Letter Sequence Response to RAI |
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TAC:ME7905, Clarify Application of Setpoint Methodology for LSSS Functions (Approved, Closed) |
Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance
Administration
- Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance
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MONTHYEARML12040A0732011-10-31031 October 2011 0000-0101-7647-R3, Columbia Generating Station Plant-Specific Responses Required by Numac Prnm Retrofit Plus Option III Stability Trip Function Topical Report, (NEDC-3241 OP-A) Project stage: Request ML12040A0752011-11-30030 November 2011 NEDO-33690, Revision 0, Columbia Generating Station Power Range Neutron Monitoring System Response Time Analysis Report Project stage: Request ML12040A0762012-01-31031 January 2012 NEDO-33694, Revision 1, Columbia Generating Station Power Range Neutron Monitoring System Diversity and Defense-in-Depth (D3) Analysis Project stage: Request GO2-12-017, License Amendment Request to Change Technical Specification in Support of Prnm/Arts/Mellla Implementation2012-01-31031 January 2012 License Amendment Request to Change Technical Specification in Support of Prnm/Arts/Mellla Implementation Project stage: Request ML12040A0772012-01-31031 January 2012 NEDO-33697, Revision 1, Columbia Generating Station Power Range Neutron Monitoring System Design Analysis Report Project stage: Request ML12040A0792012-01-31031 January 2012 NEDO-33698, Revision 1, Columbia Generating Station Power Range Neutron Monitoring System Design Report on Computer Integrity, Test and Calibration, and Fault Detection. Enclosure 2, Attachment 14 to List of Commitments and Enclosure 3 Are Project stage: Request ML12040A0802012-01-31031 January 2012 NEDO-33507, Revision 1, Columbia Generating Station Aprm/Rbm/Technical Specifications / Maximum Extended Load Line Limit Analysis (Arts/Mellla) Project stage: Request ML12040A0742012-01-31031 January 2012 NEDO-33685, Revision 1, Digital I&C-ISG-06 Compliance for Columbia Generating Station Numac Power Range Neutron Monitoring Retrofit Plus Option III Stability Trip Function Project stage: Request ML1210702222012-04-16016 April 2012 Acceptance Review Email, License Amendment Request, Technical Specification Changes to Support Installation of GE Hitachi Power Range Neutron Monitoring System; Implementation of Arts/Mellla Project stage: Acceptance Review ML1216704012012-06-15015 June 2012 E-mail, Draft Request for Additional Information, Amendment Request, Technical Specification Changes to Support Installation of GE Hitachi Power Range Neutron Monitoring System; Implementation of Arts/Mella Project stage: Draft RAI ML1216704042012-06-15015 June 2012 Draft Request for Additional Information, Amendment Request, Technical Specification Changes to Support Installation of GE Hitachi Power Range Neutron Monitoring System; Implementation of Arts/Mellla Project stage: Draft RAI ML1219301002012-07-10010 July 2012 Email, Draft Request for Additional Information, Round 2, Technical Specification Changes to Support Installation of GE Hitachi Power Range Neutron Monitoring System; Implementation of Arts/Mellla Project stage: Draft RAI ML1219301042012-07-10010 July 2012 Draft Request for Additional Information, Round 2, Technical Specification Changes to Support Installation of GE Hitachi Power Range Neutron Monitoring System; Implementation of Arts/Mellla Project stage: Draft RAI ML12201B0502012-07-23023 July 2012 Request for Additional Information, Rounds 1 and 2, Technical Specification Changes to Support Installation of GE Hitachi Power Range Neutron Monitoring System; Implementation of Arts/Mellla Project stage: RAI ML12192A3252012-07-30030 July 2012 Request for Withholding Information from Public Disclosure, Affidavit Dated 10/31/11 Executed by E. Schrull, GE Hitachi Americas LLC, 0000-0101-7647-R3 Plant-Specific Responses Required by NEDC-32410P-P-A Project stage: Withholding Request Acceptance ML12192A4542012-07-30030 July 2012 Request for Withholding Information from Public Disclosure, Affidavit Dated 1/5/12, Executed by E. Schrull, GE Hitachi Americas LLC, NEDC-33694P, Revision 1 Project stage: Withholding Request Acceptance ML12192A5352012-07-30030 July 2012 Request for Withholding Information from Public Disclosure, Affidavit Dated 1/5/12, Executed by E. Schrull, GE Hitachi Americas