ML093140463
| ML093140463 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/03/2009 |
| From: | Krupa M Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GNRO-2009-00054 | |
| Download: ML093140463 (159) | |
Text
Enteigy Entergy Operations, Entergy P. O.
P.
Port
- 0. Box Operations, Inc.
Box 756 756 Port Gibson, Gibson, MS MS 39150 39150 Inc .
Michael A.
Michael A. Krupa Krupa Director, Extended Director, Extended Power Power Uprate Uprate Grand Gulf Grand Gulf Nuclear Nuclear Station Station Tel. (601)
Tel. (601) 437-6684 437-6684 Attachment 55 contains Attachment contains PROPRIETARY PROPRIETARY informationinformation GNRO-2009-00054 GNRO-2009-00054 November November 3, 2009 3, 2009 u.s. Nuclearleer Regulatory Regulatory Commission Commission ATTN: Document ATTN: Document Control Control Desk Desk Washington, DC 20555 Washington, DC 20555 SUBJECT :
SUBJECT:
License License Amendment Amendment RequestRequest Power Range Neutron Power Range Neutron Monitoring Monitoring System System Upgrade Upgrade Grand Gulf Grand Gulf Nuclear Station, Unit Nuclear Station, Unit 11 Docket Docket No. No . 50-416 50-416 License License No. No. NPF-29 NPF-29 Dear Sir or
Dear Sir Madam :
or Madam:
Pursuant Pursuant to to 10 CFR 50.90, 10 CFR Entergy Operations, 50.90, Entergy Operations, Inc. Inc. (Entergy) proposes to (Entergy) proposes to revise revise the Grand the Grand Gulf Gulf Nuclear Nuclear Station (GGNS) Technical Station (GGNS) Technical Specifications Specifications (TS)(TS) to reflect the to reflect the installation installation of of the the digital General digital General Electric Electric -- Hitachi Hitachi (GEH)
(GEH) Nuclear Nuclear Measurement Analysis and Measurement Analysis Control (NUMAC) and Control (NUMAC)
Power Range Neutron Power Range Neutron Monitoring Monitoring (PRNM) System . The (PRNM) System. following TS The following TS (and (and associated associated TS TS Bases, Bases, ifif applicable) applicable) and and Operating License (OL)
Operating License (OL) sections are affected sections are affected byby this this change:
change :
0* OL Section OL Section 2.C(2),
2.C(2), Technical Technical Specifications Specifications
- 0 TS TS 11.1,
.1, Definitions Definitions
- 0 TS TS 3.2 3.2.4,.4, Fraction Fraction of Core Boiling of Core Boundary (FC88)
Boiling Boundary (FCBB)
I* TS TS 3.3.1 3.3.1.1, .1, Reactor Protection System Reactor Protection System (RPS)
(RPS) Instrumentation Instrumentation
System (PBDS)
- TS TS 33.10.8,
.10.8, Shutdown Shutdown MarginMargin (SDM)
(SDM) Test Test -- Refueling Refueling 0* TS TS 5.6.5, 5.6.5, CoreCore Operating Operating Limits Limits Report Report (COLR)
(COLR)
Entergy Entergy plans plans to to replace replace the the existing existing analog analog Average Average PowerPower Range Range Monitor Monitor (APRM)
(APRM) subsystem subsystem of of the the existing existing Neutron Neutron Monitoring Monitoring System System withwith the the more more reliable, reliable, digital digital NUMAC NUMAC PRNM PRNM System System duringduring thethe spring spring 2012 2012 refueling refueling outage.
outage. This This modification modification will simplify will simplify management management and and maintenance maintenance of of the the system system..
The The PRNM PRNM SystemSystem design design retrofit retrofit also also includes includes an an Oscillation Oscillation Power Power Range Range Monitor Monitor (OPRM)(OPRM) capability, capability, which which implements implements aa GEH GEH version version of of the the Boiling Boiling Water Water Reactor Reactor Owners' Owners' Group Group (BWROG)
(BWROG) Option Option IIIIII detect-and-suppress detect-and-suppress long-termlong-term reactor reactor core core stability stability solution solution When When Attach Attachment ent 55 is is removed removed from from Letter, Letter, Entire Entire Document Document is is NON-PROPRIEATRY NON-PROPRIEATRY
GNRO-2009-00054 GNRO-2009-00054 Page 22 Page methodology . The methodology. OPRIVI provides The OPRM provides automatic automatic detectiondetection and and suppression suppression of of reactor reactor thermal-hydraulic instabilities thermal-hydraulic instabilities through through monitoring monitoring neutron neutron fluxflux changes.
changes. This This license license amendment request amendment request (LAR)
(LAR) adds adds an an OPRM OPRM Upscale Upscale function function to to the the Reactor Reactor Protection Protection System System (RPS) Instrumentation TS, thereby implementing the Option III reactor stability solution . With (RPS) Instrumentation TS J thereby implementing the Option III reactor stability solution. With installation of installation of the the NUMAC NUMAC PRNM PRNM System,System, the the GGNS GGNS stability stability licensing licensing basis basis will will transition transition from Enhanced from Enhanced Option Option I-A I-A to Option III.
to Option 111 .
Following installation of Following installation of the NUMAC PRNM the NUMAC PRNM System, System, GGNS GGNS will will operate operate with the new with the new OPRM OPRM Upscale Upscale function function (TS(TS Table Table 3.3.1.1-1 3.3 .1 .1-1 Function Function 2.f) 2.f) inin an an "indicate "indicate only"only" mode for an initial mode for an initial monitoring monitoring period period forfor aa minimum minimum of of 9090 days days not not toto exceed exceed oneone fuel fuel cycle, cycle, as as discussed discussed in in the the LAR LAR.. GGNS GGNS will implement Backup will implement Backup Stability Stability Protection Protection (BSP)(BSP) measures measures specified specified in in BWROG BWROG document OG-02-0119-260, document OG-02-0119-260, GE GE to to BWROG BWROG Detect Detect and and Suppress Suppress II// Committee, Committee, ({Backup "Backup Stability Stability Protection Protection (BSP)(BSP) for for Inoperable Inoperable Option Option /// III Solution,"
Solution," as an alternate method for as an alternate method for detecting and detecting suppressing instabilities and suppressing instabilities until until the the OPRM OPRM Monitoring Monitoring Period Period hashas been been successfully completed . The successfully completed. The NRC NRC approved approved the the use use ofof the the BSP BSP measures measures for for the the alternate alternate method for method for Monticello Monticello as as documented documented in in its its Safety Evaluation .
Safety Evaluation.
Reactor Reactor stability compliance using stability compliance using this method relies this method relies upon upon operator operator action action to:to:
- 0 Avoid regions where Avoid regions where instability instability may may occur,occur, 0* Exit such regions Exit such regions whenwhen necessary, necessary, and and
- Detect Detect an an actual actual instability instability and and take mitigating action take mitigating action byby manual manual means.means .
Following review and Following review and evaluation evaluation of of operating operating data data fromfrom the the monitoring monitoring period,period, Entergy Entergy willwill enable the OPRM Upscale function . Details of the monitoring period are provided in the LAR enable the OPRM Upscale function. Details of the monitoring period are provided in the LAR..
Attachment 1 provides provides the the LAR,LAR, which which contains contains a a description description of of the proposed changes, the proposed changes, the the technical technical evaluation, evaluation, and and associated associated no significant hazards no significant hazards determination determination and environmental and environmental evaluation evaluation.. Attachment Attachment 2 2 provides provides a a copy copy of GEH Nuclear of GEH Energy Report Nuclear Energy Report GE-NE-0000-01 GE-NE-0000-0102- 02-0888, 0888, Grand Grand Gulf Gulf Nuclear Nuclear Station Station -- Plant Specific Responses Plant-Specific Responses RequiredRequired by NUMAC PRNM by NUMAC PRNM Retrofit Retrofit Plus Plus Option Option /// III Stability Stability TripTrip Function Function Topical Topical Report Report (NEDC-32410P-A),
(NEDC-32410P-A), for for NRC N RC review review in in conjunction conjunction with with thethe proposed proposed LAR. Attachment 3 LAR. Attachment 3 provides marked-up Operating provides marked-up Operating License License and and TSTS pages pages indicating indicating the proposed changes.
the proposed changes . Attachment Attachment 4 4 provides provides thethe associated draft marked-up TS Bases associated draft marked-up TS Bases pages pages for information only.
for information only.
Attachment 5 providesprovides a a proprietary proprietary versionversion of of GEH Nuclear Energy GEH Nuclear Energy Report Report 0000-0107-7607-P, 0000-0107-7607-P, Grand Grand Gulf Gulf Nuclear Nuclear Station Station - Grand Gulf
- Grand Gulf PRNM PRNM Upgrade Upgrade Project Project Option Option Ill III Stability Deviations, which Stability Deviations, which provides provides the the technical technical basisbasis for several deviations for several deviations from from thethe traditional traditional Option Option III III stability stability solution solution design design established established by by the the BWR Owners' Group.
BWR Owners' Group .
Pursuant to 10 CFR 2 .390, GEH has requested this report be withheld from public disclosure; Pursuant to 10 CFR 2.390, GEH has requested this report be withheld from public disclosure ;
the the associated associated affidavit affidavit is provided following is provided following the the report report.. Attachment Attachment 6 6 provides provides a a non-non-proprietary proprietary version version of of the the report report..
Entergy Entergy has has evaluated evaluated the proposed LAR the proposed LAR in in accordance accordance with with 10 10 CFR 50.91(a)(1)
CFR 50.91 (a)(1) using using criteria criteria in in 10 CFR 50.92(c) 10 CFR 50.92(c).. We We have have determined determined that that this this change involves no significant change involves no significant hazards hazards consideration consideration.. The The bases bases for for this this determination determination are are included included in in Attachment Attachment 11..
This This letter letter contains contains commitments commitments as as identified identified in in Attachment Attachment 7. 7.
GNRO-2009-00054 GN RO-2009-00054 Page 3 Page 3 Entergy plans Entergy to submit plans to an LAR submit an LAR to to support support an an extended power uprate extended power uprate (EPU)
(EPU) at at GGNS GGNS in in accordance with accordance GEH Licensing with GEH Topical Report Licensing Topical Report (LTR)
(LTR) NEDC-33004P-A, NEDC-33004P-A, ConstantConstant Pressure Pressure Power Uprate. The Power Uprate. NRC's Safety The NRC's Safety Evaluation Report approving Evaluation Report approving NEDC-33004P-A NEDC-33004P-A contains contains a a restriction that restriction that prohibits prohibits a a licensee licensee from submitting certain from submitting certain types types ofof LARs LARs inin parallel parallel with with the the EPU EPU LAR.LAR. This This PRNM PRNM System System LAR LAR falls within that falls within restriction ; therefore, that restriction; Entergy is therefore, Entergy is submitting submitting thisthis LAR LAR prior prior to to the the EPU EPU LAR.
LAR.
Entergy requests NRC Entergy requests approval of NRC approval the PRNMS of the PRNMS LAR LAR prior prior to to submitting submitting the the EPU EPU LAR, which LAR, which is currently is currently scheduled scheduled for for July, July, 2010 2010.. Entergy will implement Entergy will implement the the approved PRNMS LAR approved PRNMS LAR prior prior to startup to startup from the 2012 from the refueling outage.
2012 refueling outage.
If If you you have have any questions or any questions require additional or require additional information, information, please please contact contact Mr.
Mr. Guy Davant at Guy Davant at (601) 368-5756 .
(601) 368-5756.
II declare declare under penalty of under penalty of perjury perjury that that the the foregoing foregoing is is true true and correct.
and correct.
Executed Executed on on November November 3, 3, 2009.
2009 .
Sincerely, Sincerely, MAK/ghd MAKlghd Attachments:: 11..
Attachments License Amendment License Amendment Request Request - Power Range
- Power Neutron Monitoring Range Neutron Monitoring System System Upgrade Upgrade 2
2.. GE GE Hitachi Nuclear Energy Hitachi Nuclear Report GE-NE-0000-01 Energy Report GE-NE-0000-0102-0888, Grand Gulf 02-0888, Grand Guff Nuclear Nuclear Station Station -- Plant-Specific Plant-Specific Responses Responses Required Required by by NUMAC NUMAC PRNM PRNM Retrofit Retrofit Plus Option ///
Plus Option Stability Trip III Stability Trip Function Function Topical Topical Report Report (NEDC-3247OP-A)
(NEDC-32410P-A) 3 3.. Marked-Up Marked-Up Operating License and Operating License and Technical Specification Pages Technical Specification Pages 4
4.. Draft Draft Marked-Up Technical Specification Marked-Up Technical Specification Bases Bases Pages Pages (For (For Information Information Only)
Only) 5 5.. GE GE Hitachi Hitachi Nuclear Energy Report Nuclear Energy Report 0000-0107-7607-P-RO, 0000-0107-7607-P-RO, Grand Grand GulfGulf REMOVED Nuclear Station - Grand Gulf PRNM Upgrade Project Option /// Stability Nuclear Station - Grand Gulf PRNM Upgrade Project Option III Stability Deviations (Proprietary Deviations (Proprietary Version) with Affidavit Version) with Affidavit Supporting Request to Supporting Request to Withhold Withhold fromfrom Public Disclosure Public Disclosure 6.
- 6. GE Hitachi GE Hitachi Nuclear Energy Report Nuclear Energy Report 0000-0107-7607-NP-Rl, 0000-01 07-7607-NP-R1, Grand Grand GulfGulf Nuclear Station Nuclear Station -
- Grand Grand Gulf PRNM Upgrade Project Option /// Stability Gulf PRNM Upgrade Project Option III Stability Deviations (Non-Proprietary Version)
Deviations (Non-Proprietary Version) 7.
- 7. Licensee-Identified Commitments Licensee-Identified Commitments
GNRO-2009-00054 GNRO-2009-00054 Page 44 Page cc:
cc: Mr. Elmo Mr. Elmo E.E . Collins, Collins, Jr.
Jr.
Regional Administrator, Regional Administrator, Region Region IVIV U . S.
U. S . Nuclear Nuclear Regulatory Regulatory Commission Commission 612 East 612 East Lamar Lamar Blvd.,
Blvd ., Suite Suite 400 400 Arlington, TX Arlington, TX 76011-4005 76011-4005 U . S.
U. S . Nuclear Nuclear Regulatory Regulatory Commission Commission ATTN : Mr.
ATTN: Mr. C.C. F.
F Lyon, Lyon, NRR/DORL NRR/DORL (w/2)
(w/2)
ATTN : ADDRESSEE ATTN: ADDRESSEE ONLY ONLY Courier Delivery ATTN: Courier Delivery Only Only Mail Stop Mail Stop OWFN/8 OWFN/8 B1 B1 11555 Rockville 11555 Rockville Pike Pike Rockville, MD Rockville, MD 20852-2378 20852-2378 Dr. Ed Dr. Ed Thompson, Thompson, MD, MD, MPH MPH Mississippi Department Mississippi Department of of Health Health P. O.
P. 0. Box Box 1700 1700 Jackson, MS Jackson, MS 39215-1700 39215-1700 NRC Senior NRC Senior Resident Resident Inspector Inspector Grand Gulf Grand Gulf Nuclear Station Nuclear Station Port Gibson, Port Gibson, MS MS 39150 39150
bcc:
bcc:
OUTLOOK MAIL:
OUTLOOK MAIL : DISTRIBUTIO N IS DISTRIBUTION IS ALL ALL ELECTRONIC ELECTRONIC Barfield, A.
Barfield, A. D.D. (GG-ENG)
(GG-ENG)
Browning, J.
Browning, J . G.
G . (GG-GMPO)
(GG-GMPO)
Caery, J. V. (GG-TRNG)
Caery, J. V. (GG-TRNG)
Christian, K.
Christian, K. J.
J . (W3-NSA)
(W3-NSA)
Ford, B.
Ford, B. S.
S. (ECH-NS&L)
(ECH-NS&L)
GGN CENTRAL GGN CENTRAL FILE FILE (171)
(171)
GGN PLANT LICENSING GGN PLANT LICENSING James, D.
James, D . E.
E . (ANO-NSA)
(ANO-NSA)
Lorfing, D.
Lorfing, D. L. L. (RBS-PL)
(RBS-PL)
McCann, J.
McCann, J . F.
F . (WP-NS&L)
(WP-NS&L)
Murillo, R . J . (W3-PL)
Murillo, R. J. (W3-PL)
Perino, C.
Perino, C. L.
L. (GG-NSA)
(GG-NSA)
Richardson, C.
Richardson, C. J.
J . (ECH-EPU)
(ECH-EPU)
Roberts, J.
Roberts, J. C. (RBS-NSA)
C. (RBS-NSA)
Saunders, S.
Saunders, S. A.A. (ECH-EPU)
(ECH-EPU)
Higginbotham, K.
Higginbotham, K. (GG-OPS)
(GG-OPS)
OTHER:
OTHER: File (LRS_DOGS File (LRS_DOCS Directory Directory -- GNRI GNRI or or GNRO)
GNRO)
ATTACHMENT ATTACHMENT 11 G NRO-2009-00054 GNRO*2009*00054 LICENSE LICENSE AMENDMENT REQUEST AMENDMENT REQUEST POWER POWER RANGE RANGE NEUTRON NEUTRON MONITORING SYSTEM UPGRADE MONITORING SYSTEM UPGRADE
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 11 of of 41 41 TABLE TABLE OF CONTENTS OF CONTENTS SECTION SECTION TITLE TITLE PAGE PAGE 1 .0
1.0 DESCRIPTION
DESCRIPTION . . . . . . .... . . . . . . . .. . . . . . . . . . .... . . . . . . . . . . .... . . . . . . . ... . . . . . . . . ... . . . . . . . . . . . . . . . . ...... . . 3 3 22.0
.0 PROPOSED CHANGES PROPOSED CHANGES . . . . .. . . . . . . . . . . . .. . . . . . . . . . . .... . . . . . . ... . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .... . 33 33.0
.0 BACKGROUND BACKGROUND . . . . ... . . . . . . . . ... . . . . . . . . . .. . . . . . . . . . . . .... . . . . . . . . .. . . . . . . . . . .... . . . . . . . . . . . . . . ..... . . . . 4 4 3.1 3.1 Current Current GGNS GGNS Neutron Neutron Monitoring Monitoring System System Description Description . . . . . .. . . . . . . . . . . . . . . .. .. .. .44 3.2 3.2 NUMAC NUMAC PRNM PRNM System System Hardware Hardware Description Description . . . . . ... . . . . . . . . . . . .. . . . . . . . . . . . . . . . .... . .66 3.3 3.3 Changes Changes to the Reactor to the Reactor Stability Stability Solution Solution Licensing Licensing Basis Basis . .. . . . . . . . . . . . . . . ..... . . 77 44.0
.0 TECHNICAL TECHNICAL ANALYSES ANALYSES ... . . . . . . . . .. . . . . . . . . . . . . .... . . . . . . . . .. . . . . . . . . . . .... . . . . . . . . . . . . . . ...... 11 11 4.1 4.1 OL OL Section Section 22.C(2),
.C(2), Technical Technical Specifications Specifications . . . . . . . . . .... . . . . . . . . . . .. . . . . . . . . . . . . . . . ... .12 12 4.2 4.2 TS TS 11.1,
.1, Definitions Definitions . . . . . . . . . .... . . . . . . . . .. . . . . . . . . . . . . ... .. . . . . . . . . .. . . . . . . . . . .... . . . . . . . . . . . . . . . .. . . . . 13 13 4.3 4.3 TS TS 3.2.4, 3.2.4, Fraction Fraction of of Core Core Boiling Boiling Boundary Boundary (FCBB) (FCBB) . . . . . . . . . . .. . . . . . . . . . . . . . . .....13 13 4.4 4.4 TS TS 3.3 .1 .1, Reactor 3.3.1.1, Reactor Protection Protection System System (RPS) (RPS)Instrumentation Instrumentation .. . . . . . . . . . . . . . .13 13 44.4.1
.4.1 Changes Changes to to Limiting Limiting Conditions Conditions for for Operation Operation (LCO) (LCO} 3.3.1.1 3.3.1 .1 Actions Actions . . ... .13 13 44.4.2
.4.2 Changes Changes to to Surveillance Surveillance Requirements Requirements (SRs) (SRs} . . . . . . ... . . .. . . . . . . . . . .. . . . . . . . . . . . . . . . . .15 15 4 .4 .3 4.4.3 Changes Changes to to TS TS Table Table 33.3.1.1-1, .3.1 .1-1, Reactor Reactor Protection Protection System System Instrumentation Instrumentation . . . . .... . . . . . . .. .... . . . . . . . ...... . . . . . . . . ...... . . . . . . . .... . . . . . . . . . . . ..... . . . . . . . . . ...... 20 20 4.5 4.5 TS 3.3.1 .3, Period TS 3.3.1.3, Period Based Based Detection Detection System System . . . . . . . . . .... . . . . . . . . . . . . ... . . . . . . . . . . . . .. .. 28 28 4.6 4.6 TS TS 3.10.8, 3.10.8, Shutdown Shutdown Margin Margin (SDM) (SDM) Test Test -- Refueling Refueling . . . . . . . . . . . . . .. ... . . . . . . . . . . . . 28 28 4.7 4.7 TS TS 5.6.5, Core Operating 5.6.5, Core Operating Limits Limits Report Report (COLR) (COLR) . . . ... . . .. . . . . . . . . . . . ..... . . . . . . . . . . . .29 29 4.8 4.8 Conclusion . . . . . . . . . . . . .... . . . . . . . .... . . . . . . . . ..... . . . . . . . . . . .... . . . . . . . .... . . . . . . . . . . . . . .. .. . . . . . . . . . . . ... 29 Conclusion 29 5.0 5.0 REGULATORY REGULATORY ANALYSIS ANALySiS .. . . . . . . . . . . . .. . . . . . . . . . . . . .... . . . . . . . ..... . . . . . . . . . . . . . . . .. . . . . . . . . . . 30 30 5.1 5.1 Applicable Applicable Regulatory Regulatory Requirements Requirements and and Guidance Guidance . ..... . . . . . . . . . . . . . . .. . . . . . . . . . . 30 30 5.1 .1 5.1.1 10 CFR 10 CFR Part Part 5050 . . . . . . ... . . . . . . . . .... . . . . . . . . . . . .. . . . . . . . . . . . . .... . . . . . . . . ..... . . . . . . . . . . . . .. .. . . . . . . . . . . 30 30 5.1 .2 5.1.2 NRC NRC Safety Safety Evaluation Evaluation and and NUMAC NUMAC PRNM PRNM LTR LTR Requirements Requirements . . . . . . .. . . . . . 31 31 5.1 .3 5.1.3 GGNS GGNS PRNMPRNM System System Deviations Deviations from from the the NUMAC NUMAC PRNM PRNM LTR LTR . . . . . . . .. . . . . 33 33 1 to Attachment to GNRO-2009-00054 GNRO-2009-00054 Page 22 of Page of 41 41 SECTION SECTION TITLE TITLE PAGE PAGE 5.1 .4 5.1.4 GGNS Option GGNS Option III III Stability Stability Solution Solution Deviations Deviations from from the the BWROG BWROG Stability LTR Stability LTR ... . . . . . . . . . . . ...... . . . . . . . . . . . .... . . . . . . . . . . . . . ... . . . . . . . .. .. .. . . . . . . . . . . . . ... . . . . . . . . .... . . 33 33 5.1 .5 5.1.5 Methodology . ...... . . . . . . . . . . . .. . . . . . . . . . . . . . . ... . . . . . . . . . ..... . . . . . . . . . . . ... . . . . . . . . . .... . 34 Setpoint Methodology Setpoint 34 5 .2 5.2 No Significant No Significant Hazards Hazards Determination Determination . . . . . . . . . . . .. . . . . . . . . . .... . . . . . . . . . . . . . . .. . . . . . . . ..... 36 36 5 .3 5.3 ental Consideration Environmental Consideration . . . . . . . . .. . . . . . . . . . . . . . .... . . . . . . . . .... . . . . . . . . . . . . . . .. . . . . . . . . . .. . 38 38 6.0 6.0 PRECEDENCE ... . . . . . . . . .. ..... . . . . . . . . . . . . .. . . . . . . . . . . . . . .... . . . . . . . . .... . . . . . . . . . . . . . .. . . . . . . . . . . ... 39 PRECEDENCE 39 7.0
7.0 REFERENCES
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 REFERENCES 39
Attachment Attachment 11 to to GNRO-2009-00054 GNRO-2009-00054 Page 3 Page 3 of of 41 41 LICENSE AMENDMENT LICENSE AMENDMENT REQUEST REQUEST POWER RANGE POWER RANGE NEUTRON NEUTRON MONITORING MONITORING SYSTEM SYSTEM UPGRADE UPGRADE 1 .0
1.0 DESCRIPTION
DESCRIPTION Pursuant to Pursuant to 10 10 CFRCFR 50.90, 50.90, Entergy Entergy Operations, Operations, Inc. Inc. (Entergy)
{Entergy} proposes proposes to revise the to revise Grand the Grand Gulf Nuclear Gulf Nuclear Station Station {GGNS} Operating License (GGNS) Operating License (OL)
{OL} andand Technical Specifications (TS) to Technical Specifications (TS) to reflect the installation of the digital General Electric - Hitachi (GEH} Nuclear Measurement reflect the installation of the digital General Electric - Hitachi (GEH) Nuclear Measurement Analysis Analysis and and Control Control (NUMAC)
(NUMAC) Power Range Neutron Power Range Monitoring {PRNM}
Neutron Monitoring System. The (PRNM) System. The proposed changes proposed changes (described (described in in Section Section 4.0,4 .0, below) below) areare consistent with the consistent with the NRC-approved NRC-approved GEH GEH Licensing Licensing Topical Report (LTR)
Topical Report (LTR} NEDC-32410P-A, NEDC-3241 OP-A, Nuclear Nuclear Measurement Measurement Analysis Analysis and and Control Power Control Power Range Neutron Monitor Range Neutron Monitor (NUMAC (NUMAC PRNM) PRNM) Retrofit Plus Option Retrofit Plus Option III /// Stability Stability Trip Trip Function, Function, Volumes Volumes 11 and and 2, including Supplement 1 (References 1 and 2), referred to here-in 2, including Supplement 1 (References 1 and 2), referred to here-in collectively collectively as the NUMAC as the NUMAC PRNM PRNM LTR. LTR. The The NUMAC NUMAC PRNM PRNM LTR LTR provides provides the the primary primary technical basis for technical basis for the proposed changes.
the proposed changes. The The NRC approved the NRC approved the design design and application of and application of the the NUMAC PRNM NUMAC PRNM LTR LTR via References 3 via References 3 and and 4. 4.
Entergy and Entergy and GEHGEH evaluated evaluated the the proposed proposed GGNS-specific GGNS-specific PRNM System installation PRNM System installation against against the requirements of the requirements of the the NUMAC NUMAC PRNM PRNM LTR LTR and associated NRC and associated Safety Evaluations.
NRC Safety Evaluations. GEH GEH developed developed a a plant-specific comparison report plant-specific comparison report GE-NE-0000-0102-0888, GE-NE-0000-01 02-0888, Grand Grand Gulf Gulf Nuclear Nuclear Station Station -- Plant-Specific Responses Required Plant-Specific Responses Required by by NUMAC NUMAC PRNM Retrofit Plus PRNM Retrofit Plus Option Option III /// Stability Stability Trip Trip Function Function Topical Topical Report (NEDC-32410P-A), (Reference 5), which is provided in Report (NEDC-32410P-A), (Reference 5), which is provided in Attachment 2.
Attachment 2. The The deviations deviations from from the the NUMAC NUMAC, PRNM PRNM LTR are identified LTR are identified in Section 5.1.3, in Section 5.1 .3, below.
below.
Entergy Entergy plans plans to replace the to replace the analog analog Average Average Power Power Range Monitor (APRM)
Range Monitor {APRM} subsystem subsystem of of the the existing existing Neutron Neutron Monitoring Monitoring SystemSystem at at GGNS GGNS with with the the more reliable digital more reliable digital NUMAC NUMAC PRNM PRNM System System during during the the spring spring 2012 refueling outage.
2012 refueling outage.
The The NUMAC NUMAC PRNM PRNM System System design design includes includes an an Oscillation Oscillation Power Power Range Monitor {OPRM)
Range Monitor (OPRM) capability, capability, which which implements implements a a GEH GEH version version of of the Boiling Water the Boiling Water Reactor Owners' Group Reactor Owners' Group (BWROG}
(BWROG) Option Option III III detect-and-suppress detect-and-suppress long-term reactor core long-term reactor core stability stability solution solution methodology.
methodology. With With installation installation of of the the OPRM OPRM and approval of and approval of this this License License Amendment Amendment Request {LAR), GGNS will transition from currently implemented Enhanced Option Request (LAR), GGNS will transition from currently implemented Enhanced Option I-A I-A stability stability solution solution to to Option Option 111III..
