNA-DS-O 1402-GEN, Rev. 0 lIS SPS Datalink Client Software Interface Specification, WNA-DS-02208-WBT, Rev. 1 BEACON'" Datalink Interface Specification, WNA-DS-02194-WBT, Rev. 1 ICS Datalink Interface Specification, WNA-DS-02193-WBT, Rev. 1 Watts Bar 2 Incore Instrument System (lIS) Signal Processing System (SPS) Isolation Requirements, WNA-CN-00lS7-WBT, Rev. 0 379 Provide proprietary and non-proprietary versions of the WINCISE The proprietary versions of the slides were provided in TVA 11. Due 6/17/11 Open-TVA/WEC EICB slides from the May 12 public meeting. letter to NRC dated May 20, 2011 (Reference 2).

Attachment 2 contains Westinghouse document WBT-D-(Alvarado) 3191- NP Attachment, non-proprietary version of the WINCISE slides from the May 12, 2011 public meeting.

380 Provide Non-Proprietary functional description of the WINCISE Attachment 3 contains the Westinghouse Non-Proprietary 12. Due 6/24/11 Open-TVA/WEC Application Server including discussion on redundancy for both the functional description of the WINCISE Application Server.

servers and the configuration of the Beacon A/B computers NRC Update (Alvarado) - need the EICB (Alvarado) proprietary versions of reports, such as EQ tests, EMI/RFI tests, calculations, and other documents to make a safety determination, not non-proprietary reports that reference these reports and calculations.

381 Non-Proprietary description of the qualification of the MI cable Attachment 4 contains the Westinghouse non-proprietary 13. Due 6/24/11 Open-TVA/WEC A

l v

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N assemblies with references to any EQ report (if applicable) - June description of the qualification of the mineral insulated (MI) 10th cable assemblies. NRC Update (Alvarado) - need the proprietary versions of reports, such as EQ tests, EMI/RFI tests, calculations, and other documents to make a safety determination, not non-proprietary reports that reference these reports and calculations.

382 Non-Proprietary description of the qualification of the SPS cabinet Attachment 5 contains the Westinghouse non-proprietary 14. Due 6/24/11 Open-TVA/WEC with references to EQ report(s) description of the qualification of the Signal Processing System (SPS) cabinet. NRC Update (Alvarado) - need the EICB (Alvarado) proprietary versions of reports, such as EQ tests, EMI/RFI tests, calculations, and other documents to make a safety determination, not non-proprietary reports that reference these reports and calculations.

383 Non-Proprietary description of the qualification of the IITA with Attachment 6 contains the Westinghouse non-proprietary 15. Due 6/24/11 Open-TVA/WEC references to EQ report(s) description of the qualification of the IITA.

NRC Update (Alvarado) - need the EICB (Alvarado) proprietary versions of reports, such as EQ tests, EMI/RFI tests, calculations, and other documents to make a safety determination, not non-proprietary reports that reference these reports and calculations.

384 Non-Proprietary description of the differences between Unit 1 and The only similarities between the WBN Unit 1 and Unit 2 IIS 16. Due 6/24/11 Open-TVA/WEC EICB (Alvarado)

Unit 2 core monitoring with references to Westinghouse are:

documentation.

1. They will utilize the same version of the BEACNON-TSM software

2. The BEACON-TSM software will be installed on a computer utilizing a LINUX operating system.

385 Non-Proprietary description of the calc note shown to the NRC at Attachment 7 contains Westinghouse non-proprietary 17. Due 6/24/11 Open-TVA/WEC the meeting. description of the calculation note shown to the NRC at the May 12, 2011 meeting. NRC Update (Alvarado) - need the EICB (Alvarado) proprietary versions of reports, such as EQ tests, EMI/RFI tests, calculations, and other documents to make a safety determination, not non-proprietary reports that reference these reports and calculations.

386 Provide a description of the communications between the SPS and There is no direct communication between the SPS cabinets 3. Open-TVA/Bechtel the ICS. This should include what data is transmitted to the ICS and the ICS. The SPS cabinets communicate with the and what data comes from the ICS that is used by WINCISE. Also, WINCISE Application Servers. The ICS sends data to the EICB (Alvarado) how are the requirements for safety-to-non-safety isolation WINCISE Application Servers. The ICS receives data from achieved. the BEACON Servers via the WINCISE Application Servers.

In addition to the BEACON data, the WINCISE Application Servers send system status information (SPS cabinet temperatures, etc.) to the ICS. The WINCISE Application Servers receive data from the WINCISE SPS cabinets and the ICS, package the data into a form useable by the

Agenda for Weekly Telecom with TVA (I&C Chapter 7 only) rad679AD.docx Open Items to be Resolved for SER Approval

Response

SE FSAR NRC No. Issue TVA Response(s) Acceptable Status/ Current Actions Resolution Path RAI No. & Date RAI Resp. Date Comments Sec. Sec. POC Y/N BEACON TSM software and send the data to the BEACON Servers.

The data points sent by the ICS to the WINCISE Application Servers and the data points the BEACON Servers send to the ICS are listed in Attachment 8. For simplicity, the system status data points (which include the status of each individual detector, card power supply etc.) are not included.

Since the WINCISE Application Servers, the BEACON Servers and the ICS are all non-safety-related, there is no safety-to-non-safety interface so no isolation is required.

However, there is a firewall between the ICS network and the WINCISE/BEACON network to prevent a problem on one network from impacting the other.

387 Provide a copy of the analysis which states how Westinghouse has As discussed in the Westinghouse WINCISE presentation at 4. Open-TVA/Bechtel met the Reg Guide 1.75/ IEEE-384 requirements for isolation the public meeting on May 12, 2011, the WBN Unit 2 IITA between safety and non-safety for the CETs and the SPS panels assemblies are the same in this regard to those used in the AP1000. The information on how the AP-1000 IITAs meet IEEE 384 requirements is documented in WCAP-17226-P, EICB (Alvarado)

Revision 2, Assessment of Potential Interactions between the Core Exit Thermocouple Signals and the Self-Powered Detector Signals in the AP 100 0 TM In-Core Instrumentation System, dated July, 2010 submitted to the NRC on Westinghouse to NRC letter DCP_NRC_003021 Submittal of AP 1000' Instrumentation and Control Documents to Support of the AP1000 Design Certification Amendment Application (Docket No.52-006), dated August 25, 2010 (ML102390520).

388 1.

389 2.

390 3.