ML13179A128

Redacted, Request for Additional Information, Round 6, Technical Specification Changes to Support Installation of GE Hitachi Power Range Neutron Monitoring System; Implementation of Arts/Mellla

ML13179A128
Person / Time
Site:	Columbia
Issue date:	07/10/2013
From:	Lyon C Plant Licensing Branch IV
To:	Reddeman M Energy Northwest
Gibson L
References
TAC ME7905
Download: ML13179A128 (8)

Text

OFFICIAl. USEi ONl:Y PAOPAIEiTAAY INFORMATlO~

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHIN(JTON. D.C. 20555..0001 July 10, 2013 Mr. Mark E. Reddemann Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023)

Richland, WA 99352-0968

SUBJECT:

COLUMBIA GENERATING STATION - REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO IMPLEMENT PRNMIARTS/MELLLA (TAC NO. ME7905)

Dear Mr. Reddemann:

By letter dated January 31,2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML120400144), as supplemented by letters dated July 31. 2012, August 22,2012, October 5,2012, November 12. 2013, January 7, 2013, April 11. 2013, and May 9,2013 (ADAMS Accession Nos. ML12219A255, ML1224BA136, ML122920735, ML123280090, ML130150329, ML13116A013, and ML13141A581, respectively), Energy Northwest (the licensee), submitted a license amendment request for Columbia Generating Station that would allow the licensee to expand the operating domain by the implementation of Power Range Neutron Monitoring/Average Power Range Monitor/Rod Block MonitorlTechnical Specifications/Maximum Extended Load Line Limit Analysis (PRNM/ARTS/MELLLA). The Neutron Monitoring System would be modified by replacing the analog APRM subsystem with the General Electric - Hitachi Nuclear Measurement Analysis and Control (NUMAC) PRNM System. The licensee would expand the operating domain to MELLLA and make changes to certain allowable values and limits and to technical specifications. The changes to the technical specifications include the adoption of Technical Specifications Task Force (TSTF)-493 Option A surveillance notes. The amendment would also allow a change in the licensing basis to support AntiCipated Transient without Scram accident mitigation with one Standby Liquid Control pump instead gf two.

By letter dated April ii, 2013. Energy Northwest provided responses to the requests for additional information (RAls) regarding the instrumentation and controls questions that were issued by U.S. Nuclear Regulatory Commission (NRC) on March 12, 2013 (ADAMS Accession No. ML13067A102). In addition, by letter dated May 9,2013, Energy Northwest provided clarifications pertaining to the setpoint calculation audit that was conducted on April 3. 2013.

The NRC staff has reviewed the information provided by the licensee and detennined that additional information identified in Enclosure 1 to this letter is needed in order for the NRC staff to complete its review. The draft copy of the RAI was provided to Ms. Lisa Williams of your staff via e-mail on June 18. 2013. A teleconference was held on June 26, 2013, with members of your staff. During the call, Energy Northwest agreed to respond within 30 days of the date of this letter. Enclosure 2 contains a redacted, non-proprietary version of the RAI.

OFFleIAl: USE ONl:Y PROPRIEiTARY INFOAMATlO~

OFFICIAL. "Iii ONL.¥ PROPRIEiTARY INFORMATiON((

M. Reddeman

-2 If you have any questions regarding this matter. I may be reached at (301) 415-2296 or via e-mail at fred.!Yon@nrc.goy.

Sincerely, Carl F. Lyon. Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-397

Enclosures:

1. RAI (Proprietary)

2. RAI (Redacted) cc w/Enclosure 2: Distribution via Listserv OFFICIAL UIE ONLY PROPRIEiTARY INFORMATION ~

ENCLOSURE 2 REQUEST fOR ADPITIONAL INfORMATION (NON.PROPRIETARY)

LICENSE AMENDMENT REQUEST TO IMPLEMENT PRNM/ARTSIMELLbA ENERGY NORTHWEST COWMBIA GENERATING STATION DOCKET NO. 5Q..397

OFFICIAL USE ONlY PROPRIETARY INFORMATIONe REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO IMPLEMENT PRNMIARTSIMELLLA ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397 By letter dated January 31.2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML120400144). as supplemented by letters dated July 31. 2012.

