GNRO-2011/00044, Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System

Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System

ML111650148
Person / Time
Site:	Grand Gulf
Issue date:	06/13/2011
From:	Krupa M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2011/00044, TAC ME2531
Download: ML111650148 (10)

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) 437-6694 GNRO-2011/00044 June 13, 2011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531)

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCES:

1. Entergy Operations, Inc. letter to the NRC (GNRO-2009/00054),

License Amendment Request - Power Range Neutron Monitoring System Upgrade, November 3, 2009 (ADAMS Accession No. ML093140463)

2. NRC e-mail to Entergy Operations, Inc., GG Power Range Neutron Monitoring System Human Factors Branch Request for Additional Information (ME2531), May 12, 2011 (ADAMS Accession No. ML111320493)

Dear Sir or Madam:

In Reference 1, Entergy Operations, Inc. (Entergy) submitted to the NRC a license amendment request (LAR), which proposes to revise the Grand Gulf Nuclear Station (GGNS)

Technical Specifications (TS) to reflect the installation of the digital General Electric-Hitachi (GEH) Nuclear Measurement Analysis and Control (NUMAC) Power Range Neutron Monitoring (PRNM) System.

In Reference 2, the NRC staff transmitted five Requests for Additional Information (RAIs) to support their review and approval of Reference 1. Responses to these RAIs are provided in the attachment to this letter.

The No Significance Hazards Determination and the Environmental Consideration provided in Reference 1 are not impacted by these responses.

This letter contains no new commitments.

GNRO-2011/00044 Page 2 of 2 If you have any questions or require additional information, please contact Mr. Guy Davant at (601) 368-5756.

I declare under penalty of perjury that the foregoing is true and correct; executed on June 13, 2011.

Sincerely, MAK/ghd

Attachment:

Responses to NRC Requests for Additional Information Pertaining to License Amendment Request - Power Range Neutron Monitoring System Upgrade 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

bcc:

OUTLOOK MAIL: DISTRIBUTION IS ALL ELECTRONIC Adams, S. T. (W3-NSA)

Browning, J. G. (GG-GMPO)

Caery, J. V. (GG-TRNG)

Perito, M. (GG-VP)

Ford, B. S. (ECH-NS&L)

GGN CENTRAL FILE ( 660 )

GGN PLANT LICENSING Higginbotham, K. (GG-OPS)

Houston, J. L. (GG-MAINT)

James, D. E. (ANO-NSA)

Lewis, C.A. (GG-EP)

Lorfing, D. L. (RBS-PL)

McCann, J. F. (WP-VP)

Perino, C. L. (GG-PL)

Pyle, S. L. (ANO-PL)

Richey, M. L. (GG-NSA)

Roberts, J. C. (RBS-NSA)

Steelman, W. J. (W3-PL)

Wiles, D. P. (GG-ENG)

OTHER: File (LRS_DOCS Directory - GNRI or GNRO)

ATTACHMENT GNRO-2011/00044 RESPONSES TO NRC REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE

Attachment to GNRO-2011/00044 Page 1 of 6 RESPONSES TO NRC REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE By application dated November 3, 2009, Entergy Operations, Inc. (Entergy) requested NRC staff approval of a license amendment request (LAR) to the Grand Gulf Nuclear Station, Unit 1 (GGNS) Technical Specifications (TS) to reflect installation of the digital General Electric -

Hitachi (GEH) Nuclear Management Analysis and Control (NUMAC) Power Range Neutron Monitoring System (PRNMS).1 Entergy received an e-mail from the NRC GGNS Project Manager on May 12, 2011 requesting additional information from the Health Physics and Human Performance Branch needed to support their review and approval of the proposed amendment.2 Responses to these Requests for Additional Information (RAIs) are provided in this attachment.

