ULNRC-04945, Plan, DEFENSE-IN-DEPTH and Diversity Assessment for Digital Upgrade of Callaways Instrumentation and Control Systems (License Amendment Request OL-1249)
| ML040701105 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/04/2004 |
| From: | Keith Young AmerenUE, Union Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| OL-1249, ULNRC-04945 | |
| Download: ML040701105 (9) | |
Text
AmerenUE CallawayPlant March 4, 2004 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 PO Box 620 Fulton, MO 65251 wAmerefUE Ladies and Gentlemen:
ULNRC-04945 CALLAWAY PLANT UNION ELECTRIC CO.
DOCKET NUMBER 50-483 DEFENSE-IN-DEPTH AND DIVERSITY ASSESSMENT FOR DIGITAL UPGRADE OF CALLA WAY'S INSTRUMENTATION AND CONTROL SYSTEMS (LICENSE AMENDMENT REQUEST OL-1249)
AmerenUE (Union Electric Company) is implementing plans to replace Callaway's current analog-based instrumentation and controls systems, including the Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS), with the Framatome Advanced Nuclear Power (FANP) Teleperm XS (TXS) system. These planned modifications are being developed in conjunction with Wolf Creek Nuclear Operation Corporation (WCNOC) since WCNOC is planning similar modifications for the Wolf Creek Generating Station (WCGS).
The TXS design was generically described in Topical Report EMF-2 11 0(NP),
Revision 1, "TELEPERM XS: A digital Reactor Protection System." By letter dated May 5, 2000, the Nuclear Regulatory Commission (NRC) documented its acceptance of the TXS system and found Topical Report EMF-21 10(NP), Revision 1, acceptable for referencing in license applications to the extent specified in the topical report and in the NRC safety evaluation that was attached to the NRC's May 5, 2000 letter.
On November 12, 2003, AmerenUE, WCNOC and FANP met with the NRC staff to discuss the planned TXS modifications including submittal of the defense-in depth and diversity assessment required to support NRC plant-specific review of forthcoming license amendment applications for the new TXS systems. As described in that meeting, the design, qualification, and testing of the FANP TXS system minimizes the probability of software common-mode failures.
a subsidiary of Ameren Corporation
ULNRC-04945 March 4, 2004 Page 2 Attached is the requisite defense-in-depth and diversity assessment for the TXS systems to be employed at Callaway and WCGS. The assessment identifies ten techniques used in the design of the TXS system. These techniques employ concepts that, when combined, result in the capability to tolerate software common-mode failures without defeating safety functions. The design techniques use concepts of defense-in-depth and diversity that are applied to both the hardware and software architectural design of individual TXS systems. The TXS system will thus operate with diverse software to ensure that redundancy among protection set channels is preserved even in the presence of common mode failures. The enclosed report describes the features of the TXS system that result in the overall system's inherent capability to tolerate common-mode failures.
AmerenUE, WCNOC, and FANP utilized the guidance in NUREG 0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Branch Technical Position (BTP) HICB-19, "Guidance for Evaluation of Defense-in-Depth and Diversity in Digital Computer-Based Instrumentation and Control Systems," for performing the defense-in-depth and diversity assessment. In utilizing this methodology, an approach was undertaken for evaluating each of the design basis events identified in the accident analysis. This approach led to finalizing a TXS system design that effectively utilizes defense-in-depth and diversity to minimize or cope with any potential software common-mode failure within the TXS system.
In order to support the implementation schedule for replacement of the instrumentation and control systems at Callaway, AmerenUE requests NRC approval of the TXS system defense-in-depth and diversity assessment for the Callaway Plant and WCGS by December 1, 2004. As described in the November 12, 2003 meeting, implementation is to proceed in phases, beginning with the first phase during Refueling Outage 14 in September 2005 for the Callaway Plant, and Refueling Outage 15 in September 2006 for WCGS. The enclosed assessment (for both plants) is intended to support future license amendment requests (LARs) that will be separately submitted by AmerenUE for Callaway and by WCNOC for WCGS.
AmerenUE and WCNOC are submitting this assessment in advance of those license amendment requests (LARs) to allow sufficient time for NRC review of this defense-in-depth and diversity assessment prior to the LARs.
FANP has determined that certain information contained in the defense-in-depth and diversity assessment is proprietary. Therefore, this letter transmits both a proprietary copy (Enclosure 1) and non-proprietary copy (Enclosure 2) of the assessment. Enclosed is an affidavit executed by FANP (the owner of the proprietary information). Accordingly, it is respectfully requested that the proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390.
