GNRO-2011/00013, Request for Additional Information Regarding Extended Power Uprate

From kanterella
Jump to navigation Jump to search

Request for Additional Information Regarding Extended Power Uprate
ML110550318
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 02/23/2011
From: Krupa M
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML110550316 List:
References
GNRO-2011/00013
Download: ML110550318 (38)
v • d • e


Text

Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 Michael A. Krupa Director, Extended Power Uprate Grand Gulf Nuclear Station Tel. (601) 437 6684 Enclosure 1 contains PROPRIETARY information.

GNRO-2011/00013 February 23, 2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Request for Additional Information Regarding Extended Power Uprate Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCES:

1. E-Mail from A. Wang to F. Burford, GGNS EPU Instrument and Control Request for Additional Information (ME4679), dated January 26, 2011 (Accession Number ML110260281)
2. License Amendment Request, Extended Power Uprate, dated September 8, 2010 (GNRO-2010/00056, Accession Number ML102660403)

Dear Sir or Madam:

The Nuclear Regulatory Commission (NRC) requested additional information (Reference 1) regarding certain aspects of the Grand Gulf Nuclear Station, Unit 1 (GGNS) Extended Power Uprate (EPU) License Amendment Request (LAR) (Reference 2). Attachment 1 provides responses to the additional information requested by the NRC Instrumentation and Controls Branch.

The GEH Instrument Limits Calculation was developed by General Electric-Hitachi (GEH) and supports the response to RAI No. 4. This document is provided in Enclosure 1. GEH considers certain information contained in this report to be proprietary and, therefore, requests it be withheld from public disclosure in accordance with 10 CFR 2.390. GEH, as the owner of the proprietary information, has executed the affidavit contained in Enclosure 2.

This affidavit identifies that the identified proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. The proprietary information was provided to Entergy in a GEH transmittal that is referenced in the affidavit. Therefore, on behalf of GEH, Entergy requests Enclosure 1 be withheld from public disclosure in accordance with 10 CFR 2.390(b)(1). A non-proprietary version of Enclosure 1 is provided in Enclosure 3.

When Enclosure 1 is removed from this letter, the entire document is NON-PROPRIETARY.

GNRO-2011/00013 Page 2 of 2 No change is needed to the no significant hazards consideration included in the initial LAR (Reference 2) as a result of the additional information provided. There are no new commitments included in this letter.

If you have any questions or require additional information, please contact Jerry Burford at 601-368-5755.

I declare under penalty of perjury that the foregoing is true and correct; executed on February 23, 2011.

Sincerely, MAK/FGB/ghd

Attachment:

1. Response to Request for Additional Information, Instrumentation and Controls

Enclosures:

1. GEH Instrument Limits Calculation (Proprietary Version)
2. GEH Affidavit Supporting Request to Withhold Information from Public Disclosure
3. GEH Instrument Limits Calculation (Non-Proprietary Version) cc: Mr. Elmo E. Collins, Jr.

Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 612 East Lamar Blvd., Suite 400 Arlington, TX 76011-4005 U. S. Nuclear Regulatory Commission ATTN: Mr. A. B. Wang, NRR/DORL (w/2)

ATTN: ADDRESSEE ONLY ATTN: Courier Delivery Only Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378 State Health Officer Mississippi Department of Health P. O. Box 1700 Jackson, MS 39215-1700 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment 1 GNRO-2011/00013 GGNS Extended Power Uprate Response to Request for Additional Information Instrumentation and Controls to GNRO-2011/00013 Page 1 of 5 Response to Request for Additional Information Instrumentation and Controls By letter dated September 8, 2010, Entergy Operations, Inc. (Entergy) submitted a license amendment request (LAR) for an Extended Power Uprate (EPU) for Grand Gulf Nuclear Station, Unit 1 (GGNS). The U.S. Nuclear Regulatory Commission (NRC) staff has determined that the following additional information requested by the Instrumentation and Controls Branch by e-mail dated January 26, 2011 (Accession Number ML110260281) is needed for the NRC staff to complete their review of the amendment. Entergys response to each item is also provided below.

GE-Hitachi Nuclear Energy Americas, LLC (GEH) considers the information provided in , which supports the response to RAI No. 4, to be proprietary and, therefore, exempt from public disclosure pursuant to 10 CFR 2.390. An affidavit for withholding this information, executed by GEH, is provided in Enclosure 2. The proprietary information was provided to Entergy in a GEH transmittal that is referenced in the affidavit. Therefore, on behalf of GEH, Entergy requests to withhold Enclosure 1 from public disclosure in accordance with 10 CFR 2.390(b)(1). A non-proprietary version of the RAI responses is provided in .

RAI No. 1 In Section 2.4.1 of Attachment 5B of the GGNS EPU LAR, the following statement is made:

The EPU evaluation considered the new [POWER RANGE NEUTRON MONITORING SYSTEM (PRNMS)] system design and licensing basis. Section 2.4.1.1.1 states: The SRM, IRM, and APRM systems installed at GGNS are in accordance with the requirements established by the GEH design specifications. Also, Table 2.4-2 in Attachment 5B of the GGNS EPU LAR does not list the modification to the analog Average Power Range Monitor (APRM) subsystem; this table only lists the change to the APRM flow-biased STP scram/rod block.

Please clarify that the information provided in Attachment 5 of the LAR uses the new PRNMS system to replace the existing analog APRM subsystem of the existing Neutron Monitoring System (NMS), and not the currently installed analog APRM.

Response B of the GGNS EPU LAR is based on PRNMS installation and EPU conditions.

The revised Analytical Limit (AL) and Allowable Value (AL) values shown in Table 2.4-1 assume PRNMS has been installed. The Current column assumes PRNMS installation at Current Licensed Thermal Power (CLTP); the EPU column is based on PRNMS installation and EPU conditions.

to GNRO-2011/00013 Page 2 of 5 RAI No. 2 Section 2.4.1.1 of Attachment 5B of the GGNS EPU LAR does not describe the Oscillation Power Range Monitor (OPRM) capability in the PRNMS system. Also, Table 2.4-1 in B of the GGNS EPU LAR summarizes Technical Specification (TS) changes between the current and EPU. This table does not list the OPRM upscale function.

Please provide a description or reference for the OPRM in the PRNMS LAR.

Response

The purpose of Table 2.4-1 is to provide the AL and/or AV values for the TS functions affected by EPU. The OPRM Upscale function has no AL or AV associated with it; therefore, it is not listed in the table. The OPRM Upscale function trip setpoint will be documented in the GGNS Core Operating Limits Report, as discussed in Section 4.4.3.7 of the GGNS PRNMS LAR1.

