ML091770436
| ML091770436 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 06/19/2009 |
| From: | Baxter D Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TSC-2007-09, Suppl 17 | |
| Download: ML091770436 (31) | |
Text
Duke DAVE BAXTER
- oEnergy, Vice President Oconee Nuclear Station Duke Energy ON01 VP / 7800 Rochester Highway Seneca, SC 29672 864-873-4460 864-873-4208 fax dabaxter@dukeenergy. com June 19, 2009 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555
Subject:
Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287 Supplemental Request for Additional Information for License Amendment Request for Reactor Protective System/Engineered Safeguards Protective System Digital Upgrade, Technical Specification Change (TSC) Number 2007-09, Supplement 17 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. Duke responded to an August 20, 2008, NRC request for additional information (RAI) by letter dated September 30, 2008. Duke responded to a March 9, 2009 supplemental RAI by letter dated April 3, 2009. Enclosure 1 provides Duke's response to an RAI that NRC provided electronically on May 19, 2009.
Enclosures 2 and 6 provide documents requested by the NRC Staff to resolve NRC Oconee Safety Evaluation Report (SER) Open Items (01) or to provide a docketed reference for information to be described in the SER.
On June 10, 2009, NRC requested Duke to respond to SER 01 89 by submitting a revised response to RAI EICB 103. NRC also requested Duke to provide additional information associated with RAI EICB 102 described in SER 01 90 which was provided to Duke on June 17, 2009. These Ols are related to the April 3, 2009, Supplemental Cyber Security RAI Response. Enclosure 5 provides the requested information. This Enclosure contains a description of design features that secure the RPS/ESPS from electronic vulnerabilities. As such, Duke considers the information in the enclosure to be security-related information and requests that it be withheld from public disclosure pursuant to 10 CFR 2.390.
During a Duke/NRC Conference call on June 10, 2009, in response to NRC SER 01 77, Duke agreed to propose changes to the Technical Specification (TS) Surveillance Requirements (SR) to resolve NRC concerns related to the TS definition for a digital computer Channel Functional Test. Duke also agreed to revise the TS definition for Channel Check to specifically Enclosures 2 and 7 (not including Attachments 1 and 2) to this letter contain proprietary information. contains Security-Related information. Withhold from public disclosure under 10 CFR 2.390. Upon removal of these Enclosures this letter is uncontrolled.
www. duke-energy. com
U. S. Nuclear Regulatory Commission June 19, 2009 Page 2 define a digital computer Channel Check. NRC requested Duke to re-submit the proposed Technical Specifications for the RPS/ESPS LAR to consolidate changes proposed since the January 31, 2008, RPS/ESPS LAR, along with a description of the proposed changes. This information is provided in Enclosure 7. Enclosure 4 provides information requested by other NRC Ols.
The additional proposed changes do not affect the conclusions of the No Significant Hazards Consideration included in the January 31, 2008 LAR. Additionally, a copy of this LAR is being sent to the State of South Carolina in accordance with 10 CFR 50.91 requirements.
Information contained in Enclosures 2 and 7 are classified by AREVA NP as proprietary. The appropriate affidavits from AREVA NP are provided in Enclosure 3 in accordance with the provisions of 10 CFR 2.390. Enclosure 4 provides additional information that Duke agreed to submit during recent Duke/NRC teleconferences. Enclosure 6 provides a non proprietary Duke document. Attachments 1 and 2 of Enclosure 7 are non-proprietary. A non-proprietary version of Enclosure 7 is provided in Enclosure 8.
If there are any questions regarding this submittal, please contact Boyd Shingleton at (864) 873-4716.
I declare under penalty of perjury that the foregoing is true and correct. Executed on June 19, 2009.
Sincerely, Day Baxter, Vice President Oconee Nuclear Station
Enclosures:
- 1.
Duke Response to Supplemental Request for Additional Information
- 2.
AREVA NP Documents - Proprietary
- 3.
AREVA NP Affidavit
- 4.
Additional Information
- 5.
Additional Cyber Security Information [Security-Related]
- 6.
Duke Document - Non-Proprietary
- 7.
Evaluation of Proposed Technical Specification Change - Proprietary
- 8.
