ML13093A311

Submittal of Revised System Verification and Validation Plan and Tricon Documents for the License Amendment Request for Digital Process Protection System Replacement

ML13093A311
Person / Time
Site:	Diablo Canyon
Issue date:	03/25/2013
From:	Allen B Pacific Gas & Electric Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
DCL-13-028
Download: ML13093A311 (7)

Text

Attachments 9-14 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Pacific Gas and Electric Company' Barry S. Allen Diablo Canyon Power Plant Site Vice President Mail Code 104/6 P. 0. Box 56 Avila Beach, CA 93424 March 25, 2013 805.545.4888 Internal: 691.4888 Fax: 805.545.6445 PG&E Letter DCL-13-028 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Submittal of Revised System Verification and Validation Plan and Tricon Documents for the License Amendment Request for Digital Process Protection System Replacement

References:

1. PG&E Letter DCL-1 1-104, "License Amendment Request 11-07, Process Protection System Replacement," dated October 26, 2011 (ADAMS Accession No. ML11307A331).

2. Digital Instrumentation and Controls Digital I&C-ISG-06, "Task Working Group #6: Licensing Process, Interim Staff Guidance,"

Revision 1, January 19, 2011 (ADAMS Accession No. ML110140103).

3. NRC Letter "Diablo Canyon Power Plant, Unit Nos. 1 and 2 -

Acceptance Review of License Amendment Request for Digital Process Protection System Replacement. (TAC Nos. ME7522 and ME7523)," dated January 13, 2012.

4. NRC Letter "Summary of December 19, 2012, Teleconference Meeting with Pacific Gas and Electric Company on Digital Replacement of the Process Protection System Portion of the Reactor Trip System and Engineered Safety Features Actuation System at Diablo Canyon Power Plant, Unit Nos. 1 and 2 (TAC NOS. ME7522 and ME7523)," dated January 10, 2013 (ADAMS Accession No. ML12361A360).

5. PG&E Letter DCL-12-069, "Submittal of Quality Assurance Plan and Revised Phase I Documents for the License Amendment Request for Digital Process Protection System Replacement," dated August 2, 2012 (ADAMS Accession No. ML12222A094).

Attachments 9-14 to the Enclosure contain Proprietary Information T0 When separated from Attachments 9-14 to the Enclosure, this document is decontrolled.

A member of the STARS (Strategic Teaming and Resource Sharing)

Alliance i

4 Callaway -

Comanche Peak

• Diablo Canyon

• Palo Verde -

San Onofre

• South Texas Project - Wolf Creek

Attachments 9-14 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Document Control Desk PG&E Letter DCL-13-028 March 25, 2013 Page 2

6. PG&E Letter DCL-12-120, "Submittal of Revised Phase 1 and Phase 2 Documents for the License Amendment Request for Digital Process Protection System Replacement," dated November 27, 2012 (ADAMS Accession No. ML13004A468).

7. Invensys Operations Management Letter No. 993754-26T, dated October 26, 2011 (ADAMS Accession No. ML11319A069).

Dear Commissioners and Staff:

In Reference 1, Pacific Gas and Electric (PG&E) submitted License Amendment Request (LAR) 11-07 to request NRC staff (Staff) approval to replace the Diablo Canyon Power Plant (DCPP) Eagle 21 digital process protection system (PPS) with a new digital PPS that is based on the Invensys Operations Management Tricon Programmable Logic Controller, Version 10, and the CS Innovations, LLC (CS Innovations) (a Westinghouse Electric Company), Advanced Logic System. The LAR format and contents in Reference 1 are consistent with the guidance provided in Enclosure E and Section C.3, respectively, of Digital Instrumentation and Controls (I&C) Revision 1 of Interim Staff Guidance Digital I&C-ISG-06, "Task Working Group #6: Licensing Process," (ISG-06) (Reference 2). In Reference 3, the Staff documented its acceptance of Reference 1 for review.

In Open Item numbers 39, 42, 43, and 48 in Enclosure 1 of Reference 4, the Staff requested information on the PG&E PPS Replacement System Verification and Validation Plan (SyWP), Revision 0, document submitted in Attachment 5 to the Enclosure of Reference 1. The PPS Replacement SyWP has been revised, in part, to address these open items. The PPS Replacement SyVVP, Revision 1, is contained in to the Enclosure.

In Open Item numbers 79 and 80 in Enclosure 1 of Reference 4, the Staff requested that revised Invensys Operations Management Tricon 993754-1-813, Validation Test Plan, 993754-1-905, Project Management Plan, 993754-1-906, Software Development Plan, and 993754-1-909, Software Configuration Management Plan documents be submitted to reflect the terminology that is being used for the DCPP PPS replacement design. The revised documents are contained in the enclosure. In addition, a revised 993754-1-802, Software Verification and Validation (V&V) Plan document is contained in the enclosure. The revised Validation Test Plan, and Software Development Plan, and Software V&V Plan documents supersede those previously submitted in Reference 5. The revised Project Management Plan document supersedes that previously submitted in Reference 6. The revised Software Configuration Management Plan document supersedes that previously submitted in Reference 7.