22.0
.0 PROPOSED CHANGES PROPOSED CHANGES The The following following OL OL andand TS TS sections, sections, and and associated associated TS TS Bases Bases sections sections are are affected affected by by this this change change::
"* OL OL Section 2.C(2), Technical Section 2.C(2), Technical Specifications Specifications
"* TS TS 11.1,
.1, Definitions Definitions
- TS TS 3.2 .4, Fraction 3.2.4, Fraction of of Core Core Boiling Boiling Boundary Boundary (FCBB)
(FeBB)
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 44 of of4141
- TS TS 3.3-1 .3 Period 3.3.1.3, Based Detection Period Based Detection SystemSystem (PBDS)
(PBDS) 0* 0 .8, Shutdown TS 3.10.8, Shutdown Margin Margin (SDM)
(80M) Test Test --
-- Refueling Refueling
(COLR)
The proposed changes The proposed support GGNS' changes support GGNS' replacement replacement of of the the existing existing analog analog APRMAPRM subsystem, subsystem, excluding excluding the associated focal the associated Local Power Power Range Monitor (LPRM)
Range Monitor (LPRM) detectors detectors and and cables, cables, with with the the NUMAC microprocessor-based NUMAC microprocessor-based PRNIVI PRNM System System.. This This digital digi~al upgrade upgrade includes includes an an OPRIVI OPRM Upscale function, Upscale function, which which detects and suppresses detects and suppresses reactor reactor power power instabilities instabilities through through LPRM LPRM flux flux monitoring.
The planned modification The planned modification involves involves replacing replacing the existing eight the existing eight APRM APRM instrument channel instrument channel modules of modules power range of power monitor electronics range monitor electronics withwith four four channels channels of of NUMAC NUMAC PRNM PRNM System System hardware . The hardware. The existing existing equipment equipment is is located located inin multi-bay multi-bay panels panels in in the the main main control room and control room and the upper cable sp upper cable ding room spreading room in in the the GGNS Control Building.
GGNS Control Building . The The modification modification removes removes and replaces replaces th the existing power range g power range monitor monitor equipment equipment within within the panels but, the panels but, with minor with minor exceptions, exceptions, leav leaves s the the plant plant cabling cabling and and interfaces interfaces undist undisturbed.
The The modification modification provides provides redundancy redundancy to to the LPRIVI detector the LPRM detector power power supplysupply hardware hardware and and also also upgra upgrades thethe recirculation recirculation flow signal processing flow signal processing electronics electronics.. Unlike Unlike the the current analog current analog instrumen Lion, the instrumentation, the new new digital instrumentation is digital instrumentation is not not vulnerable vulnerable to instrument setpoint to instrument drift.
setpoint drift.
This This LAR LAR addresses addresses changes changes to to the the OL, OL, TSTS Limiting Limiting Conditions Conditions of of Operation Operation (LCOs},
(LCOs),
Surveillance Requirements (SRs}, and RPS APRM functions as, justified in the NUMAC Surveillance Requirements (SRs), and RPS APRM functions as justified in the NUMAC LTR . These PRNM LTR. These changes changes are are identified and discussed identified and discussed in in Section Section 4.0, 4.0, below.
below.
Attachment Attachment 33 provides provides marked-up marked-up OL OL andand TSTS pages indicating the pages indicating the proposed proposed changes changes..
Attachment Attachment 44 provides provides thethe associated associated draft draft TS TS Bases Bases pages pages forfor information information only. only.
3.0 BACKGROUND
3.1 3.1 Current Current GGNS GGNS Neutron Neutron Monitoring Monitoring System Description
System Description
The The current Neutron Monitoring current Neutron Monitoring SystemSystem at at GGNS consists consists of of five five subsystems:
subsystems:
- 1. Source Source Range Range Monitors Monitors (SR (SRM) 2.
- 2. Intermediate Range Intermediate Range Monitors Monitors (IRM) FIRM}
3.
- 3. Local Power Range Local Power Range Monitors Monitors (LPRM)
(LPRM) 4.
- 4. Average Average Power Power RangeRange Monitors Monitors (APRM)
(APRM) 5.
Of the Of above subsystems, the above subsystems, only only the e APRM subsystem is APRM subsystem is affected affected by by this this proposed proposed change.
toto GNRO-2009-00054 GNRO-2009-00054 Page 5 Page 5 of of 41 41 The APRM The APRM subsystemsubsystem has has eight eight APRM APRM channels; channels; each each channel receiving input channel receiving input signals from signals from a a number number of LPRIVI channels.
of LPRM channels . Four Four APRM channels are APRM channels are associated associated with with each trip each system of trip system of the the Reactor Reactor Protection Protection System System (RPS).
(RPS).
Each APRM Each APRM channel channel uses: uses:
(1)
(1) Electronic equipment that Electronic equipment averages the that averages output signals the output signals from from a a selected selected set set ofof LPRMs; LPRMs; (2)
(2) Trip units Trip units thatthat actuate ctuate automatic automatic devices; devices ; and and (3)
(3) Signal readout Signal equipment .
readout equipment.
The APRM channels The APRM channels supply supply signals signals to to the RIPS, the the RPS, the Rod Rod Control Control and and Information Information System System (RC&IS),(RC&IS), and and the the core core monitoring monitoring computer.
computer. The The RPSRPS and RC&IS process and RC&IS process the the APRM APRM inputs inputs to to initiate initiate reactor reactor scrams scrams and and manage manage controlcontrol rodrod manipulations manipulations (e.g (e.g.,., control control rod rod blocks),
blocks), respectively respectively.. The core monitoring The core computer uses monitoring computer LPRM flux uses LPRM flux values values for its calculations.
for its calculations .
Each Each APRM APRM channel channel receives receives two two flow flow signals signals representative representative of reactor recirculation of reactor recirculation drive flow. The drive flow. The flow flow signals are sensed signals are sensed from from two pairs of two pairs of elbow taps, one elbow taps, one in in each each recirculation recirculation loop loop..
One One APRMAPRM channel channel in in each each RPSRPS division division contains contains aa Period-Based Period-Based DetectionDetection SystemSystem (PBDS}
(PBDS) card card*thatthat takes takes input input from from A-,A-, B-,
B-, and and C-level C-Ievel LPRMs LPRMs in the associated in the associated APRM APRM..
The The PBDS PBDS is is aa defense-in-depth defense-in-depth feature feature of of the the Option Option E-I-AE-I-A core core stability stability solution solution..
(See (See Section Section 3.3, 3.3, below, below, forfor more more information information pertaining pertaining to to Option E-I-A.) The Option E-I-A.) The PBDS PSDS analyzes analyzes the the incoming incoming LPRM LPRM signals signals individually individually to to detect power oscillations detect power oscillations consistent consistent with with neutron ic/thermal-hyd rau lic instability neutronic/thermal-hydraulic instability.. Upon Upon detecting detecting power power oscillations, oscillations, control control room room annunciators annunciators alarm alarm to to indicate indicate the the need need for for operator action, operator action, as required .
as required.
Also Also in in support support of of the the Option Option E-I-A E-I-A stability stability solution, solution, the the APRMs APRMs are used to are used to determine determine the the Fraction Fraction of of Core Core Boiling Boiling Boundary Boundary (FCBB} (FCBB).. FCBB FCBB is is the the ratio ratio ofof power power generated generated in in the the lower lower fourfour feetfeet of of the the reactor reactor core core toto the the power power required required to to produce produce saturated saturated boiling boiling of of the the coolant coolant entering entering the the fuel fuel channels channels.. FCBB FCBB is established to ensure the is established to ensure the core core remains remains stable stable during during normal normal reactor reactor operations operations when when operating operating in in certain certain regions regions of of the the power/flow power/flow map map.. FCBBFCBB is is controlled controlled in in accordance accordance with with TSTS 3.2 .4, 3.2.4, Fraction Fraction of of Core Core Boiling Boiling Boundary Boundary (FCBB).(FCBB).
Each Each APRM APRM containscontains aa digital digital Flow Flow Control Control TripTrip Reference Reference card card (FCTR}
(FCTR) that that generates generates the the flow-referenced flow-referenced scram scram and and rod-block rod-block trip trip setpoints setpoints as as aa function function of of aligned aligned reactor reactor recirculation recirculation drivedrive flow.
flow. The The digital digital FCTR FCTR card card provides provides aa drivedrive flow flow alignment alignment feature feature to to convert convert andand compensate compensate for for changes changes in in the the reactor reactor total total core core flow-to-recirculation flow-to-recirculation drive drive flow flow relationship relationship.. The The FCTR FCTR also also performs performs real-time real-time reactor reactor recirculation recirculation drive drive flowflow signal signal validation.
validation. The The purpose purpose of of the the validation validation process process is is to to provide provide adequate adequate assurance assurance that that credible credible failures failures in in the the drive drive flow flow areare detected detected and and result result in in aa conservative conservative response response from from thethe FCTR.
FCTR. The The drive drive flow flow signal signal is is tested tested for for upscale upscale and and downscale downscale failures failures.. Any Any detected detected failure failure of of the the drive drive flow flow signal signal causes causes the the FCTR FCTR to to generate generate aa failsafe failsafe output.
output. ThisThis output output causes causes aa reactor reactor scram scram signal signal to to be be generated generated by by thethe corresponding corresponding Neutron Neutron Monitoring Monitoring SystemSystem channel channel..
Attachment 1 toto GNRO-2009-00054 GNRO-2009-00054 Page 6 Page 6 of of 41 41 The APRM The APRM subsystem subsystem utilizes utilizes four four safety-related safety-related functions, functions, which provide input which provide input into into the RPS.
the RPS. TheseThese functions functions are identified in are identified TS Table in TS Table 3.3.1.1-1, 3 .3 .1 .1-1, Reactor Reactor Protection Protection System Instrumentation, and System Instrumentation, and listed listed in in the the table below.
table below.
TS APRM Function TS APRM Function TS APRM Function TS APRM Function Name Name Designation Designation Neutron Neutron Flux Flux- High, Setdown
- High, Setdown 2.a 2.a Fixed Neutron Fixed Neutron Flux Flux - - Hi High 2.b 2.b I nop Inop 2 .c 2.c Flow Biased Flow Biased Simulated Simulated Thermal Thermal Power Power - - High High 2.d 2.d 3.2 3.2 NUMAC PRNM NUMAC PRNM SystemSystem Hardware Hardware Description Description The The proposed proposed NUMAC NUMAC PRNM PRNM SystemSystem consists consists of of four four APRM/OPRM APRM/OPRM channels, channels, each each performing performing APRM APRM and and OPRMOPRM functions, functions, and and four four 2-Out-Of-4 2-0ut-Of-4 Voter Voter channels channels.. The The modification modification removesremoves and and replaces replaces the the existing existing powerpower range monitor equipment range monitor equipment located in located multi-bay panels in multi-bay panels in the main in the main control control roomroom and and the the upper upper cable spreading cable spreading room in room in the the GGNS GGNS ControlControl Building Building.. WithWith minor exceptions, the minor exceptions, the modification modification leaves leaves the the plant cabling and plant cabling interfaces undisturbed and interfaces undisturbed.. One One APRM/OPRM APRM/OPRM channel channel chassis chassis contains contains both both APRM APRM and and OPRM channel circuitry OPRM channel circuitry..
As As with with thethe current system, the current system, the general general APRM APRM function function averages averages LPRM LPRM information information and, and, using using a a combination combination of predefined criteria of predefined criteria and criteria based and criteria based on on inputs inputs from from the the recirculation drive recirculation drive flow flow functions, functions, compares compares averageaverage neutron neutron flux flux and and Simulated Simulated Thermal Thermal Power Power to to specified specified limits limits..
The The recirculation recirculation drive drive flow flow signal processing, which signal processing, which was was previously previously accomplished accomplished using using the the FCTR FCTR within within the the APRM control panels, APRM control panels, is is now integrated into now integrated into the the APRM APRM circuitry circuitry in in the the new new NUMAC NUMAC PRNM PRNM SystemSystem designdesign.. The The proposed proposed modification modification utilizes utilizes the the current current recirculation recirculation drive drive flow flow channel channel configuration configuration.. See See Section Section 33.1,.1, above, for above, for a description of the recirculation drive flow channel .
a description of the recirculation drive flow channel.
The The OPRM OPRM is is aa microprocessor-based microprocessor-based monitoring monitoring and and protection protection system system that:that:
(1)
(1) Detects Detects aa thermal-hydraulic thermal-hydraulic instability instability in in the the reactor reactor core; core; (2)
(2) Alarms Alarms on on small small power power oscillation oscillation magnitudes; magnitudes; and and (3)
(3) Initiates Initiates action action to to suppress suppress an an oscillation oscillation priorprior toto exceeding exceeding safety safety limits.
limits.
The The OPRM monitors the OPRM monitors the outputs outputs fromfrom selected selected LPRMs LPRMs and and provides provides inputs inputs to to the the RPS RPS to to initiate initiate suppression suppression actions actions..
Each Each 2-Out-Of-4 2-0ut-Of-4 Voter Voter channel channel (Al,(A1, A2,A2, B1, B1, andand 132)
B2) receives receives inputinput from from thethe four four APRM/OPRM channels . Voter Channels Al and A2 input to RIPS Trip System A, APRM/OPRM channels. Voter Channels A1 and A2 input to RPS Trip System A, while B1 and B2 input to RIPS Trip System B. A reactor trip occurs when at least two while 81 and B2 input to RPS Trip System B. A reactor trip occurs when at least two 2-Out-Of-4 2-0ut-Of-4 Voter Voter channels channels (one (one in in each each RPS RPS triptrip system) system) confirms confirms aa trip trip condition condition is is
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 77 of of 41 41 being being sensed sensed by by two two or or more more APRM/OPRM APRM/OPRM channels. channels . For For example, example, if any two if any two of of the the four APRM/OPRM four APRM/OPRM channels channels sense sense an an APRM APRM or OPRM trip or OPRM trip condition, condition, each each sends sends aa corresponding corresponding signal signal to to the the 2-Out-Of-4 2-0ut-Of-4 Voters Voters.. Each Each VoterVoter processes processes the the signal, signal, determines at least two APRM/OPRM channels sense a trip condition, and then determines at least two APRM/OPRM channels sense a trip condition, and then sends sends aa trip trip signal signal to to its its corresponding corresponding RIPS RPS trip system, resulting trip system, resulting in in aa plant plant scram scram..
When When one one APRM/OPRM APRM/OPRM channel channel is is bypassed, bypassed, the voting trip the voting trip logic becomes logic becomes 2-out-of-3 2-out-of-3.., The The Voter Voter channels channels cannotcannot be be bypassed bypassed..
GEH H has has modified modified the NUMAC PRNM the NUMAC PRNM SystemSystem designdesign from from that described in that described in the the NUMAC NUMAC PRNM PRNM LTR LTR to to have have the the APRM/OPRM APRM/OPRM channel channel send send an OPRM Upscale an OPRM Upscale trip trip and and an an APRM APRM Inop Inop triptrip to to all all four four 2-Out-Of-4 2-0ut-Of-4 Voters Voters when when the the associated associated channel channel key key switch switch is is placed placed in in the "INOP" position the "INOP" position.. As As aa result, result, an an OPRM OPRM UpscaleUpscale trip trip in in one one channel channel and and anan APRM APRM Inop Inop trip trip in in another another channel channel resultsresults in in RPS RPS triptrip outputs outputs fromfrom allall four 2-Out-Of-4 Voter channels . This deviation from the previously-approved NUMAC four 2-0ut-Of-4 Voter channels. This deviation from the previously-approved NUMAC PRNM System PRNM System design design and and licensing licensing basisbasis is identified in is identified in Section Section 5.1 5.1.3,.3, below, below, and and discussed discussed withinwithin Appendix Appendix A A ofof Attachment Attachment 22 (Reference (Reference 5). 5).
The The NUMAC NUMAC PRNM PRNM System System utilizes utilizes thethe four four safety-related safety-related APRM APRM functions functions of of the the existing existing GGNSGGNS power power rangerange monitoring monitoring system system logic logic (identified (identified in in Section Section 33.1 .1,, above),
above),
as as well well as as the the existing existing LPRM LPRM detector detector signal signal processing, processing, LPRM LPRM averaging, averaging, and and APRMAPRM reactor reactor trips, and adds trips, and adds two two new new functions functions that that support support the the Option Option 111 III stability stability solution solution;;
these these areare:: (1)
(1) aa 2-Out-Of-4 2-0ut-Of-4 Voter Voter function function (new (new APRM APRM Function Function 22.e); .e) ; and and (2)(2) an an OPRM Upscale function (new APRM Function 2 .f) .
OPRM Upscale function (new APRM Function 2.f).
As As discussed discussed in in the NUMAC PRNM the NUMAC PRNM LTR LTR (References (References 11 and and 2) 2) and and recognized recognized by by the the N C in NRC in its its Safety Evaluations approving Safety Evaluations approving the the LTR LTR (References (References 33 and and 4),4), this this modification modification has has no impact on no impact on the the control control rod rod block instrumentation governed block instrumentation governed by by TS TS 3.3.2.1, 3.3.2.1, Control Control RodRod BlockBlock Instrumentation, Instrumentation, for for aa BWR/6 BWR/6 plant plant that that hashas implemented implemented Improved Technical Improved Specifications (ITS)
Technical Specifications (ITS).. GGNS GGNS is such aa plant; is such plant; therefore, therefore, TS 3.3.2 .1 TS 3.3.2.1 is not not affected.
affected.
In addition In addition as as noted noted in in Section Section 2.3 .3.5 of 2.3.3.5 of the NUMAC PRNM the NUMAC PRNM LTR, LTR, the the Average Average Power Power Range Range Monitor, Monitor, Rod Rod BlockBlock Monitor, Monitor, and and Technical Technical Specifications Specifications Improvement Improvement Program Program (ARTS)(ARTS) is is not not applicable applicable to to the the BWR/6 BWR/6 design design and, and, therefore, therefore, not not applicable applicable to to GGNS.
GGNS.
3.3 3.3 Changes Changes to to the the Reactor Reactor Stability Solution Licensing Stability Solution Licensing Basis Basis Under Under certain certain conditions, conditions, BWRs BWRs are are susceptible susceptible to coupled neutronic/
to coupled neutronic/
thermal-hydraulic thermal-hydraulic instabilities instabilities.. TheseThese instabilities instabilities are are characterized characterized by by periodic periodic power/flow power/flow oscillations. Compliance with oscillations. Compliance with the the stability stability licensing licensing criteria criteria of of 1010 CFR CFR 50 50 Appendix Appendix A, General Design A, General Design Criterion Criterion (GDC}(GDC) 10, 10, Reactor Reactor Design, Design, and and GDC GDC 12, 12, Suppression Suppression of Reactor Power of Reactor Power Oscillations, Oscillations, can can be be achieved achieved either either by preventing or by preventing or by by detecting detecting and and suppressing suppressing stability-related stability-related reactor reactor power oscillations prior to power oscillations prior to exceeding fuel exceeding fuel design limits. If design limits. these power/flow If these power/flow oscillations oscillations become become large large enough, enough, the the fuel cladding integrity fuel cladding integrity Minimum Minimum CriticalCritical Power Power Ratio Ratio (MCPR}
(MCPR) Safety Safety LimitLimit could could be be challenged challenged..
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 8 8 of of 41 41 The BWROG developed The BWROG developed several several long-term long-term stability solution options stability solution options for detecting and for detecting and suppressing core suppressing instability events, core instability events, whichwhich are documented in are documented NEDO-31960-A, BWR in NEDO-31960-A, BWR owners' Owners' Group Long-Term Stability Group Long-Term Stability Solutions Solutions Licensing Licensing Methodology, Methodology, and and associated associated Supplement Supplement 11 (Reference (Reference 6). 6). The The option option currently currently implemented implemented at at GGNS GGNS is is referred referred to to as Enhanced Option as Enhanced Option I-A I-A (E-I-A}
(E-I-A) and and was was approved approved by by the the NRC NRC in in GGNS GGNS TS TS Amendment Amendment 141 141 (Reference (Reference 7). 7). ForFor this this option, option, thethe existing existing APRM APRM Flow Flow Biased Biased Simulated Thermal Simulated Thermal Power Power - High function
- High function (TS (TS Table Table 3.3.1 .1-1 Function 3.3.1.1-1 Function 22.d).d) gravid provides aa preemptive preemptive reactor reactor scramscram to to prevent prevent power/flow that could oscillations that power/flow oscillations could lead lead to to rossly violating the operating domain .
grossly violating the operating domain.
The The NUMAC NUMAC PRNIVI PRNM System System design design uses uses a different, more a different, more general general stability stability control control approach and approach and includes includes an an OPRM OPRM Upscale Upscale function, function, referred referred toto as as Option Option III III in in the the BWROG BWROG long-term long-term stability stability solution solution methodology methodology (Reference(Reference 6). 6). The The NUMAC NUMAC PRNIVI PRNM LTR LTR discusses discusses implementing implementing the the OPRIVI OPRM functions functions within within the the PRNIVI PRNM equipment equipment..
Option Option E-I-A E-I-A is not currently is not currently licensed licensed for for use use with with the the NUMAC NUMAC PRNM PRNM System System.
The The traditional traditional Option Option III III solution solution employs employs three three different different software algorithms running software algorithms running on on the the NUMAC NUMAC PRNM PRNM microprocessor microprocessor computer computer platformplatform to to automatically automatically detectdetect andand suppress suppress reactor reactor thermal-hydraulic instabilities : (1) thermal-hydraulic instabilities: (1) an an Amplitude-Based Amplitude-Based algorithm; algorithm; (2) (2) a Growth-Rate a Growth-Rate algorithm algorithm;; and and (3) (3) aa Period-Based Period-Based Detection Detection algorithm algorithm 1..
The The Amplitude-Based Amplitude-Based algorithm algorithm discriminates discriminates between between true stability-related neutron true stability-related neutron flux flux oscillations oscillations and and other other fluxflux variations that may variations that may be be expected during plant expected during plant operation.
operation.
The primary objectives The primary objectives of of this this algorithm algorithm are are to:to:
(1)
(1) Provide aa sufficiently Provide sufficiently low low amplitude amplitude trip trip setpoint such that setpoint such margin to that margin to the MCPR the MCPR Safety Limit is maintained ; and Safety Limit is maintained; and (2)
(2) Identify Identify stability-related stability-related neutron neutron fluxflux oscillations oscillations and discriminate against and discriminate against "false" "false" signals signals from from other other expected expected plant plant evolutions evolutions..
The The Growth-Rate Growth-Rate algorithm algorithm followsfollows the the same same logiclogic asas the the Amplitude-Based Amplitude-Based algorithm, algorithm, except except that that a a trip trip is is initiated initiated if if the the relative relative signal signal value value exceeds exceeds a a specified growth-rate specified growth-rate setpoint.
setpoint.
The The Period-Based Period-Based Detection Detection algorithmalgorithm is is based based on on the the observation observation thatthat the the neutron neutron flux flux of of an an unstable unstable core core oscillates oscillates with with aa well-defined well-defined period period andand that the neutron that the neutron flux flux of of aa stable stable core core is is characterized characterized by by random random noise. noise. Detecting Detecting the inception of the inception of thermal-thermal-hydraulic hydraulic instability instability is is confirmed confirmed by by several several consecutive, consecutive, equal equal periods periods which results in which results in an alarm signal . The oscillation amplitude is then compared against a trip setpoint.
an alarm signal. The oscillation amplitude is then compared against a trip setpoint.
Meeting Meeting both both conditions conditions (both (both aa sustained sustained periodperiod and and increasing increasing signal signal amplitude) amplitude) results results in in aa channel channel trip signal .
trip signal.
A A similar similar Period-Based Period-Based Detection Detection algorithm algorithm is is currently utilized by currently utilized by Option E-l-A, as Option E-I-A, as discussed discussed in in Section 33.1.
Section .1 .
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page 9 Page 9 of of 41 41 Of the Of three algorithms, the three algorithms, only only thethe Period-Based Period-Based Detection Detection algorithm algorithm is is credited credited to to protect protect the the MCPR MCPR Safety Limit against Safety Limit against anticipated anticipated thermal-hydraulic thermal-hydraulic instabilities instabilities.. The The Amplitude-Based Amplitude-Based and and Growth-Rate Growth-Rate algorithms algorithms are are provided provided for for defense-in-depth defense-in-depth..
The Option The Option III III configuration replaces GGNS' configuration replaces GGNS' Option Option E-I-AE-I-A as as the the long-term long-term stability stability solution required by NRC Generic Letter 94-02, Long-Term Solutions and Upgrade of solution required by NRC Generic Letter 94-02, Long-Term Solutions and Upgrade of Interim Interim Operating Operating Recommendations Recommendations for Thermal Hydraulic for Thermal Hydraulic Instabilities Instabilities in in Boiling Boiling Water Reactors Water Reactors (Reference (Reference 8). 8).
Unlike Unlike Optionption E-I-A, E-I-A, Option Option III III does does not not employ employ FCBB FCBB to to detect detect and and suppress suppress potential potential reactor core instabilities. ilities . FCBB FCBB is is discussed discussed in in Section Section 3.1, above.
3.1, above.
The The OPRM OPRM Upscale Upscale function function (new (new APRM Function 2.f)
APRM Function 2.f) is is added added to to TSTS 3.3 .1 .1, Reactor 3.3.1.1, Reactor Protection Protection SystemSystem (RPS)(RPS) Instrumentation, Instrumentation, to to implement implement Option Option III III (see (see Section Section 44.4.3.7,
.4.3.7, below) below)..
Following NUMAC Following NUMAC PRNM PRNM SystemSystem installation installation and and startup startup from from the 2012 refueling the 2012 refueling outage, outage, the the OPRM OPRM will will operate operate in in an "indicate only" an "indicate only" mode mode for for anan initial initial monitoring monitoring period.
period. The The purpose purpose of of the the monitoring monitoring period period is is to to ensure ensure the the OPRM OPRM algorithms algorithms perform according to design specifications . The OPRM Monitoring Period is perform according to design specifications. The OPRM Monitoring Period is discussed discussed below. below.
OPRM Monitoring OPRM Monitoring Period Period Section Section 88.4 .4 of of the NUMAC PRNM the NUMAC PRNM LTR LTR discusses discusses an an OPRM OPRM Monitoring Monitoring Period during Period during which which time time thethe OPRM OPRM Upscale Upscale trip trip function function is is not not connected connected to RPS . The to RPS. The LTRLTR designates designates the the duration duration of of this this monitoring monitoring period period to to be be one operating cycle one operating cycle after after which which the function will the function will bebe connected connected to to RPS RPS..
Both the Both the NRCNRC staffstaff and and thethe industry industry recognized recognized that that aa possibility possibility of of problems problems with with thethe OPRM OPRM algorithms, algorithms, system system performance performance in in anan actual actual plant plant environment, environment, hardware hardware problems, etc problems, etc.,., existed existed.. Considering Considering stability stability events events are are infrequent infrequent occurrences, occurrences, the the NRC Safety Evaluation for the NUMAC PRNM LTR contains the following provision :
NRC Safety Evaluation for the NUMAC PRNM LTR contains the following provision:
"The "The OPRMOPRM function function will be monitored will be monitored during during the the first first full full fuel cycle to fuel cycle to ensure ensure the the OPRM algorithms perform according to the design specifications . During this OPRM algorithms perform according to the design specifications. During this monitoring period, monitoring period, thethe OPRM OPRM trip trip capabilities capabilities will will bebe deactivated, deactivated, but but the the OPRM OPRM alarms alarms and and indications indications will will bebe provided provided to to the the operators operators.. Upon Upon completion completion of of this this initial surveillance initial surveillance phase,phase, the OPRM trip the OPRM trip functions functions will will be be enabled, enabled, and and thethe licensee will licensee will submit submit to to the the NRCNRC technical technical specification specification changes changes that that address address the the OPRM OPRM functions functions." ."
Entergy recognizes Entergy recognizes the the potential potential for for identifying identifying an an intractable intractable problem problem duringduring the the OPRM Monitoring Period, but based upon current industry / GEH experience with OPRM Monitoring Period, but based upon current industry / GEH experience with the the NUMAC PRNM System, considers such a problem unlikely.
NUMAC PRNM System, considers such a problem unlikely.