Evaluation of Proposed Technical Specification Change - Non-Proprietary Enclosures 2 and 7 (not including Attachments 1 and 2) to this letter contain proprietary information. contains Security-Related information. Withhold from public disclosure under 10 CFR 2.390. Upon removal of these Enclosures this letter is uncontrolled.
U. S. Nuclear Regulatory Commission June 19, 2009 Page 3 cc:
Mr. J. F. Stang, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-14 H25 Washington, D. C. 20555 Mr. L. A. Reyes, Regional Administrator U. S. Nuclear Regulatory Commission - Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. E. T. Riggs Senior Resident Inspector Oconee Nuclear Station S. E. Jenkins, Manager Infectious and Radioactive Waste Management Section 2600 Bull Street Columbia, SC 29201 Enclosures 2 and 7 (not including Attachments 1 and 2) to this letter contain proprietary information. contains Security-Related information. Withhold from public disclosure under 10 CFR 2.390. Upon removal of these Enclosures this letter is uncontrolled.
-I
TSC 2007-09, Supplement 17 June 19, 2009 Page 1 Enclosure I Duke Response to Supplemental Request for Additional Information RAI-201: The following discrepancies were noted in the SQAP 01-1457.
- a. The SRR Software Requirements Review (SRR) report is specifically prescribed in the Software Quality Assurance Plan (SQAP) Section 3.2.1 and in Section 6.1.1. It is the staffs understanding that instead of producing this report, Areva completed the required documentation within the context of the V&V Activity Summary Reports and the Independent Pro Descon review and audit report. Please provide justification for this apparent deviation from the SQAP. A revision to the SQAP should also be considered if SRR reports are not to be produced for future software development efforts.
- b. The SWPR Software V&V Plan Review (SWPR) and the Software Design Review (SDR) are prescribed in the Software Quality Assurance Plan (SQAP) Sections 3.2.1, 3.2.2 and in Section 6.1.4. For these cases, no actual reports are mentioned but statements like "The' SVVPR shall be prepared by the reviewers and shall be approved by the Engineering Manager of IV&V", clearly imply that a report or document is to be produced. If the results of this review are documented in the V&V Activity Summary Reports or other documents, then this practice should be stated in the SQAP.
- c. Is the Software Verification and Validation report that is described in the SQAP Section 3.2.2 and in Section 4.2.4 the same document as the various phase V&V Activity Summary Reports provided on the docket? If yes, then why are the report names not consistent? If no, then the staff would like to review the SWR described in the SQAP.
What is Areva's intended practice for documenting these review efforts?
Duke Response: The AREVA NP SQAP is described in Operating Instruction 01-1457, TELEPERM XS Software Quality Assurance Plan. Revision 6 was submitted to NRC in License Amendment Request (LAR) Supplement 8. It is the basis for the questions in RAI 201.
.Revision 8 to 01-1457 was issued in February 2009 to clarify the incorrect, confusing, or conflicting statements discussed in the RAI.
Response to Item a: Prior to Revision 8 of the SQAP, the Software Requirements Specification (SRS) review was described in the SQAP as an Independent Verification and Validation (IV&V) activity that would be documented in the IV&V Software Requirements Review Report (SRR), as noted in 01-1457-06 Section 3.2.1. It was also stated that each revision of the SRS would be reviewed each time it was updated.
Prior to July 2007 the Oconee Software Verification and Validation Plan (SVVP), which was described in AREVA NP document 51-9010419-000, defined reports by the following names:
Software Requirements Review Report (SRR), Software Design Review Report (SDR),
Software Implementation Review Report, and Software Validation Report. In July 2007, an Activity Summary Report for each phase was added to the SWP list (AREVA NP document 51-9010419-001). During this period, the SRR was revised each time the SRS was revised.
In September 2007, the Oconee SWP (AREVA NP document 51-9010419-002) was revised to eliminate the duplication between the reports specified for each phase. The Activity Summary Report designation was retained for each phase to align directly with IEEE Std 1012-1998
TSC 2007-09, Supplement 17 June 19, 2009 Page 2 language (Section 6.1). The Oconee SVVP described the reporting requirements for the requirements phase as follows:
In Section 5.2.1 Task 8 - A summary report of the V&V Tasks completed during the Requirements V&V Activity shall be prepared. This Requirements V&V Activity Summary Report (SRR) shall be prepared using the format and content guidelines of Section 6.1. The SRR shall be approved by the V&V Organization Manager and issued as an Engineering Information Record (EIR) document.
