ML111990074

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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
ML111990074
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 08/04/2011
From: Thadani M
Plant Licensing Branch IV
To:
Energy Northwest
Thadani, M C, NRR/DORL/LP4, 415-1476
References
TAC ME5129
Download: ML111990074 (5)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 August 4, 2011 LICENSEE: Energy Northwest FACILITY: Columbia Generating Station

SUBJECT:

SUMMARY

OF JULY 6,2011, 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 MONITORfTECHNICAL SPECIFICATIONS (ARTS), AND MAXIMUM EXTENDED LOAD LINE LIMIT ANALYSIS (MELLLA) LICENSE AMENDMENT REQUEST (TAC NO. ME5129)

On July 6, 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 Monitor/Technical 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 the NRC as documented in its letter dated September 13, 2010 (ADAMS Accession No. IVIL102420659). The licensee plans to re-submit an updated LAR. A previous Phase 0 public meeting on this subject was held on January 18, 2011; that meeting summary is available at ADAMS Accession No. ML110210130.

The purpose of the July 6, 2011, 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 enclosed. The meeting handouts are available in ADAMS (ADAMS Accession No. ML111870059).

Results of Discussion The licensee informed the NRC staff that the PRNMS upgrade is built and has been delivered at the site.

During meeting held on January 18,2011, the licensee had indicated that there may be some differences with NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition," Branch Technical Position (BTP) 7-14, "Guidance on Software Reviews for Digital Computer-Based Instrumentation and Control Systems" (ADAMS Accession No. ML070670183). The NRC staff stated that these differences must be evaluated fully and documented as equivalent alternatives for acceptance. Lack of fully independent verification and validation (IV&V) was cited as one of the key areas of difference. The NRC staff stated that the licensee's program must provide

- 2 adequate verification and validation (V&V). The use of a third-party independent reviewer was identified as a possible alternative approach.

The licensee advised that NRC that it had initiated an independent assessment which was conducted by ProDesCon as a critical review. This critical review identified gaps between the IV&V requirements of Institute of Electrical and Electronics Engineers (IEEE) Standard 1012-1998, "IEEE Standard for Software Verification and Validation," and the actual testing performed.

The NRC staff and the licensee discussed how the submittal would address variances from BTP 7-14 and IEEE 1012. Specifically, one major concern identified by the staff that did not appear to be adequately addressed in the licensee's previous submittal was the independence of the V&V process from the development process. At this meeting, the licensee did not identify explicitly all the gaps and the measures to be taken to compensate for those gaps. The licensee did mention creating a few additional documents and some additional testing to fill the gaps. The NRC staff suggested that Energy Northwest describe what additional testing will be conducted to supplement the earlier testing which was not done in accordance with IEEE 1012 and how this additional testing will justify meeting the guidance of IV&V contained in IEEE 1012.

Non-testable features would need to be identified and justified for acceptance.

The licensee also agreed to provide a roadmap between ISG-06 1, Enclosure B, and the licensee documents for ease of the NRC staff's review. NRC expects all Phase I documents will be submitted along with the submittal.

The licensee states that it plans to submit four LARs (three of which may be under the same cover letter) in the place of the original LAR that was not accepted for review. The four LARs would concern PRNMS, ARTS/MELLLA, Standby Liquid Control, and Technical Specification Task Force (TSTF) Traveler 493, "Clarify Application of Setpoint Methodology for LSSS

[Limiting Safety System Setting] Functions."

The licensee and the NRC discussed having a possibly closed meeting to discuss proprietary information just prior to the licensee's submittal in order to discuss how the content of the licensee's submittal matches Appendix B of ISG-06.

A member of the public attended the meeting. No Public Meeting Feedback Forms were received for this meeting.

1 U.S. Nuclear Regulatory Commission, Digital Instrumentation and Controls, DI&C-ISG-06, "Task Working Group #6: Licensing Process," Interim Staff Guidance (ADAMS Accession No. ML110140103).

-3 Please direct any inquiries to me at (301) 415-1476, or Mohan.Thadani@nrc.gov.

Sincerely, Mohan C. Thadani, 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 July 6, 2011, PRE-LICENSING MEETING DIGITAL PRNMS/ARTS/MELLLA LICENSE AMENDMENT REQUEST ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397 NAME ORGANIZATION Norbert Carte NRC/NRRlDElEICB Bernard Dittman NRC/NRRlDE/EICB Lauren Gibson NRC/NRRlDORLlLPL4 David Rahn NRC/NRRlDE/EICB Gursharan Singh NRC/NRRlDE/EICB Don Gregoire EN M. A. (Tony) Huiatt EN James Snyder EN Lauren Kazmierski GEH Ross Merante GEH Eric Mino GEH Sara Rudy GEH Larry Walton GEH Jana Bergman* Scientech

  • Member of the public Abbreviations:

NRC - U.S. Nuclear Regulatory Commission NRR - Nuclear Reactor Regulation EICB - Instrumentation and Controls Branch DE - Division of Engineering DORL - Division of Operating Reactor Licensing LPL4- Plant Licensing Branch IV EN - Energy Northwest GEH - General Electric Hitachi Nuclear Energy Americas LLC Enclosure

Meeting Notice ML111730551 Summary ML111990074 Handouts ML111870059 OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/DE/EICB/BC NRR/LPL4/BC NRR/LPL4/PM MThadani GWilson MThadani NAME (LKGibson for) JBurkhardt (w/comments) MMarkley (LKGibson for)

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