LLC, NEDC-33697P, Revision 1 Project stage: Withholding Request Acceptance ML12192A4332012-07-30030 July 2012 Request for Withholding Information from Public Disclosure, Affidavit Dated 11/1/11, Executed by E. Schrull, GE Hitachi Americas LLC, NEDC-33690P, Revision 0 Project stage: Withholding Request Acceptance ML12192A5892012-07-30030 July 2012 Request for Withholding Information from Public Disclosure, Affidavit Dated 1/5/12, Executed by E. Schrull, GE Hitachi Americas LLC, NEDC-33698P, Revision 1 Project stage: Withholding Request Acceptance ML12192A3612012-07-30030 July 2012 Request for Withholding Information from Public Disclosure, Affidavit Dated 1/5/12 Executed by E. Schrull, GE Hitachi Americas LLC, NEDC-33685P, Revision 1 Project stage: Withholding Request Acceptance ML12193A1092012-07-30030 July 2012 Request for Withholding Information from Public Disclosure, Affidavit Dated 1/27/12, Executed by E. Schrull, GE Hitachi Americas LLC, NEDC-33507P, Revision 1 Project stage: Withholding Request Acceptance GO2-12-105, Submittal of Phase 2 Information in Support of License Amendment Request to Change Technical Specifications in Support of Prnm /Arts/Mellla Implementation; NEDO-33750, NEDO-33753; NEDO-33754: NEDO-33755; & NEDO-337582012-07-31031 July 2012 Submittal of Phase 2 Information in Support of License Amendment Request to Change Technical Specifications in Support of Prnm /Arts/Mellla Implementation; NEDO-33750, NEDO-33753; NEDO-33754: NEDO-33755; & NEDO-33758 Project stage: Request GO2-12-116, Response to Request for Additional Information Regarding License Amendment Request to Implement Prnm/Arts/Mellla2012-08-22022 August 2012 Response to Request for Additional Information Regarding License Amendment Request to Implement Prnm/Arts/Mellla Project stage: Response to RAI ML12249A0112012-09-0505 September 2012 Redacted, Request for Additional Information, Amendment Request for Technical Specification Changes to Support Installation of GE Hitachi Power Range Neutron Monitoring System; Implementation of Arts/Mellla Project stage: RAI ML12261A1972012-09-17017 September 2012 Email, Draft Request for Additional Information, Round 4, Technical Specification Changes to Support Installation of GE Hitachi Power Range Neutron Monitoring System; Implementation of Arts/Mellla Project stage: Draft RAI GO2-12-135, Response to Request for Additional Information Regarding License Amendment Request to Implement Prnmiarts/Mellla2012-10-0505 October 2012 Response to Request for Additional Information Regarding License Amendment Request to Implement Prnmiarts/Mellla Project stage: Response to RAI ML12283A2692012-10-15015 October 2012 Request for Additional Information, Round 4, Technical Specification Changes to Support Installation of GE Hitachi Power Range Neutron Monitoring System; Implementation of Prnm/Arts/Mellla Project stage: RAI ML12328A0782012-10-31031 October 2012 NEDO-33751, Revision 3, Columbia Generating Station Power Range Neutron Monitoring System Reliability Analysis, Attachment 3 Project stage: Request GO2-12-162, Response to Request for Additional Information Regarding License Amendment Request to Implement Prnm/Arts/Mellla2012-11-12012 November 2012 Response to Request for Additional Information Regarding License Amendment Request to Implement Prnm/Arts/Mellla Project stage: Response to RAI ML12192A4812012-11-13013 November 2012 Request for Withholding Information from Public Disclosure, Affidavits Dated 11/16/11 and 7/26/12, Executed by E. Schrull, GE Hitachi Americas LLC, NEDC-33696P, Revisions 0 and 1 Project stage: Withholding Request Acceptance ML12229A4682012-11-13013 November 2012 Request for Withholding Information from Public Disclosure, 6/4/12 Affidavit Executed by E. Schrull, GEH-Hitachi, NEDC-33750P, Revision 0 Project stage: Withholding Request Acceptance ML12229A4762012-11-13013 November 2012 Request for Withholding Information from Public Disclosure, 6/7/12 Affidavit Executed by E. Schrull, GEH-Hitachi, NEDC-33753P, Revision 0 Project stage: Withholding Request Acceptance ML12229A4802012-11-13013 November 2012 Request for Withholding Information from Public Disclosure, 6/7/12 Affidavit Executed by E. Schrull, GEH-Hitachi, NEDC-33754P, Revision 0 Project stage: Withholding Request Acceptance ML12229A4822012-11-13013 November 2012 Request for Withholding Information from Public Disclosure, 6/27/12 Affidavit Executed by