Attachments 9-14 to the Enclosure contain Proprietary Information When separated from Attachments 9-14 to the Enclosure, this document is decontrolled.

A member of the STARS (Strategic Teaming and Resource Sharing)

Alliance Callaway -

Comanche Peak

• Diablo Canyon Palo Verde

• San Onofre

• South Texas Project

• Wolf Creek

Attachments 9-14 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Document Control Desk PG&E Letter DCL-13-028 March 25, 2013 Page 3 The system build documents, that address Reference 2, Enclosure B Item 2.9, for the DCPP PPS replacement Tricon-based equipment are "993754-11-810, Software Design Description," "993754-12-810, Software Design Description," "993754-13-810, Software Design Description," and "993754-14-810, Software Design Description," for Protection Sets 1 through 4, respectively. The Software Design Description document for the PPS replacement Protection Set 1, "993754-11-810, Revision 0, Software Design Description," is contained in Attachment 14 to the Enclosure of this letter. The Software Design Description documents for the PPS replacement Protection Sets 2, 3, and 4 are being submitted separately upon completion.

This letter contains Invensys Operations Management documents contained in Attachments 9 to 14 to the Enclosure that contain information proprietary to Invensys Operations Management. Accordingly, Attachments 2 and 3 to the Enclosure include Invensys Operations Management Affidavits Nos. 993754-AFF-52T and 993754-AFF-54T. The affidavits are signed by Invensys Operations Management, the owner of the information. The affidavits sets forth the basis on which the Invensys Operations Management proprietary information contained in Attachments 9 through 14 to the Enclosure may be withheld from public disclosure by the Commission, and it addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the Commission's regulations. The document "993754-11-810, Revision 0, Software Design Description," contains predominately proprietary information and therefore a non-proprietary version of this document is not being submitted. PG&E requests that the Invensys Operations Management proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390. Correspondence with respect to the Invensys Operations Management affidavit or the Invensys Operations Management proprietary information provided in Attachments 9 to 14 of the Enclosure should reference Invensys Operations Management Affidavit No. 993754-AFF-52T or No. 993754-AFF-54T and be addressed to Roman Shaffer, Project Manager, Invensys Operations Management, 26561 Rancho Parkway South, Lake Forest, CA 92630.

If you have any questions, or require additional information, please contact Tom Baldwin at (805) 545-4720.

This communication does not contain regulatory commitments (as defined by NEI 99-04).

Attachments 9-14 to the Enclosure contain Proprietary Information When separated from Attachments 9-14 to the Enclosure, this document is decontrolled.

A member of the STARS (Strategic Teaming and Resource Sharing)

Alliance Callaway

• Comanche Peak

• Diablo Canyon -

Palo Verde -

San Onofre

• South Texas Project

• Wolf Creek

Attachments 9-14 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Document Control Desk March 25, 2013 Page 4 PG&E Letter DCL-13-028 I state under penalty of perjury that the foregoing is true and correct.

Executed on March 25, 2013.

Sincerely, Barry S. Allen Site Vice President

• , /I- -

kjse/4328 SAPN 50271918 Enclosure cc:

Diablo Distribution cc/enc:

Gonzalo L. Perez, Branch Chief, California Department of Public Health Elmo E. Collins, NRC Region IV Thomas R. Hipschman, NRC Senior Resident Inspector James T. Polickoski, NRR Project Manager Attachments 9-14 to the Enclosure contain Proprietary Information When separated from Attachments 9-14 to the Enclosure, this document is decontrolled.

A member of the STARS (Strategic Teaming and Resource Sharing)

Alliance Catlaway -

Comanche Peak -

Diablo Canyon

• Palo Verde San Onofre

• South Texas Project

• Wolf Creek

Attachments 9-14 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Enclosure PG&E Letter DCL-1 3-028 Submittal of Revised System Verification and Validation Plan and Tricon Documents for the License Amendment Request for Digital Process Protection System Replacement In Pacific Gas and Electric (PG&E) Letter DCL-1 1-104, "License Amendment Request 11-07, Process Protection System Replacement," dated October 26, 2011, PG&E submitted License Amendment Request (LAR) 11-07 to request NRC staff (Staff) approval to replace the Diablo Canyon Power Plant (DCPP) Eagle 21 digital process protection system (PPS) with a new digital PPS that is based on the Invensys Operations Management Tricon Programmable Logic Controller, Version 10, and the CS Innovations, LLC (CS Innovations) (a Westinghouse Electric Company), Field Programmable Gate Array based Advanced Logic System (ALS).

The LAR 11-07 format and contents are consistent with the guidance provided in Enclosure E and Section C.3, respectively, of Digital Instrumentation and Controls (I&C) Revision 1 of Interim Staff Guidance Digital I&C-ISG-06, "Task Working Group #6: Licensing Process" (ISG-06). The Staff documented its acceptance of LAR 11-07 for review in the NRC Letter "Diablo Canyon Power Plant, Unit Nos. 1 and 2 - Acceptance Review of License Amendment Request for Digital Process Protection System Replacement (TAC Nos. ME7522 and ME7523)," dated January 13, 2012.