August 22.2012, October 5,2012. November 12.2013. January 7.2013. April 11,2013. and May 9, 2013 (ADAMS Accession Nos. ML12219A255, ML12248A136. ML122920735, ML123280090, ML130150329, ML13115A013, and ML13141A581, respectively), Energy Northwest (EN, the licensee), submitted a license amendment request (LAR) for Columbia Generating Station (CGS) that would allow the licensee to expand the operating domain by the implementation of Power Range Neutron Monitoring/Average Power Range Monitor/Rod Block MonitorlTechnical Specifications/Maximum Extended Load Line Limit Analysis (PRNM/ARTS/MELLLA). The Neutron Monitoring System would be modified by replacing the analog APRM subsystem with the General Electric - Hitachi (GEH) Nuclear Measurement AnalysiS and Control (NUMAC) PRNM System. The licensee would expand the operating domain to MELLLA and make changes to certain allowable values and limits and to technical speCifications. The changes to the technical specifications include the adoption of Technical Specifications Task Force (TSTF)-493 Option A surveillance notes. Furthermore, the amendment would allow a change in the licensing basis to support Anticipated Transient without Scram (AlWS) accident mitigation with one Standby Liquid Control (SLC) pump instead of two.

By letter dated April 11, 2013, Energy Northwest provided responses to the requests for additional information (RAls) regarding the instrumentation and controls questions that were issued by the U.S. Nuclear Regulatory Commission (NRC) on March 12.2013 (ADAMS Accession No. ML13067A102). In addition, by letter dated May 9. 2013. the licensee provided clarifications pertaining to the setpoint calculation audit that was conducted on April 3, 2013.

The NRC staff has reviewed the information provided in the Energy Northwest's responses and determined that the following information is required to complete its technical review.

With regard to Staff Position 20 of Digital Instrumentation and Controls DI&C-IS<3-04, Revision 1, "Task Working Group #4: Highly-Integrated Control Room~ommunications Issues (HICRc), Interim Staff Guidance,' dated March 6,2009 (ADAMS AcceSSion No. ML083310185). the licensee has stated that [(

)). If this test data is available by middle of August 2013. please provide a summary ofthe test results. If such data is not likely to be available by August 31, 2013, please provide the date by which the data will be available for CGS.

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OFFICIAL "81 ONLY PROPRllTARY INFORMA=FIO<

-2 Recirculation flow signal processing electronics are being replaced by integrated digital NUMAC chassis based APRM electronics. The APRM is to be designed such that any single short or open of anyone of the flow inputs will not affect the other flow Inputs. Energy Northwest has stated that ((

'n.

Please confirm how the flow transmitter signal to local power range monitor (LPRM) system will be Isolated such that there Is no adverse effect on the safety system due to an open circuit. a short circuit. or a ground fault. Since the eight flow transmitters are not safety related, Energy Northwest is requested to clarify how the safety to non~safety interface and signal isolation is achieved for the flow transmitters.

In order to determine that Rod Manual Control System (RMCS) to Rod Block Monitor (RBM) communication link will not be subject to a broadcast storm, the licensee Is requested to confirm whether the data communicated over the serial link from the RMCS to the RBM is fixed and validated prior to use.

If not. please explain how data broadcast storm is avoided such that adverse effects on the functioning of RBM are prevented.

Table 1, Columbia NUMAC PRNM Licensing Topical Report (LTR) Deviations in 00OO-o101-7647-R3 (ADAMS Accession No. ML12040A073) lists three exceptions.