E. Schrull, GEH-Hitachi, NEDC-33756P, Revision 0 Project stage: Withholding Request Acceptance ML12229A4832012-11-13013 November 2012 Request for Withholding Information from Public Disclosure, 6/7/12 Affidavit Executed by E. Schrull, GEH-Hitachi, NEDC-33758P, Revision 0 Project stage: Withholding Request Acceptance ML12229A4902012-11-13013 November 2012 Request for Withholding Information from Public Disclosure, 6/12/12 Affidavit Executed by E. Schrull, GEH-Hitachi, Letter GE-MS-CT-106244-JC14 Project stage: Withholding Request Acceptance ML12328A0792012-11-30030 November 2012 NEDO-33789, Revision 0, Numac Power Range Neutron Monitoring Components 268X1331TCG001, 268X1332TCG001, G002 268X1333TCG001, Qualification Summary for Energy Northwest (Enw) Columbia Generating Station (Cgs), Attachment 5 Project stage: Request ML12229A4712012-12-18018 December 2012 Request for Withholding Information from Public Disclosure, 6/29/12 and 10/22/12 Affidavits Executed by E. Schrull, GEH-Hitachi, NEDC-33751P, Revisions 2 and 3 Project stage: Withholding Request Acceptance ML12345A3662012-12-18018 December 2012 Request for Withholding Information from Public Disclosure, Affidavit Dated 11/1/12 Executed by E. Schrull, GEH-Hitachi, NEDC-33789P, Revision 0 Project stage: Withholding Request Acceptance ML12345A3582012-12-18018 December 2012 Request for Withholding Information from Public Disclosure, 9/26/12 Affidavit Executed by E.Schrull, GEH-Hitachi, GEH 10/5/12 Responses to Nrc/De/Eicb 9/5/12 Request for Additional Information Project stage: RAI ML13015A2722012-12-31031 December 2012 NEDO-33685, Rev 2, Digital I&C-ISG-06 Compliance for Columbia Generating Station Numac Power Range Neutron Monitoring Retrofit Plus Option III Stability Trip Function. Project stage: Request ML13015A2732012-12-31031 December 2012 NEDO-33698, Rev 2, Columbia Generating Station Power Range Neutron Monitoring System Design Report on Computer Integrity, Test and Calibration, and Fault Detection Project stage: Request ML13025A3512013-02-21021 February 2013 Request for Withholding Information from Public Disclosure, Affidavit Dated 12/12/12, Executed by L. Dolan, GE Hitachi Americas LLC, NEDC-33685P, Revision 2 Project stage: Withholding Request Acceptance ML13025A3612013-02-21021 February 2013 Request for Withholding Information from Public Disclosure, Affidavit Dated 12/12/12, Executed by L. Dolan, GE Hitachi Americas LLC, NEDC-33698P, Revision 2 Project stage: Withholding Request Acceptance ML13067A1062013-03-12012 March 2013 Redacted, Request for Additional Information, Round 5, Technical Specification Changes to Support Installation of GE Hitachi Power Range Neutron Monitoring System; Implementation of Arts/Mellla Project stage: RAI ML13098A7782013-04-0808 April 2013 Request for Additional Information Following 4/3/13 Calculation Audit, Technical Specification Changes to Support Installation of GE Hitachi Power Range Neutron Monitoring System; Implementation of Arts/Mellla Project stage: RAI ML13099A0432013-04-10010 April 2013 Request for Additional Information Following 4/3/13 Calculation Audit, Technical Specification Changes to Support Installation of GE Hitachi Power Range Neutron Monitoring System; Implementation of Arts/Mellla Project stage: RAI GO2-13-059, Response to Request for Additional Information Regarding License Amendment Request to Implement Prnm/Arts/Mellla2013-04-11011 April 2013 Response to Request for Additional Information Regarding License Amendment Request to Implement Prnm/Arts/Mellla Project stage: Response to RAI PNP 2013-038, 2012 Annual Radioactive Effluent Release and Waste Disposal Report2013-04-23023 April 2013 2012 Annual Radioactive Effluent Release and Waste Disposal Report Project stage: Request ML13109A1632013-04-26026 April 2013 Request for Withholding Information from Public Disclosure - 4/2/13 and 4/10/13 Affidavits Executed by L. Dolan, GEH; Enclosures 1 and 3 of Geh'S Request for Additional Information Responses Project stage: RAI 2012-07-10
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Category:Letter type:GO