Although Although the the NUMAC NUMAC PRNM PRNM System System with with the the OPRMOPRM UpscaleUpscale trip trip function function has has now now been operating at several plants for several years without any indication of been operating at several plants for several years without any indication of an OPRM an OPRM design design problem, problem, EntergyEntergy believes believes itit remains remains prudentprudent to to assume assume that that aa design design problem problem may may still still exist exist inin the the OPRM OPRM Upscale Upscale functionfunction.. Therefore, Therefore, to to minimize minimize operational operational risk risk
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 110 0 of of 41 41 and and potentially potentially avoid avoid an an otherwise otherwise unnecessary unnecessary plant shutdown, Entergy plant shutdown, Entergy willwill conduct conduct monitoring period aa monitoring period of the OPRM of the OPRM for for aa minimum minimum of of 90 90 days days notnot to to exceed exceed one one fuel fuel cycle after plant cycle after plant startup startup following following the the 2012 2012 refueling refueling outage.
outage.
The The PRNM PRNM System System configuration configuration during during thethe monitoring monitoring period period and and the the monitoring monitoring period duration are discussed below.
period duration are discussed below.
- a. PRNM PRNM System System Configuration Configuration During During the the OPRM OPRM Monitoring Monitoring Period, Period, the the outputs outputs fromfrom thethe OPRM OPRM UpscaleUpscale function will not be connected to the RPS trip output relays while the OPRM function will not be connected to the RPS trip output relays while the OPRM alarms and indications will be provided to the operators . The OPRM portion alarms and indications will be provided to the operators. The OPRM portion ofof the the PRNM PRNM System System willwill operate operate in in an an "indicate "indicate only" only" mode mode and and will will be be considered considered "functional" "functional" based based upon upon successfully successfully performing performing those those surveillances surveillances that that can can be be performed, performed, or or partially partially performed, performed, priorprior to to startup startup or or on-line on-line asas part part ofof post-modification post-modification testing,testing, industry industry experience, experience, and and factory factory acceptance acceptance testingtesting of of the NUMAC PRNM System . System tuning may be performed as necessary the NUMAC PRNM System. System tuning may be performed as necessary during during the the OPRM OPRM Monitoring Period .
Monitoring Period.
The OPRM Upscale The OPRM Upscale function function willwill not not be relied upon be relied upon to to mitigate mitigate aa stability stability event event during during thisthis initial initial OPRM OPRM Monitoring Monitoring Period Period;; rather GGNS will rather GGNS will implement implement Backup Backup Stability Protection (BSP)
Stability Protection measures specified (BSP) measures specified in BWROG document in BWROG document OG-02-0119-260, OG-02-0119-260, GE GE to to BWROG BWROG Detect Detect andand Suppress Suppress // II Committee, Committee, "Backup"Backup Stability Stability Protection Protection (BSP)
(BSP) for for Inoperable Inoperable Option Option III /// Solution, Solution,""Reference (Reference 9) as an
- 9) as an alternate alternate method method for for detecting detecting and and suppressing suppressing instabilities instabilities until until the the OPRM OPRM Monitoring Monitoring Period Period has has been successfully completed been successfully completed.. The The NRC NRC approved approved the the useuse of the BSP measures for the alternate method for Monticello as documented in its of the BSP measures for the alternate method for Monticello as documented in its Safety Evaluation Safety Evaluation (Reference (Reference 10). 10) .
Reactor Reactor stability stability compliance compliance using using this method relies this method relies upon operator action upon operator action toto::
- 0 Avoid Avoid regions regions where instability may where instability may occur, occur,
- Exit such Exit such regions regions when necessary, and when necessary, and
- Detect an Detect actual instability an actual instability and take mitigating and take mitigating action action by manual means.
by manual means.
The The BSPBSP measures measures will will be be implemented implemented via via plant plant procedures, procedures, consistent consistent with with other OPRM license other OPRM license amendments amendments approvedapproved by by the NRC .
the NRC.
At At the the end end of of the the OPRM Monitoring Period, OPRM Monitoring Entergy will Period, Entergy review the will review the operating operating data, setpoints, and data, setpoints, and margins.
margins . Once Once the results are the results are determined determined to to be acceptable, be acceptable, Entergy will Entergy enable the will enable the OPRM OPRM (with (with applicable applicable SRs SRs met)met) byby connecting connecting itit to to the the RPS trip relays, completing implementation of the hardware changes for this RPS trip relays, completing implementation of the hardware changes for this amendment amendment..
1 to Attachment to GNRO-2009-00054 GNRO-2009-00054 Page 11 Page 1 1 of of 41 41 b.
- b. Monitoring Period Monitoring Period Duration Duration The one-cycle The one-cycle monitoring monitoring period period in in the the NUMAC NUMAC PRNM PRNM LTR LTR for for the the OPRM OPRM Upscale function Upscale function was was specified specified because, because, at at that that time, time, itit was was aa new new feature feature of of the the RPS. As RPS. As such, such, further further testing, testing, monitoring, monitoring, and and evaluating evaluating the the normal normal modes modes of of operation was operation was considered considered prudentprudent to to ensure ensure this this function function performed performed as as designed designed and did and did not not create create any any unintended consequences . Since originally introduced, unintended consequences. Since originally introduced, GEH NUMAC GEH NUMAC PRNM PRNM systems systems utilizing utilizing Option Option IIIIII with with the the OPRM OPRM UpscaleUpscale function functio have been have been installed installed in in many many plants plants within within the the U.S.
U .S. and and overseas, overseas, accumulating accumulating more than more than 90 90 reactor reactor years years of of fully-armed fully-armed operation.
operation .
Based on Based on this this operational experience, Entergy operational experience, Entergy believes believes thatthat having having the the flexibility flexibility to complete to complete the monitoring period the monitoring period after after aa minimum minimum of of 90 90 days days oror to continue itit up to continue up to the to end of the end the fuel of the fuel cycle cycle is is appropriate.
appropriate. Although Although aa slightly slightly different approach, different approach, the NRC the NRC approved approved a a fixed, fixed, 90-day 90-day monitoring monitoring period period forfor Monticello Monticello (Reference (Reference 10). 10) .
Entergy will Entergy will notify the NRC notify the NRC when when thethe monitoring period has monitoring period has been been successfully successfully completed .
completed.
4.0 4.0 TECHNICAL TECHNICAL ANALYSES ANALYSES GGNS is GGNS is aa GE BWR/6 large GE BWR/6 large core plant. The core plant. The proposed proposed OL and TS OL and changes and TS changes associated and associated draft TS Bases changes have been developed in accordance with the NUMAC PRNM draft TS Bases changes have been developed in accordance with the NUMAC PRNM LTR LTR (except (except as as specified specified within within thisthis LAR).
LAR). Attachments Attachments 3 3 and and 4 provide marked-up 4 provide marked-up pages pages of of the the proposed OL proposed OL and and TS TS changes changes and and corresponding corresponding TS Bases changes TS Bases changes associated associated with with installing installing the NUMAC PRNM the NUMAC PRNM System,System, respectively respectively.. The The draft draft TS TS Bases Bases mark-ups, mark-ups, provided provided for for information information only, only, will will bebe issued issued in in accordance accordance with TS 55.5.11, with TS .5.11, Technical Technical Specification Specification (TS) (TS)
Bases Control Program.
Bases Control Program.
As As discussed discussed in in Section Section 3.2,3.2, above, above, the the NUMAC NUMAC PRNM PRNM System System utilizes utilizes the the four four functions functions ofof the the existing existing GGNS GGNS APRM APRM systemsystem logic, including LPRM detector signal processing, LPRM logic, including LPRM detector signal processing, LPRM averaging, averaging, and and APRM APRM reactor reactor trips, trips, and and adds agds two new functions.
two new functions. The The newnew andand existing existing functions functions are are identified identified in in the the table table below:
below:
TS TS Function Function TS TS Function Function Name Name Desiqnation Designation Neutron Neutron FluxFlux - - High, High, Setdown Setdown (existing)
(existing) 2.a 2.a Fixed Fixed Neutron Neutron Flux-Flux - High High (existing)
(existing) 22.b
.b Inop Inop (existing)
(existing) 2.c 2.c Flow Flow Biased Biased Simulated Simulated ThermalThermal Power Power - HighHigh (existing)
(existing) 2.d 2.d 2-Out-Of-4 2-0ut-Of-4 VoterVoter (new)
(new) 2.e 2.e OPRM OPRM Upscale Upscale (new)(new) 22.f
.f 1 to Attachment to GNRO-2009-00054 GNRO-2009-00054 Page 12 Page 1 2 of of 41 41 The proposed OL The proposed OL and and TSTS changes changes pertaining pertaining to to the the NUMAC NUMAC PRNM PRNM SystemSystem and and these these functions functions areare identified identified and and described described below.below.
4.1 4.1 OL Section OL Section 2.C(2), Technical Specifications 2.C(2), Technical Specifications Section 3.3, Section 3.3, above, above, discusses discusses the OPRM Monitoring the OPRM Monitoring Period.
Period . Entergy Entergy proposes proposes to to conduct the conduct OPRM Monitoring the OPRM Monitoring Period Period as directed by as directed by the the NUMAC NUMAC PRNM PRNM LTR LTR and and thethe NRC beginning NRC beginning at at startup from the startup from 2012 refueling the 2012 refueling outage outage intointo Cycle Cycle 19 19 with with thethe following clarifications and following clarifications and modifications:
modifications :
(1) During During the the monitoring period, the monitoring period, the TS requirements will TS requirements will not apply to not apply to the the OPRM OPRM Upscale function, thereby eliminating the requirement to reduce power to Upscale function, thereby eliminating the requirement to reduce power to << 24%
24%
RTP after 120 RTP after 120 days, days, as as would would be be required required by by new Required Action new Required Action K.1K.1 (see (see Section 4.4.1.3, Section 4.4.1 .3, below) below).. Also, Also, BSP BSP measures measures specified specified in in BWROG BWROG document document OG-02-0119-260 (Reference OG-02-0119-260 (Reference 9) 9) will will be implemented via be implemented procedures to GGNS procedures via GGNS to provide provide an alternate method an alternate method for for detecting detecting and and suppressing suppressing reactorreactor corecore thermal thermal hydraulic instability hydraulic oscillations during instability oscillations during thethe monitoring monitoring period.
period . The The NRC approved NRC approved the use of the Backup Stability Protection measures as an acceptable alternate the use of the Backup Stability Protection measures as an acceptable alternate method method for for Monticello (Reference 10).
Monticello (Reference 10).
(2)
(2) The monitoring The period will monitoring period last for will last for a minimum of a minimum 90 days of 90 days and and maymay be be completed completed prior to completing prior to completing the the fuel fuel cycle cycle if analysis of if analysis of the the collected collected data data indicates indicates the the OPRM OPRM is is functioning properly . Upon functioning properly. Upon completing completing the the monitoring monitoring period, period, the the OPRM Upscale function OPRM Upscale function will will bebe enabled enabled and and subject subject to to all all applicable Technical applicable Technical Specification requirements . The Specification requirements. The NRC approved a NRC approved a 90-day monitoring period 90-day monitoring period for for Monticello (Reference 10).
Monticello (Reference 10).
In In order order to to reflect reflect this approach, Entergy this approach, Entergy proposes proposes to to modify modify OL OL Section Section 2 .C(2).
2.C(2).
Section 2.C(2) currently states in part :
Section 2.C(2) currently states in part:
"Entergy Operations, Inc.
"Entergy Operations, Inc. shall shall operate operate the the facility facility in in accordance accordance with the Technical with the Technical Specifications and the Environmental Plan."
Specifications and the Environmental Plan."
Specifically, Specifically, Entergy Entergy proposes proposes to add aa paragraph to add paragraph to to Section Section 2.C(2) 2.C(2) that that states states::
"During "During Cycle Cycle 19, 19, GGNS GGNS may may conduct conduct monitoring monitoring of of the the Oscillation Oscillation Power Power Range Range Monitor (OPRM}. During this time, the OPRIVI Upscale function (Function 2.f Monitor (OPRM). During this time, the OPRM Upscale function (Function 2.f of of Technical Technical Specification Specification TableTable 3.3 .1 .1-1) may 3.3.1.1-1) may bebe disabled disabled and operated in and operated in an an
`indicate
'indicate only' only' mode mode at at which which time time technical technical specification specification requirements requirements would would not not apply.
apply. During During suchsuch time, time, Backup Backup Stability Stability Protection Protection measures measures will will be be implemented implemented via via GGNS GGNS procedures procedures to to provide provide anan alternate alternate method method to to detect detect andand suppress suppress reactor reactor core core thermal thermal hydraulic hydraulic instability instability oscillations oscillations." ."
Entergy Entergy has has used used thisthis approach approach in in the the past past toto identify identify situations situations in in which which certain certain TS TS requirements would not apply to specific structures, systems, or components for a requirements would not apply to specific structures, systems, or components for a limited limited period period of of time time..
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page 113 Page 3 of of 41 41 Separate from Separate from the above proposal, the above Section 2 proposal, Section .C(2) currently 2.C(2) contains aa paragraph currently contains paragraph pertaining to pertaining to performing performing SRs SRs related related to to previous previous TS TS Amendment Amendment 169. 169 . Since Since the the current amendment current amendment to to the the GGNS GGNS TS TS isis Amendment Amendment 182, this paragraph 182, this paragraph is is no longer no longer applicable . Therefore, applicable. Therefore, Entergy Entergy proposes proposes to to delete it.
delete it.
4.2 TS 15 11.1,
.1Definitions Definitions TS TS 11.1
.1 defines the Fractions defines the Fractions of of Core Core Boiling Boundary (FCBB).
Boiling Boundary (FCBB). As discussed in As discussed in Section 4.3, below, this term and its associated TS is being deleted ; therefore, Entergy Section 4.3, below, this term and its associated TS is being deleted; therefore, Entergy proposes to delete this definition from TS 1 .1 .
proposes to delete this definition from TS 1.1.
4.3 4.3 TS 3.2.4. Fraction 15 3.2.4, Fraction of of Core Core Boiling Boiling Boundary Boundary (FCBB) (FCBB)
As As discussed discussed in in Sections Sections 3.1 3.1 and and 3.3,3.3, above, above, FCBB FCBB is is aa component component of of the Option the Option E-I-A stability solution that ensures the reactor core remains stable when operating E-I-A stability solution that ensures the reactor core remains stable when operating in certain regions certain regions ofof the power/flow map.
the power/flow map . The The new new Option Option III III stability stability solution solution doesdoes notnot use FCBB use FCBB as a component as a component to detect and to detect suppress potential and suppress potential core core instabilities instabilities;;
therefore, therefore, Entergy Entergy proposes proposes to delete TS to delete TS 3.2.4 3.2.4 in its entirety.
in its entirety .
4.4 4.4 TS 3.3.1 .1, Reactor 15 3.3.1.1, Reactor Protection Protection SystemSystem (RPS) (RPS) Instrumentation Instrumentation 4.4.1 4.4.1 Changes to Changes to Limiting Conditions for Limiting Conditions Operation (LCO) for Operation (LCO) 3 .3.1 .1 Actions 3.3.1.1 Actions 4.4.1.1 New New NotesNotes Clarifyinq Required Action Clarifying Required Action A.2 A.2 andand Condition Condition B B In In the the Actions Actions forfor TSTS 33.3.1.1,
.3.1 .1, Entergy Entergy proposes proposes to to add add a a new new note note to to Required Action A.2 Required Action A.2 and and also also to to Condition Condition B. B. These These notes notes indicate indicate thatthat neither Required Action neither Required Action A.2 A.2 nor nor Condition Condition B B apply apply to to new new and and existing existing APRM Functions 2.a, APRM Functions 2.b, 2.c, 2.a, 2.b, 2.c, 22.d,
.d, or or 2.f 2.f when when placing placing an an associated associated channel channel in in the tripped condition; the tripped condition ; rather, rather, itit applies to APRM Function 2.e, only.
applies to APRM Function 2.e, only.
Required Required ActionAction A.2 A.2 is not applicable is not applicable to to the the identified identified APRMAPRM functions because, with the new configuration following NUMAC functions because, with the new configuration following NUMAC PRNM PRNM SystemSystem installation, inoperability of installation, inoperability one APRM/OPRM of one APRM/OPRM channel affects channel affects bothboth RIPS RPS trip trip systems systems.. As discussed in As discussed Section in Section 3.2, above, 3.2, above, each each APRM/OPRM APRM/OPRM channel channel inputs inputs into the 2-Out-Of-4 into the 2-0ut-Of-4 Voters Voters for both RPS for both RPS trip systems . Thus, trip systems. Thus, for for anan inoperable inoperable APRM/OPRM APRM/OPRM channel, channel, Required Required Action Action A.1 must be A.1 must be satisfied satisfied andand is the only action (other than restoring operability) that will restore is the only action (other than restoring operability) that will restore the the capability capability toto accommodate accommodate a a single failure . Also, single failure. Also, Condition Condition B B isis not applicable not applicable because because the the inoperability inoperability of more than of more than oneone required required APRM/OPRM APRM/OPRM channel channel results results in in the the loss loss of of trip capability; thus, trip capability; thus, in in this circumstance, entry this circumstance, entry is is required required into into Condition Condition C, C, as well as as well into as into Condition Condition A A for each channel.
for each channel .
See See Section Section 33.2,.2, above, above, for for aa detailed description of detailed description of the the NUMAC NUMAC PRNM system trip logic .
PRNM system trip logic.
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page 14 of Page 14 of 41 41 4.4.1 .2 4.4.1.2 New New Condition Condition J and Associated J and Associated Required Required ActionsActions J.1 J .1 and and J.2J .2 In In accordance accordance with with Section Section 8.4.2 8.4 .2 of of the the NUMAC NUMAC PRNM PRNM LTR, LTR, Entergy Entergy proposes proposes to to add add new new Action Statement Condition Action Statement Condition JJ for new for new GPRM Upscale Function OPRM Upscale Function 2.f.
2.f. Condition Condition J J addresses addresses a a loss loss of of trip trip capability in capability both RPS in both RPS trip trip systems.
systems.
Condition Condition JJ applies applies to to Function Function 2.f 2 .f when, when, for for an OPRM Upscale an OPRM Upscale channel, channel, thethe Required Required ActionsActions for for Condition Condition A, A, B,B, or or C are not C are not metmet within the within the specified Completion Time.
specified Completion Time. Associated Associated RequiredRequired Actions Actions are implemented to are implemented to address address Condition Condition J. Specifically, Req'uired J. Specifically, Required Action Action J.1 J.1 is added to is added to initiate initiate an an alternate alternate method method of detecting and of detecting and suppressing thermal hydraulic suppressing thermal instability conditions hydraulic instability conditions within within 12 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
hours.
This This alternate alternate method method involves involves temporarily temporarily establishing establishing Backup Backup Stability Protection (BSP} measures specified in Stability Protection (BSP) measures specified in BWROG BWROG document document OG-02-0119-260 OG-02-0119-260 (Reference (Reference 9} 9)2,2 , and and will will bebe controlled controlled by plant by plant procedures . In procedures. In addition, addition, new new Required Required Action Action J.2 J .2 requires requires restoring restoring GPRM OPRM Upscale Upscale trip trip capability capability withinwithin 120 120 daysdays.. TheThe use use of of the the BSP BSP measures as measures as anan alternate alternate methodmethod was was approved approved for for Monticello Monticello by by the NRC (Reference 10).
the NRC (Reference 10).
Condition JJ addresses Condition addresses situations situations where where GPRM OPRM UpscaleUpscale trip trip capability is not maintained . The most likely reason for such aa capability is not maintained. The most likely reason for such condition would condition would be be aa common-mode common-mode software software error, error, which which would would affect affect the four channels the four channels of of the OPRM. The the OPRM. The NRC NRC staffstaff acknowledged in acknowledged in the the Safety Safety Evaluation Evaluation of of the the NUMAC NUMAC PRNM PRNM LTR LTR (References 3 (References 3 and and 4) 4) that that a a significant significant period period of time would of time would be be needed to needed arrange a to arrange a contract contract with with the GPRM software the OPRM software developer, developer, determine the cause of the error, repair the defect, test the determine the cause of the error, repair the defect, test the software software modification, and implement the software upgrade in the plant.
modification, and implement the software upgrade in the plant.
Pursuant to Pursuant to Condition Condition J, J, while while thethe OPRMGPRM softwaresoftware is is being being upgraded, the upgraded, plant would the plant would be be required required by by Required Required Action Action J.1 J.1 toto operate operate under under the BSP measures the BSP measures,, for for up up to 120 days.
to 120 days . During During this this time period, GGNS time period, GGNS management management attention attention wouldwould be be focused focused on on restoring OPRM restoring GPRM operability operability because because the plant would the plant would be be operating operating in in a Required Action that would lead to a mandatory power reduction a Required Action that would lead to a mandatory power reduction to to less less than than 24% reactor thermal 24% reactor thermal power power (RTP)(RTP} via via new new Condition Condition K K (see Section (see 4 .4.1 .3, below)
Section 4.4.1.3, below) ifif OPRMGPRM operability operability is is not not restored restored within 120 days within 120 days..
Entergy also Entergy proposes a also proposes note that a note that states states LCO LCO 3.0.4.b 3.0.4 .b is is not not applicable to applicable to new new Required Required Action Action J.2 J.2.. This This note note allows allows unit restart unitrestart in the in event of the event of a a shutdown shutdown during during the the 120-day 120-day completion completion time.
time.
This This approach approach is is consistent consistent with with the original intent the original intent of of NUMAC NUMAC PRNIVI LTR, which is to allow normal plant operations to PRNM LTR, which is to allow normal plant operations to continue continue 22 The The BSP BSP isis an an update update to to the Interim Corrective the Interim Corrective Actions Actions specified specified in NRC Bulletin in NRC 88-07,Bulletin 88-07, Supplement Supplement 1, 1, Power Power Oscillations Oscillations in in Boiling Boiling Water Water Reactors Reactors (BWRs)
(BWRs). .
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 15 of 41 15 of 41 during during the the recovery recovery time time from from aa hypothesized hypothesized design design problemproblem with with the the Option Option III III algorithms algorithms..
Adding Adding this note avoids this note avoids processing processing exigent exigent TS TS changes changes to to allow allow plant startup plant startup if if aa problem problem arises arises with with the Option III the Option III algorithms algorithms during during the 120-day completion the 120-day completion time time of Required Action of Required Action J.2, J.2, while while still still maintaining plant maintaining plant safety safety..
An An exception exception to to LCO LCO 3.0.43.0 .4 was was notnot included included withinwithin the the NUMAC NUMAC PRNIVI LTR, but has been approved in recent NRC Safety PRNM LTR, but has been approved in recent NRC Safety Evaluations Evaluations for for activating activating the the OPRM OPRM Upscale function at Upscale function at Monticello Monticello (Reference (Reference 10) 10) andand Peach Peach Bottom Bottom UnitsUnits 2 and 3 2 and (Reference 11) 3 (Reference 11) via via a note a note that that reads, reads, "LCO "LCO 3.0.43.0.4 is not applicable."
is not applicable ."
The The NRC NRC stated stated in in the the Peach Peach BottomBottom Safety Evaluation that, Safety Evaluation while that, while not included in not included in the the scope scope of of the the NUMAC NUMAC PRNM PRNM LTR, LTR, the the exception exception to to LCO LCO 3.0 3.0.4.4 would would allowallow the the plant plant to to restart restart in in the event of the event of aa shutdown during the 120-day completion time of the Required shutdown during the 120-day completion time of the Required Action Action.. The The NRC NRC recognized recognized that that thethe original original intent intent "was "was to to allow allow normal normal plant operations to plant operations to continue continue duringduring the the recovery recovery time time fromfrom a a hypothesized hypothesized design design problem problem with with thethe Option Option III III algorithms algorithms." ."
Entergy Entergy revised revised LCO LCO 3.0.43.0.4 in GGNS TS in GGNS Amendment 175 TS Amendment 175 to reflect to reflect NRC-approved NRC-approved changes changes regarding regarding mode mode change limitations via change limitations via BWROG TSTF-359, "Increased BWROG TSTF-359, "Increased Flexibility Flexibility in in Mode Restraints ."
Mode Restraints."
Entergy Entergy hashas modified modified the wording of the wording of the the approved approved note note toto state, state, "LCO 3.0.4.b is not applicable ." The note is applied to Required "LCO 3.0.4.b is not applicable." The note is applied to Required Action Action JJ.2.2 and and reflects reflects standard standard wording currently reflected wording currently reflected in in the the GGNS GGNS TS TS.. Although Although worded worded differently differently from from thethe NRC-approved NRC-approved notes, the intent notes, the intent of of the the proposed proposed note note remains remains the the same same..
4.4.1 .3 4.4.1.3 New New Condition Condition K and Associated K and Associated Required Required Action Action K.1 K.1 In In accordance accordance with with Section Section 8.4.3 8.4.3 of of the NUMAC PRNM the NUMAC PRNM LTR, LTR, Entergy Entergy proposes proposes to add new to add new Condition Condition K. K. Condition Condition K requires K requires reducing power reducing power to to < < 24%
240/0 RTP within 4 RTP within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> hours in accordance with in accordance with Required Required Action Action K.1 K.1 if Condition JJ cannot if Condition cannot be be met (i.e ., required met (Le., required number of number of OPRM OPRM channels channels restored) restored).. By By requiring requiring this this action, action, the the plant would be placed in a condition in which the OPRM Upscale plant would be placed in a condition in which the OPRM Upscale function function is is not not required required to to be be operable operable (see (see Section 4 .4 .3.7.b, Section 4.4.3.7.b, below) .
below).
44.4.2
.4.2 Changes Changes to Surveillance Requirements to Surveillance Requirements (SRs) (SRs) 44.4.2.1
.4 .2.1 SR SR 3.3 .1 .1 .10 -- Channel 3.3.1.1.10 Channel Calibration Calibration Currently, Currently, SR 3.3 .1 .1 .10 requires SR 3.3.1.1.10 channel calibrations requires channel calibrations to to be be performed performed once once every every 184 days . This 184 days. This SR applies to SR applies APRM to APRM Functions 22.a, Functions .a, 2.b, 2.b, and and 2.d, only; itit does 2.d, only; does not not apply apply to any other to any other RPS RPS instrumentation instrumentation functions identified in functions identified in TSTS Table Table 3.3.1 3.3.1.1-1..1-1 . The The SR SR to to GNRO-2009-00054 GNRO-2009-00054 Page 16 Page 16 of of 41 41 also has also has four four notes notes clarifying clarifying application application of of the the SRSR to to APRM APRIVI Functions 2.a Functions 2 .a andand 2.d. 2 .d.
Sections 8.3.4 Sections 8.3.4 and and 8.4.4.3 8.4 .4.3 of of the the NUMAC NUMAC PRNM PRNM LTR LTR provide provide justification justification for for performing performing channel channel calibrations calibrations on on newnew andand existing existing APRIVI Functions APRM Functions 2.a, 2 .a, 2.b, 2.b, 2.d, 2A and and 2.f 2 .f once once everyevery 24 24 months.
months .
Based Based on on this this justification justification and and because because SR 3 .3 . 1 . 1 .10 only SR 3.3.1.1.10 only applies applies to APRIVI to Functions 2.a, APRM Functions 2.a, 2.b, 2 .b, 2.d, 2A andand 2.f, Entergy proposes 2.f, Entergy proposes to to change the change frequency of the frequency SR 3.3.
of SR 1 . 1 .10 from 3.3.1.1.10 from "once "once everyevery 184 184 days" days" to "once to "once every ev~ry 24 months ."
24 months."
In addition In addition to to the the change change in in frequency, frequency, Note Note 4 4 isis deleted deleted.. Note Note 4 4 currently states, "For currently states, Function 22.d, "For Function .d, the digital components the digital components of of the the flow control flow control triptrip reference reference cards cards are are excluded."
excluded." As discussed in As discussed in Section 3 Section .2, 3.2, above, the function performed by the FCTRs have above, the function performed by the FCTRs have been been integrated integrated into into thethe APRIVI APRM circuitry circuitry.. With With thisthis change, change, the the FCTRs are FCTRs removed ; therefore, are removed; therefore, Note Note 4 4 isis no no longer applicable and longer applicable and is is deleted deleted..
4.4.2.2 4.4.2.2 SR 3.3 .1 .1 .16 -
SR 3.3.1.1.16 - Simulated Simulated Thermal Thermal Power Power Time Time Constant Constant To To support support the the current current OptionOption E-I-A stability solution E-I-A stability solution at at GGNS, GGNS, APRIVI Function 2.d APRM Function 2.d usesuses a a simulated simulated thermal thermal powerpower time time constant.
constant .