This language is still used in the current Oconee SWP. During this period, the actual, practice was that updates to the SRS were reviewed and documented in the IV&V Activity Summary Report for the period when the review was performed. Revision 8 of the SQAP was issued to provide clear guidance for the IV&V review of the SRS. It now requires the IV&V organization to summarize the SRS (and any subsequent revision) review activities in the IV&V Activity Summary Report for the period when the review was performed.
A recent Quality Assurance Functional Audit has identified that not all of the SRS revision review activities have been captured in the relevant V&V activity phase reports. Specifically, the Test Phase Summary Report (AREVA NP document 51-9105739-000) was approved on March 30, 2009 and references Revision 4 of the SRS; however, Revision 5 of the SRS was approved on March 17, 2009. This deficiency was documented in the AREVA NP Corrective Action Program as Condition Report (CR) 2009-2207.
The corrective action for CR 2009-2207 includes a revision to the generic SVVP (01-1459) as well as the Oconee Unit 1 and Unit 3 SVVPs to clearly describe the requirements for the IV&V review of SRS revisions and the expectations for documenting these reviews in the applicable Activity Summary Report or Final Report, depending on the timing of the revision. It will also harmonize the SVVP reporting requirements with the language used in Revision 8 of the SQAP.
Response to Item b: Prior to Revision 8 of the SQAP, the Software Design Review was described in the SQAP as an Independent Verification and Validation (IV&V) activity that would be documented in a Verification Results Report and Validation Results Report, as noted in 01-1457-06 Sections 3.2.2 and 4.2.4. No mention was made of reviews for revisions to the Software Design Description (SDD).
Prior to July 2007, the Oconee Software Verification and Validation Plan (SVVP), which was described in AREVA NP document 51-9010419-000, defined reports by the following names:
Software Requirements Review Report, Software Design Review Report, Software Implementation Review Report, and Software Validation Report. In July 2007, an Activity Summary Report for each phase was added to the SWP list (AREVA NP document 51-9010419-001). During this period, the SDR was revised each time the SDD was revised.
In/September 2007, the Oconee SWP (AREVA NP document 51-9010419-002) was revised to eliminate the duplication between the reports specified for each phase. The Activity Summary Report designation was retained for each phase to align directly with IEEE Std 1012-1998 language (Section 6.1). The Oconee SWP described the reporting requirements for the design phase as follows:
TSC 2007-09, Supplement 17 June 19, 2009 Page 3 In Section 5.2.2 Task 11 - A summary report of the V&V Tasks completed during the Design V&V Activity shall be prepared. This Design V&V Activity Summary Report (SDR) shall be prepared using the format and content guidelines of Section 6.1. The SDR shall be approved by the V&V Organization Manager and issued as an Engineering Information Record (EIR) document.
This language is still used in the current Oconee SVVP. During this period, the actual practice was that updates to the SDD were reviewed and documented in the IV&V Activity Summary Report for the period when the review was performed. Revision 8 of the SQAP was issued to provide clear guidance for the IV&V review of the SDD. It now requires the IV&V organization to summarize the SDD (and any subsequent revision) review activities in the IV&V Activity Summary Report for the period when the review was performed.
The procedure also described an SVVP review (01-1457-06 Section 3.2.1). The discussion of this review was linked to the discussion of the IV&V Activity Summary Reports (0,1-1457-06 Section 6.1.4 - see additional discussion below).- The actual practice was that the SVVP was prepared, reviewed, and approved in accordance with AREVA NP document creation requirements. The evidence for these reviews and approvals is recorded in each revision of the SVVP.
The period between August 2008 and January 2009 includes two revisions of 01-1457.
Revision 5 added the word 'Plan' to the heading of Section 6.1.4. No change was made to the text for that section. Revision 5 also changed the responsibility for the detailed software design review to the Software design group. Revision 6 added the word "Plan' to the discussion for the report title in the text of Section 6.1.4. The change was listed as an editorial change. No other changes were made to the text to change the meaning from a discussion of IV&V Activity Summary Reports. Neither of these editorial changes was intended to create a requirement for a separate SWP review report.
