WO 04-0002, Defense-in-Depth and Diversity Assessment for Digital Upgrade of Wolf Creek'S Instrumentation and Control Systems

Defense-in-Depth and Diversity Assessment for Digital Upgrade of Wolf Creek'S Instrumentation and Control Systems

ML040701087
Person / Time
Site:	Wolf Creek, Callaway
Issue date:	03/03/2004
From:	Mckinney B Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EMF-2110(NP), Rev 1, WO 04-0002
Download: ML040701087 (7)

Text

VLFCREEK W& 'NUCLEAR OPERATING CORPORATION Britt T. McKinney Site Vice President MAAR 03 2004 WO 04-0002 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Docket No.'50-482: Defense-in-Depth and Diversity Assessment for Digital: Upgrade of the Wolf Creek Generating Station's Instrumentation and Control Systems Gentlemen:

Wolf Creek Nuclear Operating Corporation (WCNOC) is implementing plans to replace the Wolf Creek Generating Station (WCGS) current analog-based instrumentation and control systems, including the Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS), with the Framatome Advanced Nuclear Power (FANP) TELEPERM XS (TXS) system.

The planed modifications are being developed in conjunction with AmerenUE (Union Electric Company) since AmerenUE is planning similar modifications for the Callaway Plant.

The TXS design was generically described in Topical Report EMF-2110(NP), Revision 1,

'TELEPERM XS: A Digital Reactor Protection'System." By letter dated May 5, 2000, the Nuclear Regulatory Commission (NRC)-documented its acceptance of the TXS system and found Topical Report EMF-2110(NP), Revision 1, acceptable for referencing in license applications to the extent specified in the topical report and in the NRC safety evaluation that was attached to the NRC's May 5, 2000 letter.

On November 12, 2003, WCNOC, AmerenUE, and FANP met with the NRC staff to discuss the planned TXS modifications including submittal of the defense-in depth and diversity assessment required to support NRC plant-specific review of forthcoming license amendment applications for the new TXS systems. As described in that meeting, the design, qualification, and testing of the FANP TXS system minimizes the probability of software common-mode failures.

• Po. Box 411/ Burlington, KS 66839 /Phone: (620) 364.8831 An Equal Opportunity Employer MIFIHCNET

WO 04-0002 Page2of3 Enclosed is the requisite defense-in-depthland diversity assessment for the TXS systems to be employed at WCGS and the Callaway Plant. The assessment identifies ten techniques used in the design of the TXS system. These techniques employ concepts that, when combined, result in the capability to tolerate software common-mode failures without defeating safety functions.

The design techniques use concepts of defense-in-depth and diversity that are applied to both the hardware and software architectural design of individual TXS systems. The TXS system will thus operate with diverse software to ensure that redundancy among protection set channels is preserved even in the presence of common-mode failures. The enclosed report describes the features of the TXS system that result in-the system's inherent capability to tolerate common-mode failures. -

WCNOC, AmerenUE, and FANP utilized the guidance in NUREG 0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Branch Technical Position (BTP) HICB-19, -Guidance for Evaluation of Defense-in-Depth and Diversity in Digital Computer-Based Instrumentation and Control Systems," for performing the defense-in-depth and diversity assessment. In utilizing this methodology, an approach was undertaken for evaluating each of the design basis events identified in the accident analysis. This approach led to finalizing a TXS system design -that- effectively utilizes defense-in-depth and diversity to minimize or cope with any potential software common-mode failure within the TXS system.

In order to support the implementation schedule for replacement of the instrumentation and control systems at the Callaway Plant, WCNOC requests NRC approval of the TXS system defense-in-depth and diversity assessment for the Callaway Plant and WCGS by December 1, 2004. As described in the November-12,'2003 meeting, implementation is to proceed in phases, beginning with the first phase during Refueling Outage 14 in September 2005 for the Callaway Plant and Refueling'Outage 15 for WCGS. The enclosed assessment (for both plants) is intended to support future license amendment requests (LARs) that will be submitted separately by WCNOC for WCGS and AmerenUE for the Callaway Plant. WCNOC and AmerenUE are submitting this assessment in advance of the LARS to allow sufficient time for NRC review of this defense-in-depth and diversity assessment in advance of the anticipated LARs.

FANP has determined that certain information contained in the defense-in-depth and diversity assessment is proprietary. Therefore, this letter transmits both a proprietary copy (Enclosure I) and non-proprietary copy (Enclosure II) of the assessment. Enclosed is an affidavit executed by FANP (owner of the proprietary information). Accordingly, it is respectfully requested that the proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390.

WO 04-0002 Page 3 of 3 Communications concerning the proprietary aspects of the information being submitted or the supporting FANP affidavit should be addressed to James F. Mallay, Director, Regulatory Affairs, Framatome ANP, 3315 Old Forest Road, Lynchburg, VA 24501.

This application was reviewed by the Plant Safety Review Committee and the Nuclear Safety Review Committee.'

Please contact me at (620) 364-4112 or.Mr.-Kevin Moles at (620) 364-4126 for any questions you may have regarding this application.

Sincerely, BrittT. McKinney BTM/rIg

Enclosures:

I Defense-in-Depth and Diversity Assessment (Proprietary) 11 - Defense-in-Depth and Diversity Assessment (Non-Proprietary) cc: V. L. Cooper (KDHE), w/Enclosure i-J. N. Donohew (NRC), w/e D. N. Graves (NRC), w/e B. S. Mallett (NRC), w/e Senior Resident Inspector (NRC), wle

STATE OF KANSAS )

) SS COUNTY OF COFFEY )

Britt T. McKinney, of lawful age, being first 'duly sworn upon oath says that he is Site Vice President 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.

Britt T. Mc.inney Site Vice President SUBSCRIBED and sworn to before me'this 3 day of mIe 2004.

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M MARY E. GIFFORD Notary PJli6 EL~h Nctary Pubiic - SI'-c of Kanses My Appt. Expires l 16 461

. Expiration Date Ie 'o Ioo7 I..- . .

AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) ss.

CITY OF LYNCHBURG )

1. My name is James F. Mallay. I am Director, Regulatory Affairs, for Framatome ANP ("FANP"), and as such I am authorized to execute this Affidavit.

2. 1am familiar with the criteria applied by FANP to determine whether certain FANP information is proprietary. I am familiar with the policies established by FANP to ensure the proper application of these criteria.

3. 1am familiar with the FANP information contained in the report, 'Callaway Plant and Wolf Creek Generating Station Defense-in-Depth and Diversity Assessment." This report is referred to herein as 'Document." Information contained in this Document has been classified by FANP as proprietary in accordance with the policies established by FANP for the control and protection of proprietary and confidential information.

4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by FANP and not made available to the public.

Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure.

6. The following criteria are customarily applied by FANP to determine whether information should be classified as proprietary:

(a) The information reveals details of FANP's research and development plans and programs or their results.

(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for FANP.

(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for FANP in product optimization or marketability.

(e) The information is vital to a competitive advantage held by FANP, would be helpful to competitors to FANP, and would likely cause substantial harm to the competitive position of FANP.

7. In accordance with FANP's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside FANP only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. FANP policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

SUBSCRIBED before me this day of _ 2004.

A-f ex-Ella F. Carr-Payne NOTARY PUBLIC, STATE OF VIRGINIA MY COMMISSION EXPIRES: 8/31/05 ELLA F.CARR-PAYNE I Notary Public Commonwealth of Virginia Cvremion Exps. At4 31, 2005 MYl