SR 3.3 .1 .1 .16 requires SR 3.3.1.1.16 requires the the simulated simulated thermal thermal powerpower time time constant constant to to bebe calibrated calibrated once once everyevery 18 18 months.
months . This This SR SR applies applies to to APRM APRIVI Function 2.d, Function 2.d, only; only; itit does does not not apply apply to to any any other other RPS RPS instrumentation instrumentation functions functions identified identified in in TS TS Table Table 3.3.1 3.3.1.1-1..1-1 .
Section Section 88.3.4.3
.3.4.3 of of the the NUMAC NUMAC PRNM PRNM LTR LTR provides provides justification justification for for deleting the requirement to check the simulated thermal power time deleting the requirement to check the simulated thermal power time constant.
constant. Based Based on this justification, on this justification, EntergyEntergy proposes proposes to to delete delete SR SR 3.3 .1 .1 .16 in 3.3.1.1.16 in its its entirety entirety..
4.4.2 .3 4.4.2.3 SR SR 3.3.1 .1 .18 -
3.3.1.1.18 - Recirculation Recirculation Flow Flow Control Control Trip Trip Reference Reference To To support support the the current current OptionOption E-I-A E-I-A stability stability solution solution utilized utilized at at GGNS, GGNS, APRIVI APRM Function Function 22.d .d uses uses aa trip trip level level generated generated by by the the FCTRs FCTRs basedbased on on recirculation recirculation loop loop drive drive flow.
flow. (The(The FCTRs FCTRs are are discussed discussed in in Sections Sections 3.1 and 33.2, 3.1 and .2, above.)
above.) SR SR 33.3.1.1.18
.3 .1 .1 .18 requires requires adjusting adjusting the the FCTRs FCTRs.. This This SR SR applies applies to to APRIVI Function 2.d, APRM Function 2.d, only; only; it does not apply to any other RPS instrumentation functions it does not apply to any other RPS instrumentation functions identified identified in in TSTS Table Table 3.3.1 .1-1 . -
3.3.1.1-1.
As As discussed discussed in in Sections Sections 3.2 3.2 and and 4.4 .2.1, above, 4.4.2.1, above, the the NUMAC NUMAC PRNM PRNM System System with with Option Option III III removes removes this this equipment equipment.. Therefore, Therefore, Entergy Entergy proposes proposes to to delete delete SR SR 33.3.1.1.18
.3.1 .1 .18 in in its its entirety entirety..
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page 17 Page 17 of of 41 41 4 .4 .2.4 4.4.2.4 New SR New SIR 33.3.1.1.19
.3 .1 .1 .19 -- Channel Channel Check Check Currently, Currently, SIR 3.3.1 .1 .1 requires SR 3.3.1.1.1 requires channel channel checks checks to to be performed be performed once every 12 once every hours for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for those functions identified those functions identified in in TS TS Table Table 3.3.1 .1-1 . Included 3.3.1.1-1. Included in in these these functions functions are are existing existing APIRMAPRM Functions Functions 2.a, 2.a, 22.b,.b, and and 2.d2.d..
Sections Sections 8.3.4 8.3.4.1 .1 and and 8.4 .4 .1 of 8.4.4.1 of the the NUMAC NUMAC PRNM PRNM LTR LTR provide provide justification justification for for performing performing channelchannel checkschecks on on new new and and existing existing APIRM APRM Functions Functions 22.a, .a, 2.b, 2.b, 2A2.d, 2.e, and 22.f 2.e, and .f on on a a frequency frequency of of once once every 24 every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> hours.. Because Because other other RPS RPS instrumentation instrumentation functionsfunctions identified in identified in TS TS TableTable 3.3 .1 .1-1 require 3.3.1.1-1 require a a channel channel check check once once every every 12 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> hours per per SIRSR 3.3.1 .1 .1, the 3.3.1.1.1, frequency of the frequency of this this SRSIR cannot cannot be be changed.
changed.
To To implement implement this change, Entergy this change, Entergy proposes proposes to to add add newnew SIRSR 3.3 .1 .1 .19, which 3.3.1.1.19, which requires requires aa channel channel check check once once every every 24 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, hours, and to apply it to new and existing APIRM Functions 2 .a, 2.b, 2.d, and to apply it to new and existing APRM Functions 2.a, 2.b, 2-d, 2.e, 2.e, and and 2.f, 2.f, only.
only. With With thisthis change, change, currentcurrent SIR SR 33.3.1.1.1
.3.1 .1 .1 no longer no longer applies to applies to the the existing existing APRIVI Functions 22.a, APRM Functions .a, 2.b, 2.b, and and 2.d, 2.d, but but remains remains applicable applicable to to the the other other identified identified functions functions..
44.4.2.5
.4.2.5 New New SIR SR 33.3.1.1.20
.3.1 .1 .20 -- Channel Channel Functional Functional Test Test Currently, SRs Currently, SRs 33.3.1.1.3
.3 .1 .1 .3 and and 3.3.1 .1 .8 require 3.3.1.1.8 channel functional require channel functional tests tests to to be performed once be performed once every every 77 daysdays andand 92 days, respectively, 92 days, respectively, for for those those functions functions identified identified in in TS TS Table Table 3.3 .1 .1-1 . Include 3.3.1.1-1. Included d in in these these functions functions are are existing existing APIRM APRM Functions Functions 2.a, 2.a, 2.b, 2.b, 2.c, 2.c, and and 2.d 2.d..
SIR 33.3.1.1.3, SR .3.1 .1 .3, which which applies applies to to APIRM APRM Function Function 2.a, contains a 2.a, contains a note note that that allows allows the the channel channel functional functional test test to be postponed to be postponed for for up up to 12 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when hours when entering entering Mode Mode 22 from from Mode Mode 11..
Sections 8.3.4 Sections 8.3.4.2 .2 and and 8.4 .4 .2 of 8.4.4.2 of the the NUMAC NUMAC PRNM PRNM LTR LTR provide provide justification justification for for performing performing channel functional tests channel functional tests on on new new andand existing existing APIRMAPRM Functions Functions 2 .a, 2.b, 2.a, 2.b, 2.c, 2.c, 2.d, 2.d, 2.e, 2.e, and and 22.f.f on on aa frequency frequency of of once once everyevery 184 184 days. Because SRs days. Because SRs 3.3.1 .1 .3 and 3.3.1.1.3 and 3.3.1 .1- .8 apply 3.3.1.1.8 apply to to other other RPS RPS instrumentation instrumentation functions functions identified identified in in TS Table 3.3.1 TS Table .1-1, the 3.3.1.1-1, the frequencies frequencies of of these these SRs SRs cannot cannot be be changed.
changed.
To To implement implement this this change, Entergy proposes change, Entergy proposes to to add add newnew SR SIR 3 .3.1 .1 .20, which requires a channel functional test once every 3.3.1.1.20, which requires a channel functional test once every 184 184 days, days, and and toto apply apply itit to new and to new and existing existing APIRM Functions 22.a, APRM Functions .a, 2.b, 2.b, 22.c,
.c, 2A 2.d, 2.e, and 22.f, 2.e, and .f, only. With this only. With this change, change, current current SRsSRs 3.3.1 .1 .3 3.3.1.1.3 and 3.3.1 .1 .8 no and 3.3.1.1.8 no longer longer applyapply to to the the existing existing APIRMAPRM Functions Functions 22.a, .a, 22.b,
.b, 2.c, 2.c, and and 2.d2.d butbut remain remain applicable applicable to to the the other identified other identified functions .
functions.
Also in Also in accordance accordance with Section 88.3.4.2 with Section .3.4.2 of of the NUMAC PRNM the NUMAC PRNM LTR, LTR, SIR 3.3.1 .1 .20 includes the following notes :
SR 3.3.1.1.20 includes the following notes:
to to GNRO-2009-00054 GNRO-2009-00054 Page 18 Page 18 of of 41 41 For Function
- 1. For Function 2.a, 2 .a, not not required required to to be be performed performed when when entering Mode entering Mode 2 2 from from Mode 1 until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering Mode 1 until 12 hours after entering Mode 2.
Mode 2.
2 . For
- 2. For Functions Functions 2.a, 2 .b, and 2.a, 2.b, and 2.c, 2.c, the APRM/OPRM channels the APRM/OPRM channels and the and the 2-0ut-Of-4 2-Out-Of-4 Voter Voter channels channels are included in are included in the the channel channel functional functional test. test.
3 . For
- 3. For Functions Functions 2.d and 22.f, 2.d and .f, the APRM/OPRM channels the APRM/OPRM channels and and the 2-Out-Of-4 the 2-0ut-Of-4 Voter Voter channels channels plus plus the the flow input function, flow input function, excluding the excluding the flow flow transmitters, transmitters, are included in are included in the the channel channel functional test.
functional test.
Because Because the 2-Out-Of-4 Voter the 2-0ut-Of-4 Voter is is included included in in the channel functional the channel functional test test for for the other APRM the other APRM functions, Function 2 .e does not require functions, Function 2.e does not require aa separate channel functional test .
separate channel functional test.
4.4.2 .6 4.4.2.6 New New SIR SR 3.3.1 3.3.1.1.21.1 .21- Logic System
- Logic System Functional Functional Test Test Currently, SR Currently, SIR 3.3.1.1.13 3 .3 .1 .1 .13 requires requires a a logic logic system system functional functional test test (LSFT} to be performed once every 18 months for those functions (LSFT) to be performed once every 18 months for those functions identified in identified in TSTS Table Table 3.3.1 .1-1 . Included 3.3.1.1-1. Included in in these these functions functions areare existing APIRM existing APRM Functions Functions 2.a, 2.a, 2.b, 2.c, and 2.b, 2.c, and 2.d 2.d..
Sections 88.3.5 Sections .3 .5 and 8.4 .5 of and 8.4.5 of the the NUMAC NUMAC PRNM PRNM LTR LTR provide provide justification justification to to::
- Delete Delete the the LSFT LSFT requirement requirement from existing APIRM from existing APRM Functions Functions 2.a, 22.b, 2.a, .b, 2.c, 2.c, andand 2.d;2.d ; and and
- Apply Apply an LSFT requirement an LSFT requirement to new APIRM to new APRM Function Function 2.e,2.e, requiring performance once every 24 months.
requiring performance once every 24 months.
Because Because otherother RPS RPS instrumentation instrumentation functions functions identified identified inin TS TS Table Table 3 .3.1 .1-1 3.3.1.1-1 require an LSFT once every 18 months per SIR 3 .3 .1 .1 .13, require an LSFT once every 18 months per SR 3.3.1.1.13, the the frequency frequency of of this this SRSIR cannot cannot be be changed.
changed. Therefore, Therefore, to to implement implement this this change, change, EntergyEntergy proposes proposes to: to:
- a. Delete Delete SIR SR 3.3 .1 .1 .13 from 3.3.1.1.13 from Table Table 3.3.1 .1-1 for 3.3.1.1-1 for existing existing APIRM APRM Functions Functions 2 .a, 2.b, 2.a, 2.b, 2.c, 2.c, and and 2.d; 2.d; andand bb.. Add Add newnew SIR SR 3.3.1 .1 .21,, which 3.3.1.1.21 which requires requires performing performing an LSFT an LSFT once once every every 24 24 months, months, and and apply apply itit to to APIRM APRM Function Function 22.e..e.
With With these these changes, changes, current current SIR SR 3.3.1 .1 .13 no 3.3.1.1.13 no longer longer applies applies to to existing existing APIRM APRM Functions Functions 2.a, 2.a, 2.b, 2.b, 2 .c, and 2.c, and 22.d,.d, but but remains remains applicable applicable to to the the other other identified identified functions.
functions.
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page 19 Page 19 of of 41 41 4.4.2.7 4.4.2.7 New SR New SR 3.3.1.1.22 3 .3.1 .1 .22 -- Response Response Time Testing Time Testing Currently, Currently, SR SR 3.3.1.1.15 3 .3.1 .1 .15 requires response time requires response testing to time testing to be be performed once every 18 months on a staggered basis for those performed once every 18 months on a staggered basis for those functions identified in functions identified TS Table in TS Table 3.3.1.1-1.
3 .3.1 .1-1 . Included Included in in these these functions functions areare existing existing APRMAPRM Functions Functions 2.b and 2.d.
2.b and 2 .d.
Section 8 .3.4.4 of Section 8.3.4.4 the NUMAC of the NUMAC PRNM PRNM LTR provides justification LTR provides justification to:
to
- Delete the Delete the response response time time testing requirement testing requirement from from existing existing APRM Functions 2 .b and APRM Functions 2.b and 2.d ; and 2.d; and
- Apply aa response Apply response time testing requirement time testing requirement to to new new APRM APRM Function Function 2.e, 2.e, requiring performance once requiring performance once every every 24 months on 24 months on a a staggered basis. (Although the NUMAC PRNM LTR discusses staggered basis. (Although the NUMAC PRNM LTR discusses applying applying staggered staggered testingtesting to the 2-0ut-Of-4 to the 2-Out-Of-4 Voter Voter function, function, itit provides provides no no specific specific changes changes to to the SRs or the SRs or Bases Bases to to define define the the testing testing requirements requirements.).)
Because other Because other RPS instrumentation functions RPS instrumentation functions identified identified in in TS Table TS Table 3.3 .1 .1-1 require a response time test once every 18 months per 3.3.1.1-1 require a response time test once every 18 months per SR SR 3.3 .1 .1 .15, the 3.3.1.1.15, the frequency frequency of of this this SR SR cannot cannot be be changed.
changed.
Therefore, Therefore, to to implement implement these changes, Entergy these changes, Entergy proposes proposes to: to:
- a. Delete Delete SR SR 3.3 .1 .1 .15 from 3.3.1.1.15 from Table Table 3.3 .1 .1-1 for 3.3.1.1-1 for existing existing APRM APRM Functions Functions 22.b .b and and 2.d2.d..
b.
- b. Add Add newnew SR SR 33.3.1.1.22,
.3.1 .1 .22, which which requires requires performing performing response response time testing once every 24 months on a staggered basis, and time testing once every 24 months on a staggered basis, and apply apply itit to to APRM APRM Function Function 2.e. 2.e.
- c. Add Add aa note note to to SR SR 3.3.1 .1 .22 that 3.3.1.1.22 that defines defines the the testing testing requirements requirements by by stating stating::
"For "For Function Function 2.e, 2.e, W 'n' equals equals 88 channels channels for for the the purpose purpose of of determining the STAGGERED TEST BASIS Frequency.
determining the STAGGERED TEST BASIS Frequency.
Testing Testing APRMAPRM and and OPRM OPRM outputsoutputs shall shall alternate."
alternate."
Adding Adding thisthis note note waswas approved approved by by the the NRCNRC in in the the Safety Safety Evaluation Evaluation for for Monticello Monticello (Reference (Reference 10) 10) and and Brunswick Brunswick UnitsUnits I1 and 2 (Reference 12) .
and 2 (Reference 12).
With With these these changes, changes, SR SR 33.3.1.1.15
.3.1 .1 .15 no no longer longer applies applies to to existing existing APRM APRM Functions Functions 22.b .b and and 2A 2.d, but but remains remains applicable applicable to to the the other other identified identified functions.
functions.
to to GNRO-2009-00054 GNRO-2009-00054 Page 20 Page 20 of of 41 41 4.4 .2.8 4.4.2.8 New New SR SR 3.3.1.1.23 3.3 .1 .1 .23 -- Verify Verify OPRM PRM not not Bypassed Bypassed In accordance In accordance with Section 8.4.4.2 with Section 8 .4 .4.2 inin Supplement Supplement 1 1 of of the the NUMAC NUMAC PRNM LTR, PRNM LTR, Entergy Entergy proposes proposes new new SR SR 3.3.1.1.23 3.3 .1 .1 .23 to to verify verify that the that the OPRM OPRM auto-enable setpoints are auto-enable setpoints are correctly correctly set.
set . SR SR 3.3.1.1.23 3.3.1 .1 .23 applies to applies to new new APRM Function 2.f APRM Function 2 .f (see (see Section Section 4.4.3.7, 4.4 .3.7, below).
below) .
This verification This verification is is to be performed to be performed once once every every 24 24 months.
months .
New SR New 3.3.1 .1 .23 verifies SR 3.3.1.1.23 verifies APRM Function 2.f APRM Function 2.f is is not not bypassed bypassed when the when APRM Simulated the APRM Simulated ThermalThermal Power Power isis ~> 29%
29% RTPRTP and the and the recirculation recirculation drive drive flow flow isis < 60% of
< 600/0 of rated recirculation drive rated recirculation drive flow.
flow.
The settings The settings forfor this this auto-enable (not-bypassed) region auto-enable (not-bypassed) region have have been been determined determined for GGNS and for GGNS and are are established established as as nominal setpoints nominal setpoints only, only, as as described described in in the the proposed proposed TS TS Bases Bases markup markup and and designated in SR 3.3.1 .1 .23 .
designated in SR 3.3.1.1.23.
4 .4.3 4.4.3 Changes Changes to to TS TS Table Table 3.3.1 Reactor Protection
.1-1, Reactor 3.3.1.1-1, Protection SYstem System Instrumentation Instrumentation Four functions Four functions are are currently currently included included underunder the the APRM heading (Function APRM heading (Function 2) in
- 2) in TS Table 3.3 .1 .1-1 :
TS Table 3.3.1.1-1:
0* Neutron Neutron FluxFlux -- High, High, Setdown Setdown (Function (Function 2.a) 2.a) 0* Fixed Neutron Fixed Neutron Flux Flux -- High High (Function (Function 22.b) .b)
I* Inop (Function Inop (Function 2.c) 2.c) 0* Flow Biased Simulated Flow Biased Simulated Thermal Thermal Power Power -- High (Function 2A)
High (Function 2.d)..
Installing the Installing the NUMAC NUMAC PRNM PRNM SystemSystem requires requires modifying modifying thethe TS TS table by table by adding adding two two new new APRM APRM functions functions::
I* 2-Out-Of-4 2-0ut-Of-4 Voter Voter (new (new Function Function 22.e) .e) and and I* OPRM OPRM Upscale Upscale (new(new Function Function 22.f) .f)
These These werewere previously previously discussed discussed in Section 3.2, in Section 3.2, above.
above.
For For each each ofof the the new new andand existing existing APRM APRM functions, functions, corresponding corresponding changes changes are are required required toto TS TS Table Table 3.3.1 .1-1 to 3.3.1.1-1 to reflect reflect the the following following criteria, criteria, asas applicable applicable::
- Applicable Applicable Modes Modes or or Other Other Specified Specified Conditions Conditions
- Required Required Channels Channels per per Trip Trip System System
- Conditions Conditions Referenced Referenced from from Required Required Action Action D.10.1 0* Surveillance Surveillance Requirements Requirements
- Allowable Allowable Values Values 1 to Attachment to GNRO-2009-00054 GNRO-2009-00054 Page 2 1 of Page 21 of 41 41 Entergy proposes Entergy proposes thethe following following changeschanges and and additions additions to to TS TS Table Table 3.3.1.1-1:
3 .3 .1 .1-1 :
4 .4-3.1 4.4.3.1 Addition Addition of of New New Notes Notes to to Clarify Requirements for Clarify Requirements APRM Functions for APRM Functions
- a. In accordance In accordance with Section 8.3.2 with Section 8.3.2.4.4 of of the the NUMAC NUMAC PRNM PRNM L LTR, TR, reflect reflect the the new new NUMAC NUMAC PRNM PRNM System System configuration configuration (Le., (i .e., the the identified identified APRM/{JPRM APRM/OPRM channel channel provides provides inputs inputs to to both both RPS RPS trip systems) trip systems) by adding new by adding new Note Note (c).
(c) . Note Note (c) states :
(c) states:
'Each channel "Each channel provides provides inputsinputs toto both both trip trip systems."
systems ."
Apply this Apply this note note to APRM Functions to APRM 2 .a, 2.b, Functions 2.a, 2.c, 2.d, 2.b, 2.c, 2.d, andand 2.f, 2 .f, as as identified identified in in the the individual individual sections, sections, below.
below.
b.
- b. Reflect Reflect application application of actions to of actions to address address the industry setpoint the industry setpoint methodology methodology issue issue as documented in TSTF-493, Clarify as documented in TSTF-493, Clarify Application Application of Setpoint Methodology of Setpoint Methodology for for LSSS LSSS Functions, Functions, (Reference (Reference 13) 13) by adding new by adding new Notes Notes (d) (d) and (e), as and (e), as follows:
follows :
i)i) Note Note (d) states :
(d) states:
"If the as-found "If the as-found channelchannel setpoint setpoint is outside its is outside its predefined predefined as-found as-found tolerance, tolerance, then then the channel shall the channel shall bebe evaluated evaluated to to verify verify that that itit is functioning as is functioning as required required beforebefore returning returning the the channel channel to to service service." ."
ii) Note Note (e) states :
(e) states:
"The instrument "The instrument channel channel setpoint setpoint shallshall bebe reset reset to to aa value value that that isis within within thethe as-left tolerance around as-left tolerance around the the Nominal Nominal Trip Trip Setpoint (NTSP}
Setpoint (NTSP) at at the completion of the completion of the the surveillance surveillance;;
otherwise, otherwise, the the channel cha'nnel shallshall bebe declared inoperable..
declared inoperable Setpoints more conservative than the NTSP are Setpoints more conservative than the NTSP are acceptable acceptable providedprovided the the as-found as-found and and as-left as-left tolerances tolerances apply apply to to the the actual actual setpoint setpoint implemented implemented in in the the Surveillance Surveillance procedures procedures to to confirm confirm channel channel performance performance..
The The NTSP NTSP and and the the methodologies methodologies used used to determine the to determine the as-found as-found and and as-left as-left tolerances tolerances are are specified specified in in the the Technical Technical Requirements Requirements Manual Manual." ."
Apply Apply these these notes notes to to the the channel channel calibration calibration SR SR 33.3.1.1.10
.3. 1 . 1 .10 listings for APRM Functions 2 .a, 2.b, 2 .d, and 22.1, listings for APRM Functions 2.a, 2.b, 2.d, and .f, as as identified identified in in the the individual individual sections, sections, below below..
Refer Refer to to Section Section 5.1 .5, below, 5.1.5, below, for for additional additional discussion discussion of of the the setpoint setpoint methodology methodology issue. issue.
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page 22 Page 22 of of 41 41 C.
- c. In accordance In accordance with Section 8.4.6.1 with Section 8 .4 .6 .1 of of the the NUMAC NUMAC PRNM PRNM LTR,LTR, add new add new Note Note (f)(f) to to denote denote thatthat the the Allowable Allowable Value Value is is contained contained in in the Core Operating the Core Operating Limits Limits Report Report (COLR).
{COLR} . NoteNote (f) states:
(f) states :
"The Allowable "The Allowable Value Value forfor thethe OPRM OPRM Upscale Upscale Period-Period-Based Detection algorithm is specified in the COLR."
Based Detection algorithm is specified in the COLR."
This This note note is is applied applied to to new new APRM APRM Function Function 2.f, 2 .f, as as discussed discussed in in Section 4 .4.3.7, below. Placing the OPRM Upscale Allowable Section 4.4.3.7, below. Placing the OPRM Upscale Allowable Value Value in in the the COLR COLR was was approved approved by by the the NRC NRC for for Monticello Monticello (Reference 10).
(Reference 10) .
4 .4 .3.2 4.4.3.2 Neutron Neutron Flux Flux - High, Setdown
- High. Setdown (existing Fun ction 2.a)
(existing Function This existing This existing function function compares compares APRM APRM flux flux toto an adjustable trip an adjustable trip with with an Allowable an Allowable Value Value set set atat ~ < 200/0 20% RTP RTP and activated in and activated in Mode Mode 22 (bypassed (bypassed in in the other Modes).
the other Modes). Three Three channels channels are are required required forfor operability . No operability. No change change in in the the Allowable Allowable Value Value is is required required..
APRM APRM FunctionFunction 2.a 2.a has has been retained but been retained but modified modified in in TS TS Table Table 33.3.1.1-1
.3 .1 .1-1 as follows :
as follows:
a.
- a. Apply Apply new new NoteNote (c)(c) toto the the "Required "Required Channels Channels per per Trip Trip System" System" value, value, as discussed in Section 4 .4.3.1 .a, above.
as discussed in Section 4.4.3.1.a, above.
b.
- b. Reflect the Reflect following changes the following changes to to the the list list of applicable SRs:
of applicable SRs :
i) i) Delete Delete SR SR 33.3.1.1.1
.3.1 .1 .1 and and add add new new SR SR 3.3.1 .1 .19 as 3.3.1.1.19 as discussed discussed in in Section Section 44.4.2.4,
.4.2.4, above.
above.
ii) ii) Delete Delete SR SR 3.3 .1 .1 .3 and 3.3.1.1.3 and add add new new SR SR 3.3.1 .1 .20 as 3.3.1.1.20 as discussed in Section 4 .4 .2.5, above.
discussed in Section 4.4.2.5, above.
iii) iii) Delete Delete the the -requirement requirement to to perform perform LSFTs LSFTs by by deleting deleting SR SR 3.3.1 .1 .13, as discussed in Section 4.4.2.6, above.
3.3.1.1.13, as discussed in Section 4.4.2.6, above.
c.
- c. Apply Apply new new Notes Notes (d)
(d) and and (e)
(e) toto the the channel channel calibration calibration SR SR 3.3 . 1 . 1 .10 listing, 3.3.1.1.10 listing, as discussed in Section 4 .4.3.1 .b, above.
as discussed in Section 4.4.3.1.b, above.
44.4.3.3
.4.3.3 Fixed Fixed Neutron Neutron Flux- Flux - High, (existing Function High. (existing Function 2.b) 2.b)
This This existing existing function function compares compares APRM APRM neutron neutron fluxflux to to aa fixed fixed trip trip setpoint with an Allowable Value of < 120% RTP . Function 2-b is setpoint with an Allowable Value of ~ 120% RTP. Function 2.b is required required to to bebe operable operable in in Mode Mode 11 with with three three channels channels required required perper trip trip system system.. No No change change to to the the Allowable Allowable Value Value is is required required.. ThisThis function function is is standard standard for for the the BWR/6 BWR/6 design design..
APRM APRM FunctionFunction 2.b 2.b has has been been retained retained but but modified modified in TS Table in TS Table 3.3.1 3.3.1.1-1:1-1 asas follows follows::
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page 23 Page 23 of of 41 41
- a. Apply Apply new new NoteNote (c) (c) toto the the "Required "Required ChannelsChannels per per Trip Trip System" System" value,value, as discussed in as discussed in Section Section 44.4.3.1.a,
.4.3.1 .a, above.
above.
b.
- b. Reflect Reflect thethe following following changeschanges to to the the list of applicable list of applicable SRs: SRs :
i) Delete SR Delete SR 3.3.1 3.3.1.1.1 .1 .1 and and addadd new new SR 3.3.1 .1 .19 as SR 3.3.1.1.19 as discussed discussed in in Section Section 4.4.2.4, above.
4.4.2.4, above.
ii) ii) Delete Delete SR SR 33.3.1.1.8
.3.1 .1 .8 andand addadd new new SR 3.3.1 .1 .20 as SR 3.3.1.1.20 as discussed discussed in in Section Section 4.4.2.5.
4.4.2.5, above above. .
iii) iii) Delete Delete the the requirement requirement to to perform perform LSFTs LSFTs by deleting SR by deleting SR 3.3 .1 .1 .13, as discussed in Section 4.4.2.6, above .
3.3.1.1.13, as discussed in Section 4.4.2.6, above.
iv) iv) Delete Delete the requirement to the requirement to perform perform response response time time testing testing by deleting SR 3.3 .1 .1 .15, as discussed in Section 4.4.2.7, by deleting SR 3.3.1.1.15, as discussed in Section 4.4.2.7, above.
above.
- c. Apply Apply new new NotesNotes (d) (d) andand (e)
(e) to the channel to the channel calibration calibration SR SR 3.3.1 .1 .10 listing, 3.3.1.1.10 listing, as as discussed discussed in in Section 4 .4.3.1 .b, above Section 4.4.3.1.b, above..
