ET 08-0014, Additional Information Regarding Main Steam and Feedwater Isolation System (Msfis) Controls Modification

Additional Information Regarding Main Steam and Feedwater Isolation System (Msfis) Controls Modification

ML080940559
Person / Time
Site:	Wolf Creek
Issue date:	02/28/2008
From:	Garrett T Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 08-0014
Download: ML080940559 (8)

Text

W'!LF CREEKINUCLEAR OPERATING CORPORATION Terry J. Garrett Vice!President, Engineering February 28, 2008 ET 08-0014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

1) Letter ET 07-0004, dated March 14, 2007, from T. J. Garrett, WCNOC, to USNRC

2) Letter ET 08-0004, dated January 18, 2008, from T. J. Garrett, WCNOC, to USNRC

3) Letter ET 08-0008, dated January 31, 2008, from T. J. Garrett, WCNOC, to USNRC

Subject:

Docket No. 50-482: Additional Information Regarding Main Steam and Feedwater Isolation System (MSFIS) Controls Modification Gentlemen:

Reference 1 provided a license amendment request that proposed revisions to Technical Specification (TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)

Instrumentation," TS 3.7.2, "Main Steam Isolation Valves (MSIVs)," and TS 3.7.3, "Main Feedwater Isolation Valves (MFIVs)." Reference 1 proposed changes to these specifications based on a planned modification to replace the MSIVs and associated actuators, MFIVs and associated actuators, and replacement of the Main Steam and Feedwater Isolation System (MSFIS) controls.

Reference 2 provided a table identifying additional/revised documentation to be submitted associated with the modification to the MSFIS Controls. Attachment I provides a discussion of the documentation being provided as committed to in Reference 2. Reference 3 provided Revision 2 to the Wolf Creek Nuclear Operating Corporation (WCNOC) System Verification and Validation Report as committed to in Reference 2. On February 22, 2008, the NRC Project Manager provided by electronic mail the NRC staff concerns associated with the WCNOC System Verification and Validation Report and subsequently indicated the staff request for a site visit in March 2008. WCNOC did not clearly communicate that there are four inputs into the 4oo/

P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HC/VET

ET 08-0014 Page 2 of 4 verification and validation process. The Table in Reference 2 indicated that verification and validation reports on the design, implementation, and test activities would be submitted by February 29, 2008. The WCNOC response for this item is to submit the CS Innovations report 6101-00200, "MSFIS V & V Report." The concerns identified on February 22, 2008 are understandable without having the opportunity to review the CS Innovations report 6101-00200 (see Enclosure II). An additional input into the verification and validation process is the activities performed by Nutherm International during commercial grade survey activities through early December 2007. The various survey activities performed by Nutherm International included verification and validation activities. These activities are being documented in a final report from Nutherm and will be provided to the NRC by March 31, 2008. The Attachment provides some additional details and describes the four inputs. WCNOC believes that an onsite visit in March 2008 is not necessary with the submittal of the information in Enclosure II and the additional documentation to be submitted by March 31, 2008.

Enclosures II, V, and VIII provide proprietary CS Innovations LLC documents. As Enclosures II, V, and VIII contain information proprietary to CS Innovations LLC, it is supported by affidavits signed by CS Innovations LLC, the owner of the information. The affidavits sets forth the basis on 'which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the Commission's regulations. Accordingly, it is respectfully requested that the information, which is proprietary to CS Innovations, be withheld from public disclosure in accordance with 10 CFR 2.390 of the Commission's regulations. The affidavits, along with a CS Innovations LLC authorization letters, 91000-00017, 91000-00018, and 91000-00019, "Application for Withholding Proprietary Information from Public Disclosure," is contained in Enclosures Ill, VI, and IX.

Enclosure XI provides the proprietary WCNOC Report "ALS Architecture Evaluation," Rev. 0.

Enclosure XII provides the non-proprietary WCNOC Report "ALS Architecture Evaluation," Rev.

0. Enclosure XIV provides the proprietary WCNOC Report "MSFIS D3 Assessment," Rev. 1.

Enclosure XV provides the non-proprietary WCNOC Report "MSFIS D3 Assessment," Rev. 1.

As Enclosures Xl and XIV contains information proprietary to WCNOC, it is supported by an affidavit signed by WCNOC, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the Commission's regulations. Accordingly, it is respectfully requested that the information, which is proprietary to WCNOC, be withheld from public disclosure in accordance with 10 CFR 2.390 of the Commission's regulations. This affidavit is contained in Enclosure XVI.

