ML080940562
| ML080940562 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 02/16/2008 |
| From: | Wolf Creek |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| ET 08-0014 | |
| Download: ML080940562 (27) | |
Text
Enclosure IV to ET 08-0014 WCNOC Configuration Management Plan, Rev. 2
ALS Class 1E Controls: Configuration Management Plan ADVANCED LOGIC SYSTEM (ALS)
CLASS 1E CONTROLS CONFIGURATION MANAGEMENT PLAN REVISION 2 PROJECT MANAGER - GREGG CLARKSON MANAGEMENT SPONSOR PATRICK GUEVEL EXECUTIVE SPONSOR - TERRY GARRETT Wolf Creek Nuclear Operating Corporation PO Box 411 1550 Oxen Lane, NE Burlington, KS 66839 2/16/2008 Page 1 ofl4 Revision 2 Revision 2/16/2008 Page I of 14
ALS Class 1E Controls: Configuration Management Plan Revision Control Rev # Approval Approval Date Description of Change(s) 0 GWC 9/16/2006 Initial Revision 1 GWC 4/6/2007 Added "Wolf Creek Proprietary" to the footer.
2 GWC 2/16/2008 Document overhaul for generic application at Wolf Creek for ALS Class IE Controls. Formatted document to meet the requirements of IEEE 828 -1998. Removed "Wolf Creek Proprietary" in footer.
2/16/2008 Page 2 of 14 Revision 22 Revision 2/16/2008 Page 2 of 14
ALS Class IE Controls: Configuration Management Plan Table of Contents RE V ISIO N 2 ............................................................................................................................................................................. R 1 I In tro du ctio n ........................................................................................................................................................................ 4 1.1 P u rp o se ..................................................................................................................................................................... 4 1.2 C M P S co p e ............................................................................................................................................................... 4 1.3 Reference M aterial ................................................................................................................................................... 5 1.3.1 IEEE Std 828-1998 - "IEEE Standard for Software Configuration Management Plans ..................... 5 1.3.2 ASME NQA-1-2004 - "Quality Assurance Requirements for Nuclear Facility Applications" ............... 5 1.3.3 6002-00002 - "ALS Configuration Managem ent Plan", CS Innovations .............................................. 5 2 M an ag emen t ....................................................................................................................................................................... 6 2.1 Configuration M anagement Responsibilites ....................................................................................................... 8 2.2 Interface Control ...................................................................................................................................................... 8 2 .3 S ch edu le ................................................................................................................................................................... 9 2.4 Configuration M anagem ent of Software Tools .................................................................................................. 9 3 Configuration M anagem ent Activities ............................................................................................................................. 10 3.1 Configuration Identification. .................................................................................................................................. 10 3.1.1 Documentation .......................................................................................................................................... 10 3 .1.2 D raw in gs ................................................................................................................................................... 11 3.1.3 Approval Authority ................................................................................................................................... 12 3.1.4 M ethods to Process Change Approval ................................................................................................... 12 3.2 Configuration Status Accounting ........................................................................................................................... 12 4 Configuration M anagem ent Plan M aintenance ............................................................................................................ 13 4 .1 Resp o n sib ilitie s ...................................................................................................................................................... 13 4 .2 U pd a te s ................................................................................................................................................................... 13 4.3 Change Approval ................................................................................................................................................... 13 4.4 Change Distribution ............................................................................................................................................... 13 Revision 2 2/16/2008 Page 3 of 14
ALS Class 1E Controls: Configuration Management Plan 1 Introduction 1.1 Purpose The purpose of the Configuration Management Plan (CMP) is to provide the methods and tools to establish the baseline, control changes to the baseline, record and track status, and audit the ALS Class 1E Controls. This CMP is intended for use once the Configuration Item (CI) has been submitted to and accepted by WCNOC. Configuration management activities prior to submittal to WCNOC shall be governed by the CS Innovations document 6002-00002 "ALS Configuration Management Plan".
The intended audience for the CMP is technical personnel from WCNOC that specify the system, the design team, and the independent group that will actually implement and perform the Verification and Validation Plan (VVP).
The CMP is based upon the requirements of IEEE 828-1998, IEEE Standard for Software Configuration Management Plans. Although the ALS Class lE Controls is a logic-based system and does not contain any microprocessors or micro-controllers, nor does it contain any executable software, the principles given therein as specifically applicable to software development systems shall be symmetrically applied to certain elements of the design, hardware, and logic design of the ALS Class 1E Controls throughout the life cycle.
