ET 08-0004, Additional Information Regarding Main Steam and Feedwater Isolation System (Msfis) Controls Modification

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Additional Information Regarding Main Steam and Feedwater Isolation System (Msfis) Controls Modification
ML080250069
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 01/18/2008
From: Garrett T
Wolf Creek
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 08-0004
Download: ML080250069 (16)


Text

W LF CREEK NUCLEAR OPERATING CORPORATION Terry J. Garrett Vice President, Engineering January 18, 2008 ET 08-0004 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 07-0008, dated April 18, 2007, from T. J. Garrett, WCNOC, to USNRC
3) Letter ET 07-0013, dated May 9, 2007, from T. J. Garrett, WCNOC, to USNRC
4) Letter dated August 8, 2007, from J. W. Lubinski, USNRC, to R. A. Muench, WCNOC
5) Letter ET 07-0039, dated August 31, 2007, from T. J. Garrett, WCNOC, to USNRC
6) Letter dated December 7, 2007, from J. N. Donohew, USNRC, to R. A. Muench, WCNOC

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. References 2 and 3 provided supplemental information requested by the NRC. c P0. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET ,j ( ,

ET 08-0004 Page 2 of 3 On August 2, 2007, WCNOC personnel met with the NRC to discuss five issues identified by the NRC staff associated to the review of the MSFIS controls modification. Subsequently, Reference 4 provided the results of the meeting and requested WCNOC to respond to the five issues. Reference 5 provided WCNOC's response to these items. Item 3 in Reference 5 identified that WCNOC would be performing a Part 50 Appendix B audit of CS Innovations in September 2007. A meeting was scheduled for December 12, 2007 between the Staff and WCNOC. However, due to inclement weather, the meeting was cancelled and a teleconference held on December 12, 2007 in lieu of the meeting. During the teleconference, WCNOC notified the NRC that the Appendix B audit of CS Innovation was performed and after a review of associated requirements, WCNOC has determined to modify the necessary documentation to procure the MSFIS controls equipment from CS Innovations as safety related equipment.

Attachment I provides additional information supporting acceptance of the equipment from CS Innovations as safety related.

Additionally, to support the December 12, 2007 teleconference, WCNOC provided the participants with a table for the discussion of the additional questions that were provided by electronic mail on November 9, 2007 and subsequently provided in Reference 6. This table also included actions/commitments from prior WCNOC correspondence. The change in approach from a commercial grade dedication effort through Nutherm International results in some impacts to completion of actions/commitments from prior WCNOC correspondence. The revised dates for completing various actions was discussed during the teleconference and the Staff did not identify any concerns. A revised table incorporating comments from the teleconference is provided in the Enclosure. WCNOC considers this table as the response to Reference 6.

The supplemental information provided in Attachment I and the Enclosure do 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.

Attachment II provides a list of commitments made in this letter. If you have any questions concerning this matter, please contact me at (620) 364-4084, or Mr. Richard Flannigan at (620) 364-4117.

Sincerfe y

JGarrett TJG/rlt Attachments: I Additional Information Regarding Main Steam and Feedwater Isolation System (MSFIS) Controls Modification II List of Commitments Enclosure cc: E. E. Collins (NRC), w/a, w/e T. A. Conley (KDHE), w/a, w/e J. N. Donohew (NRC), w/a, w/e V. G. Gaddy (NRC), w/a, w/e B. K. Singal (NRC), w/a, w/e Senior Resident Inspector (NRC), w/a, w/e

ET 08-0004 Page 3 of 3 STATE OF KANSAS )

SS 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.

arriG Terry J.'Gi Vice President/Engineering SUBSCRIBED and sworn to before me this u day of Jdn t-a r ,2008.

GAYLE SHEPHEARD Notary Pllic a& Notary Public - State of Kansas ApptEprs"kqa/

MyMppt. Expires y..l  ! JExpiration Date Il1/Lt/

Attachment I to ET 08-0004 Page 1 of 3 Additional Information Regarding Main Steam and Feedwater Isolation System (MSFIS)

Controls Modification 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.