NRC RAI 1 Changes in Emergency and Abnormal Operating Procedures (SRP Section 13.5.2.1):

a. Describe how the proposed LAR will change the plant emergency operating procedures (EOPs) or abnormal operating procedures (AOPs); i.e., will any operator actions specified in the EOPs or AOPs, (consistent with the generic emergency procedure guidelines/severe accident guidelines, EPGs/SAGs) be changed, or deleted?

b. Will any new operator actions be added to the EOPs or AOPs?

c. Are there other new or changed actions in non-EOP/AOP procedures that are high risk, such as a maintenance or surveillance procedure that includes new actions that could negatively affect Reactor Protection System functions if done incorrectly or if omitted?

Response

Each RAI item is addressed below.

a. Describe how the proposed LAR will change the plant emergency operating procedures (EOPs) or abnormal operating procedures (AOPs); i.e., will any operator actions specified in the EOPs or AOPs, (consistent with the generic emergency procedure guidelines/severe accident guidelines, EPGs/SAGs) be changed, or deleted?

The proposed LAR will not cause the revision of any Emergency Operating Procedure (EOP). The Grand Gulf Nuclear Station (GGNS) AOPs are called Off-Normal Operating Procedures (ONEPs). Only ONEP 05-1-02-III-3, Reduction in Recirculation System 1

Entergy Operations, Inc. letter to the NRC, License Amendment Request - Power Range Neutron Monitoring System Upgrade, dated November 3, 2009 (ADAMS Accession No. ML093140463) 2 NRC e-mail to Entergy Operations, Inc., GG Power Range Neutron Monitoring System Human Factors Branch Request for Additional Information (ME2531), May 12, 2011 (ADAMS Accession No. ML111320493)

Attachment to GNRO-2011/00044 Page 2 of 6 Flow Rate, is impacted by the Power Range Neutron Monitoring System (PRNMS) modification. ONEP 05-1-02-III-3 currently provides operators with instructions to follow if reactor recirculation flow is reduced to within certain power/flow regions defined in the Core Operating Limits Report (COLR).

The proposed LAR replaces the Option E-1-A stability solution with an Option III long-term stability solution. The NUMAC PRNM hardware incorporates the Oscillation Power Range Monitor (OPRM) Option III detect-and-suppress solution, which has been reviewed and approved by the NRC, as documented in GE Nuclear 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.

The OPRM meets General Design Criterion (GDC) 10, Reactor Design, and GDC 12, Suppression of Reactor Power Oscillations, requirements by automatically detecting and suppressing design basis thermal-hydraulic oscillations prior to exceeding the fuel Minimum Critical Power Ratio (MCPR) Safety Limit. With the exception of the initial OPRM Monitoring Period discussed in Section 3.3 of the PRNMS LAR, the PRNMS modification provides an automatic scram via the OPRM Upscale trip function.

Operator actions specified in ONEP 05-1-02-III-3 are being retained as backup stability protection measures to be implemented in the event of a loss of the OPRM Upscale trip function.

b. Will any new operator actions be added to the EOPs or AOPs?

As discussed in the response to RAI 1.a, above, the only EOP or ONEP impacted by the PRNMS LAR is ONEP 05-1-02-III-3. No new operator actions will be added to this procedure.

c. Are there other new or changed actions in non-EOP/AOP procedures that are high risk, such as a maintenance or surveillance procedure that includes new actions that could negatively affect Reactor Protection System functions if done incorrectly or if omitted?

Section 4.4.2 of the PRNMS LAR discusses changes to the Technical Specification surveillance requirements associated with the PRNMS modification. Due to the equipment upgrade and the revised surveillance requirements, several surveillance and maintenance procedures will require revision. As with any surveillance or maintenance procedure involving safety-related components, procedure steps that are done incorrectly or omitted could result in a negative impact. However, the PRNMS design facilitates the required surveillance testing; these tasks are within the skill and qualification level of the technicians performing the procedures. Instrument and Control (I&C) personnel will undergo detailed training on the equipment prior to performing any maintenance or surveillance activity. For these reasons, the risk of a human performance error resulting in a negative impact to the Reactor Protection System functions should not increase with the installation of PRNMS.