1.2 CMP Scope The ALS Class 1E Controls project(s) will generate the system(s) that implement the monitoring and control functions specified in WCNOC equipment specification(s), including the documentation, testing, and test data files that will be used in testing the particular system.
The CMP is applicable to the following CI developed for the ALS Class 1E Controls project(s):
- Project Control Documents
- System Design, Including Drawings, Documents, and Analyses
- Test Documents
- Test Data
- Finished Product The CMP is applicable to the Cis identified above, for the life cycle as defined herein.
This CMP assumes that the design will be in accordance with the scope as defined in the particular WCNOC equipment specification. Significant changes to the scope, schedule, or to other assumptions made will be reflected in changes to this CMP.
Revision 2 2/16/2008 Page 4 of 14
ALS Class IE Controls: Configuration Management Plan 1.3 Reference Material Binding documents for this project are as follows:
1.3.1 IEEE Std 828-1998 - "IEEE Standard for Software Configuration Management Plans" 1.3.2 ASME NQA-1-2004 - "Quality Assurance Requirements for Nuclear Facility Applications" 1.3.3 6002-00002 - "ALS Configuration Management Plan", CS Innovations 2/16/2008 Page 5 of 14 Revision 2 Revision 2/16/2008 Page 5 of 14
ALS Class IE Controls: Configuration Management Plan 2 Management The project includes three independent groups under the oversight of the ALS Class 1E Controls Project Manager and WCNOC Design Change Process, as shown in Figure 1 below:
- 1. WCNOC Design Change Process - responsible for the design and implementation of modifications at Wolf Creek using established Wolf Creek processes and procedures (AP 05-005 Design, Implementation & Configuration Control of Modifications). As a part of the established processes and procedures, an independent V&V of the Design Change Package is performed by a qualified Wolf Creek Engineer. This independent V&V is in addition to the V&V activities performed by the Class lE Controls Supplier, the Qualification and Quality Oversight Contractor, and the V&V Engineer.
- 2. Class lE Controls Supplier - responsible for the design, development, integration, and final delivery of the product. CS Innovations (CSI) provides this function.
- 3. Qualification and Quality Oversight Contractor - responsible to provide both oversight and direct actions to independently ensure that the requirements on qualification of safety related hardware for the ALS Class 1E Controls, including its performance, integration, configuration control, and documentation, are satisfied. Nutherm International (NI) is performing this function.
- 4. V&V Engineer - responsible to provide independent oversight and direct actions to ensure that the V&V requirements for a Class 1E system are satisfied. Baseline Engineering is providing this function as staff augmentation to WCNOC Engineering.
The V&V Engineer shall review and credit all underlying V&V activities performed by either the Class lE Controls Supplier and/or the Qualification and Quality Oversight Contractor.
2/16/2008 Page 6 of 14 Revision 2 2/16/2008 Page 6 of 14
ALS Class IE Controls: Configuration Management Plan
. - Class I E Controls Supplier Figure 1: ALS Class 1E Controls Project Organization 2/16/2008 Page 7 of 14 Revision 2 2/16/2008 Page 7 of 14
ALS Class I E Controls: Configuration Management Plan 2.1 Configuration Management Responsibilites Responsibilities apply to all procedures, documentation, drawings, and any development activity.
Responsibilities specific to Configuration Management of the ALS Class 1E Controls development are as follows:
Responsibilities WCNOC WCNOC Design Qualification/Quality Project V&V Contractor/Class Oversight Manager 1E Supplier Contractor Configuration Originate Identification Approve/release Approve Review Originate Review configuration item Change preparation Originate Change control Approve Change Approve Review Originate implementation Documentation Approve maintenance Status Accounting Review Originate Formal SCM Audits Review Originate Baseline Definition Approve Review Originate Review 2.2 Interface Control Change coordination between Class 1E Supplier Cl's and WCNOC CI's are the responsibility of the WCNOC Project Manager. Interface control between ALS Class IE Controls Cl's and items which are outside the scope of this Plan are controlled under the WCNOC Design Change Process, AP 05-005 "Design, Implementation & Configuration Control of Modifications", and are the responsibility of the Project Manager.
2/16/2008 Page 8 of 14 Revision 22 2/16/2008 Page 8 of 14
ALS Class I E Controls: Configuration Management Plan 2.3 Schedule This CMP is implemented upon issuance by the Project Manager. Configuration baselines shall be established as defined for each item in Section 3. The product baseline shall be established upon completion of the final configuration audit. Configuration reviews and audits shall be performed as follows.