On August 2, 2007, WCNOC personnel met with the NRC to discuss five issues identified by the NRC staff associated with the review of the MSFIS controls modification. Subsequently, Reference 2 provided the results of the meeting and requested WCNOC to respond to the five issues. Reference 3 provided WCNOC's response to these items. Item 3 in Reference 3 identified that WCNOC would be performing a Part 50 Appendix B audit of CS Innovations in September 2007. In a December 12, 2007 telecon with the NRC staff, WCNOC indicated that the Appendix B audit of CS Innovation was performed and after a review of associated requirements, WCNOC has determined to modify the necessary documentation to procure the MSFIS controls equipment from CS Innovations as safety related equipment.

As discussed in Reference 1, the current MSFIS controls were identified as a multiple single point failure system that could cause unnecessary plant shutdowns. Additionally, the current MSFIS controls contain obsolete components and technology that complicates repairs to the controls. As a result of these issues, WCNOC embarked on an effort to provide replacement controls. In early 2006, WCNOC began discussions with CS Innovations about the development of an field programmable gate array (FPGA) based logic system that could be utilized for replacement of existing instrumentation and controls at WCGS, with the MSFIS controls being the first application. WCNOC initiated the discussions with CS Innovations based on WCNOC personnel knowledge and working relations with CS Innovations personnel.

WCNOC initiated the procurement for the modifications to the MSFIS controls in accordance with the appropriate commercial grade dedication processes since CS Innovations was not a 10 CFR 50 Appendix B supplier. Nutherm International was contracted by WCNOC as the 10 CFR 50 Appendix B supplier.

In May 2006, CS Innovations began development of an Advanced Logic System based on embedded system architecture. The design of the Advanced Logic System utilized a rapid application development process. Rapid application development is a development methodology which involves iterative development and the construction of prototypes. The rapid action development allows high quality products to be developed on a schedule that can result in resource reduction. In January, 2007, CS Innovations issued the CS Innovations, LLC Quality Assurance Manual for the implementation of its Quality Assurance Program to meet the requirements of 10 CFR 50 Appendix B. From May 2006 through September 2007, Nutherm International reviewed design documentation and activities of CS Innovations' level of design and build quality in the initial design. During commercial grade survey activities, Nutherm International performed several specific activities including, but not limited to: 1) review of the process by which the individual system components were selected with a detailed review of the Actel FPGA; 2) review of the CS Innovations' verification and validation activities implemented

Attachment I to ET 08-0004 Page 2 of 3 for the design of the system as well as the verification and validation activities to detect possible defects in the software tools; and 3) review of CS Innovations' quality assurance and configuration management process. CS Innovation design activities associated with the replacement MSFIS controls were performed subsequent to the implementation of their Quality Assurance Program.

During the week of September 10, 2007, WCNOC performed Part 50 Appendix B audit of CS Innovations. The performance based supplier audit focused on the supplier's in-process activities that are needed to reach a conclusion about whether items produced by the supplier's process will perform their intended function. This audit relied, in part, on the confirmatory acceptance testing being performed by Nutherm International. The audit results concluded that the CS Innovations Quality Assurance Program was well implemented and satisfies the requirements of 10 CFR 50 Appendix B. Four programmatic deficiencies were identified and are to be resolved prior to delivery of any safety related equipment to WCGS.

WCNOC's audit of CS Innovations 10 CFR 50 Appendix B Quality Assurance Program and performance of the independent reviews and qualification testing by Nutherm International, combined with WCNOC quality and engineering personnel oversight surveillance activities, provided the basis for the approval of CS Innovations 10 CFR 50 Appendix B Quality Assurance Program to supply WCNOC with safety related material. Based on the change in approach (i.e., procuring the equipment as safety related from CS Innovations), WCNOC plans to perform an additional surveillance to observe CS Innovations testing capabilities and requirements.

Figure 1 provides a timeline depicting the activities associated with the Advanced Logic System and MSFIS controls.

Additionally, to support the December 12, 2007 teleconference, WCNOC provided the participants with a table for the discussion of the additional questions that were provided by electronic mail on November 9, 2007 and subsequently provided in Reference 4. This table also included actions/commitments for prior WCNOC correspondence. This table is provided in the Enclosure and has been updated based on the teleconference. WCNOC considers this table as the response to the additional questions provided in Reference 4.

References:

1. Letter ET 07-0004, dated March 14, 2007, from T. J. Garrett, WCNOC, to USNRC.
2. Letter dated August 8, 2007, from J. W. Lubinski, USNRC, to R. A. Muench, WCNOC.
3. Letter ET 07-0039, dated August 31, 2007, from T. J. Garrett, WCNOC, to USNRC.
4. Letter dated December 7, 2007, from J. N. Donohew, USNRC, to R. A. Muench, WCNOC.