The OPRM is described in Sections 3.2 and 3.3 of the GGNS PRNMS LAR and also in Sections 2.3.2 and 3.3.3 of GE Nuclear Energy Licensing Topical Report (LTR)

NEDC-32410P-A, Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function 2.

RAI No. 3 Section 2.4.1.1.1 of Attachment 5B of the GGNS EPU LAR states that the APRM and Local Power Range Monitor (LPRM) meet all NEDC-33044 [sic] (commonly called CLTR),

Constant Pressure Power Uprate, dispositions. In support of this request, please clarify how the APRM and LPRM meet GEH specifications, and therefore, meet the CLTR dispositions.

Response

The noted statement is based on a GEH evaluation of the GGNS neutron monitoring system (NMS) using design information requested by GEH during the EPU process. Specifically, Section 5.1 of the CLTR (NEDC-33004P-A)3 provides generic evaluations of the APRM and LPRM equipment that are applicable to GE or Reuter Stokes-supplied monitoring equipment or vendor monitoring equipment that meets GE design specifications at power uprate conditions.

The LPRM detectors were confirmed to be GEH/Reuter Stokes NA250 detectors and therefore, by design, meet GEH design specifications. The NUMAC PRNM system, which will be installed prior to EPU operation, is a GEH system, and thus, also meets GEH design specifications. The APRM subsystem is part of the NUMAC PRNM system. The NMS was then evaluated with respect to CLTR requirements.

1 ADAMS Accession No. ML093140463 2

ADAMS Accession Nos. ML9605290009 and ML9806120242 3

ADAMS Accession No. ML032170332 to GNRO-2011/00013 Page 3 of 5 RAI No. 4 Section 2.4.1.3 of Attachment 5B of the GGNS EPU LAR describes that the new PRNM and the modification to the HP turbine to account for the EPU will affect several setpoint functions.

Section 2.4.2 provides a sample calculation for the MSL High Flow Isolation. But this information is not provided for the other functions affected by the EPU. To support the NRC staff assessment of the acceptability of the LAR in regard to setpoint changes, please provide the calculations for establishing the setpoint values for those functions to be modified by the EPU, identified in Table 2.4-1 of Attachment 5B of the GGNS EPU LAR. Specifically, the calculations should be provided for the following functions:

x APRM High Flux Scram (AV) x APRM Flow-biased Scram (TLO and SLO AV) x Rod Control and Information System (RCIS) Rod Pattern Controller LPSP (lower bound)

Response

Documentation of the setpoint calculations for APRM High Flux Scram (AV) and APRM Flow-Biased Scram (TLO and SLO AVs) are contained in GEH Instrument Limits Calculation document, which is provided in Enclosures 1 and 3 (proprietary and non-proprietary versions, respectively).

Entergy has elected to rescale the RCIS Rod Pattern Controller (RPC) Low Power Setpoint (LPSP) (lower bound) to retain the CLTP AL value in terms of absolute reactor power (MWt).

Therefore, the EPU AL value of 8% Reactor Thermal Power (RTP) rounded to 1 digit in the conservative direction was obtained using the ratio of CLTP (3898 MWt) and EPU power (4408 MWt) with the CLTP AL value in RTP of 9%. This resulted in a lower RTP of 8% that adds flexibility and is conservative. Based on this, the current conservative setpoint of 100 psig Turbine First Stage Pressure (TFSP) for RPC LPSP (lower bound) is being retained.

RAI No. 5 B Sections 2.4.1.3.2 and 2.4.1.3.4 of the GGNS EPU LAR state that new Allowable Values (AV) for the following setpoints are required to support achieving the EPU RTP.

x Turbine First-Stage Pressure Scram Bypass Permissive and x Rod Control and Information System (RCIS) Rod Pattern Controller Low Power Setpoint.

Also, Attachment 5B Section 2.4.1.3.5 of the GGNS EPU LAR states that new Analytical Limit (AL) for the RCIS Rod Withdrawal Limiter High Power Setpoint is required to support achieving the EPU RTP. However, these values are not provided in the LAR, and Entergy stated that they would be revised prior to EPU implementation. Please confirm that it is appropriate for these values to be included in the Technical Requirement Manual (TRM) and not in the TS per 10 CFR 50.36.

to GNRO-2011/00013 Page 4 of 5

Response

The TFSP Scram Bypass Permissive, RCIS RPC LPSP, and RCIS Rod Withdrawal Limiter (RWL) High Power Setpoint (HPSP) all use TFSP to infer reactor power (% RTP). The relationship of % RTP to TFSP is derived based on turbine design data that correlates TFSP to % RTP. The % RTP values are determined for each parameter by analyses and are independent from any changes to this relationship. Therefore, these values, in terms of %

RTP, remain unaltered by any modifications made to the turbine design. Thus, each parameter is presented in the TS in terms of the analysis assumption units. This is consistent with the units (i.e., % RTP) presented in NUREG-1434, Standard Technical Specifications -

General Electric Plants, BWR/6. As reflected in the TS Bases provided in NUREG-1434, 10 CFR 50.36 requirements were considered in the parameter selection process used in the development of the NUREG.

Therefore, the TFSP Scram Bypass Permissive4, RPC LPSP, and RWL HPSP, and their units are presented in the TS consistent with the plant safety analyses, 10 CFR 50.36, and NUREG-1434. Entergy confirms that expressing these parameters in terms of % RTP in the TS is appropriate.

The intent of the noted descriptions in Sections 2.4.1.3.2, 2.4.1.3.4, and 2.4.1.3.5 in B of the EPU LAR was to acknowledge the need for turbine design information to support implementation of the % RTP values, inferred by TFSP. The TFSP values, essential for calibrating and maintaining the instruments, are maintained in plant-specific documents; e.g., the TRM and plant procedures.

RAI No. 6 B Section 2.4.1.3.7 of the GGNS EPU LAR states that the remaining margin for the steam line pressure sensor is adequate for operation at EPU conditions. In support of this request, please provide a reference to the margin assessment performed to determine that the sensor is adequate.

Response

The increased steam line flow generates a higher steam line pressure drop that results in lower pressure in the lines near the turbine throttle where the instruments are located. The margin assessment is performed as an operational screening check to ascertain the potential of normal turbine surveillances (individual stop and control valve full stroke closure at power) to cause pressure drops that could actuate trip instrumentation. GE Service Information Letter (SIL) 130, Main Steam Line Low Pressure Isolation Limit Change, provides a basis for reducing the margin to as low as 100 psid to avoid spurious steam line isolations in the event of plant scrams. The margin for the projected uprate conditions at GGNS was determined to be 106.3 psid.