4.4 .3 .4 4.4.3.4 Inop (existing Function Inop (existing Function 22.c) .c This existing This existing function function ensures ensures that that a a minimum minimum number number of of APRMs APRMs are are operable.
operable. Anytime Anytime an an APRM APRM mode mode switchswitch is is moved moved to any to any position position otherother than "Operate," an than "Operate," an APRM APRM module module is unplugged, the is unplugged, the electronic electronic operating operating voltagevoltage is is low, low, or or the the APRM APRM has has too few LP too few LPRM inputs, inputs, an an inoperative inoperative trip trip signal
~ignal is is sent sent to to the the RPSRPS.. Function Function 22.c .c is is required to be operable in Modes 1 and required to be operable in Modes 1 and 22 with with three three channels channels required required per per trip trip system system.. No No Allowable Allowable Value Value is applicable to is applicable to Function Function 2.c. 2.c.
As discussed As discussed in Section 8.3.1 in Section 8.3.1 of of the the NUMACNUMAC PRNM PRNM LTR, LTR, thethe NUMAC NUMAC PRNM PRNM System System design design has has removed removed the the LPRM LPRM detector detector count count from from the automatic Inop the automatic Inop trip; however, itit is trip; however, is retained retained in in the the Inop alarm.
Inop alarm . SR 3.3 .1 .1 .7, which SR 3.3.1.1.7, which requires calibrating the requires calibrating the LPRM LPRM detectors, detectors, was was used used to to ensure ensure the minimum LPRM the minimum LPRM detectordetector countcount was satisfied . With the removal of this parameter from Function was satisfied. With the removal of this parameter from Function 22.c,
.c, this this SRSR isis nono longer required . This longer required. This change change is is consistent consistent with with the TS the marked-up pages TS marked-up pages contained contained in in NUMAC NUMAC PRNM PRNM LTR, LTR, Vol Vol.. 2 2
and and Supplement Supplement 11..
APRM APRM Function Function 2.c 2.c has has been retained but been retained but modified modified in in TS TS Table Table 33.3.1.1-1
.3 .1 .1-1 asas follows follows::
a.
- a. Apply Apply new new Note Note (c) (c) toto the the "Required "Required Channels Channels per per Trip Trip System" System" value,value, as as discussed discussed in in Section Section 4.4.3 4.4.3.1.a,.1 .a, above.
above.
- b. Reflect the Reflect the following following changeschanges to to the the list list of of applicable applicable SRs: SRs :
to to GNRO-2009-00054 GNRO-2009-00054 Page 24 of Page 24 of 41 41 i) i) Delete SR Delete SR 3.3.1 .1 .7, as 3.3.1.1.7, as discussed discussed above. above.
ii) ii) Delete SR Delete SR 3.3.1 3.3.1.1.8.1 .8 and and add add new new SR SR 3.3.1 .1 .20 as 3.3.1.1.20 as discussed in Section 4 .4 .2.5, above.
discussed in Section 4.4.2.5, above.
iii) iii) Delete the Delete the requirement requirement to perform LSFTs to perform LSFTs by by deleting deleting SRSR 3 .3.1 .1 .13, as discussed in Section 4 .4 .2 .6, above.
3.3.1.1.13, as discussed in Section 4.4.2.6, above.
4.4.3 .5 4.4.3.5 Flow Biased Flow Biased Simulated Simulated ThermalThermal Power- Power - High Hi (existing Function 2.d)
This existing function This existing function compares compares filteredfiltered fluxflux (simulated (simulated thermalthermal power) to power) to aa variable variable flow-biased flow-biased trip point and trip point and alsoalso includes includes a clamp a clamp to assure that to assure that the the variable variable trip does not trip does not exceed exceed an an Allowable Allowable Value,Value, which which is is currently currently depicted depicted in in the the GGNS GGNS COLR. COLR. Function Function 2.d 2.d is is required required to be operable to be operable in Mode 11 with in Mode with three channels required three channels required perper trip trip system system.. This This function function is is standard standard for for the the BWR/6 BWRl6 design.design .
APRM APRM Function Function 22.d .d has has been retained but been retained modified in but modified in TS TS Table Table 3.3 .1 .1-1 as follows :
3.3.1.1-1 as follows:
a.
- a. Currently, Currently, the the Allowable Allowable Values Values for for APRM APRM Function Function 22.d .d are are depicted in the GGNS COLR. With the change in core stability depicted in the GGNS COLR. With the change in core stability solution solution from from Option Option E-I-AE-I-A to to Option Option III III (see (see Section Section 3.3, 3.3, above),
above), these these values values will will no longer be no longer be cycle-specific cycle-specific;; therefore, therefore, they they are are being being identified identified in in TS Table 3.3.1.1-1.
TS Table 3.3.1 .1-1 . Thi This s is is accomplished accomplished by by revising revising existing existing Note Note (b) (b) to to state:
state:
"Two-Loop "Two-Loop Operation Operation:: 0.65W O.65W ++ 62 62.9%.9% RTP RTP and and clamped clamped at at 113% RTP 1130/0 RTP "Single-Loop "Single-Loop OperationOperation:: 0.65W 0.65W ++ 42 42.3%.3% RTP" RTP" (W
(W is is total total recirculation recirculation drive drive flow flow in in percent percent of of rated rated flow.)
flow.)
The The Allowable Allowable ValuesValues have have beenbeen confirmed confirmed in in GEH GEH ReportReport 0000-0102-8815, Instrument Limits Calculation - Average 0000-0102-8815, Instrument Limits Calculation -Average Power Power Range Range Monitor-Monitor - Power Power Range Range NeutronNeutron Monitoring Monitoring System System (NUMAC) (NUMAC) - - CLTP CLTP Operation Operation (Reference (Reference 14) 14)..
In In addition, addition, Entergy Entergy proposes proposes an an editorial editorial change change to to reposition reposition the the reference reference for for Note Note (b) (b) located located the the "ALLOWABLE "ALLOWABLE VALUES" VALUES" column column of of TS TS Table Table 3.3.13.3.1.1-1.1-1 toto align align with with thethe first first rowrow of of APRM APRM FunctionFunction 2.d 2.d information information in in the the table.
table.
bb.. Apply Apply new Note (c) new Note (c) to to the the "Required "Required ChannelsChannels per per Trip Trip System" System" value, value, as as discussed discussed in Section 44.4.3.1.a, in Section .4.3.1 .a, above .
above.
c.
- c. Reflect Reflect the the following following changes changes to to the the list list ofof applicable applicable SRs SRs::
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page 25 Page 25 of 41 of 41 i) Delete Delete SR SR 3.3.1 .1 .1 and 3.3.1.1.1 and addadd newnew SR SR 3.3.1.1.19 3 .3.1 .1 .19 as as discussed in Section 4.4.2.4, above.
discussed in Section 4.4.2.4, above.
ii) Delete Delete SR SR 3.3.1 .1 .8 and 3.3.1.1.8 and addadd newnew SR SR 3.3.1.1.20 3 .3 .1 .1 .20 asas discussed in Section 4.4.2.5, above .
discussed in Section 4.4.2.5, above.
iii) Delete Delete the the requirement requirement to to perform perform LSFTsLSFTs by by deleting deleting SR SR 3 .3 .1 .1 .13, as 3.3.1.1.13, as discussed discussed in in Section 4.4-2.6, above.
Section 4.4.2.6, above.
iv) Delete Delete the the requirement requirement to to perform perform response response time time testing testing by by deleting deleting SR 3.3.1 .1 .15, as SR 3.3.1.1.15, as discussed discussed in in Section Section 4.4.2.7, 4.4 .2.7, above.
above.
V) v) Delete Delete the the requirement requirement to to verify verify the simulated thermal the simulated thermal power constant by power constant by deleting deleting SR SR 3.3.1.1.16, 3.3.1 .1 .16, as as discussed discussed in in Section 4.4 Section .2 .2, above.
4.4.2.2, above.
vi) Delete Delete the the requirement requirement to to adjust adjust thethe FCTR FCTR by by deleting deleting SR 3.3.1 SR .1 .18, as 3.3.1.1.18, as discussed discussed in Section 4 in Section .4 .2 .3, above.
4.4.2.3, above .
d
- d. Apply Apply newnew NotesNotes (d) and (e)
(d) and (e) to the channel to the calibration SR channel calibration SR 3.3.1 .1 .10 listing, 3.3.1.1.10 listing, as as discussed discussed in in Section 4.4.3 Section .1 4.4.3.1.b, .b, above .
above.
4.4 .3.6 4.4.3.6 .2-Out-Of-4 2-0ut-Of-4 Voter Voter (new(new . Function Function 2.e) 2.e)
In In accordance accordance with with Section Section 8.3.1 8.3.1.2.2 of of the the NUMAC NUMAC PRNM PRNM LTR, LTR, this this new function function facilitates minimum operable facilitates minimum channel definition operable channel definition and and associated actions.
associated actions. UnlikeUnlike the other APRM the other APRM functions, functions, each each 2-Out-Of-4 Voter does, not provide inputs to both RPS 2-0ut-Of-4 Voter does not provide inputs to both RPS trip trip systems.
systems.
See Section See Section 3.2, above, for 3.2, above, for additional additional information information pertaining pertaining to to the the 2-Out-Of-4 Voter 2-0ut-Of-4 channel and Voter channel and itsits configuration.
configuration .
APRM APRM Function Function 2.e 2.e isis added added to to TS TS Table Table 3.3.1.1-1 3 .3.1 .1-1 with with the the following following denotations, denotations, which which are are consistent consistent with the NUMAC with the NUMAC PRNM PRNM LTR requirements :
LTR requirements:
a.
- a. Add Function Add Function 2.e, 2 .e, "2-Out-Of-4 "2-0ut-Of-4 Voter,"
Voter," to to the the "Function" "Function" column.
column .
b.
- b. Specify Specify the "Applicable MODES the "Applicable MODES or Other Specified or Other Specified Conditions" Conditions" to be to be "1, 1, 2" 2" to reflect the to reflect associated Modes the associated Modes specified specified for for the the APRM functions, APRM functions, which which input input into into this this function function..
c.
C. Specify Specify the the "Required "Required ChannelsChannels per per Trip Trip System" System" to to be be "2" "2" in in accordance with Section 8.3.2 of the NUMAC PRNM LTR.
accordance with Section 8.3.2 of the NUMAC PRNM LTR.
d.
- d. Specify Specify the the "Conditions "Conditions Referenced Referenced from Required Action from Required Action D.1" D .1" to be "H." Current TS Condition H provides a conservative to be "H." Current TS Condition H provides a conservative default condition when default condition when the the lower lower tier tier conditions associated with conditions associated with combinations of combinations channel / function // RPS of channel/function RPS triptrip capability capability cannot cannot
Attachment 11 to Attachment to GNRO-2009-00054 GNRO-2009-00054 Page 26 Page 26 of of 41 41 bebe met.
met. ThatThat is,is, itit requires requires the the plant plant to to be be placed placed in in aa mode mode in in which the which the function function is is not not required.
required .
e.e. Apply the Apply the following following SRs SRs in in accordance accordance with with the the noted noted sections sections of the of the NUMAC NUMAC PRNM PRNM LTR: LTR :
i)i) SR 3.3.1.1.19 SR 3.3.1 .1 .19 -- ChannelChannel Check Check (8.3.4.1)
(8.3.4.1) ii)i) SR 3.3.1.1.20 SR 3.3.1 .1 .20 -- ChannelChannel Functional Functional Test Test (8.3.4.2, (8.3.4.2, 8.4.4.2) 8.4.4.2) iii) iii) SR 3.3.1.1.21 SR 3 .3.1 .1 .21-LEFT - LSFT (8.3.5.2,(8.3.5.2, 8.4.5.2) 8.4 .5 .2) iv)v) SR 3.3.1.1.22 SR 3.3.1 .1 .22 -- Response Response Time Time Testing Testing (8.3.4.4)
(8 .3.4.4) f.f. Specify the Specify the "Allowable "Allowable Value" Value" to to bebe "NA";
"NA"; no no allowable allowable value value is is applicable to applicable to the 2-Out-Of-4 Voter the 2-0ut-Of-4 Voter function.
function .
4.4 .3.7 4.4.3.7 QPRM Upscale OPRM Upscale (new (new Function Function 2.f) 2.f)
As discussed As discussed in in Sections Sections 3.3.2 3 .3.2 andand 8.4 8 .4 of of the NUMAC PRNM the NUMAC PRNM LTR, LTR, this new this new function function provides provides the the capability capability to to detect detect and suppress and suppress reactor thermal-hydraulic reactor thermal-hydraulic instabilities.instabilities . This This instability instability trip trip function function is is defined by defined by the the BWROG BWROG as as Option Option III III in in NEDO-31960-A NEDO-31960-A and and Supplement 11 (Reference Supplement (Reference 6). NEDO-32465-A, BWR 6). NEDO-32465-A, BWR Owners' Owners' Group Reactor Stability Detect and Suppress Solutions Licensing Group Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology Basis Methodology for for Reload Reload Applications, Applications, (Reference (Reference 15) defines
- 15) defines the the Option Option III III implementation implementation requirements requirements for for basic logic and basic logic and algorithms, algorithms, provides provides the the licensing licensing basis basis for for specific specific requirements, requirements, and and defines defines the the process process by by which which plantsplants demonstrate demonstrate safety safety limit limit protection.
protection.
The The minimum minimum number number of of 4PRM OPRM cells cells required required for for OPRM OPRM Upscale Upscale operability operability (30) (30) is is defined defined by by GEH GEH analyses analyses performed performed in in accordance accordance with with GEH GEH LTR LTR NEDO-32465-A NEDO-32465-A based based on on selecting selecting the the OPRM OPRM cell cell assignments assignments and and aa requirement requirement for for aa minimum minimum of of two two LPRMs LPRMs per per cell.
cell. The The setpoint setpoint is is established established to to conform conform to to the the licensing licensing bases bases defined defined in in NEDO-31960-A NEDO-31960-A and and NEDO-32465-A NEDO-32465-A consistent consistent with with thethe guidance guidance provided provided in in the the NUMAC NUMAC PRNM PRNM LTR LTR..
The The OPRM OPRM Period-Based Period-Based Detection Detection algorithm algorithm Upscale Upscale trip trip setpoint setpoint is is determined determined using using thethe Option Option III III reload reload licensing licensing methodology methodology described described in in NEDO-32465-A NEDO-32465-A (Reference (Reference 15) 15) with with the the exception exception that that aa plant/cycle-specific plant/cycle-specific D IVOM3 DIVOM curve 3 curve slopeslope is is applied applied in in place place of of the the generic generic DIVOM DIVOM curve curve slope.
slope. As As described described in in the the NRC NRC staff staff Safety Safety Evaluation Evaluation for for activating activating the the OPRM OPRM trip trip for for Peach Peach Bottom Bottom (Reference (Reference 11), 11), this this change change from from the the original original LTR LTR licensing licensing basisbasis was was necessitated necessitated by by the the BWROGBWROG resolution resolution of of aa 10 10 CFRCFR Part Part 2121 report report filed filed by by GEHGEH (then (then GeneralGeneral Electric)
Electric)..
3 DIVOM DIVOM -- Delta Qelta CPR CPR over over Initial Initial MCPR MCPRversus yersus thethe Oscillation Oscillation Magnitude Magnitude to to GNRO-2009-00054 GNRO-2009-00054 Page 27 of Page 27 of 41 41 The Period-Based The Period-Based Detection Detection algorithm algorithm includes includes several several "tuning" "tuning" parameters.
parameters. These These parameters, parameters, as has been as has been the case for the case for other other licensees, licensees, will will be be established established in in accordance accordance with with GGNS GGNS procedures procedures as part of as part of the the system system setupsetup and and calibration, calibration, and will be and will be defined defined in in plant procedures .
plant procedures.
The Period-Based The Period-Based Detection Detection algorithm algorithm triptrip setpoint, which can setpoint, which can change change with with each each new new fuelfuel cycle, cycle, will will be be documented documented in in the COLR.
the COLR.
Since Since the the OPRM OPRM Upscale function trip Upscale function trip setpoint setpoint is cycle-specific, itit is cycle-specific, meets meets the the requirements requirements for for inclusion inclusion in in the COLR. Also, the COLR. Also, thisthis approach approach provides provides the the same same information information as previously approved as previously approved for for other licensees and is consistent with the ITS format for references other licensees and is consistent with the ITS format for references to parameters to parameters provided provided in in the the COLR COLR and and with the NUMAC with the NUMAC PRNM PRNM LTR requirements. The LTR requirements. The NRCNRC approved approved placing placing thethe OPRIVI OPRM UpscaleUpscale trip setpoint trip setpoint in in the the COLR COLR for for Monticello (Reference 10).
Monticello (Reference 10).
There There are are also also setpoints setpoints for for the the defense-in-depth defense-in-depth algorithms, algorithms, i.e., i.e.,
the Amplitude-Based the Amplitude-Based algorithm algorithm and and thethe Growth-Rate Growth-Rate algorithm, algorithm, which are which are discussed discussed in in the the OPRM Upscale function OPRM Upscale function description description within the within draft TS the draft TS Bases Bases markup.markup . TheseThese algorithms, algorithms, together together with with the Period-Based Detection algorithm, are treated as nominal the Period-Based Detection algorithm, are treated as nominal setpoints setpoints basedbased on on qualitative qualitative studies studies documented documented in in Appendix Appendix A A ofof NEDO-32465-A NEDO-32465-A (Reference (Reference 15). 15). UseUse of of Appendix Appendix A A of of NEDO-32465-A NEDO-32465-A as as aa basis basis forfor establishing establishing these these defense-in-depth defense-in-depth settings settings is is consistent consistent with with thethe approach approach used used by by other other license licensees (and (and approved approved by by the the NRC)
NRC) for for activating activating the OPRM Upscale the OPRM Upscale function function.. The The Amplitude-Based Amplitude-Based and and Growth-Rate Growth-Rate algorithms algorithms are are not credited in the safety analysis, and their settings are not credited in the safety analysis, and their settings are documented documented only only in in GGNS GGNS procedures procedures..
The The TS-related TS-related setpoints setpoints for for the the auto-enable auto-enable (not-bypassed)
(not-bypassed) region region are are established established as as nominal nominal setpoints setpoints only, only, as as described described in in the the draft draft TS TS Bases Bases markup markup and and designated designated in in new new SR SR 33.3.1.1.23
.3 .1 .1 .23 (see (see Section Section 4.4.2.8, 4.4.2.8, above).
above).
APRM APRM Function Function 2.f2.f isis added added to to TS TS Table Table 3.3.1 .1-1 with 3.3.1.1-1 with thethe following following denotations, denotations, which which areare consistent consistent with with the the NUMAC NUMAC PRNM PRNM LTR LTR requirements:
requirements:
a.
Upscale," to to the the "Function" "Function" column column in in accordance with Section 8.4 .1 of the NUMAC PRNM LTR .
accordance with Section 8.4.1 of the NUMAC PRNM LTR.
b.
- b. Specify Specify the the "Applicable "Applicable Modes Modes or or Other Other Specified Specified Conditions" Conditions" to be "5 24% RTP" in accordance with Section 8.4 .3 of to be "? 24% RTP" in accordance with Section 8.4.3 of the the NUMAC NUMAC PRNM PRNM LTR LTR and and reflecting reflecting the the GGNS-specific GGNS-specific value. value.
1 to Attachment to GNRO-2009-00054 GNRO-2009-00054 Page 28 Page 28 ofof 41 41
- c. Specify the Specify the "Required "Required Channels Channels per per Trip Trip System" System" to to bebe "3" "Y in in accordance with accordance with Section Section 8.4.2 8.4 .2 ofof the the NUMAC NUMAC PRNM PRNM LTR LTR and and apply new apply new NoteNote (c) (c) to to the value, as the value, as discussed discussed in in Section Section 4 .4 .3.1 .a, above.
4.4.3.1.a, above.
- d. Specify Specify the the "Condition Referenced from "Condition Referenced from Required Required ActionAction 0.1" D .1" to be "J". New TS Condition J provides a conservative default to be "J". New TS Condition J provides a conservative default condition condition when when the the lower lower tiertier conditions associated with conditions associated with combinations combinations of OPRM channel/function/RPS of OPRM channel/function/RPS trip trip capability capability cannot cannot be be met.
met. This This is is discussed discussed in more detail in more detail in in Section Section 4.4.1 4.4.1.2, .2, above.
above.
- e. Apply Apply the the following following SRs SRs in in accordance accordance with with the noted sections the noted sections of of thethe NUMAC NUMAC PRNM PRNM LTR: LTR:
i)} SR SR 3.3.1 3.3.1.1.7.1 .7 - - LPRM Calibration (8.3.5 LPRM Calibration (8.3.5 andand 8.4.5) 8.4.5) ii) ii) SR SR 3.3.1 .1-10 -Channel 3.3.1.1.10 - Channel Calibration Calibration (8.4 .4 .3)
(8.4.4.3) iii) iii) SR SR 3.3.1 .1 3.3.1.1.19 Channel Check
- Channel (8.4.4.1))
Check (8.4.4.1 iv) iv) SR SR 3.3.1 .1 .20 -
3.3.1.1.20 - Channel Functional Test Channel Functional Test (8.4.4.2)
(8.4.4.2) v)
v) SR SR 3.3.1 .1 .23 -
3.3.1.1.23 - OPRM OPRM not Bypassed (8.4 not Bypassed .4 .2)
(8.4.4.2) f.f. Apply Apply new new NotesNotes (d) (d) and and (e) (e) to to the Channel Calibration the Channel Calibration SR SR 3.3.1 .1 .10 listing, 3.3.1.1.10 listing, as as discussed discussed in in Section Section 4.4.3.1 4.4.3.1.b, .b, above.
above.
9.
- g. Apply Apply new new Note Note (f)(f) to to the the Allowable Allowable Value Value reflecting reflecting that that itit is is contained contained in in the the COLR, COLR, as as discussed discussed in in Section Section 4.4.3.1 4.4.3.1.c, .c, above above..
4.5 4.5 T I TSS 3.3.1 .3 . Period 3.3.1.3. Period Based Based Detection Detection System System (PBDSJ (PBDS)
The The current current option Option E-I-A E-I-A stability stability solution solution methodology methodology (discussed (discussed in in Sections Sections 3.1 3.1 and and 3.3, 3.3, above) above) utilizes utilizes the the Period-Based Period-Based Detection Detection algorithm algorithm to to detect detect when when conditions conditions consistent consistent withwith aa significant significant degradation degradation in in the the stability stability performance performance of of the the reactor reactor core have occurred and the potential for imminent onset of neutron ic/thermal-hyd rau I ic core have occurred and the potential for imminent onset of neutronic/thermal-hydraulic instability instability may may exist.
exist. The The PRNM PRNM System System upgrade upgrade encompasses encompasses this this algorithm algorithm within within new new OPRM OPRM Upscale Upscale Function Function 22.f, .f, as as described described in in Sections Sections 33.3 .3 and and 44.4.3.7,
.4 .3 .7, above.
above. As As such, such, TSTS 3.3.1 3.3.1.3 .3 is is duplicative duplicative to to the the proposed proposed TS TS changes changes and and is is no no longer longer needed; needed; therefore, therefore, Entergy Entergy proposes proposes to to delete delete TS TS 3.3.1 3.3.1.3 .3 inin its its entirety entirety..
4.6 4.6 TSTS 3.10.8, 3.10.8. Shutdown Shutdown Maroin Margin (SDM) (SDM) Test Test - - Refueling Refueling TSTS 3.10.8 3.10.8 permits permits SDM SDM testingtesting to to bebe performed performed in in Mode Mode 5; 5; ii.e.,
.e., the the reactor reactor pressure pressure vessel vessel head head is is either either not not in in place place or or the the head head boltsbolts areare notnot fully fully tensioned.
tensioned. LCO LCO 3.10.8 3.10.8 specifies specifies conditions conditions that that must must be be met met in in order order to to perform perform SDM SDM tests, tests, oneone of of these these being being the the Mode Mode 22 requirements requirements for for APRM APRM Functions Functions 22.a .a and and 22.c..c. InIn addition, addition, SRSR 3.10.8.1 3.10.8.1 requires requires Mode Mode 2-applicable 2-applicable SRs SRs for for these these functions functions be be performed.
performed.
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page 29 Page 29 of of 41 41 As As discussed discussed in in Section 4 .4.3.6, above, Section 4.4.3.6, above, the the NUMAC NUMAC PRNM PRNM System System addsadds APRM APRM Function 2.e, Function 2.e, which which is is also also required required to to be be operable operable in in Mode Mode 2. 2 . Therefore, Therefore, Entergy Entergy proposes to add Function 2 .e to LCO 3 .10.8.a and SR 3 .10.8.1 as follows (change proposes to add Function 2.e to LCO 3.1 0.8.a and SR 3.10.8.1 as follows (change noted in noted in bold, bold, italicized text):
italicized text):
- a. LCO 3.10 .8.a is LCO 3.10.8.a is changed changed to to read:
read :
"LCO 33.3.1.1, "LCO .3.1 .1, `Reactor
'Reactor Protection System (RPS)
Protection System (RPS} Instrumentation,'
Instrumentation,' MODE MODE 2 2 requirements for requirements Function 2 for Function .a, 2.c, 2.a, 2.c, and and 2.e 2.e ofof Table 3 .3.1 .1-1 ;"
Table 3.3.1.1-1;"
b.
- b. SR 3.10.8.1 is SR 3.10.8.1 is changed changed to to read read::
"Perform the "Perform the MODE MODE 2 applicable SRs 2 applicable SRs forfor LCO 3.3 .1 .1, Functions LCO 3.3.1.1, Functions 2.a, 2 .c, and 2.a, 2.c, and 2.e 2.e ofof Table Table 33.3.1.1-1."
.3.1 .1-1 ."
4.7 4.7 TS T5 5.6 5.6.5. .5 . Core Core Operating Operating Limits Report (COLR)
Limits Report (COLR)
TS TS 55.6.5.6.5 identifies identifies the the TS TS sections sections for for which which core operating limits core operating limits are are established established and and the analytical methods used to determine these limits . To implement the NUMAC the analytical methods used to determine these limits. To implement the NUMAC PRNM PRNM System System with with Option Option III, 111, Entergy proposes the Entergy proposes the following following changes changes to to TS 5.6.5 :
TS 5.6.5:
- a. Delete APRM Delete Function 2 APRM Function .d, which is 2.d,which is no longer included no longer included in in the the COLR COLR (see(see Section Section
.4.3.5, above),
44.4.3.5, above), and and addadd APRM Function 2.f APRM Function 2 .f to to TS 5.6 .5 .a.5 as TS 5.6.5.a.5 follows (changes as follows (changes noted in noted bold, italicized in bold, italicized text):text):
"5)
"5) LCO 3.3.1 LCO 3.3.1.1,.1, RPS RPS Instrumentation, Instrumentation, Table 3.3.1 .1-1 APRM Table 3.3.1.1-1 APRM Function 2X Function 2.f' b.
- b. Delete LCO Delete LCO 3.2.43.2.4 from from TS TS 5.6.5.a.4; 5.6 .5 .a.4; TS TS 3.2.4 3 .2 .4 is is being being deleted deleted as as discussed discussed in in Section 4.3.
Section above.
4.3, above.
- c. Delete LCO Delete LCO 3.3.13.3.1.3 .3 from from TS .6 .5 .a.6 ; TS TS 55.6.5.a.6; 3.3.1 .3 is TS 3.3.1.3 is being deleted as being deleted as discussed discussed in in Section 4.5, Section above.
4.5, above.
d.
- d. Add Add the the following references to following references to TS 5.6-5 :
TS 5.6.5:
i)i) NEDO-31960-A, BWR NEDO-31960-A, BWR Owners'Owners' GroupGroup Long-Term Long-Term Stability Stability Solutions Solutions Licensing Licensing Methodology Methodology ii) ii) NEDO-32465-A, Reactor NEDO-32465-A, Reactor Stability Stability Detect Detect and and Suppress Suppress Solutions Solutions Licensing Licensing Basis Methodology and Basis Methodology and Reload Reload Applications Applications 4.8 4.8 Conclusion Conclusion With With the the above above changes, changes, the the GGNS GGNS OL OL andand TS TS appropriately appropriately reflect the NUMAC reflect the NUMAC PRNM LTR, PRNM LTR, as approved by as approved by the NRC, insuring the NRC, insuring design requirements and design requirements acceptance and acceptance criteria are criteria are met.
met.
Attachment 1 toto GNRO-2009-00054 GNRO-2009-00054 Page Page 30 30 of of 41 41 5.0
5.0 REGULATORY ANALYSIS
REGULATORY ANALYSIS 5.1 5.1 Applicable Applicable Regulatory Requirements and Regulatory Requirements and Guidance Guidance 5.1 .1 5.1.1 10 CFR 10 CFR PartPart 50 50 10 CFR 50 10 CFR .36, Technical 50.36, Technical Specifications, Specifications, provides provides the the regulatory regulatory requirements requirements for for the the content required in content required in the the Technical Specifications (TS).