02 CD0 (0-0 0

00-ALS MSFIS Controls - Vendor QA Timeline ONGOING I CS INNOVATIONS OA PR OGRAM I CS' I 'IRAPID" CYCLE ALS PLATFORM I QUAL UIIITI BUILD I QUAL OF ALS I MSFIS DESIG.

I MSFIS IMPLEMEIIl I MSFIS FAT I

I SAT I

Activities CS INNOVATIONSI CS INNOVATIONS NON-SAFETY PO J-105 P(Q) ISSUED FAT COMPLETE EQUIPMENT READY 4114 4/16 FOR INSTALL WOLF CEEK AUITI

.Feb .Max.Apr May. Jun. Jul Aug *Max .Apr .May. Jun Jul . Aug .Sept ,Oct , N4 2008 INDEPENDENT VERIFICATION OF PRODUCTION I

Nutherm EQUIPMENT Activities I - NUTHERM OA PROGRAM [DESIGN REVIEWS AND VENDOR SURVEYS] S Figure 1

Attachment II to ET 08-0004 Page 1 of 1 LIST OF COMMITMENTS The following table identifies those actions committed to by Wolf Creek Nuclear Operating Corporation in this document. Any other statements in this letter are provided for information purposes and are not considered regulatory commitments. Please direct questions regarding these commitments to Mr. Richard Flannigan, Manager Regulatory Affairs at Wolf Creek Generating Station, (620) 364-4117.

REGULATORY COMMITMENT DUE DATE Items in the enclosed table with a "NEW SUBMITTAL DATE" are See dates in the considered to be commitments. enclosed table

Enclosure to ET 08-0004 ACTIONS/COMMITMENTS - MSIVIMFIV/MSFIS CONTROLS LICENSE AMENDMENT REQUEST

ACTIONS/COMMITMENTS - MSIV/MFIV/MSFiS CONTROLS LICENSE AMENDMENT REQUEST ACTION/COMMITMENT DUE NEW REVIEWER COMMENTS DATE(1 ) SUBMITTAL DATE(2)

DATE COM.MERCIAL GRADE DEDICATION PROCESS The final acceptance test procedure(s) referenced in 7/30/07 NA Technical Procedure TPS-9064, Rev. 0 the Nutherm Dedication Plan will be available July 30, Not required (NR) due to accepting equipment as 2007. [ET 07-0022, Question 7, item F] safety related (SR) from CS Innovations (CSI)

WCNOC's evaluation and acceptance of the CS 8/31/07 NA Evaluation and Acceptance of CS Innovations Safety Plan Innovations safety plan and Nutherm International was completed 9/7/07.

Dedication Plan will be available by August 31, 2007. Evaluation and acceptance of NI Dedication Plan - NR

[ET 07-0022, Question 10] due to accepting equipment as SR from CS Innv WCNOC will submit the Nutherm International Final 11/30/07 NA NR due to accepting equipment as SR from CSI Dedication Report by 11/30/07. [ET 07-0039]

A new commercial grade dedication based upon high NA 11/15/07 ET 07-0039 indicated that the commercial dedication quality lifecycle processes [NRC handout at 8/2107 (item 3) process is not required to be redone as there has been meeting-item 3] specific emphasis on ensuring a high quality design and life cycle process.

NR due to accepting equipment as SR from CSI The staff finds that the commercial grade dedication NA NR due to accepting equipment as SR from CSI process used to dedicate the CS Innovations FPGA design was insufficient for this type of design modification because it does not appear, from the documentation submitted, to evaluate the lifecycle process in sufficient detail to determine that this product is of sufficient high quality to use in a nuclear safety-related system. [NRC e-mail RAI of 11/9/07, question 5]

1 Rev. 1, 1/7/08

ACTIONICOMMITMENT DUE NEW REVIEWER COMMENTS DATE(1 ) SUBMITTAL DATE(2" DATE VERFICATIONA.AND.VALIDATION. .