MONTHYEARGO2-24-004, License Amendment Request to Revise Emergency Plan2024-01-30030 January 2024 License Amendment Request to Revise Emergency Plan GO2-24-003, Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing2024-01-29029 January 2024 Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing GO2-24-005, Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-1702024-01-0808 January 2024 Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-170 GO2-23-136, Guarantee of Payment of Deferred Premium2023-12-20020 December 2023 Guarantee of Payment of Deferred Premium GO2-23-135, Notice of Readiness for Supplemental Inspection2023-12-14014 December 2023 Notice of Readiness for Supplemental Inspection GO2-23-130, Reply to a Notice of Violation; EA-23-0542023-12-14014 December 2023 Reply to a Notice of Violation; EA-23-054 GO2-23-105, Licensing Basis Document Update and Biennial Commitment Change Report2023-12-12012 December 2023 Licensing Basis Document Update and Biennial Commitment Change Report GO2-23-107, Application to Revise Technical Specifications to Adopt TSTS-584, Eliminate Automatic RWCU System Isolation on SLC Initiation2023-12-0505 December 2023 Application to Revise Technical Specifications to Adopt TSTS-584, Eliminate Automatic RWCU System Isolation on SLC Initiation GO2-23-126, Docket No. 50-397 Voluntary Response to Regulatory Issue Summary 2023-012023-11-28028 November 2023 Docket No. 50-397 Voluntary Response to Regulatory Issue Summary 2023-01 GO2-23-121, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-27027 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation GO2-23-097, In-Service Inspection Summary Report for the Twenty-Sixth Refueling Outage (R26)2023-09-0606 September 2023 In-Service Inspection Summary Report for the Twenty-Sixth Refueling Outage (R26) GO2-23-100, Technical Specification Section 5.6.4 Post Accident Monitoring Instrumentation 14-Day Report for Inoperable Suppression Pool Level Indication2023-08-31031 August 2023 Technical Specification Section 5.6.4 Post Accident Monitoring Instrumentation 14-Day Report for Inoperable Suppression Pool Level Indication GO2-23-056, Application to Revise Technical Specifications to Adopt TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling2023-08-29029 August 2023 Application to Revise Technical Specifications to Adopt TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling GO2-23-093, Supplement to Reply to a Notice of Violation: EA-21-1702023-07-27027 July 2023 Supplement to Reply to a Notice of Violation: EA-21-170 GO2-23-068, Notification of Completion of Commitments Required Prior to Entry Into the Period of Extended Operation2023-07-19019 July 2023 Notification of Completion of Commitments Required Prior to Entry Into the Period of Extended Operation GO2-23-090, Reply to a Notice of Violation2023-07-12012 July 2023 Reply to a Notice of Violation GO2-23-073, Notification of NPDES Permit Issuance2023-06-26026 June 2023 Notification of NPDES Permit Issuance GO2-23-072, Cycle 27 Core Operating Limits Report2023-06-0505 June 2023 Cycle 27 Core Operating Limits Report GO2-23-055, Independent Spent Fuel Storage Installation, 2022 Annual Radiological Environmental Operating Report2023-05-15015 May 2023 Independent Spent Fuel Storage Installation, 2022 Annual Radiological Environmental Operating Report GO2-23-006, License Amendment Request to Clean-Up Operating License and Appendix a Technical Specifications2023-05-0101 May 2023 License Amendment Request to Clean-Up Operating License and Appendix a Technical Specifications GO2-23-053, 2022 Annual Environmental Operating Report2023-04-26026 April 2023 2022 Annual Environmental Operating Report GO2-23-057, 2022 Annual Radioactive Effluent Release Report2023-04-25025 April 2023 2022 Annual Radioactive Effluent Release Report GO2-23-012, Application to Revise Technical Specifications to Adopt Tstf-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position2023-03-27027 March 2023 Application to Revise Technical Specifications to Adopt Tstf-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position GO2-23-041, Generation Station - Level of Financial Protection - Annual Reporting Requirement2023-03-15015 March 2023 Generation Station - Level of Financial Protection - Annual Reporting Requirement GO2-23-038, Plant Decommissioning Fund Status Report2023-03-15015 March 2023 Plant Decommissioning Fund Status Report GO2-23-034, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.462023-03-13013 March 2023 Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.46 GO2-23-035, Supplement to License Amendment Request to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-03-0909 March 2023 Supplement to License Amendment Request