Configuration Reviews shall be held subsequent to the following project milestones:
- Prior to Qualification Unit Build
" Implementation Completion
- Prior to Factory Acceptance Testing (FAT)
Configuration Audits shall be performed subsequent to the following project milestones:
- Design Completion
- FAT completion 2.4 Configuration Management of Software Tools There are no deliverable software tools for the ALS Class 1E Controls. The Class lE Controls Supplier shall ensure that the configurations of all support software used in development and test on the ALS Class 1E Controls is controlled in the same manner as the deliverable Cl's. Nondeliverable support software baselines do not require WCNOC approval.
Revision 2 2/16/2008 Page 9 of 14
ALS Class IE Controls: Configuration Management Plan Configuration Management Activities 3.1 Configuration Identification This section identifies the items covered by the CMP.
3.1.1 Documentation All documentation and drawings submitted to WCNOC and produced for the ALS Class 1E Controls shall be placed under WCNOC configuration control after initial baselining.
3.1.1.1 Configuration item baselining shall be accomplished as follows:
A revision number beginning with Revision 0 shall be used when a document is first issued for release and shall be increased for each subsequent released revision. Draft documents shall be identified by an alpha character (beginning with "A") appended to the revision number (e.g. OA, OB, IA, lB,) and shall be submitted to the Project Manager for distribution for comment.
Following review and resolution/incorporation of any comments with the originator of the document, the originator shall remove the alpha character appended to the revision number, insert the current date, and
- Issue the document as follows:
Wolf Creek Project Manager
- Store the file in the Company (CSI or NI) Project archive file.
3.1.1.2 Document Revision Control Control of revisions to documents after initial baselining shall be in accordance with the following:
Individuals perceiving the need for a revision to a previously baselined document shall initiate the process for change by completing an Engineering Change Notice (ECN) form (a copy is attached) defining the required changes and submitting the form to the Project Manager for approval. In the event that changes may require further evaluation, design effort, or customer action, and/or the individual does not have authority to initiate such actions, the individual shall prepare a Problem Report (a form is attached) defining the issue for later resolution.
Revision 2 2/16/2008 Page 10 of 14
MSFIS Configuration Management Plan The Project Manager and V&V Engineer shall review the ECN for approval of initiating the revision.
Following approval to initiate the revision, the originator will obtain a copy of the last previously archived revision of the document, and after changing the date to the current date and changing the revision designation from the existing to the next revision plus an alpha character (e.g. Rev. 1 would become Rev. 2A), the originator will provide that file to the Project Manager for approval.
After the necessary approvals are obtained by the Project Manager, the originator will remove the alpha designation, change the date to the current date, and issue and archive the latest revision for the initial baselined issue described above.
Following the issue of the revised document, drawing, or program, the ECN form shall be signed off as completed by the Project Manager and the V&V Engineer.
3.1.2 Drawings All drawings submitted to WCNOC and produced for the ALS Class 1E Controls shall be placed under configuration control after initial baselining.
3.1.2.1 Initial Baselining shall be accomplished as follows:
Drawings shall bear a "REVISION OA" designation and be submitted to the V&V Engineer for baselining.
Following review by the V&V Engineer and resolution/incorporation of any comments with the originator of the drawing, the V&V Engineer shall submit the drawing for approval by the Project Manager.
3.1.2.2 Drawing Revision Control Control of revisions to drawings after initial baselining shall be in accordance with the following:
Individuals perceiving a need for a revision to a previously baselined document shall initiate the process for change by completing an Engineering Change Notice (ECN) form defining the required changes, and submitting the form to the Project Manager and V&V Engineer for approval. In the event the corrective action cannot be performed directly or the resolution is outside the area of responsibility of the individual, that individual shall prepare a Problem Report (form attached) describing the defect.
The Project Manager and V&V Engineer shall review the ECN for approval of initiation of the revision.
Revision 2A 1/15/2008 Page 11 of 14
MSFIS Configuration Management Plan Following approval to make the revision, the Project Manager shall authorize a change to the revision designation from the existing to the next revision plus an alpha character (i.e. Rev. 1 would become Rev. 2A).
For the first revision of a drawing, the title block of the drawing shall be revised to indicate the signatures that were affixed to the approved Revision 0 (i.e., by entering S/XXX indicating that XXX signed Revision 0 of the drawing) of the drawing, and the Revision Block shall designate the new revision level in preparation. Indication of the original approvers of the drawing shall remain in the title block through all future changes.