Revision 1 of the System Verification and Validation 8/31/07(R1) 1/31/08 (R2) 3/6/08 0 Revision 1 completed 8/30/07 report will be available on August 31, 2007. Revision 2 .1!1!6/07(R2) (item 3) 0 e-mail sent to NRC on 10/25/07 - date change due to of the report will be available on November 16, 2007. 42114/07(R2) delays in the factory acceptance testing Revision 3 of the report will be available on June 13, 2008. [ET 07-0022, Question 19] 6/13/08 (R3) e Date for Revision 2 is revised based on accepting equipment as SR from CSI. The report will contain the CSI system acceptance test in lieu of the NI FAT results.

  • Revision 3 of the report cannot be completed until after installation testing is completed. The date is dependent on completion of installation testing.

The analysis of factory acceptance testing activities 111/1607 1/31/08 0 e-mail sent to NRC on 10/25/07 - date change due to -'

verifying that the procedure(s) will test the items 12-/44/07 delays in the factory acceptance testing.

required by the test plan, and that the results show that See above discussion the tests demonstrated that the system meets the requirements, will be performed by Baseline Engineering and captured in Revision 2 of the System Verification and Validation Report, to be available by November 16, 2007. [ET07-0022, Question 17, item B]

Verification and validation reports on the design, 2/29/08 implementation, and test activities [NRC e-mail RAI of 11/9/07, question 1]

2 Rev. 1, 1/7/08

ACTIONICOMMITMENT DUE NEW REVIEWER COMMENTS DATE"1 ) SUBMITTAL DATE"2 )

DATE CONFIGU RATIO*N" MANAG EM-ENT Configuration Management Plans 2/29/08 WCNOC indicated in letter ET 07-0039 that we intend to A) Format and content not consistent with IEEE maintain the capability to utilize spare boards that could 828-1998 be built onsite using the approved logic design. For MSFIS controls, we intend to stock only pre-configured B) Discussion of Software Tools boards. We do not intend to guild and/or configure boards C) Configuration Control of flash lists for flashing onsite for the MSFIS application. Subsequent stock blank boards applications may utilize a blank spare board, at which time D) Explain numbering scheme we would implement the appropriate process and E) Control of CVS software and permissive procedures for the onsite configuration of Advanced Logic actions System blank spare boards.

F) CM plan does not discuss schedules and coordination of CM activities

[NRC e-mail RAI of 11/9/07, question 3]

-QUALITY ASSURANCE Quality Assurance Plans 2/29/08 A) WCNOC MSFIS QA Plan does not fully meet the requirements of IEEE 730 B) Nutherm QA Plan (WCN-9715QAP) for CSI B) NR due to accepting equipment as SR from CSI Replacement MSFIS does not describe a QA Plan C) Nutherm QA-N-10179-5, QAM, does not C) NR due to accepting equipment as SR from CSI mention software, programmable systems, or lifecyle D) CSI 6101-00009 - FPGA programming lifecycle not mentioned, nor flash list shown as minimum governing documents E) CSI QAM, Rev. 1, does not appear to be intended for software or programming QA.

Develop a programming QA program

[NRC e-mail RAI of 11/9/07, question 4]

3 Rev. 1, 1/7/08

ACTION/COMMITMENT DUE NEW REVIEWER COMMENTS DATE(1 ) SUBMITTAL DATE(2)

DATE TEST/INSTALLATION DOC UMENTATiON 2 The CS Innovations system acceptance test 8/31/07 NA The system acceptance test reports were available on procedure(s) is encompassed within the MSFIS 8/31/2007 at CS Innovations. A full copy of the system System Test Plan (document 6101-00004) and is acceptance test reports were sent to Nutherm for provided in Enclosure 35 dedication activities on 9/3/2007. The system acceptance

-the corresponding test report will be available by test reports are available at the CSI offices for review August 31, 2007. [ET 07-0022, Question 17, item B] during the 02/08 site visit.

This procedure(s) [factory acceptance test] will be 7/30/07 NA 1/14/08

  • e-mail sent to NRC on 10125/07 - date change due to available by July 30, 2007 and the test results will be 4015/O07 (item 12) delays in the factory acceptance testing -final test available by October 5, 2007. [ET 07-0022, Question . 1 16-07results to be available on 11/16/07 _

17, item BI ..... 1 With CSI providing the controls as SR, the factory acceptance test (FAT) is the system acceptance test (CSI 6101-00004) performed at CSI. As discussed above, recommend the test results be reviewed at CSI office during 02/08 site visit.