to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling GO2-23-019, Emergency Plan - Summary of Changes and Analysis for Revision 68 of the EP-012023-02-0808 February 2023 Emergency Plan - Summary of Changes and Analysis for Revision 68 of the EP-01 GO2-22-131, Guarantee of Payment of Deferred Premium2022-12-19019 December 2022 Guarantee of Payment of Deferred Premium GO2-22-122, Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2022-11-28028 November 2022 Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b GO2-22-076, Status of License Renewal Commitments2022-10-31031 October 2022 Status of License Renewal Commitments GO2-22-110, Supplement to License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactor2022-10-17017 October 2022 Supplement to License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactor GO2-22-096, Supplement to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2022-10-0404 October 2022 Supplement to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b GO2-22-085, Docket No. 50-397, Evacuation Time Estimate Analysis2022-08-30030 August 2022 Docket No. 50-397, Evacuation Time Estimate Analysis GO2-22-075, Response to Request for Additional Information Related to Revised Pressure-Temperature Limit Curves2022-07-11011 July 2022 Response to Request for Additional Information Related to Revised Pressure-Temperature Limit Curves GO2-22-072, Summary of Changes and Analysis for Revision 57 of PPM 13.14.4 - Emergency Equipment Maintenance and Testing2022-07-11011 July 2022 Summary of Changes and Analysis for Revision 57 of PPM 13.14.4 - Emergency Equipment Maintenance and Testing GO2-22-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Colling Using the Consolidated Line Item Improvement Process2022-05-25025 May 2022 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Colling Using the Consolidated Line Item Improvement Process GO2-22-062, Registration of Spent Fuel Cask Use2022-05-19019 May 2022 Registration of Spent Fuel Cask Use GO2-22-049, Supplement to Licensing Amendment Request to Adopt 10CFR50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Rectors2022-05-10010 May 2022 Supplement to Licensing Amendment Request to Adopt 10CFR50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Rectors GO2-22-054, Independent Spent Fuel Storage Installation, 2021 Annual Radiological Environmental Operating Report2022-05-0909 May 2022 Independent Spent Fuel Storage Installation, 2021 Annual Radiological Environmental Operating Report GO2-22-056, Registration of Spent Fuel Cask Use2022-04-21021 April 2022 Registration of Spent Fuel Cask Use GO2-22-055, 2021 Annual Environmental Operating Report2022-04-20020 April 2022 2021 Annual Environmental Operating Report GO2-22-048, 2021 Annual Radioactive Effluent Release Report2022-04-15015 April 2022 2021 Annual Radioactive Effluent Release Report GO2-22-045, Registration of Spent Fuel Cask Use2022-04-0606 April 2022 Registration of Spent Fuel Cask Use GO2-22-044, Level of Financial Protection - Annual Reporting Requirement2022-03-21021 March 2022 Level of Financial Protection - Annual Reporting Requirement GO2-22-038, Docket No. 50-397, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.462022-03-0909 March 2022 Docket No. 50-397, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.46 GO2-22-031, Response to Audit Plan and Online Reference Portal Request2022-02-15015 February 2022 Response to Audit Plan and Online Reference Portal Request GO2-22-011, Docket No. 72-35; Independent Spent Fuel Storage Installation, 2021 Annual Effluent Release Report2022-02-0808 February 2022 Docket No. 72-35; Independent Spent Fuel Storage Installation, 2021 Annual Effluent Release Report GO2-22-001, License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2022-02-0303 February 2022 License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b GO2-22-012, Independent Spent Fuel Storage Installation - Biennial 50.59/72.48 Report2022-01-24024 January 2022 Independent Spent Fuel Storage Installation - Biennial 50.59/72.48 Report 2024-01-08
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Text
Bradley J. Sawatzke S
ENERG ERColumbia Generating Station P.O. Box 968, PE08 NORTHWEST NORTW ESTPh. Richland, WA 99352-0968 509.377.4300 IT. 509.377.4150 bjsawatzke @energy-northwest.com Proprietary - Withhold under 10 CFR 2.390. Attachment 2 and Attachment 4 contain PROPRIETARY information.