In Open Item numbers 39, 42, 43, and 48 in Enclosure 1 of the NRC Letter "Summary of December 19, 2012, Teleconference Meeting with Pacific Gas and Electric Company on Digital Replacement of the Process Protection System Portion of the Reactor Trip System and Engineered Safety Features Actuation System at Diablo Canyon Power Plant, Unit Nos. 1 and 2 (TAC Nos. ME7522 AND ME7523),"

dated January 10, 2013, the Staff requested information on the PG&E PPS Replacement System Verification and Validation Plan (SyWP), Revision 0, document submitted in Attachment 5 to the Enclosure of LAR 11-07. The PPS Replacement SyVVP has been revised, in part, to address these open items.

The PPS Replacement SyVVP, Revision 1, Section 2.2.1 has been updated to include reference to the PG&E design change development, software quality assurance plan software development, software configuration management for computers and software, problem identification and resolution, contractor document, and PPS replacement software configuration management plan documents.

Figure 4-1 was revised to match the PPS Replacement Project Plan document.

Section 4.1 was revised to clarify PG&E roles and responsibilities, including the PG&E Project Engineering organization, and the Engineer of Choice. Figure 5-1 was updated to clarify the lifecycle phases. Section 5.1 was updated to provide additional detail on the preparation of the PPS Replacement Conceptual Design Document and the operations and maintenance phase verification and validation (V&V) activities. Section 7 was updated to provide additional information on how deviations to the SyWP are approved. Additional information on the responsibilities 1

Attachments 9-14 to the Enclosure contain Proprietary Information When separated from Attachments 9-14 to the Enclosure, this document is decontrolled.

Attachments 9-14 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Enclosure PG&E Letter DCL-13-028 of PG&E as the owner and operator of DCPP was added throughout the document.

The PPS Replacement SyWP, Revision 1, is contained in Attachment 1 to this Enclosure.

In Open Item numbers 79 and 80 in Enclosure 1 of the NRC Letter dated December 19, 2012, the staff requested that revised Invensys Operations Management Tricon 993754-1-813, Validation Test Plan, 993754-1-905, Project Management Plan, 993754-1-906, Software Development Plan, and 993754-1-909, Software Configuration Management Plan documents be submitted to reflect the terminology that is being used for the DCPP PPS replacement design and to reflect the current project organization. In addition, the Invensys Operations Management document 993754-1-802, Software V&V Plan, has been revised. Non-proprietary versions of the documents are contained in Attachments 4 through 8 of this Enclosure and proprietary versions of the documents are contained in Attachments 9 through 13 of this Enclosure.

The system build documents, that address ISG-06, Enclosure B Item 2.9, for the DCPP PPS replacement Tricon-based equipment are "993754-11-810, Software Design Description," "993754-12-810, Software Design Description,"

"993754-13-810, Software Design Description," and "993754-14-810, Software Design Description," for Protection Sets 1 through 4, respectively. The Software Design Description document for the PPS replacement Protection Set 1 is "993754-11-810, Revision 0, Software Design Description," and is contained in 4 to this enclosure.

ATTACHMENTS

1.

PG&E Document "Process Protection System (PPS) Replacement System Verification and Validation Plan (SyVVP)," Revision 1

2.

Invensys Operations Management Affidavit No. 993754-AFF-52T

3.

Invensys Operations Management Affidavit No. 993754-AFF-54T

4.

Invensys Operations Management Document "993754-1-802, Revision 3, Software Verification and Validation Plan" (Non-Proprietary)

5.

Invensys Operations Management Document "993754-1-813, Revision 2, Validation Test Plan" (Non-Proprietary)

6.

Invensys Operations Management Document "993754-1-905, Revision 3, Project Management Plan" (Non-Proprietary)

7.

Invensys Operations Management Document "993754-1-906, Revision 2, Software Development Plan" (Non-Proprietary)

8.

Invensys Operations Management Document "993754-1-909, Revision 1, Software Configuration Management Plan" (Non-Proprietary)

9.

Invensys Operations Management Document "993754-1-802, Revision 3, Software Verification and Validation Plan" (Proprietary) 2 Attachments 9-14 to the Enclosure contain Proprietary Information When separated from Attachments 9-14 to the Enclosure, this document is decontrolled.

Attachments 9-14 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Enclosure PG&E Letter DCL-13-028

10. Invensys Operations Management Document "993754-1-813, Revision 2, Validation Test Plan" (Proprietary)

11.

Invensys Operations Management Document "993754-1-905, Revision 3, Project Management Plan" (Proprietary)

12.

Invensys Operations Management Document "993754-1-906, Revision 2, Software Development Plan" (Proprietary)

13. Invensys Operations Management Document "993754-1-909, Revision 1, Software Configuration Management Plan" (Proprietary)

14. Invensys Operations Management Document "993754-11-810, Revision 0, Software Design Description" (Proprietary) 3 Attachments 9-14 to the Enclosure contain Proprietary Information When separated from Attachments 9-14 to the Enclosure, this document is decontrolled.