Attachment to GNRO-2011/00044 Page 3 of 6 NRC RAI 2 Changes to Operator Response Times:

a. Identify and describe EOP or AOP operator actions that will involve additional response time or will have reduced time available. Your response should address any operator workarounds that might affect these response times.

b. Identify any actions that are being changed from automatic to manual as a result of the upgrading to PRNMS.

c. Provide justification for the acceptability of any increase in time required or any reduction of time available for operators to complete EOP or AOP actions.

Response

Each RAI item is addressed below.

a. Identify and describe EOP or AOP operator actions that will involve additional response time or will have reduced time available. Your response should address any operator workarounds that might affect these response times.

The PRNMS change does not impact reactor operating parameters or the functional requirements of the Average Power Range Monitoring (APRM) system. The replacement equipment continues to provide information, enforce control rod blocks, and initiate reactor scrams under appropriate specified conditions. The proposed change does not reduce safety margins. The replacement APRM equipment has improved channel trip accuracy compared to the current analog system, and meets or exceeds system requirements previously assumed in setpoint analysis. Because PRNMS is an upgrade to the APRM system, no EOP or ONEP (AOP) operator actions are impacted by this modification. In addition, there are currently no operator workarounds associated with these safety functions and implementation of PRNMS will not introduce any new ones.

b. Identify any actions that are being changed from automatic to manual as a result of the upgrading to PRNMS.

As discussed in the response to RAI 1.a, above, the PRNMS modification provides an automatic action via the OPRM Upscale trip function. There are no current automatic actions being changed to manual due to this modification.

c. Provide justification for the acceptability of any increase in time required or any reduction of time available for operators to complete EOP or AOP actions.

As discussed in the response to RAI 2.a, above, no EOP or ONEP (AOP) operator actions involve additional response time nor do they have reduced time available.

Attachment to GNRO-2011/00044 Page 4 of 6 NRC RAI 3 Changes to Control Room Controls, Displays and Alarms (SRP Section 18.0):

Describe any controls, displays, alarms (other than those already described as part of the Response to NRC Request for Additional Information, dated 12/13/2010) that will be modified as a result of, or to support, the proposed LAR.

Response

The response to RAI 7 provided in the attachment to Entergy letter GNRO-2010/00075, dated December 13, 2010 (ADAMS Accession No. ML103480114), provides a comprehensive description of the changes to Control Room controls, displays, and alarms that will be modified as a result of the proposed LAR. One change not addressed in that response is the conversion of the APRM / IRM post-accident recorders on the 1H13-P680 panel from analog to digital. Not only will these recorders reduce the operator burden associated with changing chart paper, the digital display enhances the operators ability to obtain information quickly during a transient condition.

NRC RAI 4 Changes to the Safety Parameter Display System (SRP Section 18.0):

Describe any changes to the safety parameter display system resulting from the proposed LAR. How will the operators know of the changes?

Response

The safety parameter display system (SPDS) changes consist of modifying the existing SPDS Reactor Average Power Calculation validation algorithm to reduce the number of APRM channels from eight (8) to four (4). This change has minimal impact on the SPDS displays.

As with all other changes to operator interfaces, SPDS modifications are evaluated per Entergy procedure EN-TQ-201, Systematic Approach to Training Process. This process is discussed further in the response to RAI 5.a, below.

NRC RAI 5 Changes to the Operator Training Program and the Control Room Simulator (SRP Sections 13.2.1 and 13.2.2):

a. Describe any changes to the operator training program and the plant-referenced control room simulator resulting from the proposed LAR, and provide the implementation schedule for making the changes.

b. As determined by the training analysis process, will appropriate classroom, simulator and in-plant training be conducted prior to power escalation?

c. What administrative controls are in place to monitor the ongoing ability of GGNS operators to reliably perform critical actions identified during the training analysis?

Attachment to GNRO-2011/00044 Page 5 of 6

d. How will operators, maintainers, and other affected personnel be tested to assure that they can perform required actions correctly and reliably within expected quality and time constraints to support operation of the PRNMS?

