ML15233A006

08/05/2015 Summary of Meeting with Pacific Gas and Electric Company to Discuss Digital Replacement of Process Protection System at Diablo Canyon Power Plant, Units 1 and 2 (TAC Nos. ME7522 and ME7523)

ML15233A006
Person / Time
Site:	Diablo Canyon
Issue date:	09/10/2015
From:	Siva Lingam Plant Licensing Branch IV
To:
Lingam S
References
TAC ME7522, TAC ME7523
Download: ML15233A006 (32)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 10, 2015 LICENSEE: Pacific Gas and Electric Company FACILITY: Diablo Canyon Power Plant, Unit Nos. 1 and 2

SUMMARY

OF AUGUST 5, 2015, TELECONFERENCE MEETING WITH PACIFIC GAS AND ELECTRIC COMPANY ON DIGITAL REPLACEMENT OF THE PROCESS PROTECTION SYSTEM PORTION OF THE REACTOR TRIP SYSTEM AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEM AT DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 (TAC NOS. ME7522 AND ME7523)

On August 5, 2015, a Category 1 teleconference public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Pacific Gas and Electric Company (PG&E, the licensee) at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of the teleconference meeting was to discuss the license amendment request (LAR) submitted by PG&E on October 26, 2011, for the Digital Replacement of the Process Protection System Portion of the Reactor Trip System and Engineered Safety Features Actuation System at Diablo Canyon Power Plant, Unit Nos. 1 and 2 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML113070457). The meeting notice and agenda dated July 21, 2015, are available at ADAMS Accession No. ML15202A083. A list of attendees is provided in Enclosure 1.

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

Highlights from this meeting include the following:

• NRC audit regarding this LAR was conducted from June 22-26, 2015, at the Westinghouse facility.

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

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

• The NRC staff is planning to go to Advisory Committee on Reactor Safeguards (ACRS) subcommittee with a draft safety evaluation during November 2015.

• The NRC staff and the licensee agreed to tentatively schedule the next periodic meeting on September 23, 2015.

Two members of the public were in attendance for the teleconference meeting and had no comments. Further, no public meeting feedback forms were submitted.

Please direct any inquiries to me at 301-415-1564 or at Siva.Lingam@nrc.gov.

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Siva P. Lingam, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosures:

1. List of Attendees

2. Staff Identified Issues That are Open

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

LIST OF ATTENDEES AUGUST 5, 2015, TELECONFERENCE MEETING WITH PACIFIC GAS AND ELECTRIC COMPANY DIGITAL UPGRADE FOR DIABLO CANYON POWER PLANT. UNIT NOS. 1AND2 DOCKET NOS. 50-275 AND 50-323 NAME ORGANIZATION K. Schrader Pacific Gas and Electric A. Wilson Pacific Gas and Electric L. Williams Pacific Gas and Electric K. Singh Pacific Gas and Electric K. Durinsky Westinghouse A. Breneman Westinghouse T. Tuite Westinghouse R. Stattel Nuclear Regulatory Commission (NRC)

S. Darbali NRC S. Lingam NRC G.Adams Southwest Research Institute (SwRI)

D. Pomerening SwRI E. Domes SwRI G. Clefton Nuclear Energy Institute M. Lewis Public Member D. Gilmore Public Member Enclosure 1

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

August 20, 2015A11m1~t Fi ~01 Fi DCPP PPS Open Item Summary Table Page 1 of 22

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No Src/RI Issue Description P&GE response: Status RA/No. RA/ Comments (Date Sent) Response (Due Date) 101 RJS Phase 2 Environmental Qualification Documentation: Open RAI 61 4/30/14 7/2/2015 During the second ALS audit, Per ISG 6 Section D.5.1, the NRC staff needs to review the information PG&E asked that we consider provided to determine if the PPS equipment has been demonstrated to be deferral of the able to operate within the specified environment. In order to do this the seismic evaluation staff needs to environmental data for the plant and specifically for the cable until after the SE is spreading room. The ISG 6 matrix (item 2.12) states that this information completed has been provided in the two vendor topical reports; however, these reports do not contain any plant specific data. 12/12/14 Hold OPEN until final qualification The NRC requires plant specific environmental condition data for normal documents are operating conditions and the worst conditions expected during abnormal received.

and accident conditions where the PPS equipment is expected to perform its safety function. 12/11/13- RJS Seismic Reports posted on

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

plant specific

• Seismic data for the Diablo Canyon QBE and SSE information earthquakes including frequencies and acceleration values. including ping tests

• EMI I RFI data for areas where PPS equipment is to be of PPS cabinets is installed. still needed for evaluation.

