U7-C-STP-NRC-090009 U. S. Nuclear Regulatory Commission … · 2015. 6. 22. · U7-C-STP-NRC-090009...

Nuclear Operating Company

South Texas Pro/ect lectric Generating Station PO Box 289 Wadsvorth, Texas 77483 -

February 9, 2009U7-C-STP-NRC-090009

U. S. Nuclear Regulatory CommissionAttention: Document Control DeskOne White Flint North11555 Rockville PikeRockville MD 20852-2738

South Texas ProjectUnits 3 and 4

Docket Nos. 52-012 and 52-013Additional I&C Information

References: 1. Letter, Belkys Sosa to Mark McBurnett, "Regulatory Audit Summary ofSouth Texas Project, Units 3 and 4 Instrumentation and Control DesignInformation," dated December 18, 2008, (ML083460608).

2. Letter, Scott Head to Document Control Desk, "Schedule for ProvidingAdditional I&C Information," dated December 19, 2008, (ML083640468).

Reference 1 identified four additional information items needed by the NRC staff in order forthem to complete their review of the instrumentation and controls (I&C) sections of the STP 3 & 4Combined License Application (COLA). In Reference 2, South Texas Project Nuclear OperatingCompany (STPNOC) agreed to submit responses to each of the items identified along with thenecessary proposed COLA changes. This letter provides the requested information.

Attachment 5 provides a description of the approach employed by STP for the I&C sections ofour COLA. It is intended to aid NRC reviewers by providing context for the informationprovided in our COLA and in this letter.

Attachments 1 through 4 correspond to. each of the numbered items in Reference 1. Theenclosures to this letter provide supporting data and proposed COLA revisions referenced inAttachments 1 through 4. As discussed with the NRC during the audit on December 10, 2008,and as provided in Reference 2, the attachments address those departures from Tier 1 and Tier 2*material that pertain to I&C. Departures from Tier 2 are not addressed because those departuresdo not require NRC approval.

KUA -

U7-C-STP-NRC-090009 of 3

When a change to the COLA is indicated, the change will be incorporated into the next routine

revision of the COLA following NRC acceptance of these responses.

There are no commitments in this letter.

If you have any questions, please contact me at (361) 972-7136, or Bill Mookhoek at(361) 972-7274.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on Z c Z,0q

Scott HeadManager, Regulatory AffairsSouth Texas Project Units 3 & 4

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Attachments:1.2.3.4.5.

Response to I&C Audit Item 1Response to I&C Audit Item 2Response to I&C Audit Item 3Response to I&C Audit Item 4STP Units 3 &4 Digital Instrumentation and Control Systems Design and DesignProcess

Enclosures:Summary of Enclosures1. Revisions to COLA Tier I Section 3.42. Revisions to COLA Tier 2 Sections3. Revisions to COLA Part 7 Section 2.14. Compliance Review for STP 3&4 COLA

U7-C-STP-NRC-090009 of 3

cc: w/o attachment except*(paper copy)

Director, Office of New ReactorsU. S. Nuclear Regulatory CommissionOne White Flint North11555 Rockville PikeRockville, MD 20852-2738

Regional Administrator, Region IVU. S. Nuclear Regulatory Commission611 Ryan Plaza Drive, Suite 400Arlington, Texas 76011-8064

David L. Lakey, M.D.Texas Department of State Health ServicesP.O. Box 149347Austin, TX 87814-9347

C. M. CanadyCity of AustinElectric Utility Department721 Barton Springs RoadAustin, TX 78704

(electronic copy)

*George Wunder

Loren R. PliscoU. S. Nuclear Regulatory Commission

Steve WinnEddy DanielsJoseph KiwakNuclear Innovation North America

Jon C. Wood, EsquireCox Smith Matthews

J. J. NesrstaR. K. TempleKevin PolioL. D. BlaylockCPS Energy

* Steven P. Frantz, EsquireA. H. Gutterman, EsquireMorgan, Lewis & Bockius LLP1111 Pennsylvania Ave. NWWashington D.C. 20004

*George F. Wunder

Two White Flint North11545 Rockville PikeRockville, MD 20852

U7-C-STP-NRC-090009Attachment 1

Page 1 of 3

NRC Item 1):

Describe the scope of I&C departures and how the departures conform to current standard reviewplan (SRP) acceptance criteria, related staff guidance and industry standards. Refer to theexamples listed below. If design does not meet the applicable staff guidance, provide thedescription of alternate method used.

Note:

In response to this request, STP has reviewed the Tier 1 and Tier 2* departures related to I&C,which include departures STD DEP Ti 2.2-1, STD DEP TI 2.3-1, STD DEP TI 3.4-1, and STDDEP 1.8-1. The discussions in STD DEP TI 2.2-1, STD DEP TI 2.3-1, and STD DEP 1.8-1adequately describe the departures and justifications for the changes, and therefore changes tothese departures are not needed in response to this request. The following information focusesonly on STD DEP Ti 3.4-1. The response to each of the four NRC bullet points is providedbelow.

First NRC Bullet:

* Evaluation of impact to Design Control Document (DCD) Table 1.8-7, "Summary ofDifferences from SRP Section 7," has not been fully captured.

RESPONSE:

DCD Tier 2, Subsection 7.3.2.4.2, Specific Regulatory Requirements Conformance,under item (1) 10CFR50.55a (IEEE-279), states "A clarification should be made withregard to IEEE-279, Section 4.19. The parent RHR System annunciates activity at theloop level (i.e., "RHR LOOP A, B, C ACTIVATED"). However, the individual mode ofthe RHR System is not separately annunciated."

STP 3&4 COLA, Rev. 2, appropriately deleted the first sentence, "A clarification shouldbe made with regard to IEEE-279, Section 4.19" because this should not be in the COLA.However, in Table 1.8-7 of the COLA, "Summary of Differences from SRP Section 7,"the IEEE-279, 4.19 requirement was erroneously deleted. Instead, the SummaryDescription of Difference column should have included an editorial change to reflect theabove DCD clarification. Table 1.8-7 (Enclosure 2.a) will be revised to reflect the DCDclarification in Subsection 7.3.2.4.2, and no further evaluation is necessary. With thisclarification, Table 1.8-7 is complete and considered correct.


Page 2 of 3

Second NRC Bullet:

Evaluation of impact to DCD Tier 2, Table 1.8-19, "Standard Review Plans andBranch Technical Positions Applicable to Advanced Boiling Water Reactor(ABWR)," is not documented in the COLA.

RESPONSE:

Evaluation of STD DEP T1 3.4-1 against the SRP is provided in the enclosed SRPSection 7.2 Evaluation for the Reactor Trip and Isolation System (RTIS)/NeutronMonitoring System (NMS) Departures and SRP Section 7.3 Evaluation for theEngineered Safety Feature (ESF) Logic and Control System (ELCS) Departure(Enclosures 4.b and 4.c). Evaluations of STD DEP Ti 3.4-1 against the BranchTechnical Positions are provided in Enclosure 4.d and 4.e.

Third NRC Bullet:

0 SRP 14.3 and 14.3.5 provide guidance for Tier 1 design descriptions, figures, andInspections, Tests, Analyses, and Acceptance Criteria (ITAAC) for I&C systems.Applicability of these SRP sections to STP 3 and 4 has not been evaluated.

RESPONSE:

STPNOC evaluated the guidance of SRP 14.3 and 14.3.5 to evaluate if any new ITAACis warranted or if any existing ITAAC need to be modified as a result of the changesidentified in STD DEP TI 3.4-1. The results of that evaluation are summarized inEnclosure 4.f.

The I&C platform changes identified in STD DEP TI 3.4-1 are to the design of thesubsystems that communicate the functions as described in the DCD, and do not changethe functions themselves, the ITAAC as described in the DCD remain completelyapplicable and valid. Therefore changes to the I&C ITAAC are neither required norappropriate. For clarity, the system nomenclature was updated, but this only changes thecallout of the system performing the function, and does not change the function oracceptance criteria. Further, the changes in STD DEP TI 3.4-1 do not introduce any newfunctions in addition to those already described in the DCD, and therefore no new I&CITAAC are necessary.


Page 3 of 3

Fourth NRC Bullet:

Evaluation of impact to DCD Table 1.8-20, "NRC Regulatory Guidelines Applicableto ABWR," has not been fully captured, i.e., applicability of Regulatory Guides(RGs) 1.152, 1.168 through 1.172, 1.180, and 1.209 has not been evaluated. Thisevaluation should also be addressed in COLA.

RESPONSE:

Updates to COLA Tier 2, Table 1.8-20, "NRC Regulatory Guidelines Applicable toABWR," and Table 1.8-21, "Industrial Codes and Standards Applicable to ABWR," areprovided in Enclosure 2.a.

Conformance of STD DEP Ti 3.4-1 to Regulatory Guides and IEEE Standards isprovided in Enclosure 2.b, which includes an update to COLA, Tier 2, Table 1.9S-1,"Site-Specific Conformance with Regulatory Guides," and a new Table 1.9S- I a, "IEEEStandards Applicable to the STP 3&4 I&C Platforms." Table 1.9S-1 includesapplicability of Regulatory Guides 1.152, 1.168 through 1.172, 1.180, and 1.209 to theSTP 3&4 RTIS/NMS configurable logic devices. An update to Table 7.1-2, RegulatoryRequirements Applicability Matrix for I&C Systems, is provided in Enclosure 2.c.


Page 1 of 1

NRC Item 2):

In Table 1.9S-1, "Site-Specific Conformance with Regulatory Guides," STP commits to RG1.206. RG 1.206 provides guidance on the level of detail to be captured in a COLA. STP'sCOLA Revision 2 does not contain the level of detail as prescribed in RG 1.206 for the I&Cdepartures.

Note:

In response to this request, STP has reviewed the Tier 1 and Tier 2* departures related to I&C,which include departures STD DEP TI 2.2-1, STD DEP TI 2.3-1, STD DEP TI 3.4-1, and STDDEP 1.8-1. The discussions in STD DEP TI 2.2-1, STD DEP TI 2.3-1, and STD DEP 1.8-1adequately describe the departures and justifications for the changes, and therefore changes tothese departures are not needed in response to this request. The following response focuses onSTD DEP TI 3.4-1.

RESPONSE:

Regulatory Guide (RG) 1.206 prescribes a level of detail for an applicant that is proposing a finaldesign. As stated in Attachment 5, UTLR-000 I-P, Rev. 0 has been submitted for NRC reviewand additional level of detail for the RTIS/NMS platform will be contained in the ToshibaTopical Reports to be submitted for NRC staff review and approval. The previously NRC-approved WCAPS provide additional level of detail for the ELCS platform. These TopicalReports, along with documents necessary for closeout of the I&C Design Acceptance Criteria(DAC), will provide the level of detail prescribed by RG 1.206 for the STP 3&4 final I&Cdesign.

The level of design detail submitted at this stage of design is appropriate and consistent with theDCD, DAC, and RG 1.206, and the platforms described in the topical reports for RTIS/NMS andELCS as identified in Attachment 5 are appropriate for Staff review of the STP 3&4 digital I&Csystem at this stage of design.

A comparison of STD DEP TI 3.4-1 to RG 1.206 is provided in Enclosure 4.a.Additional detail is contained in the proposed changes to COLA Tier 1, Part 2 and COLA Part 7,Section 2.1 for STD DEP TI 3.4-1 (Enclosures 1 and 3).


