ML110180381
| ML110180381 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/18/2011 |
| From: | Energy Northwest |
| To: | Office of Nuclear Reactor Regulation |
| Singal, B K, NRR/DORL, 301-415-301 | |
| References | |
| TAC ME5129 | |
| Download: ML110180381 (26) | |
Text
Columbia PRNM ARTS/MELLLA License Amendment Request Pre-submittal Meeting January 18, 2011
Meeting Goals
To communicate why this License Amendment is needed at Columbia
To provide a clear picture of the level of detail to be included in the submittal
To gain a thorough understanding of the needs of the NRC Review Staff prior to submitting the amendment request 2
Meeting Goals (contd)
To minimize the need for requests for additional information
To achieve an agreement on an acceptable approach for scope and depth of content 3
PRNM/ARTS/MELLLA Primary purposes for pursuing PRNM/
ARTS/MELLLA at Columbia Improve Neutron Monitoring System Reliability Improve Fuel Operating Margin Increase Overall Efficiency of Reactor Operations 4
Overview of Presentation
Summarize scope of LAR Submittal
Address NRC concerns identified in Sept. 2010 non-acceptance letter
Discuss schedule for submittal
Discuss approach for application of TSTF-493
Identify any additional open items or NRC staff concerns 5
LAR Submittal Scope
Information provided as part of initial submittal (separated into distinct PRNM and ARTS/MELLLA attachments)
Information provided in response to RSI 1-8
New Information
23A5161 Rev 3 - NUMAC Software Configuration Management Plan
23A5162 Rev 3 - NUMAC Software Management Plan
23A5163 Rev 3 - NUMAC Software Verification and Validation Plan
NEDO-11209-04A Rev 8 (1989) - GE Nuclear Energy QA Program Description
GEH Process Road Map
BTP 7-14 Summary Assessment
BTP 7-14 Matrix to GEH Processes
TS Scope increased to add footnotes (consistent with TSTF-493) 6
Summary of Non-Acceptance
Changes from 1995 LTR not clearly identified
B.2.1 Software Lifecycle Process Planning
- insufficient information provided
B.2.2 Software Life Cycle Process Implementation
- information provided too generic
Compliance with Regulatory Guide criteria for RGs 1.168 through 1.173 not demonstrated 7
GEH Software Quality & BTP 7-14
GEH Quality Assurance Process Not structured the same as BTP 7-14 Not managed by a single GEH document NUMAC SCMP, SMP, & SVVP provide guidance on how to utilize the GEH lower level procedures and processes to ensure software quality 8
GEH Software Quality & BTP 7-14
GEH Quality Assurance Process (contd)
A detailed understanding of several GEH Policies (P&Ps), Engineering Operating Procedures (EOPs), and Common Procedures (CPs), along with project specific documentation is necessary to assemble the software quality management process 9
GEH Software Quality & BTP 7-14
Actions for Re-submittal GEH is assembling additional documentation to assist with clarity and visibility for the NRCs review based on BTP 7-14 GEH BPT 7-14 Independent Assessment -
by ProDesCon, Inc.
GEH Process Road Map - High level pictorial view 10
11 GEH BPT 7-14 Independent Assessment Concept
12 GEH Process Road Map - Example
Changes from Approved LTR Changes to be identified as follows:
Hardware Summary of significant hardware changes Tables of differences in NUMAC platform and hardware modules by parts list Programmable Devices No changes to PLDs from LTR approved design 13
Changes from Approved LTR Software Synopsis of software evolution process Table of firmware changes for Columbia PRNM Applicable Development Processes Summary of NUMAC software development plans Table of software plans revision history*
- Copies of the NUMAC SCMP, SMP, SVVP documents will be provided, based on the revisions identified in Table 1-6. Additional documentation will be made available to the NRC, if requested.
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Changes from Approved LTR
Software Development (as related to section B.2,and the secure development and operational environment)
Summary of PRNM regulatory compliance Table correlating NUMAC design process to BTP 7-14 15
Software Lifecycle Process Planning
NUMAC Document Revision History Table with revision history of NUMAC Software Plans Copies of the NUMAC SCMP, SMP, SVVP documents will be provided based on the revisions identified in the Table.
Additional documentation will be made available to the NRC, if requested
GE Nuclear Quality Assurance Program Revision History NEDO-11209-04A Revision 8, dated 1989 was used for the ENW PRNM Project 16
Software Lifecycle Process Planning
Software Quality Assurance vs. Quality Assurance Program NEDO-11209-04A Revision 8 provided as a reference to ensure NRC understood GEH was following Appendix B approved program 17
Software Lifecycle Process Planning
Sufficient Information GEH Process Road Map
Visual Display of the GEH Process to assist with review BTP 7-14 Summary Assessment
Will communicate level of assurance that can be demonstrated through existing GEH processes and procedures, and will identify where alternate measure may be required 18
Software Lifecycle Process Planning
Sufficient Information BTP 7-14 Matrix to GEH Processes
Utilizes RG 1.168-1.173 Matrices developed by GEH
Identifies how GEH Plans, Processes, Procedures, and Documents map to the related criteria 19
Software Life Cycle Process Implementation
Specific Documentation
GEH Process Road Map
BTP 7-14 Summary Assessment
BTP 7-14 Matrix to GEH Processes 20
Regulatory Guidance Criteria 21
Analysis of Criteria
GEH Process Road Map
BTP 7-14 Summary Assessment
BTP 7-14 Matrix to GEH Processes
Deltas with BTP 7-14
Deltas will be identified and evaluated for acceptable alternatives
Noteworthy Deltas Lack of a formal Software Safety Analysis program Degree of Independence for Software V&V activities Forward/Backward Traceability throughout the lifecycle at the code specific level 22
PRNM ARTS/MELLLA Schedule
Proposed submittal date late March/early April 2011
If approved, implementation would be requested for Refueling Outage R21, scheduled for May-June 2013 23
Application of TSTF 493
Affected Setpoints
RPS and Control Rod Block (APRM/OPRM/LPRM)
Planned Approach
Option A (footnotes)
Full Implementation (no piece-meal)
Planned Schedule
Late March/Early April 2011 Submittal
Submitted in parallel with PRNM/ARTS/MELLLA 24
Application of TSTF 493
Challenges/Questions
Level of Detail Required
Columbia is a BWR/5, will need to adopt portions of NUREG-1433 and NUREG-1434
Acceptability of Timing of Submittal
Need for Commitment in PRNM Submittal 25
26 QUESTIONS?
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