4 The TFSP Scram Bypass Permissive is represented in TS Sections 3.3.1.1 and 3.3.4.1 as Turbine Stop Valve Closure, Trip Oil Pressure - Low, and Turbine Control Valve Fast Closure, Trip Oil Pressure - Low.

to GNRO-2011/00013 Page 5 of 5 RAI No. 7 Table 2.4-2 in Attachment 5B of the GGNS EPU LAR does not list RCIS rod pattern controller low-power setpoint (LPSP). According to Section 2.4.1.3.4, Entergy will scale the lower bound of this function to maintain the AL value in terms of absolute power. In support of this request, please clarify why this change is not listed in Table 2.4-2.

Response

Table 2.4-2 identifies changes to instrumentation resulting from EPU. As explained in the response to RAI No. 4, above, the RPC LPSP utilizes TFSP to represent % RTP. TFSP is listed in Table 2.4-2.

RAI No. 8 Section 4.1.10 in Attachment 1 of the GGNS EPU LAR identifies actions and Surveillance Requirements (SR) modified to support the EPU. The value for Action K is modified to 21%

RTP. The LAR states that this change is based on TS changes identified in the PRNMS LAR.

However, the modifications in the PRNMS LAR describe new condition K to be 24% RTP, but it does not explain why the change is required to be 5% less than the OPRM trip enabled region (i.e., 29% current licensed thermal power (CLTP) boundary). In support of this request, please provide a reference or description for how the 5% limit was determined.

Response

Section 4.1.10 of the GGNS EPU LAR specifies the "Applicable Mode or Other Specified Conditions" for the OPRM Upscale function (APRM Function 2.f in TS Table 3.3.1.1-1) to be greater than or equal to 21% RTP. This function was introduced into the GGNS TS via the GGNS PRNMS LAR. As discussed in Section 4.4.3.7 of Attachment 1 of the GGNS PRNMS LAR, the applicable mode was established at > 24% RTP in accordance with the methodology outlined in Section 8.4.3 of the PRNMS LTR (NEDC-32410P-A). Note that aspects of the LTR text were clarified or modified in Supplement 1 to the LTR.

Section 8.4.3.3 of Supplement 1 to the PRNMS LTR specifies that the OPRM Upscale function is automatically bypassed below a reactor power level to be determined on a plant-specific basis (nominally 30%; for GGNS at CLTP, this value is 29%). Thus, the associated surveillance requirement, SR 3.3.1.1.23, which is described in Section 4.4.2.8 of the GGNS PRNMS LAR, establishes the requirement to verify the OPRM Upscale function is not bypassed whenever the plant is greater than or equal to 29% RTP. In accordance with GEH methodology (see Section 8.4.3.3 of Supplement 1 to the PRNMS LTR), the applicable mode for the OPRM Upscale function was established at a value 5% below that power level; i.e.,

24% RTP.

For EPU, the power level at which SR 3.3.1.1.23 is to verify the OPRM Upscale function is not bypassed was scaled down (from the nominal value of 30%) based on the ratio of Original Licensed Thermal Power (OLTP) to EPU, or 3833 MWt vs. 4408 MWt. Thus, Section 4.1.10 of the EPU LAR proposes to revise SR 3.3.1.1.23 from 29% to 26%. Maintaining the 5%

difference to the surveillance requirement, Section 4.1.10 also proposes to define the applicable condition for the OPRM Upscale function in TS Table 3.3.1.1-1 as 21%.

Enclosure 2 GNRO-2011/00013 GEH Affidavit Supporting Request to Withhold Information from Public Disclosure to GNRO-2011/00013 Page 1 of 3 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). I 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 letter, GEH-GGNS-AEP-426, Larry King (GEH) to Brian Newell (Entergy), NRC Instrument and Controls RAIs, dated February 20, 2011. The proprietary information in Enclosure 1 entitled, GEH Responses to GGNS NRC I & C RAIs (Proprietary), is identified by a dotted underline inside double square brackets. ((This sentence is an example.{3})). In each case, the superscript notation {3}

refers to Paragraph (3) of this affidavit that 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 GEH and/or 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, that may include potential products of GEH.
d. Information that discloses trade secret and/or potentially patentable subject matter for which it may be desirable to obtain patent protection.

Affidavit for GEH-GGNS-AEP-426 Affidavit Page 1 of 3 to GNRO-2011/00013 Page 2 of 3 (5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to the NRC in confidence. The information is of a sort customarily held in confidence by GEH, 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 results of an analysis performed by GEH to support the Grand Gulf Nuclear Station Extended Power Uprate (EPU) license application. This analysis is part of the GEH EPU methodology. Development of the EPU methodology and the supporting analysis techniques and information, and their application to the design, modification, and processes were achieved at a significant cost to GEH.

The development of the evaluation methodology along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a 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.

Affidavit for GEH-GGNS-AEP-426 Affidavit Page 2 of 3 to GNRO-2011/00013 Page 3 of 3 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 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 20th day of February 2011.

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 GEH-GGNS-AEP-426 Affidavit Page 3 of 3

Enclosure 3 GNRO-2011/00013 GEH Instrument Limits Calculation Average Power Range Monitor Power Range Neutron Monitoring System (NUMAC)-EPU Operation (Non-Proprietary Version) to GNRO-2011/00013 Page 1 of 25 Non-Proprietary Information GEH Instrument Limits Calculation Average Power Range Monitor Power Range Neutron Monitoring System (NUMAC)-EPU Operation Please note that this document refers to APRM High Flux Scram and APRM Flow-Biased Scram as APRM Neutron Flux Scram and APRM Flow-Biased Simulated Thermal Power Scram, respectively.

The GEH Instrument Limits Calculation begins on the next page.

to GNRO-2011/00013 Page 2 of 25 Non-Proprietary Information Instrument Limits Calculation Entergy Operations, Inc.

Grand Gulf Nuclear Station Average Power Range Monitor Power Range Neutron Monitoring System (NUMAC)-EPU Operation Contents:

This document is a supplement analysis data sheet to Reference 1. Included in this document in sequential order are:

x The setpoint functions for the system, x The setpoint function analyses inputs and the source reference of the inputs, x The devices in the setpoint function instrument loop, x The component analysis inputs and input sources, x The calculated results, x Input comments and result recommendations (if any),

x References.