Page 1 of 3

NRC Item 3):

In accordance with RG 1.206, the staff expects the applicant to provide a detailed schedule forimplementation of Design Acceptance Criteria (DAC). STP has not provided the scheduleinformation of sufficient detail.

RESPONSE:

In a public meeting on October 23, 2008, STPNOC provided to the NRC the following projectedmilestone completion dates for the DAC items contained in Tier 1 Table 3.4. The followingitems will be completed as part of the site acceptance testing during the pre-operational testphase, currently scheduled for the fourth quarter of 2014. These dates are estimates as of1/29/2009.

* #1-4 Inspection and Tests of Safety System Logic and Control (SSLC)* #5 Test of anticipated transient without scram (ATWS)* #6 Inspection of Main Control Room (MCR) Alarms, Displays & Controls* #16 Tests to Verify Diversity

The programmatic DAC items will be completed as indicated:* #7-10 Digital Systems Software Plans - Second Qtr 2009* #11 Digital Systems Software Development Review - Fourth Qtr 2012* #12 Digital Platform Electromagnetic Compatibility (EMC) Qualification Plan -

Second Qtr 2009* #13 Setpoint Determination Methodology - Fourth Qtr 2009

(Setpoint CaIcs - Second Qtr 2013)• #14 Environmental Qualification Program - Second Qtr 2013S# 15 Plan for Verifying I&C Installation Correctness Verification Program - Fourth

Qtr 2014

The following additional information is being provided based on the flow of documents throughthe software life cycle and is based on the stages and documents that are shown in Tier 1 Figure3.4d. These dates are estimates as of 1/29/2009.

* All dates shown represent completion during the quarter indicated.• All dates are best estimates based on limited information available as of 1/29/2009.* These dates are expected to be impacted as detailed schedules are developed, and as

predecessors and successors are more accurately defined.• Verification and Validation (V&V) reports for Design Analysis and for

Implementation Analysis may not apply.* For activities outside of the Planning Activities there will be separate reports for each

of the platforms.* Planning Activities are common documents. Requirements Activities, Design

Activities, Implementation Activities, Integration Activities, Validation Activities,and Installation Activities are unique documents for each system.


Page 2 of 3

Estimated- Document Description orTitle]Datee ofýCompletion,

1. Planning Activities:2009Q2 1.1 Software Management Plan2009Q2 1.2 Software Development Plan2009Q2 1.3 Software Quality Assurance (QA) Plan2009Q3 1.4 Integration Plan2009Q4 1.5 Installation Plan2009Q4 1.6 Maintenance Plan2009Q4 1.7 Training Plan (Training to be provided after

Iinstallation)

2009Q4 1.8 Operations Plan2009Q3 1.9 Software Safety Plan2009Q3 1.10 Software V&V Plan2009Q3 1. 11 Software Configuration (Westinghouse Electric Company

Management (CM) Plan (WEC) and Toshiba Corporation (TSB)each have their plan)

Lead up to the Conformance Review / NRC Planning Audit

2. Requirements Activities:2010Q1 2.1 Requirements Specification2010Q2 2.2 Requirements Safety Analysis2011Q3 2.3 V&V Requirements Analysis Report2011Q3 2.4 CM Requirements Report

Lead up to the Conformance Review / NRC Requirements Audit

3. Design Activities:2010Q2 3.1 Design Specification2010Q4 3.2 Hardware & Software Architecture2011Q4 3.3 Design Safety Analysis2012Q1 3.4 V&V Design Analysis Report2012Q1 3.5 CM Design Report

Lead up to the Conformance Review / NRC Design Audit4. Implementation Activities:

2010Q2 4.1 Code Listings2011Q4 4.2 Code Safety Analysis2011Q4 4.3 V&V Implementation Analysis & Test Report2011 Q4 4.4 CM Implementation Report

Lead up to the Conformance Review / NRC Implementation Audit

5. Integration Activities:2014Q2 5.1 System Build Documents2014Q2 5.2 Integration Safety Analysis2014Q2 5.3 V&V Integration Analysis & Test Report2014Q2 5.4 CM Integration Report

Lead up to the Conformance Review / NRC Integration Audit


Page 3 of 3

Estimated Document'Descriptionhor TitleDate ofCompletion

6. Validation Activities:2013Q4 6.1 Validation Safety Analysis2013Q4 6.2 V&V Validation Analysis &Test Report2013Q4 6.3 CM Validation Report

Lead up to the Conformance Review / NRC Validation Audit

7. Installation Activities:2015Q1 7.1 Operations Manuals2015Q1 7.2 Installation Configuration Tables2015Q1 7.3 Maintenance Manuals2015Q1 7.4 Training Manuals2014Q4 7.5 Installation Safety Analysis2014Q4 7.6 V&V Installation Analysis & Test Report2014Q4 7.7 CM Installation Report

Lead tip to the Conformance Review /NRC Installation Audit

2015 FUEL LOAD - ESTIMATE (Currently scheduled for mid 2015)

8. Operation & Maintenance Activities:

2014Q4 8.1 Change Safety Analysis2014Q4 8.2 V&V Change Report2014Q4 8.3 CM Change Report


Page 1 of 2

NRC Item 4):

The audit team identified editorial changes that need to be made to the COLA. These errors, insome instances, made it difficult for the staff to understand your proposed I&C designdepartures.

RESPONSE:

STP reviewed the examples of inconsistencies identified by the NRC at the audit. STPacknowledges these inconsistencies and proposes the following resolutions:

* The inconsistency between Tier 1 Figure 2.2.5, which shows OPRM as a subsystemof APRM, and other sections of the COLA, which describe OPRM as a subsystem,will be resolved by the deletion of STD DEP 7.6-1. This will result in the COLAincorporating by reference the description in the DCD where OPRM is characterizedas a subsystem of APRM.

* The inconsistencies between the subsection numbering of Tier 1 Section 3.4 havebeen resolved as shown in the proposed COLA changes in Enclosure 1.

" The inconsistencies regarding the use of nomenclature in Tier 1 Table 3.4 which hasbeen changed by STD DEP TI 3.4-1 have been resolved as shown in the proposedCOLA changes in Enclosure 1. The terms Essential Multiplexing System (EMS) andNon-Essential Multiplexing System (NEMS) have been changed to EssentialCommunication Function(s) (ECF) and Non-Essential Communication Function(s)(NECF), respectively.

In addition, a search of the COLA was undertaken for inconsistencies in use of nomenclaturerelated to changes made by STD DEP Ti 3.4-1. A number of corrections were identified in Tier2 Chapters 2, 6, 7, 8, 9, 14, 15, and 19.


Page 2 of 2

The following table shows the editorial changes required for correcting I&C terminology in theCOLA.

DCD terminology I Revised terminology for COLAremote multiplexing data communications equipmentmultiplexer control device or controllermultiplexer controllertrip logic unit (TLU) trip logic function (TLF)trip unit trip functionmultiplex (verb) digitally transmitmultiplex (noun) data communicationessential multiplexing system (EMS) essential communications function (ECF)signal multiplexer signal A-D converterdigital trip module (DTM) digital trip function (DTF)system logic unit (SLU) system logic function (SLF)

These, and any other identified inconsistencies, will be incorporated into the next routinerevision of the COLA following NRC acceptance of the response.


Page 1 of 4

STP Units 3&4 Digital Instrumentation and Control Systems Designand Design Process

ABWR DCD

The ABWR DCD contains both Tier 1 and Tier 2 information that has been incorporated byreference into 10 CFR 52 Appendix A. Tier 1 information contains the Certified DesignMaterial (CDM), which includes the design description; Inspections, Tests, Analyses andAcceptance Criteria (ITAAC); site parameters; and interface requirements for designcertification. The Tier 1 information is derived from the more extensive information provided inTier 2.

The DCD Tier 1 information has been certified by rulemaking according to the requirements of10 CFR Part 52. It was reviewed and found acceptable by the NRC staff in NUREG-1503, Vol.1, "Final Safety Evaluation Report Related to the Certification of the Advanced Boiling WaterReactor Design" (FSER), dated July 1994. Thus, the DCD Tier 1 has been certified, has finality,and can be changed only through rulemaking or license amendment.

I&C Design Acceptance Process

The FSER describes the NRC Staff's final safety evaluation findings of the ABWRinstrumentation and control (I&C) systems design in Chapter 7. The acceptance criteria used asthe basis for the NRC Staff's evaluation of the I&C systems for the ABWR were set forth inNUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for NuclearPower Plants, LWR Edition," and 1 OCFR Part 52. The primary section of NUREG-0800 usedfor this portion of the review was Section 7, "Instrumentation and Controls."

The results of the NRC review of the DCD were that the I&C systems which are important tosafety in accordance with Regulatory Guide (RG) 1.70, Revision 3, "Standard Format andContent of Safety Analysis Reports for Nuclear Power Plants," November 1978, were identifiedand had an associated Design Description and ITAAC. Some aspects of the design which affectall I&C systems (such as the software design process) were addressed in an I&C Tier 1 Section3.4 rather than repeated in Tier 1 for each individual I&C Design Description (included in theDCD as Tier 1 Section 2).

The Staff acknowledged that the ABWR I&C systems are significantly different from I&Csystems in previously-approved designs. The primary differences result from using digitalmicroprocessor-based I&C systems with multiplexed data links in place of the analogelectronics, relay logic, and hardwired systems previously approved. The Staff previouslyreviewed designs using digital equipment similar to that proposed for the ABWR; however, theABWR significantly extended the quantity and scope of system coverage of the digitalmicroprocessor applications and, in conjunction with the 10 CFR Part 52 design certificationprocess, and required a unique review which was not directly comparable with any past licensingreview. The differences from past license reviews were addressed in detail in the FSER. TheStaff also acknowledged that the technology in this area was evolving, and therefore it wasundesirable to "lock-in" a final design for certification.


Page 2 of 4

To provide finality for the ABWR certified design, the NRC relied on a structured designimplementation process to be followed by a COL applicant during the final design of the I&Chardware and software, to ensure that design results are in conformance with the certified designdescriptions and all applicable requirements. These plans and procedures will guide the designprocess throughout the lifecycle stages (see ABWR DCD Tier 1 Figure 3.4d). Theseprogrammatic aspects are described in DCD Tier 1 Subsection 3.4B, and the Design AcceptanceCriteria (DAC) ITAAC are found in Section 3.4. The primary function of this developmentprocess is to implement all applicable functional requirements, including regulatory guidance,codes and standards, and acceptance criteria. The implementation of these plans and proceduresand the resulting design are the responsibility of the COL applicant/licensee.

The DAC activities completed by the COL applicant will be made available for inspection by theNRC to verify conformance with the requirements at several stages during the digital controlsystem design process. The COL applicant is required to satisfactorily complete DAC activitiesat each stage prior to proceeding to the next stage of the design development process. At eachstage, the COL applicant must verify that the design development is in accordance with thecertified design process and that the detailed design developed is in conformance with thecertified design, as revised by the approved COLA. This phased approach will continue until allDAC steps for all the safety-related software are complete. The DAC and the DAC process isnot being changed for STP 3&4.

