ML081260167
| ML081260167 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 04/29/2008 |
| From: | Baxter D Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML081260167 (17) | |
Text
Duke DAVE BAXTER Vice President Oconee Nuclear Station Duke Energy Corporation ON01 VP17800 Rochester Highway Seneca, SC 29672 864-885-4460 864-885-4208 fax dabaxter@dukeenergy. com April 29, 2008 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Document Control Desk
Subject:
Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287 License Amendment Request for Reactor Protective System/Engineered Safeguards Protective System Digital Upgrade, Technical Specification Change (TSC) Number 2007-09, Supplement 2 On January 31, 2008, Duke Energy Carolinas, LLC (Duke) submitted a License Amendment Request (LAR) to address replacement of the existing Oconee Nuclear Station (ONS) analog based Reactor Protective System (RPS) and Engineered Safeguards Protective System (ESPS) with a digital computer based RPS/ESPS. During a post submittal meeting for the LAR on March 18, 2008, NRC requested Duke to provide additional information associated with five issues. Enclosures 2 and 3 provide the requested information for two of the issues in accordance with the schedule for providing this information submitted by letter dated April 3, 2008.
Since information contained in Enclosure 3 is classified by AREVA NP as proprietary, an affidavit from AREVA NP in accordance with the provisions of 10 CFR 2.390 is provided in Enclosure 1.
www. duke-energy, com
U. S. Nuclear Regulatory Commission April 29, 2008 Page 2 If there are any questions regarding this submittal, please contact Boyd Shingleton at (864) 885-4716.
Very truly yours, Dav axter, Vice President Oconee Nuclear Station
Enclosures:
- 1.
AREVA NP Affidavit
- 2.
Requested Information for Issues 1 and 2
- 3.
AREVA Document No. 51-9076647-000
U. S. Nuclear Regulatory Commission April 29, 2008 Page 3 cc:
Mr. L. N. Olshan, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-14 H25 Washington, D. C. 20555 V. M. McCree, Regional Administrator (Acting)
U. S. Nuclear Regulatory Commission - Region 11 Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. Andy Hutto Senior Resident Inspector Oconee Nuclear Station S. E. Jenkins, Manager Division of Radioactive Waste Management Bureau of Land and Waste Management Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201
U. S. Nuclear Regulatory Commission April 29, 2008 Page 4 Dave Baxter affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.
Dave Baxtef Vice President Oconee Nuclear Site Subscribed and sworn to me:
bat 4-/
I Notary Public
/
My Commission Expires:
6- /?- ?,o/ 3 Date SEAL
U. S. Nuclear Regulatory Commission April 29, 2008 Page 5 bcc:
w/attachments R. W. Cornett B. R. Loftis B. M. Thomas J. L. Abbott B. G. Davenport J. E. Burchfield C. E. Curry L. F. Vaughn P.J. North R. J. Freudenberger D. B. Coyle E. L. Anderson R. L. Gill - NRI&A R. D. Hart - CNS K. L. Ashe - MNS R. V. Gambrell D. C. Richardson M. E. Bailey NSRB, EC05N ELL, ECO50 File - T.S. Working BWOG Tech Spec Committee (5)
ONS Document Management
License Amendment Request No. 2007-09, Supplement 2 April 29, 2008 AREVA NP Affidavit for Enclosure 3
)
)
ss.
CITY OF LYNCHBURG
)
- 1.
My name is Mark J. Burzynski. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.
- 2.
I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary. I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.
- 3.
I am familiar with the AREVA NP information provided to the NRC in support of a Duke Power Company LLC License Amendment Request for Oconee Nuclear Station, Units 1, 2, and 3 (Docket Numbers 50-269, 50-270, and 50-287) entitled Reactor Protective System/Engineered Safeguards Protective System Digital Upgrade, Technical Specification Change Number 2007-09. The following AREVA NP document is provided and referred to herein as the "Document."
AREVA NP document 51-9076647-000, Position Paper: Alignment of Oconee RPS/ESPS Project with NRC DI&C-ISG Task Working Group #4: Highly-Integrated Control Rooms-Communications Issues
Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP 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 AREVA NP 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. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information".
- 6.
The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary:
(a)
The information reveals details of AREVA NP'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 AREVA NP.
(d)
The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.
(e)
The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.
The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(c) and 6(d) above.
- 7.
In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8.
AREVA NP 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.
-M"tlv 9W40-)t'44 I 40ý SUBSCRIBED before me on this day of rC"
,2008.
v Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/2010 Registration # 7079129 SHERRY L. MCFADEN INotary Public 3
Commonwealth of Virginnla 7079129 My Commission Expires Oct 31. 2010
License Amendment Request No. 2007-09, Supplement 2 April 29, 2008 Requested Information for Issues 1 and 2
License Amendment Request No. 2007-09, Supplement 2 April 29, 2008 Page 1.