System: Average Power Range Monitor (APRM)

The following setpoint functions are included in this document:

x APRM Flow-Biased Simulated Thermal Power (STP) Scram with Clamp (TLO) x APRM Flow-Biased STP Rod Block with Clamp (TLO) x APRM Flow-Biased STP Scram (SLO) x APRM Flow-Biased STP Rod Block (SLO) x APRM Neutron Flux Scram x APRM Setdown Scram x APRM Setdown Rod Block x APRM Downscale Rod Block to GNRO-2011/00013 Page 3 of 25 Non-Proprietary Information

1. Function: Flow-Biased STP Scram, Flow-Biased Rod Block, Neutron Flux Scram, Setdown Scram, Setdown Rod Block and Downscale Rod Block Setpoint Characteristics: Definition Comments Limiting event for the setpoint:

Scram:

x The APRM Flow Biased STP scram setpoint function is designed to protect against slow reactivity transients x The neutron flux-high scram function protects against Event Protection: fast reactivity transients.

x The APRM setdown scram setpoint function provides a redundant scram (in addition to IRM) for reactivity transients in the startup mode.

Rod Block:

x The APRM Flow Biased STP rod block function Ref. 2 prevents operation significantly above licensed power level; (Sections 3.20, the function precedes a flow-biased scram. 3.21) x The APRM setdown rod block setpoint function provides a redundant rod block (in addition to IRM) for reactivity transients in the startup mode.

x The APRM downscale rod block function provides indication of instrument failure or insensitivity and assures proper overlap between the neutron monitoring systems.

Function After Earthquake Required Not Required Comment 6 Setpoint Direction:

APRM Flow Biased STP Scram (TLO) Increasing Decreasing APRM Flow Biased Increasing Decreasing STP Rod Block (TLO)

APRM Flow Biased Increasing Decreasing STP Scram (SLO)

APRM Flow Biased Increasing Decreasing STP Rod Block (SLO)

APRM Neutron Flux Increasing Decreasing Scram APRM Setdown Scram Increasing Decreasing APRM Setdown Rod Block Increasing Decreasing Ref. 2 APRM Downscale (Sections Rod Block Increasing Decreasing 3.20, 3.21) to GNRO-2011/00013 Page 4 of 25 Non-Proprietary Information Setpoint Characteristics: Definition Comments Single or Multiple Channel x Upscale setpoints x Downscale Single Multiple setpoint Single Multiple Comment 27 LER Calculation Basis Standard (Conservative) LER Calculation or if Multiple Channel Configuration Specific LER Calculation Ref. 1, Ref. 2 Trip Logic for Configuration Specific LER Calculation n/a n/a: Not applicable LER: Licensee Event Report STP: Simulated Thermal Power SLO: Single Loop Operation TLO: Two Loop Operation to GNRO-2011/00013 Page 5 of 25 Non-Proprietary Information Plant Data: Value Sigma if not 2 Comments Flow Primary Element (Flow Elbow) a.) +/- 5% rated a.) Accuracy (APEA) Recirc Flow a.) Comment 30 b.) Drift (DPEA) b.) n/a b.) n/a Flow Process Measurement Accuracy (PMA) a.) +/- 1.6% rated a.) PMA (flow noise) Recirc Flow a.) Comment 15 b.) PMA (static head) b.) Negligible b.) Comment 23 Plant Data: Value Sigma if not 2 Comments Power Primary Element (LPRM Detector)

(% Power) a.) +/- 1%; bias 0.49%

a.) APEAAccuracy b.) Negligible b.) Ref 2 (Section b.) APEAPowerSupply Effect c.) +/- 0.2%/ 7days; 4.5.3); Comment 16 c.) DPEA bias 0.33 %/ 7days Power Process Measurement Accuracy (PMA)

(% Power) a.) Tracking (fixed and flow-biased) a.) +/- 1.11%

b.) Noise (STP) b.) +/- 0.0% b.) Comment 13 c.) Noise (neutron flux) c.) +/- 2.0% c.) Comment 13 Components (or Devices) in Setpoint Function Instrument Loop:

x Flow Element x LPRM Detector x Flow Transmitter x Nuclear Measurement Analysis and Control (NUMAC) Chassis:

x Instrument Loop Flow Electronics (Recirculation Flow Monitor System) x Instrument Loop Power Electronics (LPRM, APRM, Trip Circuit) to GNRO-2011/00013 Page 6 of 25 Non-Proprietary Information 1.1 APRM Flow Biased Simulated Thermal Power Scram (TLO)

Value/Equation Value/Equation Comments Function Limits: PRNMS-CLTP PRNMS-EPU

(% RTP) (% RTP)

Analytical Limit n/a n/a Comment 20 0.65 Wd + 62.9 0.58 Wd + 59.1 Tech Spec Allowable Value clamped at 113 clamped at 113 Comment 22 0.65 Wd + 60.9 Results in Nominal Trip Setpoint clamped at 111.0 Section 3 100 (at 77.0% 100 (at 92.8%

Operational Limit Recirc flow rate) Recirc flow rate) Comment 18 1.2 APRM Flow Biased Simulated Thermal Power Rod Block (TLO)

Value/Equation Value/Equation Comments Function Limits: PRNMS-CLTP PRNMS-EPU

(% RTP) (% RTP)

Analytical Limit n/a n/a Comment 20 0.65 Wd + 59.9 0.58 Wd + 56.1 Tech Spec Allowable Value clamped at 110 clamped at 110 Comment 22 0.65 Wd + 57.9 Results in Nominal Trip Setpoint clamped at 108.0 Section 3 Operational Limit n/a n/a Comment 3 to GNRO-2011/00013 Page 7 of 25 Non-Proprietary Information 1.3 APRM Flow Biased Simulated Thermal Power Scram (SLO)

Value/Equation Value/Equation Comments Function Limits: PRNMS-CLTP PRNMS-EPU

(% RTP) (% RTP)

Analytical Limit n/a n/a Comment 20 Tech Spec Allowable Value 0.65Wd + 42.3 0.58 Wd + 37.4 Comment 22 Results in Nominal Trip Setpoint 0.65 Wd + 38.8 Section 3 Operational Limit n/a n/a Comment 19 1.4 APRM Flow Biased Simulated Thermal Power Rod Block (SLO)

Value/Equation Value/Equation Comments Function Limits: PRNMS-CLTP PRNMS-EPU

(% RTP) (% RTP)

Analytical Limit n/a n/a Comment 20 Tech Spec Allowable Value 0.65 Wd + 39.3 0.58 Wd + 34.4 Comment 22 Results in Nominal Trip Setpoint 0.65 Wd + 35.8 Section 3 Operational Limit n/a n/a Comment 3 to GNRO-2011/00013 Page 8 of 25 Non-Proprietary Information 1.5 APRM Neutron Flux Scram Value/Equation Value/Equation Comments Function Limits: PRNMS-CLTP PRNMS-EPU