In the FSER, the Staff provided further digital I&C (DI&C) system evaluations related to theSRP criteria (RGs, IEEE, GDC, BTP), the Electric Power Research Institute (EPRI)requirements document, and additional criteria including responses to NRC requests foradditional information (RAI). Based on findings, discussions, and resolution of the RAI issueswith GE, the NRC Staff concluded that the design and the design process of the RPS and ESFI&C as described met the requirements of the GDC and 10 CFR 50.55a(b) (IEEE 279), and thatthe design was acceptable. Although specific platforms were not identified or certified, thenomenclature used in the DCD reflects the technology in general use at the time of thecertification. Since those technologies are no longer currently accepted industry practice, insome instances, the STPNOC departures have updated the nomenclature while maintainingfunctionality described in the certified material. Consequently, the existing ITAAC and DACrequirements are appropriate, adequate, and applicable.

STP Units 3&4 I&C Licensing Considerations

The STP 3&4 project is proceeding with DI&C system design using the DCD design andDAC/ITAAC criteria based on the following platforms:

0 NRW-FPGA-Based I&C System platform for the RTIS/NMS, as described in TopicalReport UTLROOO1 P, Rev. 0, "Topical Report of NRW-FPGA-Based I&C SystemDesign Process" (Proprietary) which has been submitted for NRC generic review.

0 Common Q Digital Platform for ELCS use, which was submitted for generic use andwas approved for reference as described in Topical Report WCAP- 16097-P-A,


Page 3 of 4

Revision 0, "Common Qualified Platform Topical Report." and WCAP-16096-P-A,Revision 1, "Software Program Manual for Common Q Systems," which is alsoapproved and being used for the ELCS.

The NRW-FPGA platform topical report is not a complete submittal for the FPGA platform andwill be supplemented by future topical reports prior to approval for use by the NRC. TheCommon Q platform has already received approval by the NRC. These topical reports,supplemented by COLA STD DEP T 1 3.4-1, describe the DI&C system design including designprocesses.

The vast majority of information concerning the STP 3&4 I&C design incorporates, withoutchange and by reference, the information in the ABWR DCD. The topical reports and departureindicated above do not change any of the functions related to the I&C design as they relate to theDCD. The input data as well as all output actions taken as a result of that data are unchangedfrom the DCD. STD DEP Ti 3.4-1 eliminates the use of traditional, outdated multiplexers andimplements the more current, industry preferred design of data communication for RTIS/NMSand ELCS protection and engineered safety features signals to support the final requiredactuation of safety equipment. This departure does not change any safety criteria with respect togeneration of signals or the safety equipment actuation, but does implement the latest availabletechnology.

As noted earlier, the DAC are not affected by this departure. In addition, the ITAAC are notaffected as the requirements and functions are unchanged as summarized in the previousparagraph (Enclosure 4.). Consequently, those aspects of the I&C design which were reviewedand approved by the NRC in the DCD, including the DAC process, are already certified, havefinality, and should not be subject to re-review and approval by the NRC. Only the departures asprovided in Revision 2 of the COLA, the existing FPGA Topical Report, and future FPGATopical.Reports should be subject to review.

The codes and standards to be applied for the I&C system design are as follows: (1) for thoseaspects which are unchanged from the DCD, the codes and standards identified in the DCDapply, (2) for those aspects related to the updated equipment for the RTIS/NMS systems, currentcodes and standards will apply, and (3) for the ELCS, the codes and standards identified in theNRC approved topical report will apply. The codes, standards, and regulatory guides areprovided in Enclosure 2.a.

STD DEP Ti 3.4-1 and associated departures meet the intent of the FSER and ABWR DCD withrespect to evolution of the DI&C and the DAC/ITAAC, and provisions of Regulatory Guide1.206, Section C.I.7, and its appendices for information to be submitted with the COLA. Theassessment of STD DEP TI 3.4-1 to this Regulatory Guide is provided in Enclosure 4.a.


Page 4 of 4

Conclusion

STPNOC Project believes that the above discussion and information in the attachments regardingthe design and design process of the DI&C system demonstrates compliance with the certifiedABWR DCD. This is consistent with the NRC Staff's findings in the FSER, which concludesthat the top-level design processes, features, and performance characteristics of the I&C aspectsof the ABWR design are appropriately described in the Tier 1 design descriptions, and can beadequately verified through the DAC process.

U7-C-STP-NRC-090009Summary of Enclosures

Page 1 of 1

Summary of Enclosures

The following proposed STP 3&4 COLA changes are enclosed:

Enclosure 1: Revisions to COLA Tier 1 Section 3.4

Enclosure 2: Revisions to COLA Tier 2

a. Section 1.8

b. Section 1.9S

c. Section 7.1, Table 7.1-2 "Regulatory Requirements Applicability Matrixfor I&C Systems"

Enclosure 3: Revisions to COLA Part 7 Section 2.1, STD DEP TI 3.4-1 change description,

The following additional items are enclosed to aid the NRC Staff but are not to be included in theCOLA:

Enclosure 4: Compliance Review for STP 3&4 COLA, I&C

a. "Conformance of STD DEP TI 3.4-1 with Regulatory Guide 1.206," forSection C.I.7 evaluating departures for the RTIS/NMS and ELCS

b. "Conformance of STD DEP TI 3.4-1 with SRP 7.2, Evaluation for theRTIS/NMS Departures"

c. "Conformance of STD DEP TI 3.4-1 with SRP Section 7.3, Evaluationfor the ELCS"

d. "Review of SRP Chapter 7 BTPs for Applicability to I&C Departuresrelated to RTIS/NMS"

e. "Review of SRP Chapter 7 BTPs for Applicability to I&C Departuresrelated to ELCS"

f. "Evaluation of ITAAC for STD DEP Ti 3.4-1"

U7-C-STP-NRC-090009Enclosure 1Page 1 of 3

Revisions to COLA Tier I Section 3.4

The following changes will be made to Tier 1, Section 3.4:

3.4 Instrumentation and Control

The devices addressed in this section are electronic components of the ABWR's I&Csystems. These components are eefffigured-as include real-time mi.ro.ontrol.ers that usemicroprocessors and eer .......... configurable logic devices to perform dataacquisition, data communications, and system logic processing. These components alsocontain tmatic- on-line self-diagnostic features to monitor these tasks and off-line testcapability to aid in maintenance and surveillance. The For microprocessor based systemsýtESvf.ogic and' "Control), the operating programs for dwse the controllers are integratedinto the hardware asfifmw;'are in nonvolatile memory that cannot be modified with thesystem on-line. [ftware permanent,' stored in progr.ammable read only' memory(APR.OM%. For configurable logic devices MITIS and NS.the functions areincorporated into the logic configuration. A .. ontro•lkrs operating s.ystem an per.mit fieda Adjustment ofselectedparameters is permitted under proper change control.Adjustable parameters are stored in electrically' alter-able read only memory {-EAOM)'er equivalent that can only be altered through the use of special equipment and/orprocedures.

A4z- A Safety System Logic and Control

Design Description

SSLC equipment comprises microprocessor-based, software-controlled signal processors'(E]LCS,,$ and/or configurable logic devices WRTIS and ']M MSJ that perform signalconditioning, setpoint comparison, trip logic, system initiation and reset, self-test,e..iba.ioi.., and bypass functions. The signal processor.s associated with a particularsafety, related sysWtem are an integral par-t of that syswtem. F-unctions. in common, such aself test-, calibration-, bypass control, power supplies and certain switches and indicators,ýbelong to SSLG. However-, SSLC is not, by' itsebcf a sy'stetn, SSLC is the aggr-egate osignal processorsor s.ever.al safet, related sysMs.... SSLC hardware and software areclassified as Class 1E, safety-related.


3A3 C Diversity and Defense-in-Depth Considerations

Diver~se Backup Supp-ort for SSLC Eqipj~Iment

DiveseFeatures T Function'a4 Diversity Defense-in-Depth

Protection System it Protection System Thonfig`ratiqg

1(7)- oN6I'Pseiti

Equipment,Diversiy,

Communication

Indecpenn andeniverserorn EMS

ECF

The following nomenclature changes will be made to Figure 3.4b Safety System Logic &Control Block Diagram:

* Change "TLU" to "TLF" in upper DTF block.

• Change "System Logic Function (SLF)"to "Safety System Logic Function (SLF)"in Notes 3 and 4.

" Change misspelling "unreasonalby" to "unreasonably" in Note 4.


Table 3.4 Instrumentation and ControlInspections, Tests, Analyses and Acceptance Criteria

Design Commitment Inspections, Tests, Analyses Acceptance Criteria

Safety System Logic and Control12. Electrical and electronic components in the

systems listed below are qualified for theanticipated levels of electrical interference atthe installed locations of the componentsaccording to an established plan:a. Safety System Logic and Controlb. Essential

Communication Functionc. Non-Essential WultipleXing System

Conmmu~nication Functiond. Other microprocessor-based, software

controlled systems or equipmentThe plan is structured on the basis thatelectromagnetic compatibility (EMC) of I&Cequipment is verified by factory testing and site

.testing of both individual components andinterconnected systems to meet EMCrequirements for protection against the effects of:a. Electromagnetic Interference (EMI)b. Radio Frequency Interference (RFI)c. Electrostatic Discharge (ESD)d. Electrical surge [Surge Withstand Capability

(SWC)]

12. The EMC compliance plan will be reviewed. 12. An EMC compliance plan is in place. Theplan requires, for each system qualified,system documentation that includesconfirmation of component and systemtesting for the effects of high electrical fieldconditions and current surges. As a minimum,the following information is documented in aqualification file and subject to audit:a. Expected performance under test

conditions for which normal systemoperation is to be .ensured.

b. Normal electrical field conditions at thelocations where the equipment mustperform as above.

c. Testing methods used to qualify theequipment, including:(1) Types of test equipment.(2) Range of normal test conditions.(3) Range of abnormal test conditions for

expected transient environment.

U7-C-STP-NRC-090009Enclosure 2a

Page 1 of 2

Revisions to COLA Tier 2 Section 1.8

The following changes will be made to Tier 2 Section 1.8 to address RG applicability:

1.8 Conformance with Standard Review Plan and Applicability of Codes andStandards

Revisions have been made to Table 1.8-20 and are summarized here. The STP 3 & 4FSAR conforms with the following revisions of Regulatory Guides (RGs).

RG 1.75 Rev. 3 (ELCS conforms to Revision 2,1978)

1.8.2 Applicability of Codes and Standards

Standard Review Plans, Branch Technical Positions, Regulatory Guides and IndustrialCodes and Standards which are applicable to the ABWR design are provided in Tables1.8-19, 1.8-20 and 1.8-21. Applicable revisions are also shown. Te =:Standk R'ieN

which are applicable to the I&C plattornis selected are provided in Tables 1.9S-1 and1l.9S-la.

The following changes will be made to Table 1.8-7, restoring this row to incorporate byreference the DCD information (removing the strikeout) except for the Summary Description ofDifference, which is being corrected as follows:

Table 1.8-7 Summary of Differences from SRP Section 7

Specific SRP Summary Description of Subsection WhereSRP Section Acceptance Criteria Difference Discussed7. TableT7 1:1 a .HR ARn~iatioa6p [7.3...3.2 (•)'

IEE279, 4.49. lvel. The parent RHR E 3.2.4.2 (1)System annunciates ý...32(Iactivity at the loop level,"lRHR 1-OOP AB,CqACTIVATED .Th 6individual mode o theRIR system is notseparatey annunlciated.