ULNRC-04945 March 4, 2004 Page 3 Communications concerning the proprietary aspects of the information being submitted or the supporting FANP affidavit should be addressed to James F. Mallay, Director, Regulatory Affairs, Framatome ANP, 3315 Old Forest Road, Lynchburg, VA 24501. Please contact me at (573) 676-8659 or Dave Shafer at (314) 554-3104 for any other questions you may have regarding this application.
Very truly yours, Keith D. Young Manager, Regulatory Affairs TBE/mlo
Enclosures:
1 - Defense-in-Depth and Diversity Assessment (Proprietary) 2 - Defense-in-Depth and Diversity Assessment (Non-Proprietary)
ULNRC-04945 March 4, 2004 Page 4 cc:
U.S. Nuclear Regulatory Commission (Original and 1 copy)
Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)
Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 7E1 Washington, DC 20555-2738 Missouri Public Service Commission (w/Enclosure 2 only)
Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360
ULNRC-04945 March 4, 2004 Page 5 bcc: G. L. Randolph (w/o)
K. D. Young (w/o)
D. E. Shafer (Nv/Enclosures) (2 copies)
S. L. Klang (w/o) (NSRB)
T. B. Elwood (w/Enclosures)
D. T. Wingbermuehle (w/Enclosures)
E210.0001 R. D. Affolter (w/o)
G. A. Hughes (Nv/o)
S. L. Gallagher (w/o) (100)
M. A. Reidmeyer (w/o)
P. B. Bisges (%v/Enclosures)
J. E. Ready (w/o)
A160.0761 The following are sent without enclosures (except as noted):
Jennifer Yunk Supervisor, Licensing WCNOC P.O. Box 411 Burlington, KS 66839 Mr. Scott Bauer Regulatory Affairs Palo Verde NGS P.O. Box 52034, Mail Station 7636 Phoenix, AZ 85072-2034 Mr. Scott Head Supervisor, Licensing South Texas Project NOC Mail Code N5014 P.O. Box 289 Wadsworth, TX 77483 Mr. John O'Neill Shaw, Pittman 2300 N. Street N.W.
Washington, DC 20037 Diane Hooper STARS Projects Manager WCNOC P.O. Box 411 Burlington, KS 66839 Mr. Dennis Buschbaum Comanche Peak SES P.O. Box 1002 Glen Rose, TX 76043 Mr. Stan Ketelsen Manager, Regulatory Services Pacific Gas & Electric Mail Stop 104/5/536 P.O. Box 56 Avila Beach, CA 93424 Certrec Corporation 4200 South Hulen, Suite 630 Fort Worth, TX 76109 Mr. Paul C. Mangano (w/Enclosures)
Electrical and I&C Systems IOT Framatome - ANP, Inc.
1345 Ridgeland Parkway Alpharetta, GA 30004
STATE OF MISSOURI
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SS COUNTY OF CALLAWAY)
Keith D. Young, of lawful age, being first duly sworn upon oath says that he is Manager, Regulatory Affairs, for Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
Keith D. Yo U
Manager, Regulatory Affairs SUBSCRIBED and sworn to before me this /40' day of carcA
, 2004.
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AFFIDAVIT COMMONWEALTH OF VIRGINIA
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CITY OF LYNCHBURG
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- 1.
My name is James F. Mallay. I am Director, Regulatory Affairs, for Framatome ANP ('FANP"), and as such I am authorized to execute this Affidavit.
- 2.
1 am familiar with the criteria applied by FANP to determine whether certain FANP information is proprietary. I am familiar with the policies established by FANP to ensure the proper application of these criteria.
- 3.
1 am familiar with the FANP information contained in the report, 'Callaway Plant and Wolf Creek Generating Station Defense-in-Depth and Diversity Assessment.' This report is referred to herein as ODocument.' Information contained in this Document has been classified by FANP as proprietary in accordance with the policies established by FANP 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 FANP 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.
- 6.
The following critera ar customarily applied by FANP.to determine whether information should be classified as proprietary:
(a)
The information reveals details of FANP'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 is 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 FANP.
(d)
The informatidfireveals certain distinguishing aspects of a process, methodology; or'component, the exclusive use of which provides a competiti've'advaantage for FANP in product optimization or marketability.
(e)
The inform ion is vital to'a competitive advantage held by FANP, would be helpful to onpetitors'ts FANP, and would likely cause substantial harm to the competitive position of FANP.
- 7.
In accordance with FANP's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside FANP only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8.
FANP 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 this jmj day of H
o 2004.
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Ella F. Carr-Payne NOTARY PUBLIC, STATE OF VIRGINIA MY COMMISSION EXPIRES: 8/31105' ELLA F. CARR-PAYNE Commonwealth of Virginia Nm~zotary Public 0