Response

Each RAI item is addressed below.

a. Describe any changes to the operator training program and the plant-referenced control room simulator resulting from the proposed LAR, and provide the implementation schedule for making the changes.

Entergy procedure EN-TQ-201, Systematic Approach to Training Process, establishes the process for the systematic approach to training (SAT) used for the development, administration, and maintenance of accredited training programs at Entergys nuclear facilities. Per this procedure, Entergy is currently conducting the needs analysis for PRNMS changes. This needs analysis process provides the means to address any knowledge and skill deficiencies associated with changes to equipment, and will result in appropriate updates and changes to training program materials (e.g., lesson plans, job performance measures, and simulator scenarios).

Physical changes to the plant reference simulator include:

• Replacing two existing APRM bypass switches (joysticks) on the simulator main operator console (1H13-P680) with a single mechanical fiber optic bypass switch;

• Replacing recorders 1C51-R603A, B, C, D with newer models;

• Updating or deleting various annunciator window tiles, status lights, and computer points per the modification package; and

• Installing one NUMAC PRNMS back-panel that requires interfacing with the simulator software.

These changes are comparable to those occurring in the plant control room as described in Entergy letter GNRO-2010/00075 (ADAMS Accession No. ML103480114).

PRNMS hardware changes in the plant reference simulator are currently scheduled to be installed in December 2011, with operator simulator training to follow early in 2012.

Simulator training is planned to begin prior to the EPU installation outage, and continue during requalification training scheduled during the installation outage. Classroom training for PRNMS is expected to begin in the fourth quarter 2011 prior to the simulator updates.

b. As determined by the training analysis process, will appropriate classroom, simulator, and in-plant training be conducted prior to power escalation?

Yes, as discussed in the response to RAI 5.a, above, appropriate training will be conducted in both the classroom and simulator prior to power escalation.

Attachment to GNRO-2011/00044 Page 6 of 6

c. What administrative controls are in place to monitor the ongoing ability of GGNS operators to reliably perform critical actions identified during the training analysis?

As stated in the response to RA 5.a., above, Entergy procedure EN-TQ-201 establishes the process for the SAT used for the development, administration, and maintenance of accredited training programs at Entergy nuclear facilities. Per this procedure, a training department client / server application, known as the Training Evaluation and Action Request (TEAR) database, is utilized to provide tracking and control of changes to training programs and training material. This application provides the documentation of the needs analysis process performed when evaluating training change items. A separate database, referred to as the Learning Management System, contains a schedule of training sessions for all accredited training programs, supervisor training, General Employee Training, Plant Access Training, and Emergency Planning training.

The Learning Management System is utilized as the only acceptable method for determining the qualification status of individual workers.

d. How will operators, maintainers, and other affected personnel be tested to assure that they can perform required actions correctly and reliably within expected quality and time constraints to support operation of the PRNMS?

Entergy procedure EN-TQ-212, Conduct of Training and Qualification, provides a summary of the roles and responsibilities of workers, line management, and training personnel for the conduct of training and qualification activities within Entergy. Per this procedure, Entergy employees and supplemental personnel independently perform only those tasks or jobs that they are qualified to perform. Training program owner approval is required before an individual is qualified to independently perform a task or function.

This includes tasks, positions or duty areas for which formal training and qualification requirements have been established. A training program owner indicates this approval by granting qualifications to individuals based on the completion of established training and evaluation activities. All changes to the formal training and qualification program developed as a part of the ongoing needs analysis, discussed in the response to RAI 5.a., above, will result in new training and testing.

The timeline for operator training is discussed in the response to RAI 5.a, above.

Training for maintainers (I&C technicians) and other personnel is expected to occur following factory acceptance testing at General Electric-Hitachis (GEH) facility, and in the plant reference simulator after delivery and installation of the NUMAC PRNMS back-panel. Some introductory training has already been provided to personnel by GEH at GGNS.