Technical Specifications (TS). As As stated stated in in 10 CFR 10 CFR 50 .36, TS 50.36, TS include include Surveillance Requirements (SRs}
Surveillance Requirements (SRs) to to assure assure that that the the Limiting Conditions Limiting Conditions for for Operation Operation (LCO} (LCO) are are met.
met. TheThe proposed proposed TS TS changes changes would would revise SRs and revise SRs and the LCO actions the LCO actions and and completion completion times, times, as as applicable, applicable, for for each change in APRM functions and related LCOs.
each change in APRM functions and related LCOs.
The The GGNS GGNS Neutron Neutron Monitoring Monitoring System System was was designed designed and and licensed licensed to to the the GDCs specified GOCs specified in in 10 10 CFRCFR 50 50 Appendix Appendix A. A. The The applicable applicable GOCs GDCs are are discussed below.
discussed below.
Criterion 13 Criterion 13 ---- Instrumentation Instrumentation and control. Instrumentation and control. Instrumentation shall shall be be provided provided to to monitor monitor variables variables and and systems systems over over their their anticipated anticipated ranges ranges for for normal normal operation, operation, for for anticipated anticipated operational operational occurrences, occurrences, and and forfor accident accident conditions conditions as as appropriate appropriate to to assure assure adequate adequate safety, safety, including including those those variables variables and and systems systems that that cancan affect affect thethe fission fission process, process, the the integrity integrity of of the the reactor reactor core, core, thethe reactor reactor coolant coolant pressure pressure boundary, boundary, and and the the containment containment and and itsits associated associated systems systems.. Appropriate Appropriate controls controls shallshall be be provided provided to to maintain maintain these these variables variables and systems within and systems prescribed within prescribed operating ranges .
operating ranges.
Criterion 20 Criterion 20 ---- Protection Protection system functions. The system functions. The protection protection systemsystem shall be shall be designed designed (1) (1) toto initiate automatically the initiate automatically the operation operation of of appropriate appropriate systems systems including including thethe reactivity control systems, reactivity control systems, to to assure assure that specified acceptable that specified acceptable fuel fuel design limits are design limits are notnot exceeded exceeded as as aa result result of anticipated operational of anticipated operational occurrences occurrences and and (2)(2) to sense accident to sense accident conditions conditions and and to to initiate the initiate the operation operation of of systems systems and components important and components important to to safety safety..
Criterion 21 Criterion 21 ---- Protection Protection system system reliability reliability andand testability.
testability. The The protection protection system system shall shall be be designed designed for for high high functional functional reliability reliability and and in-service in-service testability testability commensurate commensurate with with the the safety functions to safety functions to bebe performed performed..
Redundancy and Redundancy and independence independence designed designed into the protection into the protection system system shall shall be be sufficient sufficient to to assure assure that that (1) (1) nono single failure results single failure results inin loss loss of of the the protection protection function function and and (2) (2) removal removal from from service service of of any any component component or or channel does not result in loss of the required minimum redundancy channel does not result in loss of the required minimum redundancy unless unless the acceptable the reliability of acceptable reliability of operation operation of of the the protection protection system system can can be be otherwise demonstrated.. The otherwise demonstrated The protection system shall protection system shall bebe designed designed to to permit permit periodic periodic testing testing of of its its functioning functioning when when the the reactor reactor is is in in operation, operation, including including aa capability capability to to test test channels channels independently independently to to determine determine failuresfailures and losses of redundancy that may have occurred.
and losses of redundancy that may have occurred.
Criterion Criterion 22 22 ---- Protection Protection system system independence independence.. The The protection protection systemsystem shall be designed to assure that the effects of natural phenomena, and shall be designed to assure that the effects of natural phenomena, and of of normal normal operating, maintenance, testing, operating, maintenance, testing, andand postulated postulated accident accident conditions conditions
Attachment 1 toto GNRO-2009-00054 GNRO-2009-00054 Page Page 31 31 of of 41 41 on on redundant redundant channelschannels do do not not result result in in loss loss of of the protection function, the protection function, or or shall shall bebe demonstrated demonstrated to to be be acceptable acceptable on on some some otherother defined defined basis.
basis.
Design Design techniques, techniques, such such as as functional functional diversity diversity or or diversity diversity inin component component design and principles of operation, shall be used to the extent practical design and principles of operation, shall be used to the extent practical toto prevent prevent loss loss of of the the protection protection function function..
Criterion Criterion 29 29 ---- Protection Protection against against anticipated operational occurrences.
anticipated operational occurrences. The The protection and protection and reactivity control systems reactivity control systems shall shall be be designed designed to to assure assure an an extremely extremely high high probability probability of accomplishing their of accomplishing their safety safety functions functions in the in the event event of of anticipated operational occurrences.
anticipated operational occurrences.
The BWROG The BWROG long-term long-term stability stability solution solution Option Option III approach consists III approach consists of of detecting detecting and and suppressing suppressing stability-related stability-related power power oscillations oscillations by automatically by automatically inserting inserting control control rods (scramming) to rods (scramming) to terminate terminate powerpower oscillations, thereby oscillations, thereby complying with the requirements of GDCs 10 and 12 discussed below.
complying with the requirements of GDCs 10 and 12 discussed below.
Criterion Criterion 10 10 ---- Reactor Reactor design.design. The The reactor reactor core core and associated coolant, and associated coolant, control, control, and and protection protection systems systems shall shall be be designed designed with appropriate margin with appropriate margin to to assure assure that that specified acceptable fuel specified acceptable fuel design limits are design limits are not exceeded not exceeded during during any any condition condition of normal operation, of normal operation, including including the the effects effects of of anticipated operational occurrences.
anticipated operational occurrences.
Criterion 12 Criterion 12 ---- Suppression Suppression of of reactor reactor powerpower oscillations.
oscillations. The The reactor reactor core core and associated coolant, and associated coolant, control, control, andand protection protection systems systems shallshall be designed be designed to to assure assure that power oscillations that power oscillations whichwhich can can result result in in conditions exceeding conditions exceeding specified acceptable fuel design limits are not possible or can be reliably specified acceptable fuel design limits are not possible or can be reliably and readily detected and readt'ly detected and and suppressed.
suppressed.
Entergy has Entergy has evaluated evaluated the proposed changes the proposed changes againstagainst the the applicable regulatory applicable regulatory requirements requirements and and acceptance acceptance criteria criteria andand finds the design finds the design of of the NUMAC the NUMAC PRNM System PRNM System consistent consistent with applicable regulatory the applicable with the regulatory criteria criteria described described above.
above. The The technical technical analysis analysis in in Section Section 4.0, 4 .0, above, above, concludes concludes that that the the proposed changes proposed changes to to install install andand implement implement the the NUMAC NUMAC PRNM PRNM System System continue continue to to assure assure that that the the design requirements and design requirements and acceptance acceptance criteria criteria of of the the RPS are met. Based on this, there is reasonable assurance the health and RPS are met. Based on this, there is reasonable assurance the health and safety of the safety of the public, public, following approval of following approval of this this change, change, remain remain unaffected.
unaffected .
5.1 5.1.2.2 NRC Safety NRC Evaluation and Safety Evaluation NUMAC PRNM and NUMAC PRNM LTR LTR Requirements Requirements To receive NRC To receive NRC approval approval of of an an NUMAC NUMAC PRNM PRNM SystemSystem retrofit retrofit installation installation (including the Option III OPRM Upscale function), a licensee must (including the Option III OPRM Upscale function), a licensee must indicate indicate how how the requirements the requirements of of the the NUMAC NUMAC PRNM PRNM LTR LTR and and the the conditions conditions of of the the NRC NRC Safety Evaluations Safety Evaluations for for the the system system are are met,met, or or provide provide an an acceptable acceptable alternative alternative (deviation) for (deviation) for NRC NRC staff staff evaluation.
evaluation . The The Safety Safety Evaluations Evaluations for the NUMAC for the NUMAC PRNM System PRNM System specify specify conditions conditions to to be be demonstrated demonstrated by by each each licensee licensee applying to install the NUMAC PRNM System .
applying to install the NUMAC PRNM System.
To demonstrate To demonstrate cO,nformance, conformance, Entergy Entergy has has evaluated evaluated the the GGNS-specific GGNS-specific PRNM PRNM System installation against the requirements of the NUMAC PRNM System installation against the requirements of the NUMAC PRNM LTR LTR andand associated NRC associated NRC SafetySafety Evaluations.
Evaluations. Attachment Attachment 22 provides provides aa plant-specific plant-specific
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 32 32 of of 41 41 comparison comparison matrix matrix entitled, entitled, Grand Grand GulfGulf Nuclear Nuclear Station Station Plant-Specific Plant-Specific Responses Responses Required Required by by NUMAC NUMAC PRNM Retrofit Plus PRNM Retrofit Plus Option Option III/// Stability Stability Trip Trip Function Topical Report Function Topical (NEaC-32410P-A) . A Report (NEDC-32410P-A). A response response to to each each NRC staff NRC staff requirement is requirement provided below:
is provided below:
- 1. Confirm Confirm the the applicability applicability of of the the NUMAC NUMAC PRNM PRNM LTR LTR (NEDC-3241 (NEDC-3241OP-A OP-A andand its its supplement),
supplement), including including clarifications clarifications and reconciled differences and reconciled differences between between the the specific specific plant design and plant design and thethe topical topical report design report design descriptions descriptions..
RESPONSE
RESPONSE Entergy Entergy performed performed an evaluation of an evaluation of the the proposed GGNS-specific PRNM proposed GGNS-specific PRNM System System installation against the installation against the requirements requirements of of the the NUMAC NUMAC PRNM PRNM LTR LTR and and associated associated NRC NRC Safety Safety Evaluations Evaluations;; the the resulting resulting document document is is provided provided in in Attachment Attachment 22.. Clarifications Clarifications and and reconciled reconciled differences differences between between the the plant-plant-specific specific design design andand the NUMAC PRNM the NUMAC PRNM LTR LTR design descriptions are design descriptions are identified identified inin Section below.
5.1 .3, below.
Section 5.1.3, 2.
- 2. Confirm Confirm the the applicability applicability of of the the BWROG BWROG topical topical reports reports that that address address PRNMS and associated instability functions, setpoints, and margins PRNMS and associated instability functions, setpoints, and margins.
RESPONSE
RESPONSE The The applicability applicability ofof the the various BWROG LTRs various BWROG LTRs that that address address the the NUMAC NUMAC PRNM System, the Option III stability solution, the reload-related aspects, PRNM System, the Option III stability solution, the reload-related aspects, and the development of setpoints is discussed herein or through reference and the development of setpoints is discussed herein or through reference to to the the various reports.
various reports.
3.
- 3. Provide plant-specific revised Provide plant-specific revised TS TS for for the the NUMAC NUMAC PRNMS functions PRNMS functions consistent consistent withwith NEDC-32410P-A, NEDC-32410P-A, Appendix Appendix H, H, and Supplement 11..
and Supplement
RESPONSE
RESPONSE Entergy Entergy confirms confirms thethe plant-specific plant-specific TS TS changes changes to to implement implement the the NUMAC NUMAC PRNM PRNM System System (including (including thethe OPRM OPRM Option Option III III stability stability solution),
solution), which which areare provided provided in in Attachment Attachment 3, 3, are are consistent consistent with with the requirements of the requirements of the the NUMAC NUMAC PRNM PRNM LTR. LTR.
- 4. Confirm Confirm the the plant-specific plant-specific environmental conditions are environmental conditions are enveloped enveloped by the by the NUMAC NUMAC PRNM PRNM System equipment environmental System equipment environmental qualification qualification values values..
RESPONSE
RESPONSE The The analysis analysis ofof the the plant-specific plant-specific environmental environmental conditions conditions to to the NUMAC the NUMAC PRNM PRNM System System equipment qualification (EQ}
equipment qualification (EQ) values values is is discussed discussed in in GEH GEH Report Report GE-NE-0000-0102-0888 GE-NE-0000-01 02-0888 (Reference (Reference 5), 5), which which is is provided provided in in Attachment Attachment 2. 2. The The results results ofof this this analysis analysis confirm confirm the the plant-specific plant-specific environmental conditions are enveloped by the NUMAC PRNM environmental conditions are enveloped by the NUMAC PRNM System System EQ EQ values values..
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page 33 Page 33 of of 41 41 5.
- 5. Confirm Confirm that that administrative administrative controls controls are provided for are provided for manually manually bypassing bypassing APRM APRM // OPRM OPRM channels channels or or protective protective functions, functions, and and for for controlling controlling access access to to the the APRM APRM // OPRM panel and OPRM panel and channel channel bypass switch .
bypass switch.
RESPONSE
RESPONSE In In the NRC Safety the NRC Evaluation for Safety Evaluation for the the NUMAC NUMACPRNM PRNM LTR, LTR, the NRC staff the NRC staff found found the NUMAC PRNM the NUMAC PRNM SystemSystem designdesign features features that that control control access access to to setpoint adjustments, setpoint adjustments, calibrations, calibrations, and and test test points points acceptable.
acceptable. Entergy Entergy is is not proposing any changes to those features . In accordance with the not proposing any changes to those features. In accordance with the requirements requirements of of the the NUMAC NUMAC PRNM PRNM LTR, administrative controls LTR, administrative controls will will be be provided provided for for manually bypassing the manually bypassing the APRM APRM // OPRM OPRM channels channels or or protective protective functions, functions, andand for controlling access for controlling access to to the the APRM APRM // OPRM OPRM panel panel andand channel channel bypass bypass switch.
switch.
6.
- 6. Confirm Confirm that that any changes to any changes to the the plant plant operator's operator's panel panel have have received received human human factors factors reviews reviews perper plant-specific plant-specific procedures procedures..
RESPONSE
RESPONSE The The site site design design change change process process requires requires performing performing aa HumanHuman Factors Factors Engineering Engineering {HFE} (HFE) review review of of changes changes to to the the Control Control RoomRoom Operator's Operator's panels panels.. Documenting Documenting the HFE review the HFE review willwill bebe included included in in the the final final design design package(s) for the PRNM System and available on-site for NRC package(s) for the PRNM System and available on-site for NRC inspection inspection..
Based Based upon upon the above discussions, the above discussions, EntergyEntergy believes believes the requirements raised the requirements raised within within the NRC staff the NRC staff Safety Evaluations have Safety Evaluations have been been adequately adequately addressed addressed..
5.1 .3 5.1.3 GGNS PRNM GGNS PRNM SystemSystem Deviations Deviations from from thethe NUMAC NUMAC PRNM PRNM LTR LTR The The NUMAC NUMAC PRNM PRNM SystemSystem in in development development for for GGNS GGNS by by GEH GEH reflects three reflects three deviations deviations from from the the NUMAC NUMAC PRNM PRNM LTR. LTR . They They are: are:
11.. APRM APRM Upscale Upscale // OPRIVI Upscale // APRM OPRM Upscale APRM Inop Inop Function Logic Function Logic 2.
- 3. Recirculation Flow Recirculation Flow Processing Processing Each deviation Each deviation is is discussed discussed and and justified justified in in Appendix Appendix A A of GEH Report of GEH Report 0000-0102-0888 (Reference 5), which is provided in Attachment 2.
0000-0102-0888 (Reference 5), which is provided in Attachment 2.
5.1 .4 5.1.4 GGNS Option GGNS Option 111 III -Stability Stability Solution Solution Deviations Deviations from from thethe BWROG BWROG Stability Stability LTR LTR The The Option Option III III stability stability solution developed for solution developed GGNS by for GGNS by GEH GEH reflects reflects two two deviations from the BWROG Option III methodology (References 6 and 15).
deviations from the BWROG Option III methodology (References 6 and 15)
They are:
They are:
11.. Base Period Definition Base Period Definition for for Period-Based Period-Based Detection Algorithm {PBDA}
Detection Algorithm (PBDA)
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 34 34 of of 41 41 2.
- 2. Period Tolerance Offset Period Tolerance Offset Each Each deviation deviation is is discussed discussed and and justified justified in in GEH GEH Report Report 0000-0107-7607-P, 0000-0107-7607-P, Grand Gulf Nuclear Station - Grand Gulf PRNM Upgrade Project Grand Gulf Nuclear Station - Grand Gulf PRNM Upgrade Project Option Option III ///
Stability Deviations Stability Deviations (Reference (Reference 16), 16), which which is is provided provided in in Attachments Attachments 55 and and 6 6 (proprietary (proprietary and non-proprietary versions, and non-proprietary versions, respectively) respectively)..
5.1 .5 5.1.5 Setpoint Methodolo-q Setpoint Methodology Description Description The The instrument instrument setpoint methodology currently setpoint methodology currently implemented implemented at at GGNS GGNS is is based based on Instrument Society of America (ISA) Standard 67.04 Part 11, 1994, on Instrument Society of America (ISA) Standard 67.04 Part II, 1994, Methodologies Methodologies for the Determination for the Determination of Setpoints for of Setpoints for Nuclear Nuclear Safety-Related Safety-Related Instrumentation (Reference 17),
Instrumentation (Reference 17), and and the GEH Instrument the GEH Instrument Setpoint Setpoint Methodology Methodology (ISM) (ISM) specified specified in in NEDC-31336P-A, NEDC-31336P-A, General General Electric Electric Instrument Instrument Setpoint Methodology (Reference 18).
Setpoint Methodology (Reference 18).
Setpoint Setpoint calculations provide a calculations provide conservative analysis a conservative analysis of of setpoints, setpoints, taking taking intointo account account the applicable instrument the applicable instrument measurement measurement errors. errors .
The The Nominal Nominal Trip Trip Setpoint (NTSP} is Setpoint (NTSP) is more more conservative conservative than than the the Allowable Allowable Value (AV).
Value (AV) . Because Because it it is impossible to is impossible to set set anan instrument instrument channel channel to to an exact an exact value, a calibration tolerance is established around the NTSP . The NTSP is, value, a calibration tolerance is established around the NTSP. The NTSP is, therefore, considered therefore, considered a a nominal nominal valuevalue and and the the instrument adjustment is instrument adjustment is considered considered successful successful if the "as-left" if the "as-left" instrument instrument settingsetting is is within within thethe calibration calibration tolerance established tolerance established aroundaround the NTSP .
the NTSP.
Entergy calculates the Entergy calculates the setpoints setpoints from from thethe Analytical Analytical LimitLimit (AL),
(AL), establishing establishing margins between the AL, the AV, and the NTSP based on calculated margins between the AL, the AV, and the NTSP based on calculated instrument errors . Random instrument errors. Random errors errors areare combined combined using using the the square-root-of-the-square-root-of-the sum-of-the-squares method, sum-of-the-squares method, and non-conservative bias and non-conservative bias errors errors are are added added algebraically. This approach provides sufficient margin between the AL algebraically. This approach provides sufficient margin between the AL and and AV to ensure at least 95% probability that the AL is not exceeded if the AV to ensure at least 95% probability that the AL is not exceeded if the setpoint drifts setpoint drifts toward toward the the AV AV..
Enterw's Tvpical Calibration Entergy's Typical Calibration Process Process At the start At the start of of each each calibration, calibration, the the instrument instrument is is declared declared inoperable inoperable (in (in the the case of case TS-controlled instruments) of TS-controlled instruments) and removed from service. The Operations and removed from service. The Operations Shift Supervisor Shift Supervisor or or Manager Manager reviewsreviews the the results results of of the the surveillance surveillance and and determines determines whether whether the results are the results are acceptable acceptable based based on on TSTS operability operability requirements prior requirements prior to returning the to returning the instrument instrument to service.
to service.
If If the the as-found setpoint value as-found setpoint exceeds its value exceeds its designated designated tolerance, tolerance, the the condition condition is is documented for trending purposes and appropriate corrective actions are documented for trending purposes and appropriate corrective actions are taken before the taken before instrument is the instrument is returned returned to service. Once to service. Once actions actions havehave beenbeen taken taken to to correct correct the condition, the the condition, the instrument instrument setpoint setpoint is is reset reset to to as as close close to to the the NTSP value NTSP value asas practicable practicable and and thethe instrument instrument is is returned returned to to service.
service.
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 35 35 of of 41 41 For cases in For cases in which which the the as-found as-found setpoint value is setpoint value is within its designated within its designated tolerance, tolerance, itit isis common common practicepractice to to reset reset the the setpoint setpoint value value to to asas close close toto the the NTSP NTSP value value as as practicable practicable..
This This process process is is applied applied to both safety-related to both safety-related and and non-safety-related non-safety-related setpoints setpoints..
NRC NRC and Industry Guidance and Industry Guidance and and Application Application Over the past Over the past several several years, years, thethe NRC NRC and and the the nuclear nuclear industry industry have have participated in participated various forums in various forums to to address address the setpoint methodology the setpoint methodology issue. issue. OnOn September September 7, 2005, the 7,2005, the NRCNRC transmitted transmitted a a letter letter to to the the NEI Setpoint Methods NEI Setpoint Methods Task Task Force (Reference 19)
Force (Reference 19) that that described described setpoint-related setpoint-related TS TS that that are are acceptable acceptable for for instrument instrument settings associated with settings associated with Safety Limit-related Safety Limit-related setpoints setpoints.. On On August August 24, 2006, the 24, 2006, NRC issued the NRC issued Regulatory Regulatory Issue Summary Issue Summary (RIS} 2006-17 (RIS) 2006-17 (Reference (Reference 20) 20) toto provide provide guidance guidance and and information pertaining information pertaining to to the the requirements requirements of of 10 10 CFR CFR 50.36 50.36 with respect to with respect to limiting safety system limiting safety system settings (LSSSs} assessed settings (LSSSs) assessed duringduring periodic periodic instrument instrument testing testing and and calibration calibration..
The NRC and The NRC and industry industry have have been been working working together together on on aa Technical Technical Specifications Task Force (TSTF) proposal, TSTF-493, Specifications Task Force (TSTF) proposal, TSTF-493, Clarify Clarify Application Application of of Setpoint Methodology for LSSS Functions, to address the setpoint Setpoint Methodology for LSSS Functions, to address the setpoint methodology issue.
methodology issue . In In aa letter letter to to the the NRC NRC dated February 23, dated February 23, 2009 2009 (Reference (Reference 21), the TSTF 21), the documented a TSTF documented a proposed proposed coursecourse of of action action toto be be taken taken byby the the industry industry to to address address the the NRC's NRC's questions questions and and concerns concerns with with TSTF-493 TSTF-493.. The The NRCNRC responded responded in in a a letter letter dated dated March March 9, 9, 2009 2009 (Reference 22)
(Reference 22) stating stating the the TSTF letter "meets TSTF letter "meets the the agreed course of agreed course of action action ......
for resolving the TSTF-493 setpoint issue" . The NRC's comments have been for resolving the TSTF-493 setpoint issue". The NRC's comments have been incorporated incorporated into into TSTF-493, TSTF-493, Rev Rev.. 4,4, which which was submitted to was submitted to the staff on the staff on July 31, July 31, 2009 2009 (Reference (Reference 13 13).
In order In order to address the to address the setpoint setpoint methodology methodology issue, issue, Entergy Entergy has has applied applied the the actions identified in actions identified TSTF-493 (Reference in TSTF-493 (Reference 13) 13) to this LAR to this LAR;; thethe results being results being that that the the two notes specified two notes specified in in the the TSTF TSTF are are applied applied to to channel channel calibration calibration SR SR 3.3. 1 . 1 .10 for 3.3.1.1.10 for the the following following APRM APRM functions functions listed listed inin TS TS Table Table 3.3.1 .1-1 :
3.3.1.1-1:
TS APRM Function 15 APRM Function TS 15 APRIVI APRM Function Function Name Name Designation Designation Neutron Neutron FluxFlux - - High, High, Setdown Setdown 2.a 2.a Fixed Fixed Neutron Neutron Flux Flux - - High High 2.b 2.b Flow Flow Biased Biased Simulated Simulated Thermal Thermal PowerPower - - High High 2.d 2.d OPRM OPRM Upscale Upscale 2.f 2.f The new The new notes, notes, Notes Notes (d) and (e)
(d) and Table 3.3.1.1-1, of TS Table (e) ofTS 3.3.1 .1-1, are are specified specified in in Section Section 4.4 .3 .1 .b, above.
4.4.3.1.b, above.
1 to Attachment to GNRO-2009-00054 GNRO-2009-00054 Page 36 Page 36 of of 41 41 The TRM The TRM will will bebe revised revised to to reflect reflect the the NTSP NTSP and and methodologies methodologies used used to to determine the determine the as-found as-found and and as-left as-left tolerances tolerances prior prior to to startup startup fromfrom thethe 2012 2012 refueling outage.
refueling outage.
New Notes New Notes (d) (d) and and (e)
(e) are are not not applicable applicable to to Inop Inop Function Function 2.c 2.c and and 2-0ut-Of-4 2-Out-Of-4 Voter Function Voter Function 2.e since they 2.e since meet the they meet the third third criterion for exemption provided criterion for exemption provided in in the TSTF letter, as follows:
the TSTF letter, as follows:
"3 .
"3. Instrument functions Instrument functions thatthat derive derive input input from from contacts contacts which which have have no no associated sensor associated sensor or or adjustable device, e.g.,
adjustable device, e.g., limit limit switches, breaker switches, breaker position switches, position switches, etc. Many permissives etc. Many permissives or or interlocks interlocks are excluded are excluded under this under this criterion criterion.. Other Other permissives permissives and and interlocks interlocks rely rely on on the the input from input from a a sensor sensor or adjustable device or adjustable (e.g., a device (e.g., a pressure pressure transmitter) transmitter).. If If the the permissive permissive or interlock derives or interlock derives input input from from a a sensor or adjustable device that is tested as part of another TS sensor or adjustable device that is tested as part of another T5 function, then function, then the the permissive permissive or or interlock interlock is excluded from is excluded from the the footnotes (emphasis footnotes added). Otherwise, (emphasis added). Otherwise, the footnotes are the footnotes added are added to the permissive to the permissive or or interlock interlock to ensure that to ensure that itit is is functioning functioning as as expected ."
expected."
The Bases for The Bases for TS 3.3.1 .1 describe TS 3.3.1.1 describe the the application application of of the the notes notes to to SR 3.3. 1 . 1 .10 SR 3.3.1.1.10 as as applied applied to to APRM Functions 22.a, APRM Functions .a, 2.b, 2.b, 2.d, 2 .d, and 2 .f. Draft and 2.f. Draft marked-up marked-up pages pages of of the the affected affected TS Bases are TS Bases are provided provided in in Attachment Attachment 4, 4, for information only. In for information only. In addition, addition, GGNS GGNS calibration calibration procedures procedures for for these these APRM APRM functions functions will will be be revised to revised reflect the to reflect the instructions instructions givengiven in in the the above notes.
above notes.
5.2 5.2 No No Significant Significant HazardsHazards Determination Determination In In accordance accordanc~. . with with the the requirements requirements of of 1010 CFR 50.90, Entergy CFR 50.90, Entergy Operations, Operations, Inc. Inc.
(Entergy} requests (Entergy) requests an an amendment amendment to to facility facility Operating License NPF-29, Operating License NPF-29, for for the Grand the Grand Gulf Nuclear Gulf Station (GGNS}.
Nuclear Station (GGNS). This This license amendment request license amendment request proposes proposes to to revise revise the the GGNS GGNS Technical Technical Specifications Specifications (TS) (TS) to to reflect installation of reflect installation of the the Nuclear Nuclear Measurement Measurement Analysis Analysis andand Control Control (NUMAC} (NUMAC) Power Power Range Neutron Monitoring Range Neutron Monitoring (PRNM} (PRNM) SystemSystem..
Entergy Entergy hashas evaluated evaluated the the proposed proposed license license amendment amendment request request in accordance with in accordance with 10 10 CFR CFR 50.91 50.91 against against the the standards standards in 10 CFR in 10 CFR 50.9250.92 andand has has determined determined that that the the operation operation of of GGNS GGNS in in accordance accordance with with the the proposed proposed amendment amendment presents presents no no significant hazards. Entergy's evaluation against each of the criteria in 10 CFR 50 significant hazards. Entergy's evaluation against each of the criteria in 10 CFR 50.92.92 follows.
follows.
- 1. Does Does thethe proposed proposed amendment amendment involve involve a a significant significant increase increase in in the the probability probability or or consequences consequences of of anan accident accident previously previously evaluated?
evaluated?
RESPONSE
RESPONSE: No No.