U7-C-STP-NRC-090009Enclosure 2a

Page 2 of 2

The following changes will be made to Table 1.8-20:

Table 1.8-20 NRC Regulatory Guides Applicable to ABWR

Appl. Issued ABWRRG No. Regulatory Guide Title Rev. Date Applicable? Comments

[1.75 Physical Independence of Electric Systems 23 9/-78 Yes](4 )

2/05(

ýT ab F6 -- ýbNot -e s:

ý(5) E[EQ8,conforms to Revision 2, 198

The following changes will be made to Table 1.8-21:

Table 1.8-21 Industrial Codes and Standards(*) Applicable to ABWRCode or StandardNumber Year TitleInstitute of Electrical and Electronics Engineers (IEEE)

[384(t)4-8 1992 Criteria for Independence of Class 1E Equipment andI Circuitsip"OTI

Notes:

'(9) ELCScSoii-rms to- Revision 2, 1973

U7-C-STP-NRC-090009Enclosure 2b

Page 1 of 2

Revisions to COLA Tier 2 Section 1.9S

The following RGs, Codes and Standards Conformance are applicable to I&C platformdepartures, and these changes are addressed in Tables 1 .9S-1I and new Table 1.9S-lIa:

Table 1.9S-1 Site-Specific Conformance with Regulatory GuidesNo. Title Rev.

Division Ia 4t Bypassed- and lnoperable ýýa~sIdiainf~ Nucýlear.Pow jt Safet :01(197 32

§y~stenms1.53 Application of the Single-Failure Criterion to Safety Systems 2 (11/03) forRTIS/TMM9

bOfgj3) -for ELCS

1.75 Independence of Electrical Safety Systems 3 (2/05) frRTlSFNM'92(97)2for~ ELS

1100 O Se-i'smic Quaflfflction 'of Electric ad lAehncaEqip-nfoNulr-Pwr2(981,'

971i9 Pe'i~ic Testing ofEeti oe adPoet 3 R5) fo 17NS2(1_P78)? for EL~CS

71.i5ý1 Criteria for Use of ComputersinSaeySytem s ofNuclear Power F5a's 206)1:for RTIS/NMF1 (1996)'.for ELS

1.168 Ver -ification, Validation, Re'views andAudits for Diia'-Cmu r ftwa , r :1 ( o)lfo fTTs/Nf~FUsdi aeySseso Nuclear Power Plants 0(11 987)'frEC

Safe LJrtinM n agement Plan s for Digital Comnputer Software Used in 0, `67)1.2Sfty Systemns of Nuclear~ Power Plants

1.170 Software T~est Documentation fo Diia optIe atwt sdi aey 0j_ Systems of Nu~clear Power Plants

1.1~71: SoftwareLUnit Testing for Digital CoptrSfwr sdi ae n O(11997)ýof'Nuclear Power Plants ysýe

1.172 SotaeRqieet Spec6ificationsfor~ DigtaloptSfwaeUd in 01199~Safe'ty Sysrns o~f Nuclear Power Plantis I_

11~73 Developing SotaeLf CyclePoesfrDgtaoptrSfwre Uedi 0 (997)Safety Systems of Nuclear Power Plants

~1.180 <Guidelines for Evaluiatinrg Electromag~netic and Radio- Frequenicy Interference~ lj?0~qM)',for RTI/j4ýySinSafety-RelatedInt~rumentation and CotoSsems ntuetto and ~(o'Oýbb2 tfoir ELGS

[1&9g quideines for, Eni netlQaiiain-o Safety- -Related, com -Rqased 0,O frRIS'MIns~trumentation and Control System in Nuclear Poe Pat 3foýELC'S3

~' The ToshibaT0blA-F PGA-platform has .been sub mitte for Ig -ener Iic revi -ew ,as descrIi -bed in Thpical- Re IpgxI o-"UTLR--O000ij7P~, ReY.9j

2The Common 0"'Digital Platformr was submitted for genenic use an a pproved for reference as described iqn~Topical Report-GAP1 6097'P- 'vi660, '"eommii-(Qualiid Platforhi ATo~i~c R~rbt.`,is topiclrbportincludes the SERs dated Aug~ust '14,ý2000, June 22, 2001, and"'February 4 3,ad is consistent with thereferenced-industry standiards and Regulatory Guides that reeeneNoe2-Teesinghouse 'SfwrProgram MariuaI for Commbnn`Q System§ S~PM), WCAP1 606-NP-A also inoprts tnad and,Regulatory Guide require'ments. The requiremnents that this platform wer~elicensed to' are submitted as anacce~ptabeAlt~erna'tie toctirrenttreý'quiireifn'hetsý bCe~ a,~~eiwad~S~&hstfia~ piwas~e'iewed against Rev. 2,(1978),- ____________

RG 1209 nd, Ig~E2~-203 IEE ~22~1 83 ~ andas~d-7n

U7-C-STP-NRC-090009Enclosure 2b

Page 2 of 2

Table 1.9S-1a FEEE Standards Applicable to the ST~P 3&4 Platformus

WEEE No.- I Category hIEEE 7-4.3.2 DigitalComputers and.Softwae 6Q' 20'for RTIS/jy3

_ 1'993 fr ELCSIEEE 323 EQ 20031for RTIS/NMS

____ ___ ___ __ ___ ___ ___ ___ ___ ___ ___ ___ __ 1983 2for ELCS~

IEEE 3~38 Periodic Testind ~1987IEEE E344, . eismnic 11987' for RTIS/NMS

________________~~~~~~~~ ___________987____________ i~ 2~forELCSIEEE 379 Sigl FalZ 0001 for RTIS/NMS

_________"1 994 2for, ELCSIEEE 384 Independence 11992IEEE 603 I&C 1199 fJIEEE 828 Configuration, Management 1990IEEE 829 Software Test Documien~tation' 1983IEEE 830 'Software R~eguiremhents Specificationsý ý1993'IEEE 1009 Software Unit Testing .1~987~

IEEE 1012 V 1,998IEEE 1~028 Softwre Reviews and, Audits il 997,IEEE 1042 Software Configration Managem~ent 11987I1EEE 1074 S--5oftware L~ifeCycle Progesses' ll 995

e'TshbaOSDA-PGp~af~rnhasbetuihmitted mognrceiw~~ie ii op ica Reýpot TUJTJR-OO01iP

2IhL Comm, Qýii~ if~ a ubmkied for Luse Wi~~va pvd f~ eeeedecriibd iihT~pkAlReporLWCý(AP-16O97-1P2A. ,%~o 0,~1 "( o mi uhhdPltrm opa cot. iýtopical re:portmlu,ý

a i{ prt rtctcald)kdCa1 s ato Gu ric re u iirem en sAl he re( u iremeo ts i) t htc ils

P an prci ........t'd 11 111)tc 1 1)1:~ 11~ lc~ t oo rciii m ci, nt)ýo ý; u P 'ive_

U7-C-STP-NRC-090009Enclosure 2c

Page 1 of 1

Revisions to COLA Tier 2 Section 7.1

The following changes will be made to Table 7.1-2, heading row, to address the applicability of a more recent IEEE code, due toSTD DEP 1.8-1:

Table Reguatory Rquirements Ap-J ifc-a-bi-iiiij Matrix' f~ori& AM~ 'yitms

Refeirence Stiiaridor 229:

I-- - ______•r? i :• "

T•aile 7.1-2 R••ntinued)

Regulatory Quide BTP I lI.Q '17 -1-F 11-K•E

fteterence-Standard rL)


Revisions to COLA Part 7 Section 2.1

Description

The description of STD DEP TI 3.4-1 Safety-Related I&C Architecture will be revised asfollows:

This departure can be characterized into five primary changes.

(1) Elimination of obsolete data communication technology

The departure eliminates references to the Essential Multiplexer System (EMS) and theNon-Essential Multiplexer System (NEMS) originally envisioned in the ABWRarchitecture and replaces them with separate and independent system level datacommunication capabilities. The original concept was based on a common EMS, whichcould be used by multiple safety-related, digitally-based protection systems. Thisdeparture defines separate dedicated data communication functions for each safety-related digital platform, including separate and independent data communicationfunctions for each division within a system. The-iwi, _4al ccers expressed NRCTelat d to the c~eafifSo -4 rtAppendix 7A and, y,-,hae s beenupdated to reflect the separate communication capabilities.

4h A dition, tthe ruercnc odWfr DqDivese)tifori m u for the (at eor Tri n d I slcationfrst~ANJSI X3 Seie!,. Fibtfr DiiitttlPt

fo be m DDI is ant o omoete node filro lner aP.ropri.

Tabe I lrovide fo aI e ]robSusI ta comuicatio of a cesintsioncea cpr iirieicdtiesne fkailurwpillcause lets~st h cdegr ication fthtind peonncmmunication functionsthanthe

System seminedand the Engioneere Sactithres ogicnd tr s(ELCS). This feature allows the overall Safety System Logic and Control (SSLC)to be more resistant to common mode failure.

0 Provides for a more robust communication design since a credible single failurewill cause less degradation to independent communication fuinctions than thesingle failure would cause in the centralized, common essential multiplexingsystem defined in the DCID.


" The new design is not subject to a single common cause failure disabling both theRTIS and ELCS. In the DCD design, common cause failure within the EMSwould disable both RTIS and ELCS.

" Provides the flexibility to utilize communication technologies that have benefitsin the areas of simplicity of function and improved independence, such as the useof "point to point" unidirectional data links

I-liei-cference A 11%\R DCD id~entihicd use f the:data communicattioni s'tandacrd AN SI-X3)senJC, I-IIet)I•sel- eomi'eatioe rotoc

TheTIHS LISCdirect hai-wir&Iinputs tothe systemr instead of the concept ofusimgI7rImoteiiMultiplexers as descrilbed m ~the certified ABWR DCD. This sigmflI-canltly redl-ce~

t~ecl-~eit" ~of data commiiunication requireire'iis for this sy~steni, while contmuing, toineet ABWRDCatD IeLentiona1requiremnents'

'IThie EL CScnt]inueCs to uISe r C aIc(LIISIti~nofsgnra information and remote output ofcomman1111d Iinform11ation1 to contr~olled comnponeiits.~ 'T'ie LCS will utilize seniall

77-.

Tunidirectionl, ofiher oticaiplexeraoneptrqed dalinkseinstes of the'FDDI protocol. The__dLCS vnldor's piatform, Iclmponent the ISeplOfacd w ioth nal g serial data olinks, has teeii

heNI cmlmuicatei ncid app r imard by the N scri b desdribe F in Topical ReT1ort W( T2AP-16O17-PA;:R~riskn (;, "Coinm1nQLif1d latfdrm TOpiCal Report," and has 72T2.3ratin7g( Xpe2eiceIn U. S. tuclesary ipadvertent acu ti eni T hlogi Ts demoenst.erTe r etfe oden AWof cmdui scatione methe dregilatoig and industry standard

quirements adsigcawea to saft i dath c potim encation.

The elimination of the multiplexer concept required all references to thednatetsfhandwial Iadftipexing SStw-tf (w 2S) gid onecssntial Muliplerxirg Systemn (NEMS)and Botheir primary components to be replaced with a generic data communicationreference. The terms EMS and NEMS were eliminated along with Remote MultiplexerUnit (RMU) and Control Room Multiplexer Unit (CMU).