After completion, the revision will be submitted to the Project Manager and the V&V Engineer for approval.
After approval by the Project Manager and the V&V Engineer, the originator will remove the alpha designation issue and archive the latest revision as for the initial baselined issue described above.
3.1.3 Approval Authority Approval authority for each baselining of a document or drawing shall include at least the following:
- Project Manager
" V&V Engineer Circuit description listing approvals shall be internal to the design team (CSI). Circuit description listings are not addressed in the VVP and are included in this CMP only to ensure that the "as-qualified" and "as-shipped" configurations are captured and controlled.
3.1.4 Methods to Process Change Approval Changes to previously-baselined documents, including procedures, plans, drawings, test procedures, and reports shall be initiated only in accordance with an Engineering Change Notice (ECN) approved by the Project Manager and the V&V Engineer, and shall be issued only with the approval of the Project Manager.
The ECN shall identify any iteration affecting other documents and retest requirements relating to the change.
3.2 Configuration Status Accounting The V&V Engineer shall maintain a log of the revision level in effect and date of each document that has previously been baselined.
Revision 2A 1/15/2008 Page 12 of 14
MSFIS Configuration Management Plan Configuration Management Plan Maintenance 4.1 Responsibilities The V&V Engineer shall be responsible for monitoring the CMP to ensure that it meets all of the requirements of the Wolf Creek QA Program. The V&V Engineer shall be responsible for ensuring that the CMP is kept current with the project as the design evolves.
4.2 Updates Updates to the CMP shall be made as necessary. Minor or editorial changes identified during a given design phase may be held for issue until the end of that phase. Changes shall not be held open between design phases without the concurrence of the Project Manager.
4.3 Change Approval Any revision to the CMP shall be reviewed and approved by the Project Manager.
4.4 Change Distribution Following approval of any change to the CMP, copies shall be distributed to the persons approving the change, the V&V Engineer, the Project Manager, and the project files.
Revision 2A 1/15/2008 Page 13 of 14
MSFIS Configuration Management Plan : Engineering Change Notice (ECN) Form : Problem Report Form 1/15/2008 Page 14 of 14 2A Revision 2A 1/15/2008 Page 14 of 14
ATTACHMENT I ENGINEERING CHANGE NOTICE (ECN)
FORM
- 1) REOUESTED CHANGE Originator's name Date Signature JOB NUMBER:
ITEM IDENTIFICATION:
DESCRIPTION OF CHANGE:
RECOMMENDED ACTION:
- ECN/O00 ECN controlled number II) ENGINEERING ACTION Page 2 of 3 ACTION TO BE TAKEN:
DRAWING/REPORT CHANGE NEEDED: YES NO RESPONSIBILITY:
DRAWING(S)/REPORT(S): REV.
CUSTOMER APPROVAL REOUIRED: YES NO RESPONSIBILITY:
SPECIAL TESTING REOUIRED: YES __ NO __ RESPONSIBILITY:
TEST PROCEDURE NUMBER: RESPONSIBILITY:
SOFTWARE CHANGE REOUIRED: YES _ NO_ RESPONSIBILITY:
OTHER CHANGES NECESSARY: YES NO RESPONSIBILITY:
PROPOSED ACTION APPROVED:
Project Manager Date V&V Engineer Date
- ECN/000 ECN controlled number III) ACTION COMPLETED Page 3 of 3 DRAWING OR REPORT CHANGES COMPLETED AND PROPERLY REVIEWED:
DRAWING/REPORT NUMBER: REV.
SPECIAL TESTING COMPLETED:
DATE ACCEPTABLE: YES NO COGNIZANT ENGINEER SIGNATURE DATE REOUIRED VERIFICATION TESTING COMPLETED:
DATE ACCEPTABLE: YES NO V & V ENGINEER DATE ALL OTHER CHANGES IDENTIFIED IN SECTION II. HAVE BEEN COMPLETED:
(Identify what other changes have been completed and the dates when the action was completed.)