The The probability probability (frequency (frequency of of occurrence) occurrence) of of design design basis basis accidents accidents (DBAs) (DBAs) occurring occurring is is not not affected affected by by the the NUMAC NUMAC PRNM PRNM System, System, since since the the system system does does not not interact interact with with equipment equipment whosewhose failure failure could could cause cause an an accident.
accident. Compliance Compliance with with the the regulatory regulatory criteriacriteria established established for for plant plant equipment equipment are are maintained maintained with with to to GNRO-2009-00054 GNRO-2009-00054 Page 37 Page 37 of of 41 41 the installation of the installation of the the upgraded upgraded NUMAC NUMAC PRNM PRNM System.
System . ScramScram setpoints setpoints in in the the NUMAC PRNM System are established such that the analytical limits are met.
NUMAC PRNM System are established such that the analytical limits are met.
The The unavailability unavailability of of the the new NUMAC PRNM new NUMAC PRNM System System is is equal equal to or less to or less than than the the existing system existing system and,and, as as a result, the a result, the scram scram reliability reliability isis equal equal to or better to or than the better than the existing analog existing analog power range monitoring power range system . No monitoring system. No new challenges to new challenges safety-to safety-related related equipment equipment result from the result from the NUMAC NUMAC PRNM PRNM System System modification.
modification .
Therefore, the Therefore, the proposed proposed change change doesdoes notnot involve involve a significant increase a significant increase in in the the ability of probability of anan accident previously evaluated accident previously evaluated..
The proposed The proposed change replaces the change replaces the current current Option Option E-I-A E-I-A stability stability solution solution with with an an NRC-approved Option NRC-approved Option III long-term stability III long-term stability solution.
solution . TheThe NUMAC NUMAC PRNM PRNM hardware hardware incorporates incorporates the the Oscillation Oscillation Power Power RangeRange Monitor Monitor (OPRM)
(OPRM) OptionOption III III detect-and-suppress detect-and-suppress solution, solution, which which hashas been been previously reviewed and previously reviewed and approved approved by by the NRC . The the NRC. The OPRM OPRM meets General Design meets General Design Criterion (GDC) 10, Criterion (GDC) 10, Reactor Reactor Design, and Design, and GDC GDC 12, 12, Suppression Suppression of of Reactor Reactor Power Power Oscillations, Oscillations, requirements requirements by by automatically automatically detecting detecting and and suppressing suppressing design design basis basis thermal-hydraulic thermal-hydraulic oscillations oscillations prior prior toto exceeding exceeding the the fuel fuel Minimum Critical Power Minimum Critical Power RatioRatio (MCPR)
(MCPR)
Safety Safety Limit.
Limit.
Based on Based on the above, installation the above, installation of the new of the NUMAC PRNM new NUMAC PRNIVI System System with the with the OPRIVI Option III stability solution integrated into the NUMAC PRNM equipment OPRM Option III stability solution integrated into the NUMAC PRNM equipment does does not not increase increase the the probability probability or or consequences consequences of an accident of an accident previously previously evaluated evaluated..
- 2. Does the Does proposed amendment the proposed amendment create create the possibility of the possibility of aa new new or or different different kind of kind of accident accident from om anyany accident previously evaluated?
accident previously evaluated?
RESPONSE: No RESPONSE: No.
The The components components of of the NUMAC PRNM the NUMAC PRNM System System are are equivalent equivalent or or of better of better design design andand qualification criteria than qualification criteria than those currently installed those currently installed andand utilized utilized inin the the plant.
plant. NoNo new new operating operating mode, mode, safety-related equipment lineup, safety-related equipment lineup, accident accident scenario, scenario, or or system interaction mode system interaction mode notnot reviewed reviewed and approved as and approved as part part of of the the design and licensing of the NUMAC PRNM System has been identified .
design and licensing of the NUMAC PRNM System has been identified.
Therefore, Therefore, the the NUMAC NUMAC PRNM PRNM System retrofit does System retrofit does notnot adversely adversely affect affect plant plant equipment.
equipment.
The The new NUMAC PRNM new NUMAC PRNM SystemSystem usesuses digital digital equipment equipment that that has has software-software-controlled digital processing compared to the existing power range system controlled digital processing compared to the existing power range system thatthat uses mostly uses mostly analog analog and and discrete discrete component component processing.
processing . Specific Specific failures failures ofof hardware and hardware potential software and potential software common-cause common-cause failures failures areare different different from from thethe existing system . The existing system. The effects effects of of potential potential software software common-cause common-cause failure failure are are mitigated by mitigated by specific hardware design specific hardware design andand system architecture as system architecture as discussed discussed in in Section Section 6.06.0 of NEDC-32410P-A.
of NEDC-3241 Failure(s) of OP-A. Failure(s) the system of the system have have the same overall the same overall effect effect as as the present design.
the present design. No No new new or different kinds or different kinds of of accidents accidents are are introduced . Therefore, introduced. Therefore, the the NUMAC NUMAC PRNM PRNM SystemSystem doesdoes not not adversely adversely effect effect plant equipment.
plant equipment.
1 to Attachment to GNRO-2009-00054 GNRO-2009-00054 Page 38 Page 38 of of 41 41 The The currently installed Average currently installed Average PowerPower Range Range Monitoring Monitoring (APRM)
(APRM} system system is is replaced with replaced with a NUMAC PRNM a NUMAC PRNM System System thatthat performs performs the the existing existing power power range range monitoring functions monitoring functions and and adds adds an OPRIVI to an OPRM to react react automatically automatically to to potential potential reactor thermal-hydraulic reactor thermal-hydraulic instabilities.
instabilities . Based Based on on the the above, above, thethe proposed proposed change does change does not not create create the possibility of the possibility of aa new new or or different different kind kind ofof accident accident fromfrom any accident previously evaluated.
any accident previously evaluated.
3.
- 3. Does the Does the proposed proposed amendment amendment involve involve aa significant significant reduction reduction in in aa margin margin of safety?
of safety?
RESPONSE: No RESPONSE: No.
The The proposed proposed TS TS changes associated with changes associated with the NUMAC PRNM the NUMAC PRNM System System retrofit retrofit implement the constraints of the NUMAC PRNM System design and related implement the constraints of the NUMAC PRNM System design and related stability analyses . The stability analyses. NUMAC PRNM The NUMAC System change PRNM System change does does notnot impact impact reactor reactor operating operating parameters parameters or or the functional requirements the functional requirements of of the the APRM system. The APRM system. The replacement equipment replacement equipment continues continues to to provide information, enforce provide information, enforce control control rod rod blocks, and blocks, and initiate initiate reactor reactor scrams scrams underunder appropriate appropriate specified conditions. The specified conditions. The proposed proposed changechange does does not reduce safety margins . The replacement APRM not reduce safety margins. The replacement APRM equipment equipment has has improved improved channel channel trip accuracy compared trip accuracy compared to to the the current current analog analog system, system, and meets or and meets or exceeds system requirements exceeds system requirements previously assumed in previously assumed in setpoint analysis . Thus, setpoint analysis. Thus, the ability of the ability of the the new new equipment equipment to enforce compliance to enforce compliance with with margins margins of of safety equals or safety equals or exceeds exceeds the ability of the ability of the equipment which the equipment which itit replaces.
replaces.
Therefore, Therefore, the the proposed proposed changes changes do not involve do not involve a reduction in a reduction a margin in a margin of of safety safety..
Based Based on on the the above, above, Entergy Entergy hashas determined determined that that operation operation of of the the facility in facility in accordance accordance with with the the proposed proposed change change doesdoes not not involve involve aa significant hazards significant hazards consideration consideration as as defined defined in in 10 10 CFR CFR 50 .92(c), in 50.92(c), in that that it:
it:
(1)
(1) Does Does not not involve involve a a significant significant increase increase in in the the probability probability or or consequences consequences of of an an accident previously evaluated ; or accident previously evaluated; or (2)
(2) Does Does not not create create the the possibility possibility ofof aa new new or or different different kind kind ofof accident accident from from any any accident accident previously previously evaluated evaluated;; or or (3)
(3) Does Does not not involve involve aa significant significant reduction reduction in in aa margin margin of of safety safety..
5.3 5.3 Environmental Environmental Consideration Consideration Entergy Entergy has has determined determined that that the the proposed proposed amendment amendment would would notnot change change a a requirement with respect to installation or use of a facility or component located within requirement with respect to installation or use of a facility or component located within the the restricted restricted area, area, as as defined defined inin 10 10 CFR CFR 20,20, nor nor would would itit change change an an inspection inspection or or surveillance surveillance requirement requirement.. The The proposed proposed amendment:
amendment:
(i}
(i) Does Does not not involve involve aa significant significant hazards hazards consideration consideration;; or or to to GNRO-2009-00054 GNRO-2009-00054 Page 39 Page 39 of of 41 41 (ii)
(ii) Does not Does not authorize authorize aa significant significant change change in in the the types types or or aa significant significant increase increase in in the amounts the amounts of of any any effluent effluent that that may may be be released released offsite offsite;; or or (iii) Does Does not not result result in in aa significant increase in significant increase in individual individual or or cumulative cumulative occupational occupational radiation radiation exposure exposure..
Accordingly, Accordingly, the the proposed proposed amendment amendment meets meets the eligibility criterion the eligibility for a criterion for a categorical categorical exclusion set exclusion set forth forth inin 10 10 CFRCFR 51.22(c)(9).
51 .22(c)(9). Therefore, Therefore, pursuant pursuant to 10 CFR to 10 51 .22(b),
CFR 51.22(b),
Entergy concludes no Entergy concludes no environmental environmental impact impact statement statement or or environmental assessment environmental assessment need need be be prepared prepared in connection with in connection the proposed with the proposed amendment.
amendment.
6.0 6.0 PRECEDENCE PRECEDENCE License amendments for License amendments installing the for installing the NUMAC NUMAC PRNM System with PRNM System Option III with Option III have have been been approved for many plants, among them : Susquehanna Units 1 and 2 ; Nine Mile Point Unit approved for many plants, among them: Susquehanna Units 1 and 2; Nine Mile Point Unit 22;;
Browns Ferry Units 1, 2, and 3 ; Hatch Units 1 and 2 ; Fermi Unit 2 ; Limerick Units 1 and 22;;
Browns Ferry Units 1, 2, and 3; Hatch Units 1 and 2; Fermi Unit 2; Limerick Units 1 and Peach Bottom Units Peach Bottom Units 2 and 3; 2 and Brunswick Units 3; Brunswick Units 1 1 and and 2 2;; and and Monticello Monticello..
7.0
7.0 REFERENCES
REFERENCES
- 1. GE GE Nuclear Nuclear Energy Licensing Topical Energy Licensing Topical Report Report (LTR}
(LTR) NEDC-3241 NEDC-3241 OP-A OP-A Volume Volume 1 1 and and NEDC-3241 OP-A Volume 2 -- Appendices, Nuclear Measurement Analysis and NEDC-32410P-A Volume 2 -- Appendices, Nuclear Measurement Analysis and Control Control PowerPower Range Neutron Monitor Range Neutron Monitor (NUMAG (NUMAC PRNM) PRNM) Retrofit Plus Option Retrofit Plus Option ///
III Stability Stability Trip Trip Function, Function, dateddated October October 1995 1995 (ADAMS Ascension No.
(ADAMS Ascension No. ML9605290009 ML9605290009 includes includes NRC NRC SE) SE) 22.. GE GE Nuclear Nuclear Energy Energy LTR LTR NEDC-3241 NEDC-3241 OP-A OP-A Supplement Supplement 1, 1, Nuclear Nuclear Measurement Measurement Analysis Analysis and and Control Control Power Power Range Range Neutron Monitor (NUMAG Neutron Monitor (NUMAC PRNM) Retrofit Plus PRNM) Retrofit Plus Option Option /// III Stability Trip Function, Stability Trip Function, dateddated November November 1997 1997 (ADAMS (ADAMS Ascension Ascension No. No.
ML9806120242 ML9806120242 includes includes NRC NRC SE) SE) 33.. NRC NRC letter letter toto GE GE Nuclear Nuclear Energy, Energy, Acceptance Acceptance of of Licensing Licensing Topical Topical Report Report NED C-324 I OP, Nuclear Measurement Analysis and Control Power Range Neutron NEDC-32410P, Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC-PRNM) Retrofit Plus Option /// Stability Trip Function, (TAG No.
Monitor (NUMAC-PRNM) Retrofit Plus Option III Stability Trip Function, (TAC No.
M90616)
M90616) dated dated September September 5, 5, 1995 1995 44.. NRC NRC letter letter toto GE GE Nuclear Nuclear Energy, Energy, Acceptance Acceptance of of Licensing Licensing Topical Topical Report Report NEDC-324 NEDC-32410P, I OP, Supplement Supplement 1,1, Nuclear Nuclear Measurement Measurement Analysis Analysis and and Control Control Power Power Range Range Neutron Neutron Monitor Monitor (NUMAG-PRNM)
(NUMAC-PRNM) Retrofit Retrofit Plus Plus Option Option ///III Stability Stability Trip Trip Function, Function, dated dated August August 15, 15, 1997 1997 5.
- 5. GE GE Hitachi Hitachi Nuclear Nuclear Energy Energy Report Report 0000-0102-0888, 0000-0102-0888, Grand Grand Gulf Gulf Nuclear Nuclear Station Station --
Plant-Specific Plant-Specific Responses Responses RequiredRequired by by NUMAC NUMAC PRNM PRNM Retrofit Retrofit Plus Plus Option Option ///
III Stability Stability Trip Function Topical Report (NEDG-3241QP-A)
Trip Function Topical Report (NEDC-32410P-A)
- 6. GE GE Hitachi Hitachi Nuclear Nuclear Energy Energy LTR LTR NEDO-31960-A, NEDO-31960-A, BWR BWR Owners' Owners' GroupGroup Long-Term Long-Term Stability Solutions Licensing Methodology, and associated Supplement 11 Stability Solutions Licensing Methodology, and associated Supplement
Attachment 1 to to GNRO-2009-00054 GNRO-2009-00054 Page 40 Page 40 of 41 of 41 7.
- 7. NRC letter NRC letter toto Entergy Entergy Operations, Inc., Grand Operations, Inc., Grand GulfGulf Nuclear Nuclear Station, Unit I1 -Issuance Station, Unit - Issuance of Amendment of Amendment Re: Re: Reactor Reactor Core Gore Stability Stability Enhanced Enhanced Option Option I-A I -A (TAC (TAG NO.NO. MA3406),
MA3406) ,
January 19, 2000 January 19, 2000 8.
- 8. NRC NRC Generic Letter 94-02, Generic Letter 94-02, Long-Term Solutions and Long-Term Solutions and Upgrade Upgrade of of Interim Interim Operating Operating Recommendations for Recommendations for Thermal Thermal Hydraulic Hydraulic Instabilities Instabilities inin Boiling Water Reactors Boiling Water Reactors 9.
- 9. BWR BWR Owners' Owners' Group Document OG-02-0119-260, Group Document OG-02-0119-260, GE GE to BWROG Detect to BWROG Detect and and Suppress Suppress II // Committee, Committee, "Backup Stability Protection "Backup Stability Protection (BSP)
(BSP) for for Inoperable Inoperable Option Option III/I/
Soluti Solution" 10.
- 10. NRC NRC letter letter toto Northern Northern States Power Company, States Power Company, Monticello Monticello Nuclear Nuclear Generating Generating Plant Plant (MNGP)
(MNGP) -- Issuance Issuance of of Amendment Amendment Regarding Regarding the the Power Power Range Range Neutron Neutron Monitoring Monitoring System System (TAC(TAG No. MDB064) , dated No. MD8064), dated January January 30, 2009 (ADAMS 30,2009 (ADAMS Ascension Ascension No. No.
M L083440681))
ML083440681 11 11.. NRC NRC letter letter toto Exelon Exelon Nuclear, Nuclear, Peach Peach Bottom Bottom Atomic Atomic Power Station, Units Power Station, Units 22 and and 3 3 --
Issuance of Amendment Issuance of Amendment Re:
Re: Activation of Oscillation Power Range Monitor Trip (TAC Activation of Oscillation Power Range Monitor Trip (TAC Nos . MC2219 and MC2220), dated March 21, 2005 (page 4 of SE) (ADAMS Nos. MC2219 and MC2220), dated March 21,2005 (page 4 of SE) (ADAMS Accession Accession No No.. ML05270020)
ML05270020) 12.
- 12. NRC NRC letter letter toto the the Carolina Power and Carolina Power and Light Light Company, Brunswick Steam Company, Brunswick Steam Electric Electric Plant, Plant, Units Units I1 and and 22 - - Issuance Issuance ofof Amendment Amendment to to Incorporate Incorporate the General Electric the General Electric Digital Digital Power Power Range Neutron Monitoring Range Neutron Monitoring System System (TAC (TAC Nos.
Nos. MB2321M82321 and MB2322), dated and MB2322), dated March March 8, 8, 2002 2002 13.
- 13. Technical Specifications Technical Specifications Task Task Force Force letter letter to to the the NRC, NRC, Transmittal Transmittal of of TSTF-493, TSTF-493, Rev.. 4, Rev 4, "Clarify "Clarify Application Application ofof Setpoint Setpoint Methodology Methodology for for LSSS Functions,"" dated LSSS Functions, dated July 31, July 2009 {ADAMSAccession 31,2009 (ADAMS Accession Number Number ML092150990)
ML092150990) 14 .
- 14. GE GE Hitachi Hitachi Nuclear Nuclear Energy Report 0000-0102-8815, Energy Report 0000-0102-8815, Instrument Instrument LimitsLimits Calculation Calculation- -
Average Power Range Neutron Monitor - Power Range Neutron A verage Power Range Neutron Monitor - Power Range Neutron Monitoring Monitoring System System (NUMAC)
(NUMAC) -- CL CL TP TP Operation Operation 15.
- 15. GE Nuclear GE Nuclear Energy Energy LTR NEDO-32465-A, BWR LTR NEDO-32465-A, BWR Owners' Owners' Group Reactor Stability Group Reactor Stability Detect and Suppress Solutions Licensing Basis Detect and Suppress Solutions Licensing Basis Methodology Methodology for for Reload Reload Applications Applications 16.
- 16. GE GE Hitachi Nuclear Energy Hitachi Nuclear Energy Report Report 0000-0107-7607-P, 0000-0107-7607-P, Grand Grand GulfGulf Nuclear Nuclear Station Station- -
Grand Gulf PRNM Grand Gulf PRNM Upgrade Upgrade Project Project Option Option ///
III Stability Stability Deviations Deviations 17.
- 17. Instrument Society of Instrument Society of America America standard standard 67.04, 67.04, Part 11, 1994, Part II, 1994, Methodologies Methodologies for for the the Determination of Determination Setpoints for of Setpoints for Nuclear Safety-Related Instrumentation Nuclear Safety-Related Instrumentation 18.
- 18. GE Nuclear GE Nuclear Energy Energy LTRLTR NEDC-31336P-A, NEDC-31336P-A, GeneralGeneral Electric Instrument Selpoint Electric Instrument Setpoint Methodology Methodology 19.
- 19. NRC letter NRC letter to the NEI to the NEI Setpoints Setpoints Methods Methods Task Force, Technical Task Force, Specification for Technical Specification for Addressing Addressing IssuesIssues Related Related to to Setpoint Setpoint Allowable Values, dated Allowable Values, dated September September 7, 2005 7,2005 (ADAMS Accession (ADAMS Accession NumberNumber ML052500004)
ML052500004) 1 to Attachment to GNRO-2009-00054 GNRO-2009-00054 Page 4 1 of Page 41 of 41 41 20 .
- 20. NRC Regulatory NRC Regulatory IssueIssue Summary Summary (RIS)
(RIS) 2006-17, 2006-17, NRC NRC Staff Staff Position on the Position on the Requirements of 10 CFR 50.36, "Technical Specifications," Regarding Limiting Requirements of 10 CFR 50.36, "Technical Specifications," Regarding Limiting Safety Safety System Settings System Settings During During Periodic Testing and Periodic Testing and Calibration Calibration of of Instrument Channels Instrument Channels 21 .
- 21. Technical Specifications Technical Task Force Specifications Task Force letter letter to the NRC, to the NRC, Industry Industry Plan Plan to to Resolve Resolve TSTF-493, "Clarify TSTF-493, "Clarify Application of Setpoint Application of Methodology for Setpoint Methodology for LSSS LSSS Functions, Functions,"" dated dated February 23, February 2009 (ADAMS 23,2009 Accession Number (ADAMS Accession Number MI-090540849)
ML090540849) 22.
- 22. NRC letter NRC letter to the Technical to the Specifications Task Technical Specifications Task Force, Reply to Force, Reply to Industry Industry Plan to Plan to Resolve TSTF-493, "Clarify Resolve TSTF-493, "Clarify Application Application ofof Setpoint Setpoint Methodology Methodology forfor LSSS Functions, LSSS Functions,"
dated dated March 9, 2009 (ADAMS March 9,2009 Accession Number (ADAMS Accession Number ML0905460592)
MI-0905460592)
ATTACH ATTACHMENTENT 22 RO-20 GNRO-2009-Q0054 ITA HI NUCLEAR GE HITACHI ENERGY REPORT NUCLEAR ENERGY REPORT 0000-0102-0888-RO 000-0102-0888 GRAND GULFF NUC .EAR STATION NUCLEAR STATION -- PLANT-SPECIFIC RESPONSES RE PLANT-SPECIFIC RESPONSES REQUIRED BY NU NUMAC PRNM TROFIT PLUS OPTION III STABILITY TRIP FUNCTION RETROFIT PLUS OPTION III STABiliTY TRIP FUNCTION TOPICAL TOPICAL REPORT (NEDC-3241OP-REPORT (NEDC-32410P-A)
HITACHI GE Hitachi NUclear Energy 0000-0 1 02-0888-RO 0000-0102-0888-RO GEH DRF GEH 0000-0098-4327 DRF 0000-0098-4327 Class III Class III October 2009 October 2009 Grand Gulf Grand Gulf Nuclear Nuclear Station Station Plant-Specific Plant-Specific Responses Responses Required Required By NUMAC PRNM By NUMAC PRNM Retrofit Retrofit Plus Plus Option Option IIIIII Stability Stability Trip Trip Function Function Topical Report (NEDC-32410P-A)
Topical Report (NEDC-32410P-A)
Prepared by: SS.. Rudy Prepared by: Rudy Verified Verified by:
by: R.
R. Hayes Hayes Approved Approved by:
by: E.
E. Schrull Schroll
0000-0102-0888-RO 0000-0102-0888-RO Grand Gulf Grand Gulf Specific Specific Responses Responses Required Required byby NUMAC NUMAC PRNM PRN Retrofit Retrofit Topical Topical Report Report Table of Table of Contents Content Grand Gulf Specific Grand Gulf Specific Responses Responses Required Required byby NUMAC NUMAC PRNM PRNM Pages 1-19 Pages 1-19 trofit Topical Report Retrofit Topical Report Appendix Appendix A ulf Nuclear A, Grand Gulf Nuclear Station Station NUMAC NUMAC PRNM PRNM L' eviations LTR Deviations Pages AI-A7 Pages Al-A7
0000-0102-0888-RO 0000-0102-0888-RO Grand Gulf Specific Responses Required by Grand Gulf Specific Responses Required by NUMAC NUMAC PRNM PAM Retrofit Retrofit TopicalTopical Report Report The section The section numbers numbers and and Utility Utility Actions Actions Required Required listed listed below below areare from from the the NUMAC NUMAC PRNM PAM Retrofit Plus Retrofit Option III Plus Option III Stability Stability Trip Trip Function Function Topical Topical Report Report NEDC-3 NEDC-3241 24 1 OP-A OP-A including including Supplement 1.
Supplement 1.
Section Section No. Utility Action Utility Required Action Required espouse
Response
2.3 .2 2.3.2 Option Option III III Stability Implementation Stability Implementation Not of aa required required specific specific LTR response LTR response Confirm Confirm that that the actual plant the actual Option III plant Option III The GGNS The GGNS Option Option III III implementation implementation is in is in configuration configuration is is included included in in the variations the variations accordance with accordance the LTR with the Requirements of LTR Requirements of covered covered in in the the Power Power RangeRange Neutron Neutron Monitor Monitor section 2.3.2 with section 2.3.2 with the the exception exception of of 22 deviations deviations (PAM) Licensing Topical (PRNM) Licensing Topical Report Report (LTR)
(LTR) from the from the BWROG BWROG Option Option III III Topical Report.,
Topical Report.
[NEDC-32410P-A, Volumes
[NEDC-32410P-A, Volumes I1 & & 22 and and Justification for Justification for these deviations is these deviations is provided provided Supplement Supplement 1]. 1]. separately (GEH document separately (GEH 0000-0107-7607-P-document 0000-0107-7607-P-RO, RO, September 2009).
September 2009).
2.3.4 2.3.4 lout Unique Plant Unique or or Plant-Specific Plant-Specific Aspects Aspects The The actual, current plant actual, current plant configuration configuration and and thethe Confirm Confirm that that the actual plant the actual configuration is plant configuration is proposed replacement proposed replacement PAM PRNM are are included included in in included included in the variations in the variations covered covered in in the the Power Power the PRNM LTR the PRNM LTR as as follows:
follows : (Applicable (Applicable LTR LTR Range Range Neutron Neutron Monitor Monitor (PAM) Licensing (PRNM) Licensing sections sections are are listed.)
listed.)
opical Report Topical Report (LTR) [NEDC-32410P-A, (LTR) [NEDC-32410P-A, Volumes Volumes 1I & & 22 and Supplement 1],
and Supplement 1], and and thethe Current Current Proposed Proposed configuration alternative(s) being configuration altemative(s) being applied applied for the for the APRM APRM 2 .3 .3 .1 .1 .3 2.3.3.1.1.3 2.3.3 .1 .2.2 2.3.3.1.2.2 replacement replacement PRNM PRNM are are covered covered by by the PRNM the PRNM RBM M 2.3 .3 .2.1 .2 2.3.3.2.1.2 2.3.3 .2 .2.2 2.3.3.2.2.2 LTR.
LTR. Document Document in in the the plant-specific plant-specific licensing licensing Flow Flow Unit Unit 2.3 .3 .3 .1 .3 2.3.3.3.1.3 2.3 .3 .3 .2.2 2.3.3.3.2.2 submittal for submittal for the PRNM project the PRNM project the the actual, actual, Rod Rod Control Control 2.3 .3 .4.1 .3 2.3.3.4.1.3 2.3.3 .4 .2.3 2.3.3.4.2.3 current current plant configuration of plant configuration of the replacement the replacement ARTS ARTS 2.3 .3 .5.1 .5 2.3.3.5.1.5 2.3.3.5 2.3.3.5.2.3.2.3 PRNM, and PRNM, and document confirmation that document confirmation that those those Panel Panel Interface Interface 2.3 .3 .6.1 .2 2.3.3.6.1.2 2.3.3 .6 .2.1 2.3.3.6.2.1 are covered are covered by by thethe PRNM PRNM LTR LTR.. For For anyany changes changes to to the plant operator's the plant operator's panel, panel, document document in in the the submittal submittal the the human human factors factors review review Human Human Factors Factors Engineering Engineering review review willwill bebe actions that actions that were were takentaken toto confirm confirm compatibility compatibility performed as performed as part of the part of the normal design process normal design process..
with existing with existing plant plant commitments commitments and and procedures.
procedures.
The The actual actual PRNMS PRNMS System System to to be be installed installed at at GGNS GGNS contains contains 33 deviations deviations from from the system the system design design as as described described in in the the LTR LTR.. Justification Justification for for these these deviations deviations is is provided provided as as Appendix Appendix A. A.
33.4
.4 System System Functions Functions As As part part ofof the the plant-specific plant-specific licensing licensing submittal, submittal, the the utility utility should should document document the the following following::
- 1) The The pre-modification pre-modification flow flow channel channel 1) The The current current flow flow channel channel configuration configuration configuration, configuration, and and any any changes changes planned planned consists of four flow channels, eight consists of four flow channels, eight (normally (normally changes changes will will be be either either adding adding two two transmitters . Thus, the current transmitters. Thus, the current channels channels to to reach reach four four oror no no change change configuration configuration meetsmeets the the requirements requirements planned) planned) described described in in LTR LTR Section Section 33.2.3.2.2,
.2 .3 .2 .2, therefore therefore no no changes changes will will bebe made.
made.
NOTE:
NOTE: If If transmitters transmitters are are added, added, thethe requirements requirements on the added on the added transmitters transmitters should should be: be:
0
- Non-safety Non-safety related, related, but but qualified qualified I1 of of 19 19
0000-0102-0888-RO 0000-0102-0888-RO Grand Gulf Specific Responses Required by Grand Gulf Specific Responses Required by NUMAC NUMAC PRNM PAM Retrofit Retrofit TopicalTopical Report Report Section No.