(% RTP) (% RTP)

Analytical Limit 122 122 Results in Ref. 4.1 (Table 3.3.1.1-1);

Tech Spec Allowable Value 120 Section 3 Comment 22 Results in Ref. 4.2 (Table TR3.3.1.1-1);

Nominal Trip Setpoint 118 Section 3 Comment 22 100 (at 77.0% 100 (at 92.8%

Operational Limit Recirc flow rate) Recirc flow rate) . Comment 21 1.6 APRM Setdown Scram Value/Equation Value/Equation Comments Function Limits: PRNMS-CLTP PRNMS-EPU

(% RTP) (% RTP)

Analytical Limit n/a n/a Comment 20 Ref 4.1 (Table 3.3.1.1-1);

Tech Spec Allowable Value 20 20 Comment 22 Results in Ref 4.2 (Table TR3.3.1.1-1);

Nominal Trip Setpoint 15 Section 3 Comment 22 Operational Limit 12 12 Comment 28 to GNRO-2011/00013 Page 9 of 25 Non-Proprietary Information 1.7 APRM Setdown Rod Block Value/Equation Value/Equation Comments Function Limits: PRNMS-CLTP PRNMS-EPU

(% RTP) (% RTP)

Analytical Limit n/a n/a Comment 20 Ref 4.2 (Table TR3.3.2.1-2);

Tech Spec Allowable Value 14 14 Comment 22 Ref 4.2 (Table Results in TR3.3.2.1-2);

Nominal Trip Setpoint 12 Section 3 Comment 22 Operational Limit n/a n/a Comment 3 1.8 APRM Downscale Rod Block Value/Equation Value/Equation Function Limits: PRNMS-CLTP PRNMS-EPU

(% RTP) (% RTP) Comments Analytical Limit n/a n/a Comment 20 Ref 4.2 (Table TR3.3.2.1-2);

Tech Spec Allowable Value 3 3 Comments 22, 27 Ref 4.2 (Table Results in TR3.3.2.1-2);

Nominal Trip Setpoint 4 Section 3 Comment 22 Operational Limit n/a n/a Comment 3 CLTP: Current Licensed Thermal Power n/a: Not applicable RTP: Rated Thermal Power Wd: % Recirculation drive flow, may also be referred to as W or WD to GNRO-2011/00013 Page 10 of 25 Non-Proprietary Information

2. Components:

2.1 Flow Transmitter Component Information: Value/Equation Comments 1B33 N014A-D, Plant Instrument ID No. 1B33 N024A-D Instrument vendor Rosemount Model ID No. (including Range Code) 1152DP5N Plant Location(s) Containment Building, el. 133 Process Element Flow elbow (No component ID available)

Inputs:

Vendor Specifications Value / Equation Sigma if not Comments 2

Top of Scale 430.3 InWC (20mA) Ref. 5.6 (Step 5.4.10)

Bottom of Scale 0 InWC (4mA) Ref. 5.6 (Step 5.4.10)

Upper Range Limit 750 InWC Ref 6.6 Accuracy +/- 0.25% Span Ref 6.6

+/- (0.5% URL + 0.5%

Temperature Effect Span) per 100ºF Ref 6.6 r 0.25% URL during and after 3g over range of 5-100 Hz in Seismic Effect 3 major axes Ref 6.6 r 8% URL during and after 5 x 106 Rads TID of gamma radiation at 0.4 Radiation Effect Mrad/hr Ref 6.6 Humidity Effect Included in accuracy Ref 6.6

+/- 0.005% of output Power Supply Effect span per volt Ref 6.6 RFI/EMI Effect negligible Ref 6.6; Comment 4 Insulation Resistance Effect negligible Ref 6.6; Comment 4 r 1% URL after 2000 Over-pressure Effect psig Ref 6.6 a.) +/- 0.25% URL per Static Pressure Effect 2000 psi a.) Random zero effect b.) +/- 0.25% input b.) Random span effect reading per 1000 (Correction uncertainty) psi c.) Bias span effect c.) n/a Ref 6.6 Mounting Position Effect a.) Zero Shift a.) Up to 1 InH20 b.) Span Effect b.) None Ref 6.6 to GNRO-2011/00013 Page 11 of 25 Non-Proprietary Information 2.1 Flow Transmitter (contd)

Plant Data: Value Sigma if not Comments 2

Ref 5.2 (Table 1, Areas 1A311, Calib Temperature Range 60 to 105 ºF 1A313)

Ref 5.2 (Table 1, Areas 1A311, Normal Temperature Range 60 to 105 ºF 1A313)

Trip Temperature range 60 to 105 ºF Comment 24 Plant seismic value n/a Comment 6 Ref 5.2 (Table 1, Areas 1A311, Plant Radiation value negligible 1A313); Comment 25 Ref 5.2 (Table 1, Areas 1A311, Plant Humidity value 20 to 90% 1A313)

Power Supply Variation value +/- 0.9 Vdc RFI/EMI value negligible Over-pressure value 1100 psig Static Pressure value 1060 psig Vdc: DC voltage Drift: Value Sigma if not 2 Comments Ref 4.1 (SR 3.3.1.17);

Current Calib. Interval 18 mo. Includes extra 25% n/a Comment 29 Desired Calib. Interval 24 mo. Includes extra 25% n/a Drift Source Vendor Calculated n/a Ref 6.6 Ref 6.6; Ref 1, Ref 2 Drift Value r 0.2% URL / 30 months Comment 7 to GNRO-2011/00013 Page 12 of 25 Non-Proprietary Information 2.1 Flow Transmitter (contd)

Calibration: Value / equation Sigma if not 3 Comments As Left Tolerance (ALT) +/- 0.25% Span (+/- 0.04 mA)

Leave Alone Tolerance (LAT) =ALT Input Calibration Tool: Wallace & Tiernan Model 65-120 n/a Ref 5.4

+/- 1.075 inWC(= 0.13% of Full Ref. 5.6 (Step 3.3)

Accuracy Scale; Full Scale=850 inWC) Ref 5.4 Resolution / Readability 0.5 inWC Comment 26 Minor Division 1 inWC Upper Range n/a Temperature Effect negligible Ref 5.4 Input Calibration Mensor model 8100 quartz Standard: pressure calibrator n/a Ref 5.4a

=1/4 input calibration tool Accuracy accuracy Comment 8 Resolution / Readability Minor Division Upper Range Temperature Effect Output Calibration Tool: Fluke model 45 Multimeter n/a Ref 5.7 Ref 5.6 (Step 3.2; Accuracy +/- 0.04 mA Ref 5.7 (Pg 1-9)