November 12, 2012 G02-12-162 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO IMPLEMENT PRNM/ARTS/MELLLA
References:
- 1) Letter, G02-12-017, dated January 31, 2012, BJ Sawatzke (Energy Northwest) to NRC, "License Amendment Request to Change Technical Specifications in Support of PRNM/ARTS/MELLLA Implementation" (ADAMS Accession No. ML12040A072)
- 2) Letter, G02-12-105, dated July 31, 2012, BJ Sawatzke (Energy Northwest) to NRC, "Submittal of Phase 2 Information in Support of License Amendment Request to Change Technical Specifications in Support of PRNM/ARTS/MELLLA Implementation" (ADAMS Accession No. ML12219A255)
- 3) Letter, G02-12-135, dated October 5, 2012, BJ Sawatzke (Energy Northwest) to NRC, "Response to Request for Information Regarding License Amendment Request to Implement PRNM/ARTS/MELLLA"
- 4) Letter dated October 15, 2012, NRC to ME Reddemann (Energy Northwest), "Columbia Generating Station - Request for Additional Information Regarding License Amendment Request to Implement PRNM/ARTS/MELLLA (TAC NO. ME7905)"
Dear Sir or Madam:
By Reference 1, and as supplemented by Reference 2, Energy Northwest requested approval of a license amendment request to revise the Columbia Generating Station Technical Specifications to reflect improvements in the Average Power Range Monitor (APRM) / Rod Block Monitor (RBM) Technical Specifications (ARTS) and expand the facility operating domain to reflect operations using the Maximum Extended Load Line Limit Analysis (MELLLA). These improvements coincide with the installation of the digital General Electric-Hitachi (GEH) Nuclear Measurement Analysis and Control (NUMAC) Power Range Neutron Monitoring (PRNM) System.
When Attachment 2 and Attachment 4 are removed from this; letter, the letter and remaining Attachments are NON-PROPRIETARY.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO IMPLEMENT PRNM/ARTS/MELLLA Page 2 of 3 Via Reference 4, the Nuclear Regulatory Commission (NRC) requested additional information related to the Energy Northwest submittal. Transmitted herewith in is the Energy Northwest response to the request for additional information (RAI).
In addition to the response to the RAI described above, this letter also contains revisions to two documents previously submitted. Specifically, in Reference 2, Attachment 2, GEH document NEDC-33751 P had been identified as being entirely proprietary. Upon further review, GEH has identified portions of this document that do not contain proprietary information. Included with this letter as Attachment 2 is a revised proprietary version of this document with the only changes being the demarcations as to which information is considered to be proprietary information. Attachment 3 is the non-proprietary version (NEDO-33751). Additionally, in Reference 3, the GEH document included as Enclosure 1 had been identified as being entirely proprietary. Upon further review, GEH has identified portions of this document that do not contain proprietary information. Included with this letter as Attachment 4 is a revised proprietary version of this document with the only changes being the demarcations as to which information is considered to be proprietary information. The document has been provided with a GEH document number of NEDC-33789P. Attachment 5 is the non-proprietary version (NEDO-33789). The affidavits for the proprietary documents are included within the first few pages of the documents themselves.
There are no new regulatory commitments identified in this letter. Should you have any questions or require additional information regarding this matter, please contact Mr. Z. K.
Dunham, Licensing Supervisor, at (509) 377-4735.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.
Respectfully, B. J. Sa watzke Vice President, Nuclear Generation & Chief Nuclear Officer - Response to Request for Additional Information - NEDC-33751 P, Revision 3, "Columbia Generating Station Power Range Neutron Monitoring System Reliability Analysis," October 2012 (Proprietary) - NEDO-33751, Revision 3, "Columbia Generating Station Power Range Neutron Monitoring System Reliability Analysis," October 2012
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO IMPLEMENT PRNM/ARTSIMELLLA Page 3 of 3 - NEDC-33789, Revision 0, "NUMAC Power Range Neutron Monitoring (PRNM) Components 268X1 331 TCGO01, 268X1 332TCG001, G002 268X1 333TCG001 Qualification Summary for Energy Northwest (ENW)
Columbia Generating Station (CGS)," November 2012 (Proprietary) - NEDO-33789, Revision 0, "NUMAC Power Range Neutron Monitoring (PRNM) Components 268X1 331 TCGO01, 268X1 332TCG001, G002 268X1 333TCG001 Qualification Summary for Energy Northwest (ENW)
Columbia Generating Station (CGS)," November 2012 cc: NRC Region IVAdministrator NRC NRR Project Manager NRC Senior Resident Inspector/988C AJ Rapacz - BPA/1 399 W.A. Horin - Winston & Strawn JO Luce - EFSEC RR Crowley - WDOH
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO IMPLEMENT PRNMIARTS/MELLLA Page 1 of 4 Response to Request for Additional Information NRC Request:
- 1. In the submittal, there is information related to verification and validation (V&V) of the software for this upgrade, but there does not appear to be information related to V&V of the operator actions. Please describe the on-site validation of the system, with the revised procedures, and trained operators.
