ML110210130

1/18/2011 Summary of Pre-Licensing Meeting with Energy Northwest to Discuss Proposed Power Range Neutron Monitoring System/Arts/Mellla License Amendment Request for Columbia Generating Station

ML110210130
Person / Time
Site:	Columbia
Issue date:	02/03/2011
From:	Balwant Singal Plant Licensing Branch IV
To:	Energy Northwest
Singal, B K, NRR/DORL, 301-415-301
References
TAC ME5129
Download: ML110210130 (5)

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UNITED STATES

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February 3, 2011

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ENERGY NORTHWEST FACILITY:

COLUMBIA GENERATING STATION

SUMMARY

OF JANUARY 18, 2011, CATEGORY 1 MEETING WITH ENERGY NORTHWEST - PRE-LICENSING MEETING TO DISCUSS THE PROPOSED INSTALLATION OF A DIGITAL POWER RANGE NEUTRON MONITORING SYSTEM (PRNMS), AVERAGE POWER RANGE MONITOR/ROD BLOCK MONITORITECHNICAL SPECIFICATIONS (ARTS), AND MAXIMUM EXTENDED LOAD LINE LIMIT ANALYSIS (MELLLA) LICENSE AMENDMENT REQUEST (TAC NO. ME5129)

On January 18, 2011, a public meeting was held between the U.S. Nuclear Regulatory Commission (NRC), and representatives of Energy Northwest (the licensee), at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, MD. The purpose of the meeting was to discuss the forthcoming license amendment request (LAR) for installation of a digital Power Range Neutron Monitoring System (PRNMS), Average Power Range Monitor/Rod Block MonitorlTechnical Specifications (ARTS), and Maximum Extended Load Line Limit Analysis (MELLLA) for Columbia Generating Station. The licensee originally submitted a similar LAR for this modification by letter dated May 11, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML101390368), which was non-accepted by NRC as documented in the NRC's letter dated September 13, 2010 (ADAMS Accession No. ML102420659). The licensee now intends to re-submit an updated LAR.

The purpose of the meeting was to provide NRC staff with an overview of the proposed modification and receive early NRC staff feedback.

A list of meeting attendees is provided in the Enclosure.

Results of Discussion The licensee provided an overview of the proposed modification during the meeting. As noted above, the licensee had requested for a similar LAR earlier, but the application was not accepted by the NRC staff due to a number of concerns as documented in the NRC's letter dated September 13, 2010. During the presentation, the licensee also discussed how it proposes to address the NRC staff concerns. A copy of the licensee's presentation slides is located at ADAMS Accession No. ML110180381.

The licensee intended to show compliance with NRC Regulatory Guides (RGs) 1.168, 1.169, 1.170, 1.171, 1.172, and 1.173. The NRC staff clarified that for all of the modifications since the

- 2 original topical report1 was approved, the licensee should meet or justify any deviations from the current regulations and the review criteria established in NUREG-0800, "Standard Review Plan for Review of Safety Analysis Reports for Nuclear Power Plants: LWR [light-water reactor]

Edition" (SRP). This would include, but not be limited to, addressing compliance with NRC RG 1.152, "Criteria for Digital Computers in Safety Systems of Nuclear Power Plants," and fully addressing common-cause software failures per the guidance of SRP Branch Technical Position (BTP) 7-19, "Guidance for Evaluation of Diversity and Defense-in-Depth in Digital Computer-Based Instrumention and Control Systems" (ADAMS Accession No. ML070550072).

The licensee requested clarification for meeting the Institute of Electrical and Electronics Engineers (IEEE) Standard 603, "Standard Criteria for Safety Systems for Nuclear Power Generating Stations," and was advised that the licensee should meet IEEE Standard 603-1991 requirements per paragraph 50.55(a)(h), "Protection and safety systems," of Title 10 of the Code of Federal Regulations (1 0 CFR), for the modifications. The licensee was additionally advised to provide a compliance matrix for IEEE Standard 603 and IEEE Standard 7-4.3.2, "Standard Criteria for Digital Computers in Safety Systems of Nuclear Power Generating Stations."

The PRNMS/ARTS/MELLLA systems are provided by General Electric (GE) and the licensee stated that the GE processes and procedures do not correspond to the guidance of BTP 7-14, "Guidance on Software Reviews for Digital Computer-Based Instrumentation and Control Systems" (ADAMS Accession No. ML070670183). The licensee stated that GE intends to provide a roadmap of GE processes and procedures and corresponding BTP guidance sections with explanations as to how the BTP 7-14 guidance is met. The NRC staff agreed to the suggested approach, but requested that the clarifications should be adequate to assess conformance with BTP 7-14 and other SRP guidance that will be included in the roadmap.

Due to a shortened meeting schedule forced by inclement weather, the application of Technical Specification Task Force (TSTF) Change Traveler TSTF-493, "Clarify Application of Setpoint Methodology for LSSS [Limiting Safety System Settings] Functions," could not be addressed in sufficient detail. The licensee felt that due to the lack of precedence, the level of detail required is unclear. The NRC staff offered to be available for a follow-up meeting or a phone call to discuss this issue. The licensee also sought clarification as to whether it will be better to include TSTF-493 changes in the LAR for PRNMS/ARTS/MELLLA or submit a separate LAR for TSTF-493. The licensee was advised that either method is acceptable, but it would be cleaner if the TSTF-493 related changes are addressed via a separate LAR.