The FRS section does specify the ranges of temp and humidity but for 11/1/13 - RJS seismic environment, it refers to documents DCM C-17, DCM C-25, DCM Waiting for C-30, DCM C-28, and DCM T-10. additional testing to be completed.

Note: The required information may also be contained in the UFSAR. The staff is reviewing design basis information in the UFSAR, however specific environmental 6/26/2013: during conditions applicable to the PPS equipment remain unclear to the staff. this call the following 3/28/14 Update: clarifications were In-Equipment Response Spectra (IERS): In the seismic test report, it is provided:

stated the IERS spectra will change as a result of the equipment

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- . fi DCPP PPS Open Item Summary Table Page 2 of 22 No Src/RI Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response (Due Date) modifications. So far, the evaluation is based on comparing the ALS and - Describe specific Tricon test data (TRS) with the RRS derived from the 140' elevation conditions for the spectra provided in DCM No. C-25. I think that these RRS spectra will be room where the system will be conservative in comparison to the IERS but I will need to confirm this once installed.

I see the revised IERS. - Is there any restrictive requirement for this room?

Electromagnetic Comgatibilit~ - What is the Was the plant-specific electromagnetic environment confirmed to be similar relationship between the to that identified in EPRI TR-102323?

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

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

3/28/14 Update:

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

Based on the following criteria:

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

Section 7.6.3.1.1 O that it can be shown by a resonance search that no

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Fi ::>01fi DCPP PPS Open Item Summary Table Page 3 of 22 No Src/RI Issue Description P&GE response: Status RA/No. RA/ Comments (Date Sent) Response (Due Date) resonance response phenomena exist below 5Hz, it is required to envelop the RRS only down to 3.5 Hz. Excitation must continue to be maintained in the 1 Hz to 3.5 Hz range to the capability of the test facility.

3) According to Draft NTS Report No TR62987-07N-SEI, Revision O (Reference 8.9 of Draft TR ICON v1 O Nuclear Qualification Project ,

Seismic Test Report 9600164-526, Date 04/13/07) Section 6.8, Resonance Survey Results shows that the ETP or Chassis has no resonance occurred below 40 Hz. The TRS did not envelop RRS below 3 .

Hz meet the above IEEE 344-1975 as well as IEEE 344-1987 criteria.

Therefore, Tricon seismic test response are acceptable.

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

The PCS racks are identical to the PPS racks and are in the same location/elevation. Since there are no natural frequencies below 5Hz, you

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only need to envelop down to 3.5Hz. The resonance survey showed that the natural frequencies were all greater than 40Hz. So the TRS below 3.5Hz does not matter.

Response to follow-up questions:

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

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

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DCPP PPS Open Item Summary Table Page 4 of 22 No Src/RI Issue Description P&GE response: Status RA/No. RA/ Comments (Date Sent) Response (Due Date)

• Also, the EQLR-2248 document is specific to the ALS, so will there be a similar seismic test report for the Tricon?

Yes, Tricon has seismic test report for ETP and chassis per IEEE 344.

• Will there be a different set of IERS for ALS and Tricon or can the same set of spectra be applied to both subsystems?

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

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

8/5/15 PG&E will 12erform shake tests of the cabinets with egui12ment installed to address this 012en Item. The schedule for tests and re12ort are being develo12ed.

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

the DCPP FRS. These requirements include the EMC requirements from Section 3.1.6 of the FRS which states: "the PPS shall be qualified by test, 4/16/14 - RAI will analysis, or a combination thereof, to function without fault or error in an be required.

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

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DCPP PPS Open Item Summary Table Page 5 of 22 No Src/RI Issue Description P&GE response: Status RA/No. RA/ Comments (Date Sent) Response (Due Date)

In contrast to this, the Tricon V1 O safety evaluation determined that the Tricon V1 O PLC system did not fully meet the guidance of RG 1.180, Revision 1, for conducted or radiated emissions or susceptibility. As a result, the SE states: "before using the Tricon V1 O system equipment in SR systems in a nuclear power plant, licensees must determine that the plant-specific EMI requirements are enveloped by the capabilities of the Tricon V1 O system as approved in this SE."

To complete its safety evaluation, the NRC requires the licensee to provide documentation to show the DCPP specific EMI requirements to be enveloped by the Tricon V10 test levels achieved and documented in the Tricon V1 O safety evaluation.