01-1457-08 was issued in February 2009 to clarify the incorrect, confusing, or conflicting statements. Specifically, Section 3 was reorganized to clearly define design and IV&V tasks in the various development phases. Section 4 was revised to align with the changes made in Section 3. Section 6 was reorganized based on lessons learned from Oconee Unit 1 and global standardization activities to clearly define a better set of technical and management reviews to be performed per IEEE Std 730-2002 and IEEE Std 1028-1997. These activities are separate from the Appendix B design verification activities or the IV&V activities. These activities are forward fit and will be performed for work on Oconee Units 2 and 3 and other TELEPERM XS projects.
The Software Verification and Validation Report discussed in SQAP Sections 3.2.2 and 4.2.4 is the same report as the IV&V design Activity Summary Report discussed in the SWP. The Software V&V Plan Review (SWPR) is discussed in response to Item c.
Response to Item c: The SQAP procedure also described an SWP review (01-1457-06 Section 3.2.1). The discussion of this review was linked to the discussion of the IV&V Activity Summary Reports (01-1457-06 Section 6.1.4-see additional discussion below). The actual practice was that the SVVP was prepared, reviewed, and approved in accordance with AREVA NP document creation requirements. The evidence for these reviews and approvals is recorded in each revision of the SVVP.
TSC 2007-09, Supplement 17 June 19, 2009 Page 4 The period between August 2008 and January 2009 includes two revisions of 01-1457.
Revision 5 added the word 'Plan' to the heading of Section 6.1.4. No change was made to the text for that section. Revision 5 also changed the responsibility for the detailed software design review to thne Software design group. Revision 6 added the word "Plan' to the discussion for the report title in the text of Section 6.1.4. The change was listed as an editorial change. No other changes were made to the text to change the meaning from a discussion of IV&V Activity Summary Reports. Neither of these editorial changes was intended to create a requirement for a separate SWP review report.
Summary: 01-1457-08 was issued in February 2009 to clarify the incorrect, confusing, or conflicting statements. Specifically, Section 3 was reorganized to clearly define design and IV&V tasks in the various development phases. Section 4 was revised to align with the changes made in Section 3. Section 6 was reorganized based on lessons learned from Oconee Unit 1 and global standardization activities to clearly define a better set of technical and management reviews to be performed per IEEE Std 730-2002 and IEEE Std 1028-1997. These activities are separate from the Appendix B design verification activities or the IV&V activities. These activities are forward fit and will be performed for work on Oconee Units 2 and 3 and other TELEPERM XS projects.
The generic SVVP (01-1459) as well as the Oconee Unit 1 and Unit 3 SWPs will be revised to clearly describe the requirements for the IV&V review of revisions to the SRS and other design documents and the expectations for documenting these reviews in the applicable Activity Summary Report or Final Report, depending on the time of the revision. It will also harmonize the SWP reporting requirements with the language used in Revision 8 of the SQAP.
AREVA NP document Operating Instruction 01-1457-08, TELEPERM XS Software Quality Assurance Plan, is provided as Enclosure 2.
TSC 2007-09, Supplement 17 June 19, 2009 Page 1 AREVA NP Proprietary Affidavits
AFFIDAVIT COMMONWEALTH OF VIRGINIA
)
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 referied to herein as the "Document."
AREVA NP document 51-5052804-10, Oconee Nuclear Station 1, 2 & 3 RPS/ESFAS Controls Upgrade - Component Arrangement Specification 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.
SUBSCRIBED before me on this day of May 2009.
Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/10 Reg. # 7079129
AFFIDAVIT COMMONWEALTH OF VIRGINIA
)
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. lam 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 51-9006444-009, Oconee Nuclear Station, Units 1, 2, & 3 RPS/ESFAS Controls Upgrade Software Configuration Management Plan 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 US. 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.
SUBSCRIBED before me on this I'61 day of AA/"
,2009.
Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/10 Reg. # 7079129 SHERRY L. MCFADEN Notary Public Commonwealth of Virginia" 7079129 My Commission Expires Oct 31, 2010
AFFIDAVIT COMMONWEALTH OF VIRGINIA
)
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 51-9113322-000, Oconee Nuclear Station Unit 1 RPS/ESFAS Controls Upgrade Software V&V Final Report 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 competiti'e 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 a
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.
SUBSCRIBED before me on this __-
day of
- M 2009.
Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/2010 Registration # 7079129 SHERRY L. MCFADEN Notary Public Commonwealth of VlrgInla 7079129 My Commlslon Expires Oct 31. 2010
AFFIDAVIT COMMONWEALTH OF VIRGINIA 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 Operating Instruction 01-1457-08, TELEPERM XS Software Quality Assurance Plan 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.
SUBSCRIBED before me on this _
day of
,2009.
Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/10 Reg. # 7079129
AFFIDAVIT COMMONWEALTH OF VIRGINIA 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 Operating Instruction 01-1585-02, TXS System-Hardware Configuration Management Plan 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.
SUBSCRIBED before me on this "______
day of 2009.
209 Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/2010 Registration # 7079129
AFF.I DAVIT COMMONWEALTH OF VIRGINIA 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 200,7-09, Supplement 17. Enclosure 7, Evaluation of Proposed Technical Specification Change, of Supplement 17 is provided and referred to herein as the "Document."
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.
SUBSCRIBED before me on this _________
day of
)v 2009.
S Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/2010 Registration # 7079129 4
SHERRY L. MCFADrN I
Notary PUbllc J
Commonwealth of Vfglnlo 7079129 My Commission Expires Oct 31. 2010
TSC 2007-09, Supplement 17 June 19, 2009 Page 1 Additional Information Related to NRC SER Open Items Duke agreed to provide the following additional information associated with the NRC Safety Evaluation Report (SER) Open Item (01) List for the Oconee Reactor Protective System (RPS)/Engineered Safeguards Protective System (ESPS) License Amendment Request (LAR) during weekly conference calls with the NRC.
0129 Duke agreed to revise the Software Configuration Management Plan (SCMP) to provide additional descriptors for the Configuration Items listed in Table 3-1. The revised SCMP is provided in Enclosure 2.
0177 In response to questions related to the Channel Functional Test definition, Duke proposed to amend the proposed Technical Specification Surveillance Requirements for RPS and ESPS Channel Functional Tests. Duke also agreed to propose a change to the Channel Check definition to specifically address requirements for the digital computer channel. These changes are described in detail in Enclosure 7.
0180 NRC identified several inconsistencies in the V&V summary reports related to the disposition of AREVA Open Items. AREVA stated that the process for handling open items in the Verification and Validation (V&V) reports was not clearly defined and will be addressed by the AREVA corrective action program for improvement looking forward. Disposition of Open Items and AREVA Condition Reports (CRs) is addressed in the V&V final report which is included in of this submittal.
0181 In response to a question associated with the quality requirements for the diverse actuation systems, Duke agreed to clarify the quality requirements for these systems.
Enhanced quality was required and provided for the diverse actuation systems (Diverse Low Pressure Injection Actuation System (DLPIAS) and Diverse High Pressure Injection Actuation System (DHPIAS)) similar to what was provided for the Anticipated Transient Without Scram (ATWS) modification and accepted by NRC in the safety evaluation dated November 29, 1989 for the final design of the ATWS modification. Duke did not establish an augmented quality program for ATWS equipment. Rather, this equipment was classified as non-safety and controlled in accordance with existing quality programs, which conform to the quality assurance (QA) guidance of Generic Letter 85-06. The DLPIAS and DHPIAS modifications are being controlled in the same manner.
TSC 2007-09, Supplement 17' June 19, 2009 Page 2 0183 NRC identified-that OSC-3348, Rev. 0, provided in Supplement 1, describes the DLPIAS as meeting single failure criteria but does not address the DHPIAS. NRC asked if DHPIAS meets the same criteria and where this is described. Duke responded that OSC-3348 was revised August 20, 2008 to include the DHPIAS. OSC-3348, Rev. 1 is included in Enclosure 6 of this submittal.
0184 Duke agreed to revise the FMEA to reflect the explanation provided in response to this 01. NRC indicated that they did not need a revision to the FMEA docketed but requested Duke describe the changes that will be made: The FMEA will be revised to add the following information:
"Non-Detectable Failures There are three component failures that are non-detectable through periodic testing that involve the following components: decoupling diodes in the S451 output circuits (can fail short = S and can fail open = 0), the varistors in the NI Interface module circuits (can also fail short = S and fail open = 0) and the varistors in the Reactor Coolant Pump Power Monitor circuits (can also fail short = S and fail open = 0). Only some instances of their failures are non-detectable. Their failures (both detectable and non-detectable) are tabulated below along with the effects of the failures and indication as to whether the effects are acceptable with respect to meeting the single failure criteria.