Ref 5.7 (Pg 1-9);

Resolution / Readability 0.005 Comment 26 Minor Division n/a Upper Range n/a Ref 5.7 (Pg 1-4);

Temperature Effect Included in accuracy Comment 4 Output Calibration Standard: Fluke model 5700A Calibrator n/a Ref 5.7a

=1/4 output calibration tool Comment 8 Accuracy accuracy Ref 5.7a (Pg 1-23)

Resolution / Readability Minor Division Upper Range Temperature Effect Application Specific Input: Value Sigma if not 2 Comments n/a to GNRO-2011/00013 Page 13 of 25 Non-Proprietary Information 2.2 Flow Electronics (Recirculation Flow Monitor System)

Component Information: Value/Equation Comments Plant Instrument ID No. Undefined Comment 2 Instrument vendor GEH Model ID No. (including Range Code) NUMAC Plant Location(s) Control Room area, El 166-0; Control cabinet area, El 190-0 Ref 5.2 (Table 1)

Process Element n/a Inputs:

Vendor Specifications Value / Equation Sigma if not 2 Comments Top of Scale FS = 125% loop flow n/a Bottom of Scale 0% loop flow n/a Upper Range Limit n/a n/a r 0.122 mAdc (where 16 mAdc input span from Accuracy FT corresponds to 125% flow) Comment 9 Temperature Effect included in accuracy Seismic Effect included in accuracy Comment 4 Comment 4, Comment Radiation Effect included in accuracy 10 Humidity Effect included in accuracy Comment 4 Power Supply Effect included in accuracy Comment 4 RFI/EMI Effect negligible Comment 4 Insulation Resistance Effect negligible Comment 4 Over-pressure Effect n/a Comment 5 Static Pressure Effect n/a Comment 5 to GNRO-2011/00013 Page 14 of 25 Non-Proprietary Information 2.2 Flow Electronics (contd)

Plant Data: Value Sigma if not 2 Comments Calib Temperature Range 60 to 90 ºF n/a Ref 5.2 (N-028 Data Sheet)

Normal Temperature Range 60 to 90 ºF n/a Ref 5.2 (N-028 Data Sheet)

Trip Temperature range 60 to 90 ºF n/a Ref 5.2 (N-028 Data Sheet)

Plant seismic value n/a n/a Comment 6 Plant Radiation value 1.8 E2 Rad TID n/a Ref 5.2 (N-028 Data Sheet)

Plant Humidity value 20 to 50% n/a Ref 5.2 (N-028 Data Sheet)

Power Supply Variation value +/- 0.9 Vdc n/a RFI/EMI value negligible n/a Over-pressure value n/a n/a Comment 5 Static Pressure value n/a n/a Comment 5 Drift: Value Sigma if not 2 Comments Ref 4.1 (SR 3.3.1.10);

Current Calib. Interval 184 days Includes extra 25% n/a Comment 29 Desired Calib. Interval 24 mo. Includes extra 25% n/a Drift Source Vendor Calculated n/a Ref. 1; Ref. 2 Drift Value Not specified; (( )) Ref. 1 (Section 3.3);

x (% rated drive flow) = r 0.122 mAdc / 6 months Ref. 2 to GNRO-2011/00013 Page 15 of 25 Non-Proprietary Information 2.2 Flow Electronics (contd)

Calibration: Value / equation Sigma if not 3 Comments As Left Tolerance (ALT) n/a Leave Alone Tolerance (LAT) n/a Input Calibration Tool: Internal to NUMAC n/a Accuracy r (1.1)*0.192% units on 125% scale Comment 14 Resolution / Readability included in accuracy Minor Division included in accuracy Upper Range 125% n/a Temperature Effect included in accuracy Input Calibration Standard: included in calibration tool Accuracy n/a Resolution / Readability n/a Minor Division n/a Upper Range n/a Temperature Effect n/a Output Calibration Tool: n/a Accuracy Resolution / Readability Minor Division Upper Range Temperature Effect Output Calibration Standard: n/a Accuracy Resolution / Readability Minor Division Upper Range Temperature Effect Application Specific Input: Value Sigma if not 2 Comments n/a to GNRO-2011/00013 Page 16 of 25 Non-Proprietary Information 2.3 Power Electronics (LPRM, APRM, Trip Circuit)

Component Information: Value/Equation Comments Plant Instrument ID No. Undefined Comment 2 Instrument vendor GEH Model ID No. (including Range Code) NUMAC Control Room area, El 166-0; Plant Location(s) Control cabinet area, El 190-0 Ref 5.2 (Table 1)

Local Power Range Monitor (LPRM) Neutron Process Element detector Inputs:

Vendor Specifications Value / Equation Sigma if not 2 Comments Top of Scale FS = 125% n/a Bottom of Scale 0% n/a Upper Range Limit n/a n/a Accuracy

  • LPRM Electronics +/- 0.943% (% local power)

Temperature Effect included in accuracy Seismic Effect included in accuracy Comment 4 Comment 4, Comment Radiation Effect included in accuracy 10 Humidity Effect included in accuracy Comment 4 Power Supply Effect (Detector) See APRM PEA RFI/EMI Effect negligible Comment 4 Insulation Resistance Effect negligible Comment 4 Over-pressure Effect n/a Comment 5 Static Pressure Effect n/a Comment 5 2.3 Power Electronics (LPRM, APRM, Trip Circuit) (contd)

Plant Data: Value Sigma if not 2 Comments Calib Temperature Range 60 to 90 ºF n/a Ref 5.2 (N-028 Data Sheet)

Normal Temperature Range 60 to 90 ºF n/a Ref 5.2 (N-028 Data Sheet)

Trip Temperature range 60 to 90 ºF n/a Ref 5.2 (N-028 Data Sheet) to GNRO-2011/00013 Page 17 of 25 Non-Proprietary Information Plant seismic value n/a n/a Comment 6 Plant Radiation value 1.8 E2 Rad TID n/a Ref 5.2 (N-028 Data Sheet)

Plant Humidity value 20 to 50% n/a Ref 5.2 (N-028 Data Sheet)

Power Supply Variation value +/- 0.9 Vdc n/a RFI/EMI value negligible n/a Over-pressure value n/a n/a Comment 5 Static Pressure value n/a n/a Comment 5 Drift: Value Sigma if not 2 Comments Ref. 4.1 (SR 7 days Includes 3.3.1.1.2);

Current Calib. Interval extra 25% n/a Comment 29 7 days Includes Ref. 4.1 (SR Desired Calib. Interval extra 25% n/a 3.3.1.1.2)