PG&E Response: AEIElitieRal eleetFema§Retie eR>rirnRmeRt testiR§ Ras 13eeR 13eFfeFmeEI feF tl:le +FiGeR tl:lat im13Fe1Je meetiR§ tl:le ~G ~. ~ BQ §l::liElaRGe.

IRfeFmatieR eR tl:le aEIElitieRal testiR§ aREI e1Jal1::1atieR te tl:le PG&~

req1::1iFomeRts *.viii 13e s1::18mittoEI. DetmmiRatieR et tl:lo s1::18mittal Elate is iR J3F9§Fess. The PG&E Functional Reguirements Sgecification (FRS}

(Section 3.1.6.2} reguires the PPS Eguigment to be EMl/RFI gualified in accordance with the guidance in Reg Guide 1.180.

The Triconex EMl/RFI test regort 9600164-527 concluded that the TRICON unit under test comglied with the allowable emissions and suscegtibility levels reguired by RG 1.180 with the excegtion of allowable conducted emissions level (MIL-STD-461 E., CE101 and CE102} for low and high freguency conducted emissions on the 120 VAC chassis gower suggly line.

In section 7.2.2 of the Triconex test regort, documentation is included for a final CE102 (high freguency} test gerformed with a Corcom Model 30VSK6 line filter installed. With the line filter installed the MIL-STD-461-E, CE102 conducted emissions were accegtable. Therefore, PG&E is including a

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DCPP PPS Open Item Summary Table Page 6 of 22 No Src/RI Issue Description P&GE response: Status RA/No. RA/ Comments (Date Sent) Response (Due Date)

Corcom Model 30VSK6 line filter on the in12ut of the 120 VAC 12ower su1212ly. With use of the Corcom Model 30VSK6 line filter on the in12ut of the 120 VAC 12ower su1212ly 1 the high freguency conducted emissions meets the guidance of RG 1.180.

RG 1.180 12rovides an exem12tion from CE101 testing if: 1) the 12ower guality reguirements of the egui12ment are consistent with the existing 12ower su1212ly and design 12ractices include 12ower guality controls and, 2) the new egui12ment will not im12ose additional harmonic distortion on the 12ower distribution system exceeding 5% total harmonic distortion or other 12ower guality criteria established with a valid technical basis. The 120 VAC 12ower to the Tricon is to be su1212lied by Class 1 E vital instrument 12ower with a1212ro12riate guality reguirements and design 12ractices in 12lace. Based on testing 12erformed for another similar a1212lication (safety-related auxilia!Y building and fuel handling ventilation control system) at Diablo Canyon, no a1212reciable difference in the harmonic distortion of the instrument AC system was observed before and after the 12ower SUQQlies were installed. Therefore, the RG 1.180 criteria for exem12tion from CE101 testing are met for the PPS Re12lacement Tricon egui12ment.

119 sd (Audit Item) IOM is using laptops, one per Protection Set plus one backup, Close RAI 72 3/19/15 Hold in 01 each with TriStation 1131 installed, to develop the V1 O Tricon protection list until RAI is sent.

set application code for the DCPP PPS Replacement project. PG&E bought these 5 development laptops and IOM will be delivering them to PG&E as part of the Tricon product delivery. However, during the Invensys audit on June 3-5, 2014, PG&E informed the staff that it does not plan to use these laptops, and only plans use the TriStation installed on the MWS's. Please clarify what PG&E will do with the 5 development laptops once they are delivered to them. Also, please clarify what controls will be placed on the TriStation software installed on these laptop computers.

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- DCPP PPS Open Item Summary Table Page 7 of 22 No Src/RI Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response (Due Date)

PG&E Response: The PG&E laptops provided for development for the V10 Tricon were not designated as safety related and will not be used by PG&E in the future because they are obsolete.

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

The ALS topical report addendum identifies changes in Category 4 as those modifications that are applicable to the approved ALS topical report. 12/10/14 - The ALS Please describe how these changes affect the DC PPS replacement, in addendum is being particular description and functionality of the Halt mode. withdrawn.

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

Therefore, a RAI is necessary.

135 RA ALS Project Organization 3/1 /15: A new

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

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2015 DCPP PPS Open Item Summary Table Page 8 of 22 No Src/RI Issue Description P&GE response: Status RA/No. RA/ Comments (Date Sent) Response (Due Date) 136 RA ALS Management Plan 3/1 /15: A new Gf3eR revision of the The Management Plan (6116-00000, Rev. 6), Section 4.1.2, states ALS close Management Plan personnel required support from Global Instrumentation and Control will address this Production (GICP) to complete the project. Can you please provide information about the support provided by G ICP?