IV) APPROVALS Project Manager Date V&V Engineer Date
ATTACHMENT 2 PROBLEM REPORT FORM
PROBLEM REPORT PROBLEM REPORTED Originator's Name Date Signature JOB NUMBER:
ITEM IDENTIFICATION:
PROGRAM PHASE WHEN PROBLEM WAS DETECTED:
PROBLEM DESCRIPTION: (Attach and number additional pages if required)
ENGINEERING ACTION (To be completed by the Cognizant Engineer)
PROBLEM RESOLUTION: (Attach and number additional pages if required)
ACTION TO BE TAKEN:
APPROVALS:
Project Manager Date V & V Engineer Date
Enclosure IX to ET 08-0014 CS Innovations Letter 9100-00018, "Application for Withholding Proprietary Information from Public Disclosure"
Ref: 9100-00018 CS INNOVATIONS LLC CS INNOVATIONS Direct phone: 480-612-2040 9150 E. DEL CAMINO, SUITE 110 Fax: 623-505-1055 SCOTTSDALE, AZ, 85256 e-mail: stcen@cs-innovation.oom U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Our ref: 9100-00018 February 25th, 2008 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
6002-00001, "ALS Quality Assurance Plan", Revision 1 (CS Innovations LLC 2008 Confidential and Proprietary)
The proprietary information for which withholding is being requested in the above referenced report is further identified in Affidavit 9100-00015 signed by the owner of the proprietary information, CS Innovations LLC. The affidavit, which accompanies this letter, 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 Section 2.390 of the Commission's regulhtions.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by the Wolf Creek Nuclear Operating Corporation.
Correspondence with respect to the proprietary aspects of the application for withholding or the CSI affidavit should reference this letter, 9100-00018, and should be addressed to Steen D. Sorensen, President & CEO, CS Innovations LLC, 9150 E. Del Camino, Suite 110, Scottsdale, AZ, 85256.
Verysdytours, C S~ten%D.So~renseA4ii' President & CEO
Ref- 9100-00015 AFFIDAVIT State of Arizona County of Maricopa Before me, the undersigned authority, personally appeared Steen D. Sorensen, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of CS Innovations LLC (CSI), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
St*%
tn D. Sorensen President & CEO Sworn to and subscribed before me thisa!LH day of 4j~h4.__,12008 Page 1 of 4
Ref. 9 100-00015 (1) 1am President & CEO, CS Innovations LLC (CSI), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of CSI.
(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the CSI "Application for Withholding" accompanying this Affidavit.
(3) 1have personal knowledge of the criteria and procedures utilized by CSI in designating inform-ation as a trade secret, privileged or as confidential commercial or financial information.
(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining the information sought to be withheld from public disclosure should be withheld.
(i) The information sought to be withheld from public disclosure is owned and been held in confidence by CS].
(ii) The information is of a type customarily held in confidence by CSI and not customarily disclosure to the public. CSI has a rational basis for determining the types of information customarily held in confidence by it and,, in that connection, utilizes a system to determining when and whether to hold certain types of information in confidence. The application of that system and substance of that system constitutes CS1 policy and provides the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
(a) The information reveals the distinguishing aspects of a process (or component structure, tool, method, etc.) where prevention of its use by any of CSI's competitors without license from CSI constitutes. a competitive economic advantage over other companies.
(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.) the application of which data secures a competitive economic advantage, e.g. by optimization or improved marketability.
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Ref. 9100-00015 (c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d) It reveals costs or price information, production capacities, budget levels, or commercial strategies of CSI, its customers or suppliers.
(e) It reveals aspects of past, present, or future CSI or customer funded development plans and programs of potential commercial value to CS].
(f) It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the CS! system which include the following:
(a) The use of such information by CST gives CST a competitive advantage over its competitors. It is,therefore, withheld from disclosure to protect the CST competitive position.
(b) It isinformation that is marketable in many ways. The extent to which such information is available to competitors diminishes the CST ability to sell products and services involving the use of the information.
(c) Use by our competitor would put CSI at a competitive disadvantage by reducing his expenditure of resources at our expense.
(d)Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving CST of a competitive advantage.
(e) The CS! capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.
(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.
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Ref, 9100-00015 (v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in 6002-00001, "ALS Quality Assurance Plan",
Revision 1,dated February 21, 2008 (CS Innovations LLC 2008 Confidential and Proprietary). The information is provided in support of a submittal to the Commission, being transmitted by the Wolf Creek Nuclear Operating Corporation and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk.
This information is part of that which will enable CSI to:
(a) Provide a replacement MSFIS Controls for Wolf Creek Generating Station.
Further this information has substantial commercial value as follows:
(a) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by CSI.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of CSI.
The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive CSI effort and the expenditure of a considerable sum of money.
In order for competitors of CSI to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.
Further the deponent sayeth not.
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