Energy Northwest Response:
NUREG-071 1, Revision 2, "Human Factors Engineering Program Review Model," identifies that Human Factors Verification and Validation evaluations are used to confirm that a final design conforms to Human Factors Engineering (HFE) design principles and that it enables personnel to successfully and safely perform their tasks to achieve operational goals. The three evaluation types spelled out in NUREG-0711 include:
- Human Systems Interface (HSI) Task Support Verification - an evaluation to verify that the HSI supports personnel task requirements as defined by task analyses.
- HFE Design Verification - an evaluation to verify that the HSI is designed to accommodate human capabilities and limitations as reflected in HFE guidelines such as those provided in NUREG-0700, "Human-System Interface Design Review Guidelines."
- Integrated System Validation - an evaluation using performance-based tests to determine whether an integrated system design (i.e., hardware, software, and personnel elements) meets performance requirements and acceptably supports safe operation of the plant.
HSI Task Support Verification - Discussion:
This verification ensures that the HSI provides all alarms, information, and control capabilities required for personnel tasks. The upgrade to the Power Range Neutron Monitor System (PRNMS) change does not impact reactor operating paramneters or the functional requirements of the Average Power Range Monitoring (APRM) system. The replacement equipment continues to provide information, enforce control rod blocks, and initiate reactor scrams under appropriate specified conditions. As such, the operator actions remain unchanged when upgrading to the PRNMS, in that the same actions/responses occur with data received from the digital upgrade as with the analog APRM system that is being replaced. This is reflected in the response to the request for additional information (RAI) 7 of Reference 1-1, where Energy Northwest identified that no operator actions were being
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO IMPLEMENT PRNMIARTS/MELLLA Page 2 of 4 changed, added, or deleted as a result of the PRNMS upgrade. In the corresponding response to RAI 8 of Reference 1-1, Energy Northwest identified that with no significant changes to operator actions or functions, no new task analyses were performed. Hence, with no operator actions changing, or new task analyses performed, the need for a HSI Task Support Verification is obviated with the upgrade to the PRNMS.
HFE Design Verification - Discussion:
This verification ensures that the characteristics of the HSI and the environment in which it is used conform to HFE guidelines. Section 4.4.1.9, "Human Factors," of the Nuclear Measurement and Control (NUMAC) Power Range Neutron Monitoring (PRNM) NRC approved Licensing Topical Report (LTR), Reference 1-2 identifies that:
The design of the PRNM replacement equipment meets the intent of NUREG-0700 as applicable to the back panel equipment. The base design for the plant operator's panel uses the existing operator interface devices, so there is no effect on the plant human factor's evaluations. The digital NUMAC Operator's Display Assembly (ODA) alternate for the plant operator's panel display has been designed to meet NUREG-0700 to the extent possible.
Energy Northwest is employing the alternate ODA option for the replacement PRNMS. The Human Factors Engineering (HFE) review included in the LTR (Reference 1-2) as well as the HFE review conducted by Energy Northwest for the Columbia Generating Station (CGS) ensured that the requirements of NUREG-0700 were met, and is summarized in the License Amendment Request (LAR), Reference 1-3, and LTR, Reference 1-2, respectively.
Integrated System Validation - Discussion:
Integrated system validation is the process by which an integrated system design (i.e.,
hardware, software, and personnel elements) is evaluated using performance-based tests to determine whether it acceptably supports safe operation of the plant. Section 4.4.1.10,
'Training and Maintenance", of the LTR (Reference 1-2) states:
The replacement PRNM equipment is designed to facilitate maintenance and minimize necessary operational training. The information presented is structured to be easily understood by a user familiar with the Neutron Monitoring System and its primary functions.
Energy Northwest confirmed the LTR's diagnosis of minimal operator impact during the Factory Acceptance Test (FAT) conducted during October 2010 using the new CGS hardware attached to a plant simulator. During the FAT the following activities were conducted:
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO IMPLEMENT PRNMIARTS/MELLLA Page 3 of 4 o Classroom training for selected personnel from Operations, Maintenance and Engineering o Hands-on training for selected personnel from Operations and Maintenance o Verification and validation of Operations and Maintenance procedures NUREG-071 1, section 11.4.3.1, "Integrated System Validation Review Objective," states the following:
For the case of plant modifications, the applicability and scope of integrated system validation may vary. An integrated system validation should be reviewed for all modifications that may (1) change personnel tasks; (2) change tasks demands, such as changing task dynamics, complexity, or workload; or (3) interact with or affect HSIs and procedures in ways that may degrade performance. Integrated system validation may not be needed when a modification results in minor changes to personnel tasks such that they may reasonably be expected to have little or no overall effect on workload and the likelihood of error.