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

137 RA ALS Management Plan 3/1 /15: A new Gf3eR revision of the The Management Plan (6116-00000, Rev. 6), Section 6.16, describes NA close Management Plan 4.51 "Fiel Programmable Gate Array Development Procedure" as the will address this procedure used for software development. Can you please provide a copy of this procedure in the Sharepoint?

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

138 RA ALS Configuration Management Plan Gf3eR 3/1 /15: A new revision of the The Management Plan (6002-00002, Rev. 10), Sections 1.2.5 and 2.1, close Management Plan states the ALS Project Management Plan will identify the configuration andthe management organizational structure. However, the ALS Project Configuration Management Plan does not provide this information. Furthermore, Section Management Plan 2.2 of the Configuration Management Plan describes allocation for will address this.

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

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

August 20, 2015A11m1F>t

,., fi. ::>01 fi DCPP PPS Open Item Summary Table Page 9 of 22 No Src/RI Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response (Due Date) 140 RA ALS Configuration Management Plan Gf3eR 3/1 /15: A new revision of the Section 3.1.1 refers to a Document Index (DI). This document is not close Configuration identified or described in the ALS Management Plan. Please describe how Management Plan the DI is used in conjunction with the configuration items and the will address this Configuration Status Accounting. This is SE reference 72 PG&E Response: This will be addressed by an update to 6116-00000 (new Revision 7) that will contain an updated Section to address the project specific portions of the ALS Configuration Management Plan (6002-00002). .~.'

141 RA ALS Configuration Management Plan Gf3eR 3/1/15: A new" close revision of thet

Section 3.2.5 described the use of REC to manage requirement changes to Configuration.\

Cls. Please explain the relationship of the REC and the OnTime ticket Management Plan process. will address this, PG&E Response: This will be addressed by an update to 6116-00000 (new This is SE reference 72 . *

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Revision 7) that will contain an updated Section to address the project specific portions of the ALS Configuration Management Plan (6002-00002).

142 RA ALS Configuration Management Plan Gf3eR 3/1 /15: A new revision of the Section 3.2.5 states that the control points for release of Level A, B and C close Cont ig u ration are described in Section 3.2.2, but the section referenced does not provide Management Plan that information. Please clarify when these points are released will address this.

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

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Page 10 of 22 No Src/RI Issue Description P&GE response: Status RA/No. RAJ Comments (Date Sent) Response (Due Date) 143 RA ALS Configuration Management Plan GJ3eR 3/1 /15: A new close revision of the Section 3.6 describes control of subcontractors and vendors. This section Configuration refers to the ALS management plan for further description of integration Management Plan and sightseeing of activities conducted by subcontractors and vendors. will address this.

However, the Management Plan does not provide any information about This is SE control of subcontractors and vendors. reference 72

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Furthermore, Section 4.1.2 identifies Global Instrumentation and Control Production as a provider for this project. This section does not describe how WEC will manage and integrate the work performed by GICP.

Please provide this information.

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

144 Rjs/ga Environmental qualification: EMl/RFI Open Added 01 on 3/18/15 Clarify if CD-ER 993754-30 demonstrates Triconex components comply with RG 1.180 conducted emissions levels for CE101 and CE102 testing.

Basis:

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

PG&E Response: In progress.

Aug_ust 20, 2015"11r111~t F. ?01.S DCPP PPS Open Item Summary Table Page 11 of 22 No Src/RI I Issue Description P&GE response: Status I RA/ No. I RA/ Comments (Date Sent) Response (Due Date) 145 RA Remaining Document Submittals 7/10/1 - Added new documents identified during Next Supplement: (to include) second ALS audit to be docketed.

• Removal of Printers from system

• Response to ALS ASAl's DCL-15-072 Is being processed in

• T.S. Implementation Commitment byNRC 6/16/15 Added PG&E Documents: 6116-00204 EQ DCPP Seismic Calculation I IERS (See 01101) (Ref. 166 no docket) Evaluation to list.