Drift Source Vendor Calculated n/a Ref. 1, Ref. 2 Drift Value

(% power) r 0.5% FS / 700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> to GNRO-2011/00013 Page 18 of 25 Non-Proprietary Information 2.3 Power Electronics (LPRM, APRM, Trip Circuit) (contd)

Calibration: Value / equation Sigma if not 3 Comments Included in APRM calibration As Left Tolerance (ALT) AGAF Comment 11 Ref 4.1 (SR 3.3.1.1.2);

Leave Alone Tolerance (LAT) = ALT Comment 11 Input Calibration Tool: n/a Comment 11 Accuracy Resolution / Readability Minor Division Upper Range Temperature Effect Input Calibration Standard: n/a Comment 11 Accuracy Resolution / Readability Minor Division Upper Range Temperature Effect Output Calibration Tool: n/a Comment 11 Accuracy Resolution / Readability Minor Division Upper Range Temperature Effect Output Calibration Standard: n/a Comment 11 Accuracy Resolution / Readability Minor Division Upper Range Temperature Effect Application Specific Input: Value Sigma if not 2 Comments Minimum no. of LPRMs per APRM Channel 21 of 44 n/a APRM Gain Adjustment Factor Ref 4.1 (SR (AGAF) r 2% RTP 3 3.3.1.1.2) to GNRO-2011/00013 Page 19 of 25 Non-Proprietary Information

3. Summary Results:

Calculated Values

- Meets Setpoint Analytical Allowable Value Spurious Function Limit (AL) (AV) Nominal Trip Meets LER Trip (from Section 1) (from Section 1) Setpoint (NTSP) Avoidance Avoidance

%RTP %RTP %RTP Criteria Criteria APRM Flow Biased STP 0.58 Wd + 59.1 0.58 Wd + 57.1 Scram (TLO) n/a clamped at 113 clamped at 111.0 Y Y APRM Flow Biased STP Rod 0.58 Wd + 56.1 0.58 Wd + 54.1 Block (TLO) n/a clamped at 110 clamped at 108.0 Y n/a APRM Flow Biased STP Scram (SLO) n/a 0.58 Wd + 37.4 0.58 Wd + 34.3 Y n/a APRM Flow Biased STP Rod Block (SLO) n/a 0.58 Wd + 34.4 0.58 Wd + 31.3 Y n/a APRM Neutron Flux Scram 122 119.3 117.3 Y Y APRM Setdown Scram n/a 20 18 Y Y APRM Setdown Rod Block n/a 14 12 Y n/a APRM Downscale Rod Block n/a 3 5 Y n/a Wd: % Recirculation drive flow n/a: Not applicable Y: Yes Application Specific Setpoint Adjustments APRM Flow Biased STP Scram Nominal Trip Setpoints (NTSPs):

x Two Loop Operation (TLO): 0.58 Wd + 57.1 %RTP clamped at 111.0 %RTP x Single Loop Operation (SLO): 0.58 Wd + 34.3 %RTP where Wd is defined as the % Recirculation drive flow; 92.8% drive flow is that required to achieve 100% core power and flow at EPU. The TLO to SLO Setting adjustment, SLOSettingAdj, is found as indicated below:

Calculated TLO to SLO Setting Function Adjustment Reference TLO to SLO Setting Adjustment for SLOSettingAdj =

NUMAC setpoints 39.4% Comment 12 to GNRO-2011/00013 Page 20 of 25 Non-Proprietary Information

4. Comments and Recommendations:
1. Unless specifically identified as bias errors in this document, all instrument uncertainty errors will be considered to be random in nature, even when the r symbol is not shown.
2. Some plant specific information has not been provided or is not currently available in the current GGNS documentation, but is considered unnecessary because the effects of this information are included within the instrument accuracy values or are not necessary for setpoint evaluation.
3. STA evaluations are not performed for rod blocks or permissives per GEH setpoint methodology (References 1 and 2), such as the APRM Rod Blocks. Therefore, the Operational Limits (OLs) are not applicable.
4. Seismic effect, radiation effect, humidity effect, power supply effect, Radio Frequency Interference / Electromagnetic Interference (RFI/EMI) effect, and insulation resistance effect errors are marked negligible or included in accuracy and are considered to have negligible impact on the manufacturers accuracy terms if they are not identified separately. Temperature effect of the Output Calibration Tool is assumed to be included in the accuracy as specified for the Input Calibration Tool.
5. Per References 1 and 2, overpressure effects are applicable only to pressure measurement devices (e.g., differential pressure transmitters), and static pressure effects are applicable only to differential pressure measurement devices. These effects are marked n/a for other devices or not considered.
6. The APRM Flow Biased Simulated Thermal Power, Setdown and Downscale setpoint functions are not safety related. Therefore, they are not required to function after a seismic event. Thus, the Seismic Effect for the flow transmitters and associated electronics is not considered.
7. The current approach in GEH setpoint calculation methodology treats the Flow Transmitter drift for this instrument to be a 2-sigma value.
8. The error of the calibration standard used to calibrate a calibration tool will not exceed 1/4 of the error associated with the calibration tool. Temperature effects and readability errors need not be considered for calibration standards.
9. The accuracy of the flow electronics is not given in the NUMAC specifications, and [

] The combined error for the loop flow electronics is +/- 0.122 mA at 2V.

10. The NUMAC electronics are located in the Control Room or Control Room area at GGNS, where the radiation dose is expected to be within equipment qualification requirements as indicated by Ref. 5.2 (Area N-028) to GNRO-2011/00013 Page 21 of 25 Non-Proprietary Information
11. The APRM subsystem is calibrated on-line weekly (Reference 4.1) using the AGAF process, where the gain of the APRMs is adjusted to read the Core Thermal Power determined by the Process Computer, within a specified As Left Tolerance. [

)). Thus, the only calibration error to consider for the APRM electronics sub-loop is the As Left Tolerance specified by the AGAF process.

12. ((

] As indicated in Section 3, the NTSP for TLO is 0.58 Wd + 57.1 %, indicating an intercept of 57.1 %. The NTSP for SLO, 0.58 Wd + 34.3%, has an intercept of 34.3%. [

]. The resulting TLO to SLO setting adjustment is 39.31. Because the Setting Adjustment is programmed into the NUMAC equipment to one decimal place, each calculated number is rounded up to one decimal place for conservatism. This adjustment may be used in the implementation of the new NUMAC equipment.