Exception (a) states that Oseillatlon Power Range Monitor (OPRM) Upscale function Is voted with APRM INOP [Inoperable) Function with the justification that it Improves operating flexibility. The PRNM licensing basis, as described in the in the document cited above, Is that *OPRM Upscale function Is voted separately from the APRM INOP function. W The justification for this deviation is to improve operational flexibility. As the licensee states, Thia deviation allows USing the APRM chassia keylock sWitch to place APRM and OPRM outputs from a second channel in the tripped condition when another APRMlOPRM channel Is already bypassed (and cannot be returned to service within the allowed out of service time) without having to resort to other actions such as disconnecting a fiber-optic cable to the 2-out*of~ voters or removing power from the APRM chassis.

OFFICIAL "BE ONlY PRQPRI&TARY INFORMAT'0tt)

OFFICIAL UIE ONLY PROPRIETARY INFORMATION(

-3 Section 8.4.1.3 of NEDC-3241 Opl. Supplement 12 states. In part. that combining the OPRM upscale with the APRM INOP function could result In unnecessary trips.

Unnecessary trips are considered nuisances and challenges to the safety system. Based on the rationale provided in Section 8.4.1.3 of NEDC*3241 OP. Supplement 1. please further justify this change with the regard to spurious trips.

Table 1. Columbia NUMAC PRNM LTR Deviations in 0000*0101-7647-R3 (ADAMS Accession Nos. ML12040A081 (non-public) and ML12040A073 (public>> lists three exceptions and the second exception (Exception b) states that time to calculate the Flow-biased Trip Setpoint takes more than the allocated time in LTR NEDC-32410P-A. Volume 14. Section 3.3.2. with the explanation that ((

])

Section 3.3.2 of NEDC-32410P*A, in part states that:

((

n

((

]) The NRC staff is concemed that the intent of the trip may not be met for fast transients due to the excessive response time. Please further justify this deviation for back up protection against all transients. In addition. please cite any precedence with regard to this deviation. if available.

RAt 27 Table 1. Columbia NUMAC PRNM LTR Deviations In 000o-0101-7647-R3 lists three exceptions and the third exception (Exception C) atatea that any missing module In e chaeele cause. an alarm but not necessarily a trip whereas the PRNM licensing basis states that [t D. Energy Northwest Justifies this exception by referring to the purpose of the APRM INOP trip described In NEDC-32410P-A. Section 3.2.10.1, and stating that ((

nIs beyond the Intent.

The NRC staff has not found any statement in NEDC-32410P-A. Section 5.3.8.2 or Section 3.2.10.1. which states this rationale. Therefore. please clarify and further Justify this exception.

NEDC*32410P-A. "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function. Volumes 1 and 2: October 1995 (ADAMS Legacy Accellfon No. 9605290009).

NEDC-32410P.A. *Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function, Supplement 1". November 1997 (ADAMS Legacy Accession No. 9805120242).

OFFICIAL "IE ONLY PROPRIETARV INFORMATION (

2

OFFICIAL U8E ONLY PROPRIETARY INFORMATIO~

-4 As mentioned earlier, the setpoint calculation audit was conducted by NRC on April 3, 2013.

Subsequent to the meeting, the staff observed that there are minor discrepancies between the prevIously provided Figure 9.3.8.1 in GEH setpoint methodology in NEDC-33685P (ADAMS Accession Nos. ML12040A062 and ML12040A074) and the response to RAI 16 provided by Energy Northwest's letter dated October 5, 2012. Figure 9.3.6.1 shows the required limit ((

• .J] whereas Figure RA118-1 shows the ((

n. Energy Northwest is requested to explain the noted discrepancy.

OFFICIAL USE ONLY PROPRIIiTARY INFORMATION(

OFFIQIAIa UIE ONI.Y PROPRIETARY INFORMAl'I05 M. Reddeman

-2 If you have any questions regarding this matter, I may be reached at (301) 415-2296 or via e-mail at fred.lyon@nrc.gov.

Sincerely.

IRAJ Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50*397

Enclosures:

1. RAJ (Proprietary)

2. RAJ (Redacted) cc w/Enciosure 2: Distribution via Listserv DISTRIBUTION:

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