ML061530284

06/19/2006 Notice of Meeting with South Carolina Electric & Gas Company Online Monitoring of Instrument Channel Performance at V. C. Summer

ML061530284
Person / Time
Site:	Summer
Issue date:	06/05/2006
From:	Martin R E Plant Licensing Branch III-2
To:	Marinos E C Plant Licensing Branch III-2
Martin R E, NRR/DORL, 415-1493
References
Download: ML061530284 (6)

Text

June 5, 2006MEMORANDUM TO:Evangelos MarinosPlant Licensing Branch 2-1 Division of Operating Reactor LicensingFROM:Robert E. Martin /RA/Plant Licensing Branch 2-1 Division of Operating Reactor Licensing

SUBJECT:

FORTHCOMING MEETING WITH SOUTH CAROLINA ELECTRIC &GAS COMPANYDATE & TIME:Monday, June 19, 2006Time: 1:00 p.m. - 4:00 p.m.LOCATION:U.S. Nuclear Regulatory CommissionOne White Flint North 11555 Rockville Pike, Room O 4 B 4Rockville, MarylandPURPOSE:To discuss concerns, identified in the enclosure, with the licensee'sapplication of February 6, 2006, to implement online monitoring of instrument channel performance at the V. C. Summer Nuclear Station.CATEGORY 1: *This is a Category 1 Meeting. The public is invited to observe thismeeting and will have one or more opportunities to communicate with theNRC after the business portion, but before the meeting is adjour ned.PARTICIPANTS:Participants from the NRC include members of the Office of NuclearReactor Regulation (NRR). NRCSouth Carolina Electric & GasA. Howe, NRRR. Sweet, et alP. Rebstock, NRR E. Marinos, NRR R. Martin, NRRMEETING CONTACTS:R. Martin, NRRS. Monarque, NRR301-415-1493301-415-1544Docket No. 50-395

Enclosure:

Agenda Discussion Topics cc w/encl: See next page

• Commission's Policy Statement on "Enhancing Public Participation in NRC Meetings"(67 FR 36920), May 28, 2002 June 5, 2006MEMORANDUM TO:Evangelos MarinosPlant Licensing Branch 2-1 Division of Operating Reactor LicensingFROM:Robert E. Martin /RA/Plant Licensing Branch 2-1 Division of Operating Reactor Licensing

SUBJECT:

FORTHCOMING MEETING WITH SOUTH CAROLINA ELECTRIC &GAS COMPANYDATE & TIME:Monday, June 19, 2006Time: 1:00 p.m. - 4:00 p.m.LOCATION:U.S. Nuclear Regulatory CommissionOne White Flint North 11555 Rockville Pike, Room O 4 B 4Rockville, MarylandPURPOSE:To discuss concerns, identified in the enclosure, with the licensee'sapplication of February 6, 2006, to implement online monitoring of instrument channel performance at the V. C. Summer Nuclear Station.CATEGORY 1: *This is a Category 1 Meeting. The public is invited to observe thismeeting and will have one or more opportunities to communicate with theNRC after the business portion, but before the meeting is adjour ned. PARTICIPANTS:Participants from the NRC include members of the Office of NuclearReactor Regulation (NRR). NRCSouth Carolina Electric & GasA. Howe, NRRR. Sweet, et alP. Rebstock, NRR E. Marinos, NRR R. Martin, NRRMEETING CONTACTS:R. Martin, NRRS. Monarque, NRR301-415-1493301-415-1544Docket No. 50-395

Enclosure:

Agenda Discussion Topics cc w/encl: See next page

• Commission's Policy Statement on "Enhancing Public Participation in NRC Meetings"(67 FR 36920), May 28, 2002 DISTRIBUTION: See next pageADAMS Accession No.: ML061530284 NRC-001 OFFICENRR/LPL2-1/PMNRR/LPL2-1/LANRR/LPL2-1/BC NAMERMartin:sxd6RSolaCMillerfor EMarinosDATE6/5/066/05/066/05/06OFFICIAL RECORD

SUBJECT:

FORTHCOMING MEETING WITH SOUTH CAROLINA ELECTRIC &GAS COMPANYDATE & TIME:Monday, June 19, 2006Time: 1:00 p.m. - 4:00 p.m.DISTRIBUTION:PUBLICLPL2-1 Reading RidsNrrDorlLpl2-1 RidsNrrPMRMartin RidsNrrPMSMonarque RidsNrrLACSola RidsNrrDorl RidsNrrDeEicb A. Howe, NRR P. Rebstock, NRR RidsRgn2MailCenterSLee, EDO Region II KClark, OPA Region II RJasinski, NRR PMNS W. Kemper, RES RidsNrrAdro RidsAcrsAcnwMailCenter RidsOgcMailCenter RidsNrrOgcRp RidsOpaMail Receptionist, OWFN and TWFN AGENDA DISCUSSION TOPICS FOR APPLICATION REGARDINGONLINE MONITORING (OLM) OF INSTRUMENT CHANNEL PERFORMANCE VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)The licensee's application of February 6, 2006, is an incomplete submittal and is, therefore,unacceptable for review. The application does not include adequate VCSNS-specific information to support an evaluation of the particular approach to OLM and the accommodation of OLM in the VCSNS Technical Specifications (TS). The NRC staff views OLM as a viable concept as reflected in Reference 1. In particular, the application does not include: (a) an adequate description of the particular OLMmodeling methodology and algorithms to be implemented at VCSNS, (b) analyses showing that the planned implementation is appropriate for VCSNS, (c) analyses of the uncertainties introduced by the use of OLM and the incorporation of those uncertainties into the individual channel uncertainty calculations and the associated TS limits for VCSNS.Some examples of the NRC staff's concerns are provided below. This is not a comprehensivelisting, but rather a selection of examples gleaned from the NRC staff's pre-acceptance reviewof the application. Resolution of these comments alone may not be sufficient to ensure theacceptability of a future re-application.1.The application should include an overall description of the particular software to beused in support of OLM, including description of both the data algorithms and the operator interfaces and related capabilities. The software specification and verificationand validation (V&V) process should also be described, to show that the proposed software will perform its intended function.2.Model training and the elimination of "bad" data from the training sets, as specificallyimplemented for VCSNS, is not adequately addressed.3.The licensee's application dated February 6, 2006, appears to indicate that the softwareto be implemented has the capability for the use of multiple algorithms with provisionsfor the analyst to apply whatever algorithm is desired at any time. Unless there are adequate controls to ensure that only specifically-predesignated algorithms are available for use, it would be necessary to show that all available algorithms are suitable for all applications. If different algorithms are to be applied to different measured process variables, then it will be necessary to show that the selected algorithm is suitable foreach variable and that adequate controls are in place to prevent the application ofalgorithms not shown to be suitable.4.The licensee included two Electric Power Research Institute (EPRI) reports with theapplication package. These reports appear to supplement the EPRI Technical Report TR-104965, that was accepted by the NRC staff in a Safety Evaluation provided to EPRIby letter dated July 24, 2000 (Reference 1). These two additional reports have not previously been presented to NRC. The licensee relies on these two additional reportsalmost exclusively for responding to the 14 items identified in Reference 1 as applicable to plant-specific applications. Although the two additional reports may be based largelyupon VCSNS experience, they are not written as being specific to VCSNS. They do not provide any specific information as to how OLM will be implemented at VCSNS and theydo not explicitly support the proposed VCSNS TS changes. Also, if the NRC staff were to accept the application on the basis of the EPRI reports, then the NRC staff would need to review those reports in detail. Depending upon howthe reports are constructed, it may be necessary for that review to encompass matters not directly related to the VCSNS application, and it may also be necessary to review additional material referenced in those reports. The NRC staff recommends that thelicensee reconsider the extent that they wish to cite unreviewed materials, rather thanincorporating the necessary details directly into the license amendment application package. 5.There are several statements in the application to the effect that "the analysis is basedupon the approach explained in," but neither the reference nor any further explanation is provided. The NRC staff therefore can address neither the referenced material nor thedegree of conformance of the proposed design to it, and can, therefore, not assess the adequacy of the statement. The application should present the specific analyses and processes applicable to the license amendment application for VCSNS.6.The application asserts that no setpoint-related TS limit will need to change as a resultof OLM, but it provides no analysis in support of this claim. However, there are indications that the associated uncertainty analyses have yet to be completed, so it is not clear how the results of those analyses can already be known. The licensee should provide explicit justification for each TS setpoint limit related to a channel affected by OLM, whether the limit is to be changed or not. The OLM process introduces uncertainties that do not otherwise exist and that must be accounted for in the TSsetpoint limits. It is possible that OLM, in the specific implementation prepared forVCSNS, also reduces other uncertainties enough to compensate for the added uncertainties and results in no net change or even a net reduction in uncertainty for some channels, but that is by no means assured and it has not been demonstrated.Reference s1.Letter, S. A. Richards, NRC, to G. L. Vine, EPRI, dated July 24, 2000, "EPRI TopicalReport 104965, "Online Monitoring of Instrument Channel Performance," Final Report, November 1998, TAC No. M93653," Agency Documents Access and Management System Accession (ADAMS) No. ML003734509.2.Letter, J. Archie, SCE&G, to NRC, dated February 6, 2006, "License AmendmentRequest - LAR 05-0677, On-Line Monitoring of Instrument Channel Performance,"

ADAMS No. ML060400220.

Virgil C. Summer Nuclear Station cc:

Mr. Jeffrey B. Archie Sr. Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 800 Jenkinsville, SC 29065Mr. R. J. WhiteNuclear Coordinator S.C. Public Service Authority c/o Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 802 Jenkinsville, South Carolina 29065Resident Inspector/Summer NPSc/o U.S. Nuclear Regulatory Commission 576 Stairway Road Jenkinsville, South Carolina 29065Chairman, Fairfield County CouncilDrawer 60 Winnsboro, South Carolina 29180Mr. Henry Porter, Assistant DirectorDivision of Waste Management Bureau of Land & Waste Management Dept. of Health & Environmental Control 2600 Bull Street Columbia, South Carolina 29201Mr. Thomas D. Gatlin, General ManagerNuclear Plant Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 300 Jenkinsville, South Carolina 29065Mr. Robert G. Sweet, ManagerNuclear Licensing South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 830 Jenkinsville, South Carolina 29065Ms. Kathryn M. SuttonMorgan, Lewis & Bockius LLP 111 Pennsylvania Avenue, NW.

Washington, DC 20004