Table for Failures of S451 Output Diodes The evaluation of decoupling diode failures is addressed in FMEA Attachments 2, 3 and 4. The Table below is a summary of the failure effects for the diodes.
FUNCTION DETECTABLE EFFECT ACCEPTABLE ESFAS Safety S: Yes (S451 short Safety function Yes related outputs circuit detection) operable. Trouble alarm actuated.
0: Yes (periodic No-Safety function Yes Go test) inoperable. Test fails.
TSC 2007-09, Supplement 17 June 19, 2009 Page 3 FUNCTION DETECTABLE EFFECT ACCEPTABLE ESFAS Non-safety S: No Degraded EMI Yes outputs protection of S451 non-safety outputs.
Safety function operable.
0: Yes (Trouble/Fail The Channel Trouble Yes alarms) and Failure alarms fail in the actuated state.
0: Yes (detectable Other status alarms Yes by GSM output such as Channel tests)
Bypass fail. Safety function remains.
RPS Trip Outputs s: No Degraded EMI Yes protection of S451 outputs following turn-off cycle. No affect on trip function.
0: Yes (spurious Single channel trip Yes channel trip),
results in 1-o-o-4 logic.
Table for Failures of Varistors in NI Power Range Interface The evaluation of Varistor failures in the NI Power range Interface circuits is addressed in FMEA. The Table below is a summary of the Varistor failure effects.
FUNCTION DETECTABLE EFFECT ACCEPTABLE NI Power Range S: Neutral to No effect on modules Yes Varistors ground: Not detectable (No)
S: Line to ground:
Loss of NI in Channel, Yes and Line to neutral:
affects single channel (Yes)
O No Degraded EMI Yes protection of NI power supplies (has back up 120 VAC surge protection at input to cabinet) and modules.
TSC 2007-09, Supplement 17 June 19, 2009 Page 4 FUNCTION DETECTABLE EFFECT ACCEPTABLE Random failure or degradation of NI power supplies or modules monitored by software which provides alarm. Power supplies for each channel are independent therefore only one channel affected. Safety function operable.
Irnhin ferw Pnili~rac if VIoriafrtre in Pmn#-+r~r Irir~e~6 n* Diimmi 0v%%Axr Miun i*~r 4t S
- *M S
V~
- W SU The evaluation of Varistor failures in the NI Power range Interface circuits is addressed in FMEA. The Table below is a summary of the Varistor failure effects.
FUNCTION DETECTABLE EFFECT ACCEPTABLE RC Pump Power S: Neutral to No Effect on modules Yes Monitor Varistors ground: Not detectable (No)
S: Line to ground Loss of power to Yes and Line to neutral:
RCPPM causes pump Yes trip signal so is "safe" failure All 0: No - Not Degraded EMI Yes detectable protection of RCPPM power supplies (has back up 120 VAC surge protection at input to cabinet),
comparator module and time delay relay.
Random failure or degradation of these RCPPM components is detectable by testing per Tech Spec Channel Calibration
TSC 2007-09, Supplement 17 June 19, 2009 Page 5 The non-detectable failure effects are acceptable. The non-detectable failures of the decoupling diode short in the ESFAS Non-safety outputs and the RPS trip outputs have no effect on safety function and are acceptable with respect to the single failure criteria. The non-detectable failures of the varistors in the fail open mode in NI Interface and RCPPM circuits do not affect safety function and have installed backup in the 120 VAC input power circuits.
The detectable failures are addressed in the same manner as other single failures. The non-detectable failures only degrade EMI protection of various modules (the power supplies have backup protection). The EMI surge occurs only when inductive loads are de-energized.
Repetitive EMI surges may cause eventual degradation of RCPPM modules or S451 single digital outputs. The potential failure modes of the modules and digital outputs used for safety related functions are periodically tested and independence and isolation prevents the EMI surge from affecting multiple channels. Therefore, the effects are limited to single failures as analyzed in the FMEA which do not defeat safety function. There is no additional periodic testing required to detect these failures."