The licensee indicated that there may be some deltas (differences) with BTP 7-14. The NRC staff stressed that these deltas must be fully evaluated and documented as equivalent alternatives for acceptance. One of the deltas is the lack of fully independent verification and validation (IV&V). The NRC staff advised the licensees program must provide an adequate verification and validation (V&V) effort. A third party IV&Vis an acceptable alternative if the vendor's IV&V approach does not meet the requirements of the NRC regulations.

GE Nuclear Energy, Licensing Topical Report (LTR), NEDC-32410P-A, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," Volume I, dated October 1995, and Supplement I, dated November 1977 (not publicly available).

- 3 The licensee indicated that the LAR is scheduled to be submitted to NRC by late March/early April 2011 for implementation during refueling outage R21, scheduled for May/June 2013.

Representatives from Exelon Corporation and Entergy Operations, Inc., also attended the meeting. No Public Meeting Feedback Forms were received for this meeting.

Please direct any inquiries to me at (301) 415-3016, or Balwant.Singal@nrc.gov.

Sincerely, b,,'w~"~i tL_b,y-,~

Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-397

Enclosure:

List of Attendees cc w/encl: Distribution via Listserv

LIST OF ATTENDEES JANUARY 18, 2011, PRE-LICENSING MEETING DIGITAL PRNMS/ARTS/MELLLA LICENSE AMENDMENT REQUEST ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397 NAME TITLE ORGANIZATION Gursharan Singh Technical Reviewer I NRC/NRRIDE/EICB David Rahn Senior Electronic Engineer NRC/NRR/DE/EICB Pat Hiland Division Director NRC/NRR/DE George Wilson Electrical Engineer NRC/NRR/DE/EICB

• Rossnyev Alvarado Electrical Engineer NRC/NRRlDE/EICB

! Anthony Uses Branch Chief NRC/NRRIDSS/SRXB William Kemper*

Branch Chief NRC/NRR/DE/EICB

• Kristy Bucholtz*

Reactor Systems Engineer NRC/NRR/DIRSIITSB Balwant Singal Senior Project Manager NRC/NRR/DORL Graydon Strong Columbia Elect.ll&C Design Supervisor EN M. A. (Tony) Huiatt Principal Engineer Licensing EN Ty Rogers I&C Engineer GEH Charles Waite Consultant Pro Des Con Michael Jesse

~on Licensing Manager Exelon Corporation Ed Schrull President, Wash. Regulatory Affairs GEH Patricia Campbell Vice President, Wash. Regulatory Affairs GEH Don Gregoire Acting Manager, Regulatory Affairs EN Eric Meno Controls Manager GEH Suresh Gambhir Vice President - Engineering

!EN Guy Davant Manager. Extended Power Uprate Licensing Entergy Operations. Inc.

Vikram Shah Manager, Power Uprate Exelon Corporation James Snyder*

Project Manager EN

., Attended the meeting via teleconference Abbreviations:

NRC - U.S. Nuclear Regulatory Commission NRR - Nuclear Reactor Regulation EICB -Instrumentation and Controls Branch DE - Division of Engineering SRXB Reactor Systems Branch ITSB - Technical Specifications Branch DORL - Division of Operating Reactor Licensing DSS - Division of Safety Systems DIRS - Division of Inspection and Regional Support EN Energy Northwest GEH - General Electric Hitachi Nuclear Energy Americas LLC Enclosure

- 3 The licensee indicated that the LAR is scheduled to be submitted to NRC by late March/early April 2011 for implementation during refueling outage R21, scheduled for May/June 2013.

Representatives from Exelon Corporation and Entergy Operations, Inc., also attended the meeting. No Public Meeting Feedback Forms were received for this meeting.

Please direct any inquiries to me at (301) 415-3016, or Balwant.Singal@nrc.gov.

Docket No. 50-397

Enclosure:

List of Attendees cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC LPLIV rtf RidsAcrsAcnw _MaiICTR Resource RidsNrrDe Resource RidsNrrDeEicb Resource RidsNrrDirsltsb Resource RidsNrrDorlLpl4 Resource RidsNrrDssSrxb Resource RidsNrrPMColumbia Resource RidsNrrLAJBurkhardt Resource ADAMS Accession No. ML110210130 Sincerely,

/RN Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation RidsOgcRp Resource RidsRgn4MailCenter Resource CSteger, NRR JTrapp, EDO Region IV WKemper, NRR/DE/EICB GSingh, NRR/DE/EICB GWilson, NRR/DE/EICB RAlvarado, NRR/DE/EICB KBucholtz, NRR/DCI/ITSB OFFICE NAME DATE NRRlLPL4/PM BSingal 1/21/11 NRR/LPL4/LA JBurkhardt 1/21111 NRR/DE/EICB/BC (A)

N RR/D I RS/ITS B/BC NRRlLPL4/BC MMarkley DRahn REliiott (JRHall for) 1/24/11 1/25/11 2/2/11 NRRlLPL4/PM BSingal 2/3/11