Interface Requirements Specification (Current docketed revision is 7) (Reference 67) Added 01 on 3/18/15 Functional Requirements Specification (Current docketed revision is 7) (Reference 68)

Controller Transfer Functions Design Input Specification (Current docketed revision is 1) (Reference 208)

PG&E Failure Modes and Effects Analysis (FMEA) (No reference yet)

Licensee Scope Requirements Traceability Matrix (ATM) (No reference yet)

ALS Documents:

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

6116-10020, "Diablo Canyon PPS Software Safety Plan" (Ref. 182) 6116-00003, "Diablo Canyon PPS VV Plan" (Ref. 91) 6116-00000, "Diablo Canyon Management Plan" (Ref. 72) 6116-00005, "Diablo Canyon PPS System Test Plan" (Ref. 93) 6116 70140, "PPS /\LS Test Design SpeGifisation" (NR) 6116-70030. "Diablo Canyon PPS System Design Specification"

Auqu~L20, 2015A11rn 1~t Fi ?01 Fi DCPP PPS Open Item Summary Table Page 12 of 22 No I Src/RI I Issue Description P&GE response: I Status I RAI No. I RAI Comments (Date Sent) Response (Due Date) 6116-10216, "Diablo Canyon PPS VV Simulation Environment Specification" (Ref. 205) DCL-15-009 6116-00100, TxB1 and TxB2 Communications Protocol Specification" (NR) 6116-00054, "Diablo Canyon PPS ISG04 Matrix" (NR) 6116-00204, "Diablo Canyon PPS ALS Subsystem Equipment Qualification Evaluation" (Ref. 225) 6116-00011, "ALS System Design Specification" (Docketed version is 1) (Ref. 112) 6116-00400. "ALS Configuration Management Report" 6116-00401, "ALS Configuration Management Baseline Report" ALS Platform Documents 6002-00002, "ALS Configuration Management Plan" (Ref. 70) 6002-00006, "ALS Security Plan" Rev. 3 llifil_(Rev. 1 is docketed ML13036A380) 6002-00030, "ALS Design Tools" Rev. 12 (Ref. 150 Rev. 9)

Tricon Documents:

993754-11-854-1 Revision 1 Protection Set I Factory Acceptance Report (filled out test paperwork does not need to be included) (Reference 192) 993754-11-854-0 Revision 1 Protection Set I HVT Report (Reference 188) 993754-11-861 Revision 2 VnV Design Phase Summary Report PPS I (Reference 179) 993754-11-862 Revision 1 VnV Implementation Phase Summary Report PPS I (Reference 180) 993754-11-818 Revision O Protection Set I System Time Response Confirmation Report (Reference 196) 993754-12-818 Revision O Protection Set II System Time Response Confirmation Report (Reference 197) 993754-12-854-0 Revision O Protection Set II HVT Report (Refeence 189) 993754-12-854-1 Revision O Protection Set II Factory Acceptance Report (Reference 193)

Auqust 20, 2015A11rn1~t Fi ?01Fi DCPP PPS Open Item Summary Table Page 13 of 22 No Src/RI I Issue Description P&GE response: Status I RAJ No. I RAJ Comments (Date Sent) Response (Due Date) 993754-12-862 Revision O VnV Implementation Phase Summary Report PPS II-IV (Reference 202) 993754-13-818 Revision O Protection Set Ill System Time Response Confirmation Report (Reference 198) 993754-13-854-0 Revision O Protection Set Ill HVT Report (Reference 190) 993754-13-854-1 Revision O Protection Set Ill Factory Acceptance Report (Reference 194) 993754-14-818 Revision O Protection Set IV System Time Response Confirmation Report (Reference 199) 993754-14-854-0 Revision O Protection Set IV HVT Report (Reference 191) 993754-14-854-1 Revision O Protection Set IV Factory Acceptance Report (Reference 195) 993754-1-915 Revision 9 Safety Analysis (Reference 200 PG&E Response: The ALS documents have been uploaded to the Share Point Site and will all be docketed, except for the NA 4.50 and NA 4.51 procedures which are quality assurance procedures that are part of the Westinghouse Quality Management System (QMS) and can be made available for audit purposes. (Staff agrees that these two documents can be removed from docketing list) 146 I Rjs/ga I Environmental Qualification: I Open I RAI 7 4 I I 6/16/15 - The EQ evaluation In the response to 01 94 (ASAl-04), PG&E referred to document 6116- document will need 00204, Revision 1, "ALS Subsystem Equipment Qualification to be submitted on Evaluation." The NRC staff needs to review this document. Please docket as a basis place on sharepoint or provide on docket. for our EQ SE safety conclusions.

PG&E Response: 6116-00204-R1 was placed on the Sharepoint site in the (Added to 01 145)

ALS directory on 4/14/15.