For the Energy Northwest upgrade to the PRNMS, an Integrated System Validation is not warranted as there is no change in required operator actions for the replacement hardware.
Operator tasks remain unchanged; hence there is no impact to task dynamics, complexity or workload for the Operations staff. The HSI is designed such that the replacement PRNMS provides the same information as the legacy Neutron Monitoring System such that it is a reasonable expectation that there will be little or no overall effect on the operations staff with regards to workload or the likelihood of an error.
References 1-1 Letter, G02-12-116, dated August 22, 2012, BJ Sawatzke (Energy Northwest) to NRC, "Response to Request for Additional Information Regarding License Amendment Request to Implement PRNM/ARTS/MELILA" (ADAMS Accession No. ML12248A136) 1-2 (a) GE Nuclear Energy, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," NEDC-3241OP-A Volume 1, October 1995.
(b) GE Nuclear Energy, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," NEDC-3241 OP-A Volume 2 -- Appendices, October 1995.
(c) GE Nuclear Energy, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," NEDC-3241OP-A, Supplement 1, November 1997.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO IMPLEMENT PRNMIARTS/MELI.LA Page 4 of 4 1-3 Letter, G02-12-017, dated January 31, 2012, BJ Sawatzke (Energy Northwest) to NRC, "License Amendment Request to Change Technical Specifications in Support of PRNM / ARTS / MELLLA Implementation" (ADAMS Accession No. ML12040A072)
NRC Request:
- 2. Please describe the long-term human performance monitoring program, if any, and how this modification affects it.
Energy Northwest Response:
NUREG-071 1, Revision 2, identifies that, "A human performance monitoring strategy will help to provide reasonable assurance that the confidence developed by the completion of the integrated system validation is maintained over time."
As identified in the response to RAI 1 above, with no changes being made to any operator actions with the installation of this replacement system, no Integrated System Validation was warranted. Since the system provides automatic functions (e.g., input to Reactor Protection System scram signals, input to the Reactor Manual Control System control rod withdrawal blocks), the same as the existing analog NMS systems, there are no changes in required operator actions. Therefore, there is no need to monitor the human actions for degradation in performance, and, hence, there is no need for a human performance monitoring program for this planned systern upgrade.
GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Edward D. Schrull, PE, state as follows:
(1) I am the Vice President, Regulatory Affairs, Services Licensing, GE-Hitachi Nuclear Energy Americas'LLC ("GEH"), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in GEH proprietary report, NEDC-33751P, "Columbia Generating Station Power Range Neutron Monitoring System Reliability Analysis," Revision 3, dated October 2012. The GEH proprietary information in NEDC-33751P is identified by a dotted underline inside double square brackets. ((This sentence is an example..3 )) Large tables and figures containing GEH proprietary information are identified with double square brackets before and after the object. In each case, the notation (3) refers to Paragraph (3) of this affidavit, Which provides the basis for the proprietary determination.
(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought also qualifies under the narrower definition of trade secret, within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC Cir. 1983).
(4) The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that fit into the definition of proprietary information are:
- a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's competitors without license from GEH constitutes a competitive economic advantage over other companies;
- b. Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design,, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;
- c. Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;
- d. Information that discloses trade secret and/or potentially patentable subject matter for which it may be desirable to obtain patent protection.
(5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GEH, Affidavit for NEDC-3375 1P Revision 3 Affidavit Page I of 3
GE-Hitachi Nuclear Energy Americas ]LLC and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GEH, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary and/or confidentiality agreements that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in the following paragraphs (6) and (7).
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH. Access to such documents within GEH is limited to a "need to know" basis.
(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist, or other equivalent authority for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary and/or confidentiality agreements.
(8) The information identified in paragraph (2), above, is classified as proprietary because it contains detailed GEH design information of the instrumentation and control equipment used in the design and analysis of the power range neutron monitoring system for GEH Boiling Water Reactors (BWRs). Development of these methods, techniques, and information and their application for the design, modification, and analyses methodologies and processes was achieved at a significant cost to GEH.
The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the extensive experience databases that constitute major GEH asset.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.
The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to Affidavit for NEDC-33751P Revision 3 Affidavit Page 2 of 3
GE-Hitachi Nuclear Energy Americas ILLC quantify, but it clearly is substantial. GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.
I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.
Executed on this 2 2 nd day of October 2012.
Edward D. Schrull, PE Vice President, Regulatory Affairs Services Licensing GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Rd.
Wilmington, NC 28401 Edward.Schrull@ge.com Affidavit for NEDC-33751P Revision 3 Affidavit Page 3 of 3