WCNOC is providing only proprietary versions of Enclosures II, V, VIII, and XIII as a non-proprietary version would be of no value to the public due to the extent of the proprietary information.

The documentation provided in the Enclosures does not impact the conclusions of the No Significant Hazards Consideration provided in Reference 1. In accordance with 10 CFR 50.91, a copy of the submittal is being provided to the designated Kansas State official.

ET 08-0014 Page 3 of 4 If you have any questions concerning this matter, please contact me at (620) 364-4084, or Mr.

Richard D. Flannigan at (620) 364-4117.

Terry J. Garrett TJG/rlt Attachment Il Submittal of Additional/Revised Documentation List of Regulatory Commitments Enclosure I WCNOC MSFIS V & V Report, Rev. 2.1 II CS Innovations Report 6101-00200, "MSFIS V & V Report," Rev. 2 III CS Innovations Letter 9100-00017, "Application for Withholding Proprietary Information from Public Disclosure" IV WCNOC Configuration Management Plan, Rev. 2 V CS Innovations Report 6002-00002, "ALS Configuration Management Plan," Rev. 1 VI CS Innovations Letter 9100-00019, "Application for Withholding Proprietary Information from Public Disclosure" VII WCNOC Quality Assurance Plan, Rev. 1 VIII CS Innovations Report 6002-00001, "ALS Quality Assurance Plan, Rev. 1 IX CS Innovations Letter 9100-00018, "Application for Withholding Proprietary Information from Public Disclosure" X WCNOC Maintenance Plan, Rev. 1 Xl WCNOC ALS Architecture Evaluation, Rev.0, Proprietary XII WCNOC ALS Architecture Evaluation, Rev.0, Non-Proprietary XIII WCNOC Operation Plan, Rev. 1 XIV WCNOC MSFIS D3 Assessment, Rev. 1, Proprietary XV WCNOC MSFIS D3 Assessment, Rev. 1, Non-Proprietary XVI WCNOC Affidavit for Withholding Proprietary Information from Public Disclosure cc: E. E. Collins (NRC), w/a J. N. Donohew (NRC), w/a V. G. Gaddy (NRC), w/a B. K. Singal (NRC), w/a Senior Resident Inspector (NRC), w/a

ET 08-0014 Page 4 of 4 STATE OF KANSAS )

COUNTY OF COFFEY )

Terry J. Garrett, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

Terry J//arrett Vice P, esident Engineering SUBSCRIBED and sworn to before me this day of 2008.

GA AYLE SHEPHEARDi Notary PJblic RIM Notay Public - tate of KansasI My Appt. Exire", ?11 LI/d_ I Expiration Date ,/, qP l

Attachment I to ET 08-0014 Page 1 of 3 Submittal of Additional/Revised Documentation Reference 1 provided a license amendment request that proposed revisions to Technical Specification (TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)

Instrumentation," TS 3.7.2, "Main Steam Isolation Valves (MSIVs)," and TS 3.7.3, "Main Feedwater Isolation Valves (MFIVs)." Reference 1 proposed changes to these specifications based on a planned modification to replace the MSIVs and associated actuators, MFIVs and associated actuators, and replacement of the Main Steam and Feedwater Isolation System (MSFIS) controls. The Enclosures to this letter provides documentation committed to be submitted by February 29, 2008 in Reference 2.

WCNOC MSFIS V & V Report, Rev. 2.1 Revision 2.1 of this report includes as revised Requirements Traceability Matrix as discussed in Reference 3 and addresses Staff comments provided in Reference 4.

Reference 3 provided Revision 2 to the Wolf Creek Nuclear Operating Corporation (WCNOC)

System Verification and Validation Report as committed to in Reference 2. On February 22, 2008, the NRC Project Manager provided by electronic mail the NRC staff concerns associated with the WCNOC System Verification and Validation Report and subsequently indicated the staff request for a site visit in March 2008. WCNOC did not clearly communicate that there are four inputs into the Verification and Validation (V & V) Process. The Table in Reference 2 indicated that verification and validation reports on the design, implementation, and test activities would be submitted by February 29, 2008. The WCNOC response for this item is to submit the CS Innovations report 6101-00200, "MSFIS V & V Report." The concerns identified on February 22, 2008 are understandable without having the opportunity to review the CS Innovations report 6101-00200 (see Enclosure II). An additional input into the V & V Process is the activities performed by Nutherm International during commercial grade survey activities through early December 2007. The various survey activities performed by Nutherm International included verification and validation activities. These activities are being documented in a final report from Nutherm and will be provided to the NRC by March 31, 2008.

WCNOC believes that an onsite visit in March 2008 is not necessary with the submittal of the information in Enclosure II and the additional documentation to be submitted by March 31, 2008.