Added on 4/8/15 147 Rjs/ga \ Environmental Qualification: Temperature and Humidity Open Added on 4/8/15 Clarify if FAS Section 3.1.4.1 specifies the temperature and relative humidity worst case conditions expected in the cable spreading room (i.e., mild environment) for normal, abnormal, and accident conditions.

Aug_u_$L20, 2015A11niwt Fo ?01Fo DCPP PPS Open Item Summary Table Page 14 of 22

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No Src/RI Issue Description P&GE response: Status RA/No. RA/ Comments (Date Sent) Response (Due Date)

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

a. Maximum temperature rise in each cabinet,

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

c. Design basis temperature margin has not been affected?

The licensee has specified a broader range of relative humidity than the qualified and tested range for the ALS and Tricon platforms. Clarify how the use of the ALS and Tricon subsystems is acceptable for the broader range of 0% to 95% RH specified in the FRS Section 3.1.4.1.2 when subsystems were ~ested to a narrower range.

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

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

8/5/15 ALS Humidity Tests. Additional information on humidity testing has been added to SOS, 6116-00011, Revision 8. The methodology to gerform the humiditv environmental testina is contained in WCAP-8587-<NP) Rev.

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DCPP PPS Open Item Summary -

Table Page 15 of 22 No Src/RI Issue Description P&GE response: Status RA/No. RA/ Comments (Date Sent) Response (Due Date) 6-A, "Methodology for Qualifying Westinghouse WRD (Water Reactor Division} Su1212lied NSSS Safety Related Electrical Egui12ment 1" Westinghouse Electric Com[2any LLC, and justifies the 0% to 95% relative humidity levels based on test levels of 35% to 95% relative humidity. The low humidity is not an environmental failure mechanism for electronic egui12ment, and, therefore, all humidity conditions below 35% (0-35%

relative humidity} are envelo12ed by the more conservative humidity levels included in the test. The only failure mechanism associated with low humidity is electrostatic discharge [ESD], which is addressed by item R161 O of the SOS, 6116-00011.

ALS Tem12erature Test: Testing was 12erformed to envelo12e a tem12erature range of 40-140°F 1 consistent with the ALS 12latform reguirements.

The tem12erature in the cable s12reading room is monitored and controlled to 103 degrees F (101 degree set12oint with 2 degrees allowed for instrument uncertainty} by Egui12ment Control Guideline 23.1, "Area Tem12erature Monitoring." If the tem12erature exceeds 103, actions are reguired to restore the tem12erature to less than 103 degrees F in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or 012en the cabinet doors and verify tem12erature less than 119 degrees, or 12erform an evaluation of 012erability, or to declare the egui12ment in the cabinet ino12erable.

The humidity in the cable s12reading room is monitored and controlled to less than 90% relative humidity. If 90% relative humidity is exceeded, 12rocedural actions reguire restoration of the humidity to within limits.

Procedure OP H-10:1V, "Combating High Humidity Inside the CSR" 12rovides guidance to restore humidity to within limits.

PG&E will 12erform a calculation of the maximum tem12erature rise in the cabinets with egui12ment installed to address this 012en Item. The schedule for calculation is being develo12ed.

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DCPP PPS Open Item Summary Table Page 16 of 22 No Src/RI Issue Description P&GE response: Status RA/No. RA/ Comments (Date Sent) Response (Due Date) 148 Rjs/ga Environmental Qualification: EMl/RFI Open Added on 4/8/15

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

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

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

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

c. Clarify how the installation limitation for the safety power supply is met as described in Section 7.2 of the ALS Platform EQ Summary Report.

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

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DCPP PPS Open Item Summary Table Page 17 of 22 No Src/RI Issue Description P&GE response: Status RA/ No. RA/ Comments (Date Sent) Response (Due Date)

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

PG&E Response. PG&E to discuss with staff if EMl/RFI testing done in 1990s for Eagle-21 installation (re12ort submitted to NRG) can be credited.

IA PF9§Fess.

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

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

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

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

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

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DCPP PPS Open Item Summary Table Page 18 of 22 No Src/RI Issue Description P&GE response: Status RAI No. RAI Comments (Date Sent) Response (Due Date)

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

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

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

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

3. Provide DCM T-24 for the seismic qualification of plant instrumentation and controls. DCM T-24 is referenced by DCM T-1O is identified in FRS Section 3.1.5.2. Clarify what category the ALS and Tricon subsystems fall under in DCM T-24 and how they meet the specific seismic qualification requirements in DCM T-24.