Issue 1: Bidirectional communications among safety divisions and between safety and non-safety equipment (interdivisional communication) is acceptable provided certain restrictions are enforced to ensure that there will be no adverse impact on safety systems. The ISG on Highly-Integrated Control Rooms - Communications lssues (HICRc), describes the methods that the staff will use to evaluate licensee compliance with NRC requirements with respect to interdivisional communication. The ISG section on interdivisional communication contains 20 staff positions for which the staff needs information beyond what is in the LAR in order to evaluate the communications strategy of the application.
Response to Issue 1: The Oconee Reactor Protection System (RPS)/Engineered Safeguards Protective System (ESPS) License Amendment Request (LAR) was in the final internal review stages when NRC DI&C-ISG Task Working Group #4: Highly-Integrated Control Rooms-Communications Issues, was issued. Duke Energy Carolinas, LLC (Duke) evaluated the Interim Staff Guideline (ISG) and concluded that the LAR and the TELEPERM XS (TXS)
Topical Report (Topical Report EMF-21 10(NP), Revision 1, "TELEPERM XS: A Digital Reactor Protection System," dated September 1, 1999) addressed the applicable parts of the ISG.
Nuclear Regulatory Commission (NRC) Staff indicated in a Duke/NRC teleconference on February 26, 2007 that it was not readily apparent what parts of the LAR address the ISG. To facilitate NRC review, Duke agreed to provide a matrix identifying where these documents address the applicable parts of ISG-04.
DI&C-ISG-04 addresses four basic areas of interest:
- 1.
Interdivisional communications: communications among different safety-related divisions or between a safety-related division and a non-safety entity,
- 2.
Command prioritization: selection of a particular command to send to an actuator when multiple and conflicting commands exist,
- 3.
Multidivisional control and display stations: use of operator workstations or displays that are associated with multiple safety-related divisions and/or with both safety related and non-safety functions, and
- 4.
Digital system network configuration: the network or other interconnection of digital' systems that might affect plant safety or conformance to plant safety analysis assumptions (interconnections among safety-related divisions or between safety related and non-safety divisions should also satisfy the guidance provided for interdivisional communications).
Areas of Interest 1 through 3 are each addressed in a separate section of DI&C-ISG-04. The ISG indicates that Area of Interest 4 has implications concerning each of the first three and is incorporated into those sections as needed.
License Amendment Request No. 2007-09, Supplement 2 April 29, 2008 Page 2 (AREVA NP document 51-9076647-000, Position Paper: Alignment of Oconee RPS/ESPS Project with NRC DI&C-ISG Task Working Group #4: Highly-Integrated Control Rooms-Communications Issues) assesses the alignment of the Oconee RPS/ ESPS digital upgrade, to NRC's interim staff guidance outlined in DI&C-ISG-04.
The Oconee RPS/ESPS design aligns with DI&C-ISG-04 for 18 of the 20 elements in Area of Interest 1. The TXS design has a previously established acceptable alternative method for complying with the other 2 elements (10 & 11), as documented in the NRC Safety Evaluation Report (NRC letter dated May 5, 2000, "Acceptance for Referencing of Licensing Topical Report EMF-21 10(NP), Revision 1, "TELEPERM XS: A Digital Reactor Protection System.") for the TXS Topical Report and described in Enclosure 3 (Table 1, Oconee position for elements 10 and 11).
DI&C-ISG-04 Area of Interest 2 is not applicable to the Oconee RPS/ESPS design because it does not utilize digital priority modules.,
The Oconee RPS/ESPS design aligns with the applicable elements of DI&C-ISG-04 for Area of Interest 3 for the TXS Service Unit and TXS Gateway connections. The TXS design has a previously established acceptable alternative method for the TXS Service Unit design, as documented in the NRC SER for the TXS Topical Report and described in Enclosure 3.
Issue 2: The LAR states that the TXS application software development was performed in accordance with the Software Program Manual (SPM). The Office of New Reactors (NRO) is currently reviewing the referenced SPM; however, this is not an approved program at this time.
Therefore, the licensee should provide stand alone documents for application software quality assessment.
Response to Issue 2:
The RPS/ESPS LAR references the AREVA SPM in several locations in Enclosure 1 of the LAR. The SPM describes the program measures incorporated at AREVA NP to ensure that the TXS application software attains a level of quality commensurate with its importance to safety functions, performs the required safety functions correctly and conforms to established technical and documentation requirements, conventions, and rules. The SPM consists of several plans that are implemented by AREVA Operating Instructions and in Oconee specific documents as described in Table 1 below. The SPM discusses a software development plan, integration plan, installation plan, and training plan. These plans-are also addressed by AREVA procedures or Oconee plans as discussed below.
Duke has evaluated the references to the SPM made by the RPS/ESPS LAR and concluded that there is no need to reference the SPM. This evaluation is provided in Table 2 below.
License Amendment Request No. 2007-09, Supplement 2 April 29, 2008 Page 3 The SPM identifies documents that were created to address the software life cycle model presented in IEEE Std. 1074. Many of these documents, such as the functional requirements specification, software requirements specification, software design description, the application software requirements traceability matrix, and the verification and validation (V&V) plan, were submitted with or addressed by the RPSIESPS LAR. These documents make up the software development plan documentation. Therefore, reference to the SPM is not necessary.