The V&V Process for the MSFIS controls project consists of four input levels (see Figure 1 in Enclosure I).

1) The first input level was performed by CS Innovations. The first input level is a detailed level of verification and validation. CS Innovations Report 6002-00002, "MSFIS V & V Report," Rev. 2, is provided in Enclosure I1. The CS Innovations verification and validation activities included the following:

a. Analyzing system requirements to determine if they are consistent with, and within the scope of the system

b. Assuring that the requirements are testable and capable of being satisfied

c. Development of test beds and test vectors

Attachment I to ET 08-0014 Page 2 of 3

d. Prepare Acceptance Test Plans and verification matrixes, including test specifications and unit test plans

e. Conducting informal reviews and walkthroughs and inspections of the design

f. Conducting Code inspections and/or walkthroughs

g. Conducting Unit testing software and data structures

h. Development of detailed test procedures for the next two phases

i. Conducting tests per test procedures

j. Documenting test performance, test completion, and conformance of test results versus expected results

k. Providing a test report that includes a summary of non-conformances found during testing I. Locating, recording, correcting, and retesting non-conformances

m. By test, analysis, and inspection, demonstrating that the developed system meets its functional, performance, and interface requirements

2) The second input level was performed by Nutherm International. As discussed in Reference 2, WCNOC initially contracted with Nutherm for Commercial Grade Dedication activities and subsequently procured the equipment from CS Innovations as safety related. However, the activities Nutherm International has performed are valid verification and validation activities. These activities include the following:

a. Analyzing system requirements to determine if they are consistent with, and within the scope of the system

b. Assuring that the requirements are testable and capable of being satisfied

c. Prepare Final Acceptance Test Procedure

d. Conduct Final Acceptance Test

e. Conducting surveys and audits of CS Innovations, including thread audits of the FPGA development

f. Verification of all documentation vs. the actual equipment

Attachment I to ET 08-0014 Page 3 of 3

3) The third input level was performed by the V & V Engineer. The third input level of verification and validation is a periphery level review where the verification and validation activities involve the verification of the outputs from CS Innovations and Nutherm International as well as the final results of the Final Acceptance Test, Site Acceptance Test, and Post Installation Test. As noted in the Staffs concerns (provided by electronic mail on February 22, 2008) the V & V Engineers efforts have been hardware focused.

The V & V Engineer performed VHDL code reviews early in the project, but has not performed detailed "software based" activities in the later stages of the project. WCNOC has relied on CS Innovations for the detailed verification and validation of these activities, as CS Innovations has employed an independent team to perform these activities. The V & V Engineer's activities are provided below.

a. Analyzing system requirements to determine if they are consistent with, and within the scope of the system

b. Assuring that the requirements are testable and capable of being satisfied

c. Analyzing verification and validation activities performed by CS Innovations

d. Analyzing verification and validation activities performed by Nutherm International

e. Verification and validation of final design products

f. Conduct Post Installation Test

4) The fourth level is to be performed by WCNOC Engineering during the final review of the Design Change Package. During this level of V&V the final output documents, drawings, and equipment are verified for correctness as it applies to the installation at WCGS.

This is the traditional verification and validation for design changes at WCGS.

References

1. WCNOC letter ET 07-0004, "Revision to Technical Specification (TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," TS 3.7.2, "Main Steam Isolation Valves (MSIVs)," and TS 3.7.3, "Main Feedwater Isolation Valves (MFIVs),"

March 14, 2007.

2. WCNOC letter ET 08-0004, "Additional Information Regarding Main Steam and Feedwater Isolation System (MSFIS) Controls Modification," January 18, 2008.

3. WCNOC letter ET 08-0008, "Additional Information Regarding Main Steam and Feedwater Isolation System (MSFIS) Controls Modification," January 31, 2008.

4. NRC letter, "Wolf Creek Generating Station - Request for Additional Information for the Main Steam and Feedwater Isolation System Modification (TAC NO. MD4839), December 7, 2007.

Attachment II to ET 08-0014 Page 1 of I LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by WCNOC in this document. Any other statements in this submittal are provided for information purposes and are not considered to be commitments. Please direct questions regarding these commitments to Mr. Richard Flannigan at (620) 364-4117.

COMMITMENT Due DatelEvent An additional input into the verification and validation process March 31, 2008 is the activities performed by Nutherm International during the initial commercial grade survey activities. The various survey activities performed by Nutherm International included verification and validation activities. These activities are being documented in a final report from Nutherm and will be provided to the NRC by March 31, 2008.