Site acceptance test (SAT) procedure(s) are being 9/7/07 SAT results 5/12/08

  • SAT procedure was completed on 8/21/07 developed by WCNOC and will be available by 006107 available for (item 13)
  • e-mail sent to NRC on 10/25/07 - date change due to September 7, 2007. The results of this testing will be 12/! 407 review during delays in the factory acceptance testing - results of documented and available by October 26, 2007. [ET WC site visit site acceptance testing and documentation will be 07-0022, Question 17, item C] in 5/08 available by 12/14/07
  • With CSI providing the controls as SR, the SAT will be performed utilizing CSI 6101-00004, "MSFIS System Test Plan (and procedure)". The SAT will be performed by CSI personnel with oversight by WCNOC personnel. CSI 6101-00004 was submitted in ET 07-0004, Enclosure 35.
  • SAT results will be available for NRC review during the WC site visit in May 08.

4 Rev. 1, 1/7/08

ACTIONICOMMITMENT DUE NEW REVIEWER COMMENTS DATE('1) SUBMITTAL DATE(2, DATE Installation test procedure(s) are being developed by 10/16/07 5/15/08 5/12/08 Rev. 0 of the post installation test procedure is complete WCNOC and will be available by October 16, 2007. (submit test (item 14) (10/14/07). Additional revision expected in 2/08. The post The results of this testing will be documented and procedure) installation test procedure will be submitted to the NRC by available by May 30, 2008. The final revision of the 6A-3/08 5/15/08.

System Verification and Validation Report will include a verification and validation analysis of the installation With NRC schedule to approve in Fall 2008, the results of testing and will be available by June 13, 2008. [ET 07- the testing will depend on installation of the system.

0022, Question 17, item D] Final revision of the System Verification and Validation Report is dependent upon installation of the system.

WCNOC has not submitted test plans for site NA 5/12/08 0 Installation Plan was submitted in ET 07-0022, acceptance tests or for installation tests. [NRC e-mail (item 10) Enclosure 18.

RAI of 11/9/07, question 10] 0 WCNOC utilizing CSI 6101-0004 for SAT. Previously submitted in ET 07-0022, Enclosure 35.

Environmental Test Plans 3/15/08 Plan is to conduct the additional testing in lieu of providing A) Licensee can choose either test method MIL- additional justification.

STD-461E or IEC 61000-4, request licensee provide the entire set of test results of the selected method.

B) Tests IEC 61000-4-9 and IEC 61000-4-10 were not included. Since the waiver of these two EMC susceptibility tests is only allowed under special conditions, provide the justification why the tested equipment satisfied these special conditions.

C) Provide justification why 61000-4-13 was not performed. This justification should include the distance to the nearest AC power lines and the expected signal strength.

[NRC e-mail RAI of 11/9/07, question 11]

TRAINING/MAINTENANCE/OPERATION:' .

The manual [Operations and Maintenance] will be 9/A14/07 3/15/08 4/12/08 0 Letter ET 07-0041 identified that incorrect dates had developed by September 14, 2007 with WCNOC 11/30/07 (item 16) been provided and new dates for completion were acceptance of the manual by September 28, 2007. [ET gi2-807 provided.

0 7-0022, Question 22; ET 07-004 1]

12/14/07

  • Date revised due to accepting equipment as SR from CSI. CSI to provide manuals.

5 Rev. 1, 1/7/08

ACTION/COMMITMENT DUE NEW REVIEWER COMMENTS DATE"1 ' SUBMITTAL DATE"2 '

DATE The training material associated with the MSFIS 9/26/07 5/15/08 4/12/08

  • Training material completed on 9/16/07.

controls will be available by September 26, 2007. [ET (synopsis) (item 16) 0 Per telecon on 12/12/07, the training material is not 07-0022, Question 22] required to be submitted. Provide a synopsis of the training and references to the training documents.

Provide the procedure which will be used to program 2/29/08 4/12/08 The maintenance plan will be revised to indicate that stock FPGA boards into application specific boards. (item 16) blank FPGA boards will not be stocked.

Provide required modifications to the maintenance WCNOC indicated in letter ET 07-0039 that we intend to plan. [NRC e-mail RAI of 11/9/07, question 8] maintain the capability to utilize spare boards that could be built onsite using the approved logic design. For MSFIS controls, we intend to stock only pre-configured boards. We do not intend to guild and/or configure boards onsite for the MSFIS application. Subsequent applications may utilize a blank spare board, at which time we would implement the appropriate process and procedures for the onsite configuration of Advanced Logic System blank spare boards.