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

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

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

b. Clarify the resonance search results. The executive summary states that there were no resonances below 100

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DCPP PPS Open Item Summary Table Page 19 of 22 No Src/RI Issue Description P&GE response: Status RA/No. RA/ Comments (Date Sent) Response (Due Date)

Hz. Section 7.3 states that there was amplification between 20 and 70 Hz up to about 20 times.

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

d. Reference 9.14 of the Tricon Seismic Test Report may contain this information (National Technical Systems Test Report No. TR62987-07N-SEI, "Test Report for Seismic Qualification of TR ICON v 1O Nuclear Qualification Project TRICON-Under-Test,"Rev. 0)

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

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

Aux Bldg. E-W Horizontal 11 Sft.

Aux Bldg N-S Horizontal 115ft.

Aux Bldg. T ortional 11 Sft.

Aux Bldg. E-W Horizontal 140ft.

Aux Bldg N-S Horizontal 140ft.

Aux Bldg. Tortional 140ft.

2015Auauci5.

Auqu~20, --- . -* --*v-- - ' 2015

-- - - DCPP PPS Open Item Summary Table Page 20 of 22 No Src/RI Issue Description P&GE response: Status RA/No. RAJ Comments (Date Sent) Response (Due Date)

Part 2. In progress.

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

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

SSE-B was developed in EQ EV 48 and was designed to envelop all locations within athe standard safety Corry cabinet under representative loading. These levels were originally developed for Common Q generic applications, specifically for the HSL modems, and were therefore decided to be applied to generic ALS applications. This seismic spectrum is not applicable to the Diablo Canyon project.

Part 5. In 13FegFess. 8/5/15 PG&E will perform shake tests of the cabinets with eguipment installed to address this Open Item. The schedule for tests and report are being develo12ed. The report for the tests will supersede previous Seismic Test Report Document No. 9600164-526.

150 RA Westinghouse and PG&E New PG&E letter DCL-15-072 identifies several modifications to section 4.8, compliance to ISG-04, in the LAA. These changes are inconsistent with the information provided in WEC 6116-00054, Diablo Canyon PPS ISG04 Matrix. So we will make a clarification in the safety evaluation stating the LAA supersedes the WEC document since design changes were not made (only clarifications).

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..., fi '.201 fi DCPP PPS Open Item Summary Table Page 21 of 22 No Src/RI Issue Description P&GE response: Status RA/No. RA/ Comments (Date Sent) Response (Due Date)

PG&E Resgonse: PG&E agrees with this NRG action because the LAA information 12rovided additional clarifications on how ISG-04 guidance is met for ALS.

151 RA PG&E New The PG&E "Quality Assurance Plan for the Diablo Canyon Process Protection System Replacement" state PG&E will perform management and oversight activities during the work performed by Invensys and Westinghouse/AL, as well as evaluate deviations or anomalies during software development, approved corrective actions, and coordinated the disposition of discrepancies in the course of V&V. Please indicate how these activities will be documented and when this information will be available.

PG&E Res12onse: In 12rogress.

152 RA PG&E New The PG&E "DCPP Project Procedure, System Verification and Validation Plan (SyVVP) for the PPS Replacement Project" defines activities for PG&E to perform, such as preparing the final system V&V report for Diablo Canyon PPS. Please indicate how these activities will be documented and when this information will be available.

PG&E Res12onse: In 12rogress.

153 RA PG&E New The FAS, TFS and IRS include requirements that are the responsibility of PG&E. Will PG&E prepare a traceability matrix to show how these requirements were fulfilled?

PG&E Res12onse: PG&E is gerforming a groject s12ecific traceability matrix to document how reguirements are met for PG&E sco12e egui12ment.

August 20, 2015AllrnJF>t

..., fi 2015 DCPP PPS Open Item Summary Table Page 22 of 22 No Src/RI Issue Description P&GE response: Status RA/No. RA/ Comments (Date Sent) Response (Due Date)

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

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

2 Jan. 12,2012 Acceptance Review complete. LAR accepted for Jan. 12, detailed technical review. Several issues identified 2012 that could present challenges for the staff to complete its review. Scheduled public meeting with PG&E to discuss the results of the acceptance review.

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

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

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

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

7 July First RAI sent to PG&E on Phase 1 documentation August 7, 2012 (e.g., specifications, plans, and equipment 2012 qualification). Continue review of the application.

Request 45 day response. (ML12208A364) 8 June SER for Tricon V10 Platform issued final. This May 15, 2012 platform becomes a Tier 1 review of the LAR. 2012 (ML12146A010) 8.1 June SER for Westinghouse ALS Platform issued final.