The communication functions are primarily described in FSAR Sections TI 2.2, TI 2.7,TI 3.4, T2 7.2, T2 7.3 and T2 7.9S.

(2) Elimination of unnecessary inadvertent actuation prevention logic and equipment.

The reference ABWVR DCD described the design of the Engineered Safety Features (ESF)actuation outputs as being fully redundant within each division of the ESF digital controlssystems. This design was to minimize the potential for false actuation of ESFcomponents. In the design, each output was processed through two redundant sets ofhardware and a final two-out-of-two (2/2) logic decision was performed on a componentlevel. Both sets of outputs had to demand actuation before a component would actuallyrespond. As part of the detailed design of the ABWVR ESF digital controls, it was


determined that only selected ESF components required the redundant actuationprevention logic. f c t4at.... . ........ .....• p.i.t . ... ... ....most of th eSF... ..... nts

db~no . 1aCoa - dzs kiipc I -L+~j tile ~4c~ pla!t. Thle limiited stet otr atlnens ethat ca bL ell dSt the

isolation ov ti kith deditndctntostuaniomn elauiueieais altgic

The roeferneB R dlp emintng4ile manyre at afunctioig requirements i a on) to ber adtoeimient to the dension associated with purely fuctia r mnt and nte~mphile prequidinre difine in thte plant. elixabilites iAs e:

S igial TimpleMc~odul (DMpo DigtalTri Fuctini(TF

• Saety ystm Loic nit SLU tohafty S~ystem pLagcFnction (SLF)raton

4)a y dang Comlputler tem (P S) tio Plan t Compute Functi (PCF.

The adeition, atcbtteri login c is only im plementte foration of ahe dgt lsinlem compondent Pra ointiate failse potective actions dinig itnoal plntr t olpre ationi. ForthMpenE S suchtas ate de CS Automatic Depressuoic atiCon System (ADS), a alve

Iunc ill ons a resiplme the reactors For such compons:nthe a TwOSseqmied to(T actuate Neah tvale 0ith two S N . temSfety vote istheir-C o IW~c a1 %výwiht~ different progyrammrable logiyc 'onrolle~rs aind

separte ~pt an oup dpukýes withini.a singýle dkivisioii,fAS a resu;ltý, the redunidaiit actuation lo(gic i only imp e iein o p n ns h tm

inipacýt plan~t safr-ty o1# operation1 1f'actUAted during nqrmiaI pl1alt 01per-ýatiI suIch aIs theCEC.CS fun~ctionis of thec E,'C', is d'escibed in FSAR S"e&tion V1 3.4.

(3) Clarifications of digital controls nomenclature and systems

The reference ABWR DCD defined many functional design requirements in termstypically reserved for hardware. Examples include the terms "module," "unit,"and "system." The terminology was corrected to refer to the requirement as a "fuinction"

to eliminate the confusion associated with purely functional requirements and notphysical requirements defined in the DCD. Examples include:

" Digital Trip Module (DTM) to Digital Trip Function (DTF)

" Trip Logic Unit (TLU) to Trip Logic Function (TLF)

" Safety System Logic Unit (SLU) to Safety System Logic Function (SLF)

" Plant Computer System (PC S) to Plant Computer Functions (PCF)

" Essential Multiplexer System (EMS) to Essential Communication Function (ECF)

In addition, to better define the functional design and implementation of the digitalcontrols platforms, specific I&C system names were assigned to the ESF digital controlssystems and the Reactor Protection System (RPS). The digital controls responsible forthe ESF systems are designated as the ESF Logic & Control System (ELCS). The RPSfunctions are implemented in two separate I&C systems: the Reactor Trip & IsolationSystem (RTIS) and the Neutron Monitoring System (NMS). The term Safety System


Logic & Control (SSLC) was clarified as a general term used to cover all of the logic andcontrols associated with safety-related control systems.

The nomenclature changes required datg several sections of the original DCD tomake all sections of the STP 3&4 COLA consistent.

(4) Final selection of platforms changed the implementation architecture

This departure revises the implementation architecture to use configurable logic devicesfor NMS and RTIS in lieu of microprocessors. Tlls latform cliange was necessýirytoilcr~rt viaeIIaiomsta etIol tre ij-i~toy% aid tcchiiiciq !recjuiremencts.These design updates are primarily described in Tier 2 Section 7.2.

(5) Testing and surveillance changes for SSLC

This departure revises the testing and surveillance descriptions for SSLC (NMS, RTIS,and ELCS) consistent with the characteristics of the design platforms selected. Thesechanges are primarily described in Tier 2 Section 7.1.

Additionally, the Chapter 16 Technical Specifications Section 3.0 is modified to reflectthe above changes to the safety-related I&C architecture.

Compliance Review for STP 3&4 COLA U7-C-STP-NRC-090009Enclosure 4aPage I of 20

Conformance of STD DEP T1 3.4-1 with Regulatory Guide 1.206

Criteria Description Departure EvaluationC.1.7.1.1 Identification of Safety-Related Elimination of obsolete data communication This departure has no impact on the

Systems technology identification of safety related systems.Elimination of unnecessary inadvertent This departure has no impact on theactuation prevention logic and equipment. identification of safety related systems.Clarifications of digital controls nomenclature This departure has no impact on theand systems identification of safety related systems.Final selection of platforms changed the This departure has no impact on theimplementation architecture identification of safety related systems.Testing and surveillance changes This departure has no impact on the

identification of safety related systems.C. 1. 7.1.2 Identification of Safety Criteria Elimination of obsolete data communication This departure has no impact on the

technology safety criteria. The new communicationtechnology continues to meet therequired industry standards andregulatory criteria as described in theR.G. and industry standards evaluationdescribed in Table 1.9S-1 and Table1.9S-1 a

Elimination of unnecessary inadvertent This departure has no impact on theactuation prevention logic and equipment. safety criteria. The design continues to

meet the required industry standards andregulatory standards as described in theR.G. and industry standards evaluationdescribed in Table 1.9S-1 and Table1.9S-1 a.

Compliance Review for STP 3&4 COLA U7-C-STP-NRC-090009Enclosure 4aPage 2 of 20


Criteria Description Departure EvaluationClarifications of digital controls nomenclature This departure has no impact on theand systems safety criteria. The design continues to

meet the required industry standards andregulatory criteria as described in theR.G. and industry standards evaluationdescribed in Table 1.9S-1 and Table1.9S-la

Final selection of platforms changed the Conforms. This departure resulted in theimplementation architecture imposition of Regulatory Guides and

Standards that are more recent than thestandards of the ABWR DCD. See theR.G. and Industry standard evaluationprovided in Table 1.9S-1 and Table 1.9S-la

Testing and surveillance changes This departure has no impact on thesafety criteria. The modified testing andsurveillance continues to meet therequired criteria

C.1.7.2 Reactor Trip SystemC.1.7.2.1.1 System Description Elimination of obsolete data communication Conforms. This departure is described in

technology the revised COLAElimination of unnecessary inadvertent Conforms. This departure is applicableactuation prevention logic and equipment. only to the ELCS, not the RPS.Clarifications of digital controls nomenclature Conforms. This departure is described inand systems the revised COLAFinal selection of platforms changed the Conforms. The areas in the systemimplementation architecture description that were affected by this

departure are described in the revisedCOLA

Testing and surveillance changes Conforms. The areas in the descriptionaffected by this departure are describedin the COLA.



Criteria Description Departure EvaluationC.1.7.2.1.2 Design Basis InformationC.1.7.2.1.2 Single Failure Criterion Elimination of obsolete data communication Conforms. The use of unidirectional,

technology serial point to point data links with fiberoptic communication media continues tomeet the single failure criterion.

Elimination of unnecessary inadvertent This departure is applicable to ELCSactuation prevention logic and equipment. only. The overall design, including this

departure, continues to meet the singlefailure criterion.

Clarifications of digital controls nomenclature This departure has no impact onand systems compliance to the single failure criterion.Final selection of platforms changed the Conforms. The implementationimplementation architecture architecture will meet the single failure

criterion as described in the complianceevaluation described in Table 1.9S-1 andTable 1.9S-la.

Testing and surveillance changes for SSLC This departure has no impact oncompliance to the single failure criterion.

C.1.7.2.1.2 Quality of Components and Modules Elimination of obsolete data communication These departures have no impact on thetechnology requirements for the quality ofElimination of unnecessary inadvertent components and modules.actuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architecture

I_ I Testing and surveillance changes



Criteria Description Departure EvaluationC.1.7.2.1.2 Defense in Depth and Diversity Elimination of obsolete data communication Conforms. This departure has no

technology negative impact on the ABWR DCDdescription of defense in depth anddiversity. The RPS will be utilizingdifferent communication hardware andsoftware from the ELCS. As a result ofnot utilizing a central EMS, as originallydescribed in the ABWR DCD, thediversity between the RPS and the ELCSis increased.

Elimination of unnecessary inadvertent This departure has no impact on theactuation prevention logic and equipment ABWR DCD description of defense in

depth and diversity.Clarifications of digital controls nomenclature This departure has no impact on theand systems ABWR DCD description of defense in

depth and diversityFinal selection of platforms changed the Conforms. This departure has noimplementation architecture negative impact on the ABWR DCD

description of defense in depth anddiversity. Since the RPS will be utilizingdifferent hardware and software from theELCS, the diversity between the RPSand the ELCS is increased.

Testing and surveillance changes This departure has no impact on theABWR DCD description of defense indepth and diversity

C.1.7.2.1.2 System testing and inoperable Elimination of obsolete data communication Conforms. This departure does notsurveillance technology change the commitment to meet the

Elimination of unnecessary inadvertent requirements for system testing andactuation prevention logic and equipment inoperable surveillance. The COLA

describes the self-test changes for datacommunication that result from the

I I_ technology changes.


Conformance of STD DEP TI 3.4-1 with Regulatory Guide 1.206

Criteria Description DeDarture EvaluationEvlato

Clarifications of digital controls nomenclatureand systems

This departure has no impact on thesystem test or inoperable surveillance

Final selection of platforms changed theimplementation architecture

This departure does not change thecommitment to meet the requirements forsystem testing and inoperablesurveillance.

Testing and surveillance changes for SSLC Conforms. This departure resulted in achange the detailed description ofperiodic testing and on-line self testing.The scope of automatic on-line selftesting was reduced and the scope ofperiodic testing that was manuallyperformed or manually initiated wasincreased. The departure is described inthe revised COLA. The departure meetsReg. Guide 1.22 requirements forsurveillance and testing. See R.G. andindustry standards in Table 1.9S-1 andTable 1.9S-1a.

C.1.7.2.1.2 Use of Digital Systems Elimination of obsolete data communication Conforms. SRP Chapter 7, Appendixtechnology 7.0-AElimination of unnecessary inadvertent These departures do not impact theactuation prevention logic and equipment review process outlined in SRP ChapterClarifications of digital controls nomenclature 7 Appendix 7.OA. The deviations fromand systems the Reg. Guides and industry standardsFinal selection of platforms changed the necessitated by the departure areimplementation architecture described and evaluated in Table 1.9S-1Testing and surveillance changes and Table 1.9S-la.

C.1.7.2.1.2 Setpoint Determination Elimination of obsolete data communication These departures have no impact on thetechnology methodology utilized for setpointElimination of unnecessary inadvertent determination.