DESIGN SPECIFICATIONS/R EQUIREMENTS,- .

Nutherm International's evaluation and acceptance of 8/17/07 NA Completed during NI surveyweek of 8/14/07. NI letter the CS Innovations architecture will be available on dated 8/23/07 - transmittal # QA-4887 August 17, 2007. [ET 07-0022, Question 14, item B] NR due to accepting equipment as SR from CSI WCNOC's evaluation and acceptance of the CS 9/7/07 2/29/08 1/23/08 WCNOC evaluation and acceptance of the NI review of Innovations architecture and of the Nutherm (item 7) the CSI architecture is not required with WCNOC International review of that architecture will be available accepting equipment as SR from CSI. Final design on September 7, 2007. [ET 07-0022, Question 14, documents are completed and accepted by WCNOC.

item C]

The system build documentation will be available by 7/16/07 2/29/08 5/12/08 This information is available at the CSI offices for review.

July 16, 2007. [ET 07-0022, Question 16) (item 11) Recommendation is that the information be reviewed by the Reviewer during 2/08 visit to CSI.

Acknowledgement by licensee that this is a software NA 9/2/07 Letter ET 07-0039 (8/31/07) based digital system. [8/2/07 meeting] (item 2) 6 Rev. 1, 1/7/08

ACTION/COMMITMENT DUE NEW REVIEWER COMMENTS DATE"1 ) SUBMITTAL DATE(2)

DATE Documentation of security requirements (RG 1.152) 2/29/08 1/23/08 IEEE Std 7-4.3.2-2003 does not provide guidance

[8/2/0 7 meeting] (item 6) regarding security measures for computer based system equipment and software systems. Regulatory Positions 2.1 - 2.9 of RG 1.152, provides specific guidance concerning computer based (cyber) safety system security. Review of the security requirements is in progress.

WCNOC will provide a detailed comparison of IEEE 7- 9/20/07 NA 9/20/07 ET 07-0041 (9/20/07) provided HiRely comparison.

4.3.2-2003 to RTCA DO-254 by September 20, 2007. (item 1) Telecon with NRC on 9/25/07, we agreed to provide draft

[8/2/07 meeting, ET 07-0039] matrix by 10/12/07 of IEEE 7-4.3.2 requirements as they pertain to MSFIS controls design. 10/12/07 - provided draft matrix by e-mail. Matrix formally submitted 11/16/07 by letter WO 07-0028.

Provide a corrected and updated Requirements 2/29/08 Traceability Matrix. Current version (Rev. 0, submitted in ET 07-0022, Enc 19) is not usable in format presented. [NRC e-mail RAI of 11/9/07, question 2]

Software tools verification program. Provide a NA 10/30/07

  • Letter ET 07-0039 (8/31/07) provide revised report description of how the assessment of the output of the (item 5) "ALS Design Tools" to iiiclude additional details as to tools is done or be prepared to discuss this aspect in why the tools are suitable for this application and why detail during the site visit to CSI in 02/08. [NRC e-mail these specific tools were selected, and CS RAI of 11/9/07, question 9] Innovations experience with these tools. This revision was based on discussions during the NRC site visit to CS Innovations during the week of July 23, 2007.
  • Recommendation is that this be further discussed in detail during the CSI site visit.

DIVERSITY AND DEFENSE IN DEPTH.,

The Diversity and Defense in Depth Analysis will be 12/12/07 2/29/08 1/14/08 Propose to submit by 2/29/08. Schedule impacted due to submitted to the NRC by 12/12/07. [ET 07-0039] (item 4) resources to support the valve replacement in Spring outage, utilizing interim staff guidance (final guidance to be issued in December), further discussions with Reviewer on approach.

7 Rev. 1, 1/7/08

(1) The "due date" is the date that was committed to in previous submittals for either having the information available for NRC review or to submit the information to the NRC.

(2) The "reviewer date" is based on the document entitled "Items Still Needed for Review of Wolf Creek FPGA" that was provided at the 8/2/07 meeting. The date provided in this document were to support an NRC approval date of Fall 2008.

8 Rev. 1, 1/7/08