As indicated in the SPM, AREVA NP uses the approved SPACE tool to automatically generate the application software, and the SPACE tool produces software that is designed to work with the system software of the TELEPERM XS system. Because of this, no Oconee application specific software integration effort is required between the system software and application software.
Software installation is controlled by the Software Generation and Download Procedure, which is a configuration item governed by the Oconee Software Configuration Management Plan (SCMP).
Software training is addressed in Section 3.6.2 of Enclosure 1 to the RPS/ESPS LAR.
License Amendment Request No. 2007-09, Supplement 2 April 29, 2008 Page 4 Table 1 SPM Implementation Documents SPM Plan Description AREVA Generic Oconee Application Procedure Specific Document Software Quality Describes the necessary 01-1457, N/A Assurance Plan processes that ensure "TELEPERM XS that the software attains Software Quality a level of quality Assurance Plan" commensurate with its importance to safety function.
Software Safety Identifies the process to TXS Topical AREVA NP Doc No.
Plan reasonably eliminate Report, and 01-51-9005043-005, hazards that could 1578, TELEPERM "Oconee Nuclear jeopardize the health and XS Software Station, Unit 1, 2, & 3 safety of the public from Safety Plan" RPS/ESFAS Controls safety critical software.
Upgrade Software Safety Plan (SSP)"
Software Describes the method 01-1459, AREVA NP Doc No.
Verification and that ensures correctness "TELEPERM XS 51-9010419-006, Validation Plan of the software.
Software "Oconee Nuclear Verification and Station Unit 1 Validation Plan" RPS/ESFAS Controls Upgrade Software Verification and Validation Plan" Software Describes the method 01-1460, AREVA NP Doc No.
Configuration that maintains the "TELEPERM XS 51-9006444-005, Management Plan software in a controlled Software "Oconee Nuclear configuration at all Configuration Station, Units 1, 2, and 3 times.
Management Plan" RPS/ESFAS Controls Upgrade Software Configuration Management Plan" Software Describes post-customer 01-1592, N/A Operations and delivery software "Software Maintenance Plan practices.
Operations and Maintenance Plan"
License Amendment Request No. 2007-09, Supplement 2 April 29, 2008 Page 5 Table 2 Disposition of References to the SPM from the ONS RPS/ESPS LAR Reference to SPM Comment Page 1-8, Table 1-2 Item 19 Software installation is controlled by the Software indicates that the ONS Generation and Download and procedure which is a Software Installation Plan is configuration item of the Oconee SCMP. As such specific incorporated into SPM reference to the SPM is not necessary.
Page 3-27, Section 3.3.3.2, Section 3.3.3.2 only describes the AREVA SPM and then AREVA QA Program goes on to explain that all design work, products and services provided for the RPS/ESPS digital upgrade project are performed to the requirements of the AREVA NP Quality Management Manual, which is supplemented by the additional QA requirements for TXS projects described in the TXS Topical Report and the TXS Software Program Manual. The SPM is implemented by a number of AREVA Ols, some of which are used to develop Oconee specific documents. The Oconee specific documents appropriately address life cycle product without the need to reference the SPM.
Page 3-85, Section 3.4.3.2, The development process for application software is AREVA Software QA addressed by AREVA operating instructions and Oconee Program specific plans. As such there is no need to reference the SPM. LAR Section 3.4.3.3 concludes that the ONS digital RPS/ESPS have been developed with high quality consistent with industry standards and in accordance with Duke and AREVA NP software QA programs. This conclusion is valid without specifically referencing the SPM.
Page 3-86, Section 3.4.3.2.1, Same as above Software Development Page 3-88, Section 3.4.3.2.2, Same as above Software Quality Metrics Page 3-88, Section 3.4.3.2.3, Same as above Software Tools Page 3-90, Section 3.4.3.2.4, Same as above Software V&V Page 3-93, Section 3.4.3.2.5, Same as above Independent V&V
License Amendment Request No. 2007-09, Supplement 2 April 29, 2008 Page 6 Reference to SPM Comment Page 3-95, Section 3.4.3.2.6, Same as above Software Configuration Mgt Page 3-96 Section 3.4.3.2.7 Same as above Software Project Risk Mgt Page 3-122 Section 3.6.4.1 This section indicates that project and application specific Project Related guidance is included in the TXS Software Program Manual Configuration Management (Reference 11) and several OIs addressing software QA (requirements in Ois) plans, software verification and validation plans, software documentation and software and hardware CM. The specific 01 or lower level document will replace the SPM reference.
Page 3-123 Section 3.6.4.3 This section indicates that additional AREVA NP software Software Related related configuration guidance is contained in the TXS Configuration Management Software Program Manual (Reference 11) and Ois for (requirements in Os) software QA plans and software V&V plans. The specific 01 or lower level document will replace the SPM reference.
Page 6-1, Section 6.10, Delete AREVA SPM manual as a reference to the LAR.
References