I actuation prevention logic and equipment



Criteria Description Departure EvaluationClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

C.1.7.2.1.2 Equipment Qualification Elimination of obsolete data communication These departures have no impact on thetechnology equipment qualification requirementsElimination of unnecessary inadvertent described in the ABWR DCD.actuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

C.1.7.2.2 AnalysisC.1.7.2.2 GDC requirements Elimination of obsolete data communication These departures have no impact on the

technology compliance to the GDCs.Elimination of unnecessary inadvertentactuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

C.1.7.2.2 IEEE Std 603 Elimination of obsolete data communication These departures have no impact on thetechnology compliance to IEEE Std 603.Elimination of unnecessary inadvertentactuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architecture

I Testing and surveillance changes



Criteria Description Departure EvaluationC.1.7.2.2 IEEE Std 7-4.3.2 Elimination of obsolete data communication These departures have no impact on the

technology compliance to IEEE Std 7-4.3.2.Elimination of unnecessary inadvertentactuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

C.1.7.2.2 Postulated accidents and failures Elimination of obsolete data communication These departures have no impact on thetechnology required performance of the RTIS.Elimination of unnecessary inadvertentactuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architecture

I Testing and surveillance changesC.1.7.3 Engineered Safety Feature SystemsC.1.7.3.1.1 System Description Elimination of obsolete data communication Conforms. This departure is described in

technology the COLA description for ELCS.Elimination of unnecessary inadvertentactuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes



Criteria Description Departure EvaluationC.1.7.3.1.2 Design Basis InformationC.I.7.3.1.2 Single Failure Criterion Elimination of obsolete data communication Conforms. The use of unidirectional,

technology serial point to point data links forcommunicating safety functioninformation rather than the FDDIimplementation described in the ABWRDCD does not change the ELCSsystem's compliance to the single failurecriterion.

Elimination of unnecessary inadvertent This departure has no impact onactuation prevention logic and equipment compliance to the single failure criterion.Clarifications of digital controls nomenclature This departure has no impact onand systems compliance to the single failure criterion.Final selection of platforms changed the The design, including this departure,implementation architecture continues to meet the single failure

criterion.Testing and surveillance changes This departure has no impact on

compliance to the single failure criterion.C.1.7.3.1.2 Quality of Components and Modules Elimination of obsolete data communication This departure has no impact on the

technology quality of components and modules.Elimination of unnecessary inadvertent This departure has no impact on theactuation prevention logic and equipment quality of components and modules.Clarifications of digital controls nomenclature This departure has no impact on theand systems quality of components and modules.Final selection of platforms changed the Conforms. ELCS, RTIS, and NMSimplementation architecture platforms will be provided by qualified

vendors utilizing approved QualityAssurance methods.

Testing and surveillance changes This departure has no impact on thequality of components and modules.



Criteria Description Departure EvaluationC.1.7.3.1.2 Independence Elimination of obsolete data communication Conforms. The use of unidirectional,

technology serial point to point data links that utilizefiber optic communication media meetthe independence requirements imposedby Reg. Guides and standards asdescribed in Table 1.9S-1 and Table1.9S-la.

Elimination of unnecessary inadvertent This departure has no impact onactuation prevention logic and equipment independence.Clarifications of digital controls nomenclature This departure has no impact onand systems independence.Final selection of platforms changed the This departure has no impact onimplementation architecture independence as described in the

"elimination of obsolete communicationtechnology" in Table 1.9S-1 and Table1.9S-1 a.

Testing and surveillance changes This departure has no impact onindependence.

C.1.7.3.1.2 Defense in Depth and Diversity Elimination of obsolete data communication Conforms. This departure has notechnology negative impact on the ABWR DCD

description of defense in depth anddiversity. The ELCS will be utilizingdifferent communication hardware andsoftware from the RPS. As a result of notutilizing a central EMS, as originallydescribed in the ABWR DCD, thediversity between the ELCS and the RPSis increased.

Elimination of unnecessary inadvertent This departure has no impact to theactuation prevention logic and equipment ABWR DCD description of defense in

depth and diversity.

Compliance Review for STP 3&4 COLA U7-C-STP-NRC-090009Enclosure 4a

Page 10 of 20


Criteria Description Departure EvaluationClarifications of digital controls nomenclature This departure has no impact to theand systems ABWR DCD description of defense in

depth and diversity.Final selection of platforms changed the Conforms. This departure has noimplementation architecture negative impact on the ABWR DCD

description of defense in depth anddiversity. Since the ELCS will be utilizingdifferent hardware and software from theRPS, the diversity between the ELCSand the RPS is increased.

Testing and surveillance changes This departure has no impact on theABWR DCD description of defense indepth and diversity.

C.1.7.3.1.2 System Testing and Inoperable Elimination of obsolete data communication Conforms. This departure does notSurveillance technology change the commitment to meet the

requirements for system testing andinoperable surveillance. The COLAdescribes the self-test changes thatresult from the technology changes.

Elimination of unnecessary inadvertent Conforms. This departure does notactuation prevention logic and equipment change the commitment to meet the

requirements for system testing andinoperable surveillance. The COLAdescribes the self-test changes thatresult from the technology changes.

Clarifications of digital controls nomenclature This departure has no impact on theand systems system test or inoperable surveillance.Final selection of platforms changed the This departure does not change theimplementation architecture commitment to meet the requirements for

system testing and inoperablesurveillance. See testing andsurveillance changes described in thenext item.


Page 11 of 20


Criteria Description Departure EvaluationTesting and surveillance changes Conforms. This departure does not

change the commitment to meet therequirements for system testing andinoperable surveillance. This departureresulted in a change to the detaileddescription of periodic testing and on-lineself testing. The scope of automatic on-line self testing was reduced and thescope of periodic testing that wasmanually performed or manually initiatedwas increased. The departure isdescribed in the revised COLA. Thedeparture meets Reg. Guide 1.22requirements for surveillance and testing.See R.G. and industry standardsevaluation in Table 1.9S-1 and Table1.9S-la.

C.1.7.3.1.2 Use of Digital Systems SRP Chapter 7, Appendix 7.0-AThese departures should not impact thereview process outlined in SRP Chapter7 Appendix 7.OA. The deviations fromthe Reg. Guides and industry standardsnecessitated by the departure aredescribed and evaluated in Table 1.9S-1and Table 1.9S-la.

C.l.7.3.1.2 Setpoint determination Elimination of obsolete data communication These departures have no impact on thetechnology methodology to determine setpoints.Elimination of unnecessary inadvertentactuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes


Page 12 of 20


Criteria Description Departure EvaluationC.1.7.3.1.2 ESF control systems Elimination of obsolete data communication These departures do not change the

technology functional design for the ESF controls.Elimination of unnecessary inadvertent Therefore there is no impact of theseactuation prevention logic and equipment departures on the ABWR DCDClarifications of digital controls nomenclature descriptions of the ESF control systems.and systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

C.I.7.3.1.2 Equipment qualification Elimination of obsolete data communication These departures have no impact on thetechnology equipment qualification requirementsElimination of unnecessary inadvertent described in the ABWR DCD and COLA.actuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

C.1.7.3.2 AnalysisC.1.7.3.2 GDCs Elimination of obsolete data communication These departures have no impact on the

technology compliance to the GDCs.Elimination of unnecessary inadvertentactuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

C.1.7.3.2 IEEE Std 603 Elimination of obsolete data communication These departures have no impact on thetechnology compliance with IEEE Std 603Elimination of unnecessary inadvertentactuation prevention logic and equipment


Page 13 of 20



C.1.7.3.2 IEEE Std 7-4.3.2 Elimination of obsolete data communication Deviation. The supplier of the ELCStechnology platform has received a generic reviewElimination of unnecessary inadvertent and approval of the digital platform. Theactuation prevention logic and equipment NRC review of the platform utilized aClarifications of digital controls nomenclature previous revision of IEEE-Std-7-4.3.2.and systems Based on the previous review and NRCFinal selection of platforms changed the approval, the version of the standard thatimplementation architecture was utilized by the NRC in their review isTesting and surveillance changes an acceptable alternative to the revision

indicated in the current SRP.C.1.7.3.2 Postulated accidents and failures Elimination of obsolete data communication This departure has no impact on the

technology required ELCS performance forpostulated accidents and failures

Elimination of unnecessary inadvertent Conforms. This departure has noactuation prevention logic and equipment negative impact on the ability of the

system to provide the safety actuationfunction in the event of a single, crediblefailure. The arrangement of actuatedcomponents, such as pumps and valves,assigned to controllers is such that asingle failure will not result in aninadvertent actuation of the safetyfunction.

Clarifications of digital controls nomenclature This departure has no impact on theand systems required ELCS performance forFinal selection of platforms changed the postulated accidents and failuresimplementation architectureTesting and surveillance changes


Page 14 of 20


Criteria Description Departure EvaluationC. 1. 7.4 Systems Required for Safe Shutdown Elimination of obsolete data communication These departures have no impact on the

technology Systems required for Safe Shutdown.Elimination of unnecessary inadvertentactuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

CA .7.5 Information Systems Important to Elimination of obsolete data communication These departures have no impact onSafety technology Information Systems Important to Safety

Elimination of unnecessary inadvertentactuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

C.1.7.6 Interlock Systems Important to Safety Elimination of obsolete data communication These departures have no impact on thetechnology Interlock Systems Important to SafetyElimination of unnecessary inadvertentactuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

C.1.7.7 Control Systems Not Required for Elimination of obsolete data communication These departures have no impact on theSafety technology Control Systems Not Required for Safety

Elimination of unnecessary inadvertentactuation prevention logic and equipmentClarifications of digital controls nomenclatureand systems


Page 15 of 20


Criteria Description Departure EvaluationFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

C. 1. 7.8 Diverse Instrumentation and Control Elimination of obsolete data communication Conforms. These departures have noSystems technology negative impact on Diverse

Elimination of unnecessary inadvertent Instrumentation and Control Systems.actuation prevention logic and equipment The RTIS and ELCS are implemented onClarifications of digital controls nomenclature different platforms, enhancing theand systems diversity between these two systems.Final selection of platforms changed theimplementation architecture

I Testing and surveillance changesC.1.7.9 Data CommunicationC. 1. 7.9.1 System Description Elimination of obsolete data communication This departure is described in the COLA

technologyElimination of unnecessary inadvertent This departure has no impact on Dataactuation prevention logic and equipment Communications System DescriptionClarifications of digital controls nomenclature Conforms. The new nomenclature isand systems utilized to describe data communications

in the COLA.Final selection of platforms changed the Conforms. The data communicationsimplementation architecture departures are described in the COLATesting and surveillance changes Conforms. The departure is described in

the COLA as it pertains to datacommunication.


Page 16 of 20


Criteria Description Departure EvaluationC.I.7.9.2 Design Basis InformationC.1.7.9.2 Quality of Components and Modules Elimination of obsolete data communication Conforms. ELCS, RTIS, and NMS

technology platforms will be provided by qualifiedElimination of unnecessary inadvertent vendors utilizing approved Qualityactuation prevention logic and equipment Assurance methods.Clarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

C.1.7.9.2 Data Communication System (DCS) Elimination of obsolete data communication These departures have no impact onsoftware quality technology data communication quality.