2013 This platform becomes a Tier 1 review of the LAR.

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

Page 1 of 4

Project Plan for Diablo Canyon Replacement of Digital RPS and ESFAS (PPS) - LAR Review 10.1 December 2012 Audit report provided to PG&E. February 21,2013 11 February 2013 Audit trip to Westinghouse/CS! facility for thread February audit; audit the life cycle planning documents and 21,2013 outputs, with particular emphases on verification and validation, configuration management, quality Assurance, software safety, the W/ALS application software development procedures, and PPS ALS aoolication software proQram desiQn.

11.1 April Audit report provided to PG&E and its contractor. April 11, 2013 2013 12 March Second RAI Letter to PG&E on Phase 1 March 2013 documentation 20,2013 12.1 April Receive responses to Second set of RAl's May9, 2013 2013 13 April LAR revision and all supporting documentation April 30, 2013 associated with the change in ALS and Tricon V1 O 2013 workstation desiQns for the PPS are submitted.

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

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

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

17.1 July 2014 Second Invensys audit report provided to PG&E. April 30, Report sent to DORL 8/14. ML14216A398 2015 Final report 4/30/15. ML15103A011/ML15103A010 Page 2 of 4

Project Plan for Diablo Canyon Replacement of Digital RPS and ESFAS (PPS) - LAR Review 18 February Third RAI Letter to PG&E on Phase 2 February 2014 documentation 27, (e.g., FMEA, safety analysis, RTM, EQ test results, 2014 setpoint calculations.) ML14055A058 18.1 April Receive responses to third set of RAl's. April 30, 2014 DCL-14-036 - ML14121A002 2014 19 June 2015 Audit trip to W/ALS facilities for additional thread June 22-audit items; audit hardware and software 26,2015 installation plans, configuration management reports, detailed system and hardware design, completed test procedures, V&V activities, summary test results (including FAT) and incident reports, and application code listings.

Audit Plan - ML15090A716 19.1 August/September Audit report provided to PG&E.

2015 22 February 18 I Presentation to ACRS Subcommittee/Full ACRS February March Committee on DCPP PPS LAR Safety Evaluation. 18; 2014 March 6, 2014 November 2015, Presentation to ACRS Subcommittee/Full ACRS 22.1 and February 10, Committee on DCPP PPS LAR Safety Evaluation.

2016 23 September 2015 Complete draft technical SER for management review and approval.

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

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

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

29 TBD Inspection trip to DCPP for PPS installation tests, training and other system installation activities for the new system. To be coordinated with region visit.

Page 3 of 4

Project Plan for Diablo Canyon Replacement of Digital RPS and ESFAS

{PPS) - LAR Review Page 4 of 4

• The NRC staff is planning to go to Advisory Committee on Reactor Safeguards (ACRS) subcommittee with a draft safety evaluation during November 2015.

• The NRC staff and the licensee agreed to tentatively schedule the next periodic meeting on September 23, 2015.

Two members of the public were in attendance for the teleconference meeting and had no comments. Further, no public meeting feedback forms were submitted.

Please direct any inquiries to me at 301-415-1564 or at Siva.Lingam@nrc.gov.

IRA/

Siva P. Lingam, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosures:

1. List of Attendees

2. Staff Identified Issues That are Open

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

PUBLIC RidsNrrLAJBurkhardt Resource RStattel, NRR/DE/EICB LPL4-1 Reading RidsNrrPMDiabloCanyon Resource SDarbali, NRR/DE/EICB RidsAcrsAcnw_MailCTR Resource RidsNsirDsp Resource RAlvarado, NRR/DE/EICB RidsNrrDeEicb Resource RidsRgn4MailCenter Resource SMakor, RIV/DRS/EB2 RidsNrrDorl Resource TWertz, NRR BMaier, RIV RidsNrrDorllpl4-1 Resource CRosales-Cooper, EDO RIV ADAMS A ccess1on N OS. M ee f mg N01cef ML15202A083 Mee f mg S ummary ML15233A006 OFFICE NRR/DORULPL4-1 /PM NRR/DORULPL4-1 /LA

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NAME Slingam JBurkhardt DRahn DATE 8/24/15 8/21/15 8/24/15 OFFICE NRR/DORULPL4-1 /BC NRR/DORULPL4-1 /PM NAME MMarkley Slingam (MMarkley for)

DATE 9/9/15 9/10/15 OFFICIAL RECORD COPY