13. The neutron noise value is not applied to the APRM flow-biased setpoints because they are based on an STP signal. The high neutron flux scram in Run and Setdown modes is based on the neutron flux signal; the rod block is based on the STP signal. The neutron noise value is conservatively applied to the Setdown rod block as well as the Setdown scram setpoint evaluation.
14. Complete inputs are unavailable for the Flow Electronic calibration errors for all Maintenance and Testing Equipment (M&TE) to be used at GGNS. Therefore, the Flow Electronics calibration errors are based on using errors that are 10% higher than the errors for assumed calibration tools. Moreover, the error of the calibration standard used to calibrate a calibration tool is conservatively assumed to be equal to the error of the calibration tool.
15. For the flow noise PMA, a typical value of r1% rated Recirc flow can be used.

However, several plants were evaluated, some with Recirculation System flow elements being a venturi, and some being a flow elbow. Grand Gulf Nuclear Station has flow elbows, so the largest number for a plant with flow elbows was used, rounded up to one decimal place for conservatism.

16. ((

)) (Reference 2 Section 4.5.3)

17. Not used.

to GNRO-2011/00013 Page 22 of 25 Non-Proprietary Information

18. The Operational Limit in the non-clamped region is determined by maintaining the same margin between the NTSP at the intercept point and OL as between the NTSP and OL in the clamped region.
19. An STA evaluation is not performed for single loop operation due to the rarity of plant operation in this configuration; thus, the OL is not applicable.
20. The APRM Flow Biased Simulated Thermal Power scram and rod block (TLO and SLO) functions do not provide a safety function after installation of the PRNMS. Also, the Setdown scram and rod block and Downscale functions are not safety related.

Thus, an Analytical Limit is not applicable and the Nominal Trip Setpoint is calculated based on the Allowable Value.

21. The Operational Limit is the same as that used for the clamped region of the Flow-Biased STP scram.
22. The Tech Spec Allowable Value may be retained in the Technical Specifications or a supporting document such as the Core Operating Limits Report. The calculations were performed based on the AV point values indicated; a  or  sign typically accompanies the values retained in licensing documentation.
23. For the static head portion of Flow PMA, installation of the differential pressure (dP) transmitter nozzle taps on the Recirculation pipes and instrument lines must be evaluated for a random error due to ambient temperature fluctuations in the section of instrument line producing a static head. This error is negligible if the static head difference for the dP measurement is less than 1 foot, and the high and low pressure instrument lines are routed close together). The static head difference for the taps is 16.8 inWC at room temperature. Consideration of system operating temperatures reduces the static head to less than 1 foot, thus, this error is considered to be negligible.
24. The Neutron Monitoring System performs its trip functions before accident temperatures are reached, so temperatures for trip and normal conditions are assumed to be the same.
25. Ref. 5.2 provides a Total Integrated Dose (TID) of 2.8 x 103 Rads for 40 yrs and dose rate of 0.008 Rad/hr gamma for Normal Environment N-028. These values are negligible in comparison to flow transmitter capability.
26. Readability of the analog Input Calibration Tool is based on 1/2 of minor division, which is more conservative than the actual 0.02% full-scale value. Readability of the digital Output Calibration Tool (Ref. 5.7) is based on three digits after decimal on range used, but conservatively assumes staff does not use last decimal.
27. The APRM Downscale Rod Block provides an indication of equipment function and overlap of neutron monitoring systems. Because it provides indication of channel function, a single channel configuration is assumed in the setpoint calculation. The AV for the Downscale Rod Block is an operational choice to detect a malfunctioning APRM and is generally conservatively selected. As such, the AV is anticipated not to change with EPU.

to GNRO-2011/00013 Page 23 of 25 Non-Proprietary Information

28. For the APRM Setdown Scram, the Operational Limit was set equal to the NTSP for the APRM Setdown Rod Block. This ensures that a Rod Block occurs prior to reaching a Scram for the setdown function.
29. The current calibration interval refers to CLTP values prior to PRNMS installation.

For EPU, the desired calibration interval was used in the setpoint calculation for all functions considered in this evaluation.

30. The flow elbow PEA is estimated for use in this calculation based on generally accepted references and experience, as a GGNS plant-specific value is not available.
31. Transfer functions used in this calculation:

Flow Transmitter: Output (mA) linearly converted from input (InWC).

Flow Electronics: Output proportional to the square root of the two inputs, which are then summed.

Power Electronics: Output is proportional to the average of the inputs and a comparison of the APRM signal with the flow-biased reference is made.

to GNRO-2011/00013 Page 24 of 25 Non-Proprietary Information

5.

References:

1. NEDC-32889P, General Electric Methodology for Instrumentation Technical Specification and Setpoint Analysis, Rev. 3, Class 3 (Proprietary), November 2002
2. NEDC-31336P-A, General Electric Instrument Setpoint Methodology, Class 3 (Proprietary), September 1996
3. Current applicable Grand Gulf Nuclear Station setpoint calculations:

3.1. Not used

4. Grand Gulf Nuclear Station Licensing and related documents:

4.1. Grand Gulf Nuclear Station Technical Specifications, as revised through Facility Operating License Amendment 182 4.2. Grand Gulf Nuclear Station Technical Requirements Manual, as revised through as revised through Facility Operating License Amendment 182

5. Applicable Grand Gulf Nuclear Station procedures/documents:

5.1. Not used 5.2. GGNS-E-100, System Energy Resources, Inc. Grand Gulf Nuclear Station Environmental Parameters for GGNS Safety Related, Rev. 6, 04/23/08 5.3. Not used 5.3a Not used 5.4. Vendor Manual 460001012, Wallace & Tiernan Portable Pneumatic Calibrator, Series65-120, 06/26/95 5.4a. Vendor Users Manual PN 0017108001A, Mensor 8100 Quartz Pressure Calibrator, March 2001 5.5. Not used 5.6. Surveillance Procedure 06-IC-1C51-R-0075, APRM Recirculation Flow Transmitter Calibration, Rev 103, 03/08/07 5.7. Vendor Service Manual 460003671, Fluke Model 45 Multimeter, July 1989 5.7a Vendor Operator Manual 460003696, Fluke 5700A Calibrator, 02/8/89

6. Vendor Specifications:

6.1. Not used to GNRO-2011/00013 Page 25 of 25 Non-Proprietary Information 6.2. Not used 6.3. Not used 6.4. Not used 6.5. Not used 6.6. Rosemount Nuclear Product Data Sheet 00813-0100-4235, Rev. BA, Model 1152 Alphaline Nuclear Pressure Transmitter, April 2007 6.7. Not used

Retrieved from "https://kanterella.com/w/index.php?title=GNRO-2011/00013,_Request_for_Additional_Information_Regarding_Extended_Power_Uprate&oldid=2645261"