Elimination of unnecessary inadvertentactuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

C.1.7.9.2 Protocol selected for the DCS should Elimination of obsolete data communication The communication protocols thatmeet the performance of all supported technology replace the obsolete FDDIsystems communication method are required to

meet the required system performancerequirements. The departure does notchange the requirements, only themethod of meeting them.

Elimination of unnecessary inadvertent This departure has no impact.actuation prevention logic and equipment.Clarifications of digital controls nomenclature This departure has no impact.and systemsFinal selection of platforms changed the This departure has no impact.implementation architecture

I Testing and surveillance changes This departure has no impact.


Page 17 of 20


Criteria Description Departure EvaluationC.1.7.9.2 Potential hazards to the DCS Elimination of obsolete data communication The COLA describes the self-testing, and

including inadvertent actuation, error technology surveillance testing departuresrecovery, self-testing, and associated with the departures.surveillance testing Elimination of unnecessary inadvertent Conforms. This departure has no

actuation prevention logic and equipment. negative impact on the ability of thesystem to provide the safety actuationfunction in the event of a single, crediblefailure.

Clarifications of digital controls nomenclature This departure has no impact.and systemsFinal selection of platforms changed the Conforms. The COLA describes the self-implementation architecture testing and surveillance changes

associated with the departure. Thedesign continues to conform to industrystandard and R.G. requirements.

Testing and surveillance changes Conforms. Testing and surveillancechanges are described in the COLA.

C.1.7.9.2 Access control to DCS Elimination of obsolete data communication These departures have no negativetechnology impact on the compliance to theElimination of unnecessary inadvertent requirements for access control to DCS.actuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes


Page 18 of 20


Criteria Description Departure EvaluationC.I.7.9.2 Consequential failure as a result of Elimination of obsolete data communication Conforms. The departure of a

using single path for multiple signals technology centralized communication system usingand appropriate assignment of FDDI to separate systems for RPS andchannels to ensure redundancy and ELCS that utilize unidirectional serialdiversity point to point data links reduces the

effect of consequential failures that resultfrom a single failure. This result occursbecause multiple point to point linksreplace a single set of FDDIcommunication paths.

Elimination of unnecessary inadvertent These departures have no impact on theactuation prevention logic and equipment DCS consequential failures.Clarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

C.1.7.9.2 See IEEE 603 for Independence Elimination of obsolete data communication These departures have no impact ontechnology compliance to IEEE Std 603. TheElimination of unnecessary inadvertent required independence is maintained.actuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architecture



Page 19 of 20


Criteria Description Departure EvaluationC. 1. 7.9.2 Fail into a Safe State or State Elimination of obsolete data communication This departure has no impact on the

Determined to be Acceptable technology requirement or the ability of the systemdesign to meet this requirement

Elimination of unnecessary inadvertent Conforms. This departure has noactuation prevention logic and equipment negative impact on the ability of the

system to provide the safety actuationfunction in the event of a single, crediblefailure.

Clarifications of digital controls nomenclature This departure has no impact.and systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

C. 1. 7.9.2 System Testing and Surveillances Elimination of obsolete data communication Conforms. The impact on system testingtechnology and surveillance is described in theElimination of unnecessary inadvertent COLA. System testing and surveillanceactuation prevention logic and equipment requirements continue to be metClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

C. 1. 7.9.2 Status Of DCS in the Design and Elimination of obsolete data communication These departures have no impact on theInoperable Status Indications technology requirement or ability of the design to

Elimination of unnecessary inadvertent meet bypass and inoperable statusactuation prevention logic and equipment indication requirements.


Page 20 of 20



C.1.7.9.2 Communication Media Relative to Elimination of obsolete data communication The departure has no impact on theFault Propagation technology communication media relative to fault

Elimination of unnecessary inadvertent propagation.actuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architectureTesting and surveillance changes

C.1.7.9.3 Analysis of Conformance to Reg. Elimination of obsolete data communication Partial conformance. Reg. Guides andGuides, Industry Standards, GDC 1, technology industry standards are described in Tableand 10 CFR 50.55a(a)(1) Elimination of unnecessary inadvertent 1.9S-1 and Table 1.9S-la.

actuation prevention logic and equipmentClarifications of digital controls nomenclatureand systemsFinal selection of platforms changed theimplementation architecture


Compliance Review for STP 3&4 COLA U7-C-STP-NRC-090009Enclosure 4b

Page 1 of 8

Conformance of STD DEP T1 3.4-1 with SRP 7.2 Acceptance Criteria for the RTIS/NMS Departures

SRP 7.2 Description Departure EvaluationAcceptance

CriteriaRequirements1 10 CFR 50.55a (a) (1), "Quality Elimination of obsolete data These departures have no impact on the

Standards." communication technology, compliance to the requirement.

Clarifications of digital controlsnomenclature and systems,

Final selection of platforms changedthe implementation architecture,

Testing and surveillance changes forthe SSLC.

2 10 CFR 50.55a(h) Elimination of obsolete data These departures have no impact on the(IEEE Std 603-1991) communication technology, compliance to the requirement.

Clarifications of digital controls The referenced standard is included in thenomenclature and systems, Regulatory Guides, Codes and Standards

Conformance Table that describesFinal selection of platforms changed Regulatory Guide and industry standardthe implementation architecture compliance.

Testing and surveillance changes forthe SSLC


Page 2 of 8

Conformance of STD DEP T1 3.4-1 with SRP 7.2 Acceptance Criteria for the RTISINMS Departures


Criteria3 10 CFR 50.34(f), "Additional TMI-

Related Requirements,"10 CFR 50.34(f), (2) (v), "Bypass Elimination of obsolete data These departures have no impact on theand Inoperable Status Indication." communication technology, compliance to this requirement.




10 CFR 50.34(f), (2) (xxiii), Not applicable to the ABWR."Anticipatory Trip on Loss of MainFeedwater or Turbine Trip."

4 10 CFR 50, Appendix A, General Elimination of obsolete data These departures have no impact on theDesign Criterion (GDC) 1, "Quality communication technology, compliance to this requirement.Standards and Records."





Page 3 of 8

Conformance of STD DEP TI 3.4-1 with SRP 7.2 Acceptance Criteria for the RTISINMS Departures


Criteria5 GDC 2, "Design Basis for. Elimination of obsolete data These departures have no impact on the

Protection Against Natural communication technology, compliance to this requirement.Phenomena."




6 GDC 4, "Environmental and Missile Elimination of obsolete data These departures have no impact on theDesign Basis." communication technology, compliance to this requirement.





Page 4 of 8

Conformance of STD DEP TI 3.4-1 with SRP 7.2 Acceptance Criteria for the RTIS/NMS Departures


Criteria7 GDC 10, "Reactor Design." Elimination of obsolete data These departures have no impact on the

communication technology, compliance to this requirement.




8 GDC 13, "Instrumentation and Elimination of obsolete data These departures have no impact on theControl." communication technology, compliance to this requirement.





Page 5 of 8

Conformance of STD DEP TI 3.4-1 with SRP 7.2 Acceptance Criteria for the RTIS/NMS Departures


Criteria9 GDC 15, "Reactor Coolant System Elimination of obsolete data These departures have no impact on the

Design." communication technology, compliance to this requirement.




10 GDC 19, "Control Room." Elimination of obsolete data These departures have no impact on thecommunication technology, compliance to this requirement.





Page 6 of 8

Conformance of STD DEP TI 3.4-1 with SRP 7.2 Acceptance Criteria for the RTISINMS Departures


Criteria11 GDC 20, "Protection Systems Elimination of obsolete data These departures have no impact on the

Functions. communication technology, compliance to this requirement.




12 GDC 21, "Protection System Elimination of obsolete data Conforms. These departures have anReliability and Testability." communication technology, impact on the methods of periodic testing as

described in the ABWR DCD. TheseFinal selection of platforms changed departures resulted in testing designs thatthe implementation architecture, use manual tests or manually initiated test

sequences rather than the automatic testingClarifications of digital controls described in the ABWR DCD. The modifiednomenclature and systems, test design continues to meet the

requirements of GDC 21.Testing and surveillance changes forthe SSLC


Page 7 of 8



Criteria13 GDC 22, "Protective System Elimination of obsolete data The departures have no impact the

Independence." communication technology, compliance to independence requirements.




14 GDC 23, "Protection System Elimination of obsolete data Conforms. The RTIS and NMS fail safe.Failure Modes." communication technology,




15 GDC 24, "Separation of Protection Elimination of obsolete data These departures have no impact on theand Control Systems." communication technology, compliance to this requirement.

Clarifications of digital controlsnomenclature and systems,Final selection of platforms changedthe implementation architecture



Page 8 of 8



Criteria16 GDC 25, "Protection System Elimination of obsolete data These departures have no impact on the

Requirements for Reactivity Control communication technology, compliance to the requirements of GDC 25.Malfunctions."




17 GDC 29, "Protection Against Elimination of obsolete data These departures have no impact on theAnticipated Operational communication technology, compliance to the requirements of GDC 29.Occurrences




SRP Acceptance Criteria

See Table above for compliance to Reg. Guides and industry standards, and see RG 1.206 evaluation (Enclosure 4a)

Compliance Review for STP 3&4 COLA U7-C-STP-NRC-090009Enclosure 4cPage 1 of 10

Conformance of STD DEP TI 3.4-1 with SRP Section 7.3 Acceptance Criteria for the ELCS


CriteriaRequirements1. 10 CFR 50.55a (a) (1), "Quality Elimination of obsolete data These departures do not have an impact on

Standards." communication technology, the compliance to Quality Standards.

Elimination of unnecessaryinadvertent actuation prevention logicand equipment,




2. 10 CFR 50.55a(h) Elimination of obsolete data These departures do not have an impact on(IEEE Std 603-1991) communication technology, the compliance to IEEE Std-603.








Criteria3 10 CFR 50, Appendix A, General Elimination of obsolete data These departures do not have an impact on

Design Criterion (GDC) 1, "Quality communication technology, the compliance to the requirements forStandards and Records." Quality Standards and Records.





4 GDC 2, "Design Basis for Protection Elimination of obsolete data These departures do not have an impact onAgainst Natural Phenomena." communication technology, the compliance to GDC 2 requirements.








Criteria5 GDC 4, "Environmental and Missile Elimination of obsolete data These departures do not have an impact on

Design Basis." communication technology, the compliance to GDC 4 requirements





6 GDC 10, "Reactor Design." Elimination of obsolete data These departures do not have an impact oncommunication technology, the compliance to GDC 10 requirements






Conformance of STD DEP T1 3.4-1 with SRP Section 7.3 Acceptance Criteria for the ELCS


Criteria7 GDC 13, "Instrumentation and Elimination of obsolete data These departures do not have an impact on

Control." communication technology, the compliance to GDC 13 requirements





8 GDC 15, "Reactor Coolant System Elimination of obsolete data These departures do not have an impact onDesign." communication technology, the compliance to GDC 15 requirements








Criteria9 GDC 16, "Containment Design" Elimination of obsolete data These departures do not have an impact on

communication technology, the compliance to GDC 16 requirements





10 GDC 19, "Control Room." Elimination of obsolete data These departures do not have an impact oncommunication technology,, the compliance to GDC 19 requirements








CriteriaAdditional acceptance criteria applicable to the ESFAS1 10 CFR 50.34(f), "Additional TMI-

Related Requirements,"10 CFR 50.34(f), (2) (v), "Bypassand Inoperable Status Indication."

Elimination of obsolete datacommunication technology,





These departures do not have an impact onthe compliance to 10 CFR 50.34(f), (2)(v),"Bypass and Inoperable Status Indication."requirements

10 CFR 50.34(f), (2) (xii), "AuxiliaryFeedwater System AutomaticInitiation and Flow Indication"."10 CFR 50.34(f), (2)(xiv),Containment Isolation Systems

-4 .4Not applicable to ABWR

-4 .1Elimination of obsolete datacommunication technology,





These departures do not have an impact onthe compliance to 10 CFR 50.34(f), (2)(xiv),Containment Isolation Systemsrequirements




Criteria2 GDC 20, "Protection Systems Elimination of obsolete data These departures do not have an impact on

Functions. communication technology, the compliance to GDC 20 requirements

Elimination of unnecessaryinadvertent actuation prevention logicand equipment,Clarifications of digital controlsnomenclature and systems,



3. GDC 21, "Protection System Elimination of unnecessary Conforms. Arrangement of actuatedReliability and Testability." -. inadvertent actuation prevention logic components, such as pumps and valves

and equipment. prevent inadvertent actuation of a completesafety function due to a single failure.

Elimination of obsolete data These departures have no impact on thecommunication technology, compliance to GDC 21.


Final selection of platforms changedthe implementation architecture.Testing and surveillance changes for Conforms. This departure changes thethe SSLC. automatic testing to a combination of

manual tests and manually initiated tests.The testing described in the COLAcontinues to meet GDC 21.




Criteria4. GDC 22, "Protective System Elimination of obsolete data These departures have no impact on the

Independence." communication technology, compliance to GDC 22 requirements





5. GDC 23, "Protection System Failure Elimination of unnecessary This departure does not negatively impactModes." inadvertent actuation prevention logic the compliance to GDC 23. The system

and equipment. continues to meet the requirements of GDC23.

Elimination of obsolete data These departures have no impact on thecommunication technology, compliance to GDC 23 requirements.


Final selection of platforms changedthe implementation architecture,Testing and surveillance changes forthe SSLC.




Criteria6. GDC 24, "Separation of Protection Elimination of obsolete data These departures have no impact on the

and Control Systems." communication technology, compliance to GDC 24 requirements.





7. GDC 29, "Protection Against Elimination of obsolete data These departures have no impact on theAnticipated Operational communication technology, compliance to GDC 29 requirements.Occurrences





Compliance Review for STP 3&4 COLA U7-C-STP-NRC-090009Enclosure 4c

Page 10 of 10



Criteria1-6 Additional acceptance criteria Elimination of obsolete data These departures have no impact on the

applicable to ESF control systems communication technology, functioning of the ESF control systems asGDC 33, GDC 34, GDC 35, GDC described in the COLA.38, GDC 41 and GDC 44. Elimination of unnecessary

inadvertent actuation prevention logicand equipment,




SRP Acceptance Criteria

See Table above for compliance to Reg. Guides and industry standards, and see RG 1.206 evaluation (Enclosure 4a)

Compliance Review for STP 3&4 COLA U7-C-STP-NRC-090009Enclosure 4d

Page 1 of 2

Review of SRP Chapter 7 BTPs for Applicability to I&C Departures related to RTISINMS

Applicable toRTIS/NMS

BTP Description SRP 7.2 Discussion7-1 Guidance on Isolation of Low-Pressure Systems No Not applicable to departures

from the High-Pressure Reactor Coolant System7-2 Guidance on Requirements of Motor-Operated No Not applicable to departures

Valves in the Emergency Core Cooling SystemAccumulator Lines

7.3 Guidance on Protection System Trip Point No Not applicable to departuresChanges for Operation with Reactor CoolantPumps Out of Service

7-4 Guidance on Design Criteria for Auxiliary No Not applicable to departuresFeedwater Systems

7-5 Guide on Spurious Withdrawals of Single Control No Not applicable to departuresRods in Pressurized Water Reactors

7-6 Guidance on Design of Instrumentation and No Unaffected by the departuresControls provided to Accomplish Changeover frominjection to Recirculation Mode

7-8 Guidance for Application of Regulatory Guide 1.22 Yes Conforms. Departures related to changes to test andsurveillance meet this BTP.

7-9 Guidance on Requirements for Reactor Protection Yes Conforms.System Anticipatory Trips

7-10 Guidance on the Application of Regulatory Guide No Unaffected by the departures1.97

7-11 Guidance on Application and Qualification of Yes Conforms. Fiber optic isolation is generally used and thisIsolation Devices meets the requirements of this BTP. Surge testing

requirements are covered by compliance to RG 1.180.7-12 Guidance on Establishing and Maintaining Yes Unaffected by the departures

Instrument Setpoints7-13 Guidance on Cross-Calibration of Protection No, sensors only Unaffected by the departures

System Resistance Temperature Detectors7-14 Guidance on Software Reviews for Digital Yes Conforms. Topical Reports UTLR-0001-P outline

Computer-Based Instrumentation and Control conformance.Systems

Compliance Review for STP 3&4 COLA U7-C-STP-NRC-090009Enclosure 4d

Page 2 of 2

Review of SRP Chapter 7 BTPs for Applicability to I&C Departures related to RTIS/NMS

Applicable toRTIS/NMS

BTP Description SRP 7.2 Discussion7-17 Guidance on Self-Test and Surveillance Test Yes Conforms. The departure in the COLA reduces the amount of

Provisions automatic self-testing and increased the amount of manualtesting and manually initiated self-testing. This was done tominimize the potential for self-testing to have a negativeimpact on reliability and availability, Self-testing was alsomodified to be consistent with the platform capabilities of theselected suppliers. The departure conforms to the intent ofthis BTP.

7-18 Guidance on the Use of programmable Logic No The RTIS and NMS do not use programmable logicControllers in Digital Computer-Based controllers.Instrumentation and Control Systems

7-19 Guidance for the Evaluation of Diversity and No Conforms. The departures do not negatively impact theDefense -in-Depth in Digital Computer-Based design for diversity and defense-in-depth.Instrumentation and Control Systems

7-21 Guidance on Digital Computer Real-Time Yes The departures do not impact conformance to this BTP.Performance

Compliance Review for STP 3&4 COLA U7-C-STP-NRC-090009Enclosure 4e

Page 1 of 2

Review of SRP Chapter 7 BTPs for Applicability to I&C Departures related to ELCS

Applicable toELCS

BTP Description SRP 7.3 Discussion1

7-1 Guidance on Isolation of Low-Pressure Systems No Not applicable to departuresfrom the High-Pressure Reactor Coolant System

7-2 Guidance on Requirements of Motor-Operated No Not applicable to departuresValves in the Emergency Core Cooling SystemAccumulator Lines

7.3 Guidance on Protection System Trip Point No Not applicable to departuresChanges for Operation with Reactor CoolantPumps Out of Service

7-4 Guidance on Design Criteria for Auxiliary No Not applicable to departuresFeedwater Systems

7-5 Guide on Spurious Withdrawals of Single Control No Not applicable to departuresRods in Pressurized Water Reactors

7-6 Guidance on Design of Instrumentation and Yes Unaffected by the departuresControls provided to Accomplish Changeover frominjection to Recirculation Mode

7-8 Guidance for Application of Regulatory Guide 1.22 Yes Conforms. Departures related to changes to test andsurveillance meet this BTP.

7-9 Guidance on Requirements for Reactor Protection No Not applicable to ELCS, including departures.System Anticipatory Trips

7-10 Guidance on the Application of Regulatory Guide No Unaffected by the departures1.97

7-11 Guidance on Application and Qualification of Yes Conforms. Fiber optic isolation is generally used and thisIsolation Devices meets the requirements of this BTP. Surge testing

requirements are covered by compliance to RG 1.180.7-12 Guidance on Establishing and Maintaining Yes Unaffected by the departures

Instrument Setpoints7-13 Guidance on Cross-Calibration of Protection No Unaffected by the I&C Departures

System Resistance Temperature Detectors

Compliance Review for STP 3&4 COLA U7-C-STP-NRC-090009Enclosure 4e

Page 2 of 2

Review of SRP Chapter 7 BTPs for Applicability to I&C Departures related to ELCS

Applicable toELCS

BTP Description SRP 7.3 Discussion1

7-14 Guidance on Software Reviews for Digital Yes Conforms. Topical Reports WCAP-16097-P-A outlinesComputer-Based Instru- mentation and Control conformance.Systems

7-17 Guidance on Self-Test and Surveillance Test Yes Conforms. The departure in the COLA reduces the amount ofProvisions automatic self-testing and increased the amount of manual

testing and manually initiated self-testing. This was done tominimize the potential for self-testing to have a negativeimpact on reliability and availability, Self-testing was alsomodified to be consistent with the platform capabilities of theselected suppliers.

7-18 Guidance on the Use of programmable Logic Yes The ELCS platform was reviewed and approved by the NRCControllers in Digital Computer-Based in Topical Report WCAP-16097-P-A, Common QualifiedInstrumentation and Control Systems Platform.

7-19 Guidance for the Evaluation of Diversity and No Conforms. The departures do not negatively impact theDefense -in-Depth in Digital Computer-Based design for diversity and defense-in-depth.Instrumentation and Control Systems

7-21 Guidance on Digital Computer Real-Time Yes The I&C departures do not impact compliance to this BTP.Performance

Note:1. ELCS complies with Reg.Guides and Standards revisions that may differ in revision dates. The ELCS design is based upon the NRC

approved topical report generic platform that used the revisions in effect at that time.

Compliance Review for STP 3&4 COLA U7-C-STP-NRC-090009Enclosure 4f

Page 1 of 1

EVALUATION OF TIER 1 ITAAC FOR STD DEP T1 3.4-1

If yes, identify Does SRP 14.3

Are elements of associated: identify specific Do the existingthis departure Chapter 2 ITAAC(s) ITAAC that are ITAAC encompass

item covered by applicable to the requirements ofSpecific Departure Items ITAAC(s)? Chapter 3 DAC departure item? the SRP 14.3 ITAAC? Comments

1) Elimination of obsolete Table 2.7.5 Yes Yesdata communication Items 1-7technology YES Table 3.4 SRP 14.3 does not

Items 1-4, 6-12, 14-16 No N/A identify specificDAC related ITAAC

2) Elimination of No No SRP 14.3 does notunnecessary identify specificinadvertent actuation YES N/A DAC related ITAACprvninlogic and Table 3.4prevention Items 1 & 2 Noequipment

3) Clarifications of digital Administrativecontrols nomenclature NO N/A N/A N/A changes onlyand systems

4) Final selection of Table 2.2.7platforms changed the Items 1-4, 6, 7, 8implementation YES SRP 14.3 does notarchitecture Table 3.4Item 1-4, 6-12, 14-16 No N/A identify specific

DAC related ITAAC

5) Testing and N/A Yes Yessurveillance changes YESSRP 14.3 does notfor SSLC (defined in DAC Table 3.4

3.4 only) Items 1 & 4 No N/A identify specificDAC related ITAAC

U7-C-STP-NRC-090009 U. S. Nuclear Regulatory Commission … · 2015. 6. 22. · U7-C-STP-NRC-090009...

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Transcript of U7-C-STP-NRC-090009 U. S. Nuclear Regulatory Commission … · 2015. 6. 22. · U7-C-STP-NRC-090009...