Section No. I Utility Action Required Utility Action Required Response
Response
environmentally environmentally and and seismically seismically to to operate operate in in the the application application environment environment..
- " Mounted Mounted with structures equivalent with structures equivalent or or better than those better than those for for the the currently currently installed channels.
installed channels .
- " Cabling routed to Cabling routed achieve separation to achieve separation to the extent to the extent feasible feasible using using existing existing cableways cableways and and routes.
routes.
- 2) Document
- 2) Document the the APB APRM tripstrips currently currently applied applied 2) The new
plant. If If different from those different from those documented documented are listed are listed below.
below. The The "post-modification" "post-modification" in the in PRNM LTR, the PRNM LTR, document document plans to change plans to change to to trips will trips be the will be same as the same those identified as those identified in in those in those in the the LTR.
the LTR.
"* The Neutron The Neutron Flux Flux -- High, Setdown High, Setdown function (APRM function {APB Function Function 2.a) 2.a) has has been retained been retained as as described described in LTR in LTR paragraphs 3.2.4 paragraphs 3.2.4 and and 8.3.1.4.
8.3 .1 .4.
"* The Fixed The Neutron Flux-High Fixed Neutron function Flux-High function
{APB Function (APRM Function 2.b) 2.b) has has been been retained as retained as described described in in LTR paragraph LTR paragraph 3.2.5) .
3.2.5).
"* The The Inop Inop function function (APB(APRM Function Function 2.c) has 2.c) has been been retained retained as as described described in in LTR paragraph 3 .2.10.
LTR paragraph 3.2.10.
"* The Flow The Flow Biased Biased Simulated Simulated Thermal Thermal Power - High Power High function function (APRM (APB Function 2.d)
Function 2.d) has has been been retained retained as as described in LTR paragraph 3.2 .5 .
described in LTR paragraph 3.2.5.
"* The 2-Out-of-4 The 2-0ut-of-4 Voter function (APRM Voter function {APB Function 2 .e) has been added Function 2.e) has been added as as described in described in as as described described in in LTR LTR paragraphs paragraphs 3.2.23.2.2 and and 8.3.2 .4.
8.3.2.4.
"* The OPT The OPRM Upscale function (APB Upscale function (APRM Function Function 2J) 2.f) has been added has been added as as described in described in LTR LTR paragraph paragraph 8.4 .1 .2.
8.4.1.2.
3)
- 3) Document Document the the current current status status related related toto 3)
- 3) ARTS ARTS is is not not applicable applicable to to GGNS GGNS because because ARTS ARTS and and the the planned planned postpost modification modification status status Grand Grand Gulf Gulf isis aa BWR6 BWR6..
as:
as:
0* ARTS ARTS currently currently implemented, implemented, and and retained retained in in the the PAM PRNM 0* ARTS ARTS will will be be implemented implemented concurrently concurrently with with thethe PRNM PRNM (reference (reference ARTS ARTS submittal) submittal) 0* ARTS ARTS not not implemented implemented and and will will not not be be implemented implemented with with thethe PRNM PRNM 0* ARTS ARTS not not applicable applicable 4.4.1.11 4.4.1.11 Re gulatoly Requirements Regulatory Requirements of of the the Replacement Replacement A review of A review of the the GGNS GGNS requirements requirements confirms confirms System System -- System System D Design that that the the regulatory regulatory requirements requirements addressed addressed in in the the LTR LTR encompass encompass the the related related GGNS GGNS 22 of of 19 19
0000-0102-0888-RO 0000-0102-0888-RO Grand Gulf Grand Gulf Specific Specific Responses Responses Required Required by by NUMAC NUMAC PRNM PAM Retrofit Retrofit Topical Topical Report Report Section No.
Section No. Utility Action Utility Action Required Required Response
Response
This section This section identifies identifies requirements requirements that that are are requirements . Part requirements. Part of of the the normal normal design design process process expected to expected to encompass encompass most most specific specific plant plant confirms that confirms that the the detailed detailed PRNM PAM design design meets meets commitments relative commitments relative to to the the PRNM PRNM replacement replacement the applicable the applicable detailed detailed GGNS GGNS technical technical and and project, but project, but may may not not bebe complete complete and and some some may may licensing requirements.
licensing requirements, not apply not apply to to all all plants.
plants . Therefore, Therefore, the the utility utility must confirm must confirm that that the the requirements requirements identified identified here address here address all all ofof those those identified identified in in the the plant plant commitments . The commitments. The plant-specific plant-specific licensing licensing submittal should submittal should identify identify the the specific specific requirements applicable requirements applicable for for the the plant, plant, confirm confirm that any that any clarifications clarifications included included here here apply apply to to the the plant, and plant, and document document the the specific specific requirements requirements that the that the replacement replacement PRNM PRNM is intended to is intended to meet meet for the for the plant.
plant.
4.4.2.2 .1 .4 4.4.2.2.1.4 Re gulatoly Requirements Regulatory Requirements for for the the Replacement Replacement The PRNM The PRNM control control room room electronics electronics are are System -Equipment System -Equipment i$,Iualification Qualification -- Temperature Temperature qualified for continuous operation under qualified for continuous operation under thethe and Humidity and Humidity following temperature following temperature conditions conditions:: 55 to 50 'C [41 to 50°C [41 to 122 'F]
to 122 OF].. The The GGNS GGNS normalnormal control control roomroom Plant-specific Plant-specific action action willwill confirm confirm that the that the temperature is:
temperature is: 72°F.
72'F . The The design design process process maximum maximum control control room temperatures plus room temperatures plus includes actions to confirm that the PAM includes actions to confirm that the PRNM mounting mounting panel temperature rise, panel temperature rise, allowing allowing for for equipment, as installed in the plant, is equipment, as installed in the plant, is qualified qualified heat load of heat load of the the PRNM PRNM equipment, equipment, does does not not for for the the environmental environmental limits, limits, including including exceed exceed the the temperatures temperatures presentedpresented in in the PRNM the PRNM temperature temperature rise measurements .
rise measurements.
LTR, LTR, andand that that control control roomroom humidity humidity is is maintained maintained within within the the limits stated in limits stated in the the PRNM PRNM The The PRNM PRNM control control room room electronics electronics are are LTR.
LTR. ThisThis evaluation evaluation will will normally normally be be qualified qualified for continuous operation for continuous operation under under thethe accomplished accomplished by determining the by determining the operating operating following relative humidity following relative humidity conditions conditions:: 10 10 to to temperature temperature of of the the current current equipment equipment which which willwill 90%
90% (non-condensing)
(non-condensing).. The The GGNSGGNS relative relative be be used used as as aa bounding bounding value value because because the the heat heat humidity humidity requirement requirement for for control control roomroom load load ofof the the replacement replacement system system is less than is less than the the equipment equipment is is 20-50%,
20-50%, whichwhich is is within within the the range range current current system system while while the the panel panel structure, structure, and and for for which which thethe PRNM PRNM equipment equipment is is qualified.
qualified.
thus thus cooling, cooling, remains remains essentially essentially the the same.
same. The The qualification qualification results results will will bebe documented documented in in Documentation Documentation of of the the above above action, action, including including aa plant plant unique unique "Qualification "Qualification Summary"Summary"..
the the specific specific method method used used forfor the the required required confirmation confirmation should should be be included included in in plant-plant-specific specific licensing licensing submittals submittals..
4.4.2.2.2 .4 4.4.2.2.2.4 Re aulatoly Requirements Regulatory Requirements for for the the Replacement Replacement The The PRNM PRNM control control room room electronics electronics are are Systern System -Equipment
-Equipment Qualification Qualification -- Pressure Pressure qualified qualified for for continuous continuous operation operation under under thethe Plant-specific Plant-specific action action willwill confirm confirm that that the the following pressure conditions : 13 -16 psia. The following pressure conditions: 13 - 16 psia. The maximum maximum control control room room pressure pressure does does notnot GGNS normal control room pressure is ambient GGNS normal control room pressure is ambient exceed exceed the the limits limits presented presented in in the the PRNM PRNM LTR, LTR. atmospheric atmospheric pressure pressure +1/4+ 1/4 in.
in. -- 00 in in w.g.
w.g. This This Any Any pressure pressure differential differential from from inside inside to to outside outside range is within these limits . The qualification range is within these limits. The qualification the the mounting mounting panel panel assumed assumed to to be be negligible negligible results results will will bebe documented documented in in aa plant plant unique unique since since the the panels panels are are not not sealed sealed and and there there isis no no "Qualification "Qualification Summary.
Summary.
forced forced cooling cooling or or ventilation.
ventilation. Documentation Documentation of of this this action action andand the the required required confirmation confirmation should should be be included included in inplant-specific plant-specific licensinglicensing submittals.
submittals.
4.4.2.2.3.4 4.4.2.2.3.4 Regulatoly Regulatory Requirements Requirements for for the the Replacement Replacement The The PRNM PRNM control control room room electronics electronics are are System System -Equipment
-Equipment Qualification Qualification -Radiation
-Radiation qualified for continuous operation under the qualified for continuous operation under the 330f19 of 19
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Section No. I Utility Action Utility Required Action Required Response
Response
Plant-specific action Plant-specific action will will confirm confirm that that the the following conditions: Dose following conditions: Dose Rate.:s Rate < 0.001 0.001 Rads Rads maximum control maximum control room room radiation radiation levelslevels do do not not (carbon)/hr and Total Integrated Dose (TID) <
(carbon)/hr and Total Integrated Dose (TID).:s exceed the exceed the limits limits presented presented in in the the PRNM PRNM LTR. LTR. 1000 Rads 1000 Rads (carbon).
(carbon) . The The GGNSGGNS control control roomroom Documentation of Documentation of this this action action and and thethe required required (Zone A) dose rates are 0.2 and 0.5 mrem/hr and (Zone A) dose rates are 0.2 and 0.5 mrem/hr and confirmation should confirmation should be included in be included in plant-plant- TID are TID within the are within the qualified qualified limits.
limits . The The specific licensing submittals.
specific licensing submittals . qualification results qualification results willwill be documented in be documented in aa plant unique plant unique "Qualification "Qualification Summary~Summary .
4.4.2.3.4 4.4.2.3.4 gulatoly Requirements Regulatory Requirements for for thethe Replacement Replacement Evaluations to Evaluations to confirm confirm that that the the maximum maximum System -Seismic System -Seismic Qualification Qualification seismic accelerations at seismic accelerations at the the mounting mounting locations locations Plant-specific action Plant-specific action or or analysis analysis will confirm will confirm of the of the equipment equipment do do not not exceed exceed qualification qualification that the that the maximum maximum seismic accelerations at seismic accelerations at the the limits limits of of the equipment is the equipment completed as is completed as part part of of mounting locations mounting locations of of the the equipment equipment (control(control the normal the normal design design change change process.
process . TheThe seismic seismic room floor room acceleration plus floor acceleration plus panel panel qualification results will qualification results will be documented in be documented in amplification) for both OBE and amplification) for both aBE and SSESSE spectrums spectrums "Qualification Summary".
"Qualification Summary".
do not do exceed the limits stated in the not exceed the limits stated in the PRNM PRNM LTR. Documentation LTR. Documentation of of this this action action and and thethe required confirmation required confirmation should should be be included included in in plant-specific plant-spec(fic licensing submittals.
licensing submittals.
4.4.2.4.4 4.4.2.4.4 Re gulatoly Requirements Regulatory Requirements for for thethe Replacement Replacement System -EMI System -EMI Qualification Qualification The utility The utility should should establish establish or or document document practices practices to to control control emission sources, maintain emission sources, maintain good grounding good grounding practices practices and and maintain maintain equipment and equipment and cable cable separation.
separation.
- 1) Controlling Emissions Controlling Emissions 1) Controlling
- 1) Controlling Emissions Emissions a) a) Portable Portable Transceivers (walkie-talkies) :
Transceivers (walkie-talkies): a) The a) The qualification qualification levels levels used used forfor the the Establish Establish practices practices to to prevent prevent operation operation of of NUMAC PRNM NUMAC PRNM system system exceed those exceed those portable transceivers in close proximity of portable transceivers in close proximity of expected to expected to result result from from portable portable equipment equipment sensitive sensitive to to such such emissions emissions.. transceivers, even if such transceivers transceivers, even if such transceivers are are (NOTE:
(NOTE: The The qualification qualification levels levels used used for for operated immediately adjacent to operated immediately adjacent to NUMAC NUMAC the the NUMAC NUMAC PRNM PRNM exceed exceed those those equipment . GGNS equipment. GGNS generally generally prohibits prohibits expected expected to to result result from from portable portable operation of operation portable transceivers of portable transceivers near near transceivers, transceivers, even even ifif such such transceivers transceivers are are sensitive equipment, sensitive equipment, and and ifif warranted, warranted, operated operated immediately immediately adjacentadjacent to to the the requires requires positioning positioning of of warning warning signssigns at at NUMAC NUMAC equipmentequipment.) .) critical critical locations locations throughout throughout the the plant.
plant.
Placement Placement of of warning warning signs signs isis evaluated evaluated as as part part of of the the modification modification process process..
b) b) ARC ARC Welding:
Welding: b) b) TheThe qualification qualification levels levels used used forfor the the Establish practices Establish practices to to assure assure thatthat ARC ARC NUMAC NUMAC PRNM PRNM system system minimize minimize the the welding activities do not occur in the welding activities do not occur in the likelihood likelihood of of detrimental detrimental effects effects duedue toto ARC ARC vicinity vicinity of of equipment equipment sensitive sensitive to to such such welding as long as reasonable ARC welding welding as long as reasonable ARC welding emissions, emissions, particularly particularly duringduring times times whenwhen control control and and shielding shielding practices practices areare used.
used.
the the potentially potentially sensitive sensitive equipment equipment is is ARC ARC welding welding is is only only performed performed at at GGNS GGNS required required to to be be operational operational for for plant plant safety.
safety. with with specific specific workwork orders orders andand directions, directions, (NOTE:
(NOTE: The The qualification qualification levels levels used used forfor and and is is known known to to have have thethe potential potential to to affect affect NUMAC NUMAC PRNM PRNM minimize minimize the the likelihood likelihood operation operation of of I&C I&C equipment equipment at at aa number number of of of of detrimental detrimental effects effects due due to to ARC ARC welding welding locations locations in in the the plant plant.. Therefore, Therefore, ARC ARC as as long long asas reasonable reasonable ARC ARC welding welding control control welding welding activity activity is is only only performed performed when when any any and and shielding shielding practices practices are are used.)
used.) potential potential effect effect on on I&C I&C equipment equipment is is tolerable tolerable relative relative to to plant plant operation.
operation.
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Response
c) Limit c) Limit Emissions Emissions from from NewNew Equipment:
Equipment : c) EMI emissions from c) EMI emissions from newnew equipment equipment Establish practices Establish practices for for new new equipment equipment and and installed at GGNS are evaluated as installed at GGNS are evaluated part of as part of plant plant modifications modifications to assure that to assure that they they the normal the normal design design modification process modification process either do either do not produce unacceptable not produce unacceptable levels levels described in described in GGNS GGNS procedures.
procedures .
of emissions, of emissions, or or installation installation shielding, shielding, filters, grounding filters, grounding or or other other methods methods prevent prevent such emissions such emissions from from reaching reaching otherother potentially sensitive equipment potentially sensitive equipment.. These These practices should address practices should address both radiated both radiated emissions and emissions and conducted conducted emissions, emissions, particularly particularly conducted emissions on conducted emissions on power power lines and lines and power power distribution distribution systems.
systems .
Related Related to to power power distribution, distribution, both both thethe effects effects of of new new equipment equipment injecting injecting noise noise on the power on the power system system and and the the power power system system conducting conducting noise noise to to the the connected connected equipment equipment shouldshould be be addressed.
addressed. (NOTE: (NOTE :
For For thethe qualification qualification of of the the PRNM PRNM equipment equipment includes emissions testing includes emissions testing.) .)
- 2) Grounding
- 2) Grounding Practices Practices 2)
- 2) Grounding Grounding Practices Practices Existing Grounding Existing Grounding System:System: The The specific specific The PRNM The PRNM systemsystem equipment equipment is is being being installed installed details and details and effectiveness effectiveness of of the original the original in place in of existing place of existing Power Power Range Range Monitor Monitor grounding system grounding system in in BWRs BWRs variedvaried significantly significantly.. (PRM) system (PRM) system electronics electronics.. , The The replacement replacement As As part part ofof the the modification modification process, process, identify identify any any system interfaces system interfaces withwith the the same same cables and cables and known known or or likely likely problem problem areas areas based based on on wiring at wiring at the panel interfaces the panel interfaces as as the current the current previous experience and previous experience and include include in in the the system, including system, including ground ground busbus connections.
connections . NoNo modification program either an evaluation step modification program either an evaluation step problems problems have have been identified with been identified with the current the current to to determine determine if if problems actually exist, or problems actually exist, or PRM PRM system system related related to grounding or to grounding or grounding grounding include include corrective corrective action action as as part part ofof the the practices. The original installation included practices. The original installation included modification.
modification. (NOTE (NOTE:: The The PRNM PRNM equipment equipment is is specific grounding specific grounding practices practices designed designed to to being being installed installed in in place place of of existing existing PRM PRM minimize minimize performance problems . The performance problems. The electronics electronics which which is is generally generally more more sensitive sensitive to to replacement replacement PRNMPRNM systemsystem is is less less sensitive sensitive to to EMI EMI than than thethe NUMAC equipment. As NUMAC equipment. As long long as as grounding grounding issues issues than than is is the current system the current system and and the the plant plant hashas experienced experienced no no significant significant includes includes specific specific actions actions in in the the wiring wiring inside inside the the problems problems with with the the PRM, PRM, no no problems problems are are panel panel to to maximize maximize shielding shielding andand grounding grounding anticipated anticipated withwith thethe PRNM PRNM provided provided grounding grounding effectiveness.
effectiveness.
is is done done inin aa comparable comparable manner manner.) .)
Grounding Grounding Practices Practices for for New New Modifications Modifications::
New New plant plant modifications modifications process process should should include include aa specific specific evaluation evaluation of of grounding grounding methodsmethods to to be be used used toto assure assure bothboth that that the the new new equipment equipment is is installed installed inin aa way way equivalent equivalent to to the the conditions conditions used used inin the the qualification qualification.. (NOTE: (NOTE: NUMAC NUMAC RNM equipment PRNM equipment qualification qualification is is performed performed in in aa panel panel assembly assembly comparable comparable to to that that used used in in the the plant.)
plant.)
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Section No. Utility Action Utility Action Required Required espouse
Response
3)
- 3) Equipment and Equipment and Cable Cable Separation Separation 3)
- 3) Equipment and Equipment and Cable Separation Cable Separation Cabling Cabling:: Establish cabling practices practices to to The original The original PRM PRM system system cable cable installation installation
- Establish cabling requirements met met this objective . The assure that assure signal cables that signal with the cables with the requirements this objective. The potential potential to to be "receivers" are be "receivers" are kept kept replacement PRNM replacement system uses PRNM system uses the the same same separate from separate from cables cables thatthat are are sources sources of of cable routes cable routes and and paths paths atat comparable comparable energyenergy noise noise.. (NOTE:
(NOTE: The The original original PRMPRM cable cable levels where levels where feasible.
feasible . Because Because no specific no specific installation requirements installation requirements met met this this problem has problem has been been identified identified in in the current the current objective objective.. The The replacement replacement PRNM PRNM system, no system, no special special action action is is necessary necessary for for the the useses the the same same cable cable routes routes and and papaths, so PRNM modification.
PRNM modification The The existing existing system system unless some specific problem has been unless some specific problem has been cabling complies cabling complies withwith. applicable applicable GGNS GGNS identified identified in in the the current current system, no system, no cable routing and separation requirements.
cable routing and separation requirements .
special action special action should should be be necessary necessary for for Additionally, the Additionally, the modification modification processprocess isis the the PAM PRNM modification.)
modification.) performed in accordance with the existing performed in accordance with the existing quipment : Establish equipment separation criteria.
separation criteria.
- Equipment: Establish equipment separation and separation shielding practices and shielding practices forfor the the installation installation of of new equipment to new equipment to simulate simulate thatthat equipment's equipment's qualification qualification condition, condition, both both relative relative to to susceptibility susceptibility and and emissions emissions.. (NOTE:(NOTE: The The original original PRM PRM cabinet design met cabinet design met this this objective objective..
The The replacement replacement PAM PRNM uses uses the same the same mounting mounting cabinet, cabinet, and and used used anan equivalent mounting assembly equivalent mounting assembly for for qualification.
qualification. No No special special action action should should be necessary for the PRNM be necessary for the PRNM modification.)
modification.)
The The plant-specific licensing submittals plant-specific licensing submittals should should identify the practices identify the practices that that are are inin place place oror will will be be applied applied for for the the PRNM PRNM modification modification to address to address each each of of the the above above items items..
6.6 6.6 System System Failure Failure Analysis Analysis The utility must confirm The utility must confirm applicability applicability of of the the failure failure analysis analysis conclusions conclusions contained contained in in the the PRNM PRNM LTR L TR by by the the following following actions:
actions:
1 . Confirm
- 1. Confirm thatthat the the events events defined defined in in EPRI EPRI 11.. The The GGNS GGNS Technical Technical Specification Specification Report Report No.
No. NP-2230 NP-2230 or or in in Appendices Appendices F F and and G G Surveillance Surveillance Requirements Requirements for for the the Reactor Reactor of Reference I I of the PRNM LTR, encompass of Reference 11 of the PRNM L TR, encompass Protection System (RPS) are based on Protection System (RPS) are based on Reference Reference the the events events that that are are analyzed analyzed for for the the plant; plant; I I of the PAM LTR as discussed in the GGNS 11 of the PRNM L TR as discussed in the GGNS Technical Specification Bases (Section 3.3 .1 .1, Technical Specification Bases (Section 3.3.1.1, Reactor Reactor Protection Protection System System Instrumentation, Instrumentation, Reference Reference 99 inin GGNS GGNS TS TS Bases)
Bases).. Therefore, Therefore, the the Reference Reference I11I failure failure analysis analysis is is applicable applicable to to GGNS.
GGNS. The The overall overall redundancy redundancy and and diversity diversity ofof sensors sensors available available to to provide provide trip trip signals signals inin the the RPS RPS meets meets NRC-approved NRC-approved licensing licensing basisbasis requirements.
requirements.
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Section No. Utility Action Utility Required Action Required Response
Response
- 2. Confirm
- 2. Confirm' that that the configuration implemented the configuration implemented 2 . The
- 2. The proposed proposed PRNM PRNM configuration configuration is is by the by the plant plant isis within within the limits described the limits described in the in the included among included among the the configurations configurations described described inin LTR; and LTR; and the PRNM the PRNM LTR, LTR, as as itemized itemized under under Section Section 2.3.4 2.3 .4 above. The above. The proposed configuration is proposed configuration is being being designed by designed by GEH GEH andand is is within within the the limits limits described in described in the the LTR.
LTR.
- 3. Prepare
- 3. Prepare aa plant-specific IOCFR50 .59 plant-specific 10CFR50.59 3. The
- 3. The requirements requirements of of 10CFR50.59 IOCFR50 .59 applies applies toto evaluation of the modification evaluation of the modification per the applicable per the applicable the PRNMS the PRNMS modification modification in in accordance accordance with with plant procedures.
plant procedures. applicable plant applicable plant procedures.
procedures .
These confirmations These confirmations and and conclusions conclusions should should be be documented in documented in the the plant-specific licensing plant-specific licensing submittals submittals for for the PRNM modification.
the PRNM modification .
[Reference
[Reference 11 I I of of the the LTR LTR is NEDC-3085 IP-A, is NEDC-30851P-A, "Technical "Technical Specification Improvement Analysis Specification Improvement Analysis for BWR for BWR Reactor Reactor Protection Protection System",
System", Licensing Licensing Topical Report, Topical Report, GE GE Nuclear Energy, Class Nuclear Energy, Class III III (proprietary), dated March 1988.
(proprietary), dated March 1988.
7.6 7.6 Impact on Impact UFSAR on UFSAR Applicable sections Applicable sections ofof the FSAR are the FSAR are reviewed reviewed The plant-specific The plant-specific actionaction required required for for FSAR FSAR and appropriate revisions of those sections are and appropriate revisions of those sections are updates will updates will vary vary between between plants.
plants. In In all all cases, cases, prepared and prepared and approved approved as as part of the part of the normal normal however, existing however, existing FSAR documents should FSAR documents should be be design design process process.. Following Following implementation implementation of of reviewed to reviewed identify areas to identify areas that that have have descriptions descriptions the design modification, the design modification, and closure of and closure of the the specific to specific the current to the current PAMPRNM using the general using the general design design package, package, thethe FSAR FSAR revisions revisions are are guidance of guidance of Sections Sections 77.2 .2 through through 7.5 7.5 ofof the the iincluded ncluded in in the the updated updated FSAR FSAR as part of as part of the the PRNM PRNM LTR LTR to identify potential to identify areas impacted.
potential areas impacted. periodic periodic
' 10 10 CFR CFR 50.71(e}
50.71(e) FSAR FSAR update update The utility The utility should should include include in in the the plant-specific plant-specific submittal.
submittal.
licensing submittal a statement of the licensing submittal a statement of the plans plans for for updating updating the the plant FSAR for the PRNM project.
plant FSAR for the PRNM project.
8.3 .1 .4 8.3.1.4 APB-Related APRM-Related RPS RPS TripTrip Functions Functions -- Functions Functions Covered Covered by by Tech Tech Specs Specs 11.. Delete Delete the the APBAPRM Downscale Downscale function, function, if if I.
- 1. GGNS GGNS doesdoes not not have have an an "APB "APRM currently currently used, used, fromfrom thethe RPS RPS Instrumentation Instrumentation Downscale" Downscale" RPS RPS Trip Trip Function Function Tech Spec.
Tech Spec.
"function" "function" table, table, thethe related related surveillance surveillance requirements, requirements, and, and, ifif applicable, applicable, the the related related setpoint, setpoint, and and related related descriptions descriptions in in the the bases bases sections.
sections.
2.
- 2. Delete Delete thethe APRM APRM Flow-biased Flow-biased NeutronNeutron 22.. APB APRM Flow Flow Biased Biased Simulated Simulated Thermal Thermal Flux Upscale function, if currently used, from Flux Upscale function, if currently used, from Power Power -- High High and and the the APB APRM FixedFixed Neutron Neutron the the RPS RPS Instrumentation Instrumentation "function" "function" table, table, thethe Flux Flux -- High High functions functions have have been been retained.
retained.
related related surveillance surveillance requirements, requirements, and, and, ifif applicable, applicable, the the related related setpoint, setpoint, and and related related descriptions descriptions in in the the bases bases sections.
sections. Replace Replace thesethese with with the the corresponding corresponding entries entries forfor the the APB APRM Simulated Simulated Thermal Thermal Power Power -- HighHigh andand thethe APB APRM Neutron Neutron Flux Flux -- High High functions.
functions. Perform Perform analysis analysis necessary necessary to to establish establish setpoints setpoints for for 77 of of 19 19
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Section No. - 1 Utili Action Utility Action Required Required Response
Response
added trips.
added trips.
3.
- 3. Add the Add the APB Neutron Flux APRM Neutron Flux -- High High 3 . The
- 3. The current current APRM APB Neutron Flux -- High, Neutron Flux High (Setdown) function, (Setdown) function, if if not currently used, not currently used, toto Setdown function Setdown function has has been been retained.
retained.
the RPS the Instrumentation "function" RPS Instrumentation "function" table, table, add the add the related related surveillance surveillance requirements, requirements, and, if and, applicable, the if applicable, related setpoints, the related setpoints, and and related descriptions related descriptions in in the the bases, sections.
bases. sections.
Perform analysis Perform analysis necessary necessary to establish to establish setpoints for setpoints for added trips.
added trips.
8.3 .2 .4 8.3.2.4 APB-Related RPS APRM-Related RPS TripTrip Functions Functions -- MinimumMinim Number of Number of Operable Operable APB Channels APRM Channels I.
- 1. For the 4-APRM For the 4-APRM channelchannel replacement replacement I . The
- 1. The PRNM modification and PRNM modification and the proposed the proposed configuration, revise configuration, revise thethe RPS Instrumentation RPS Instrumentation Tech Tech Spec and Bases Spec and Bases change change implement implement the the "function" "function" tabletable to to show show 33 APB APRM channels,channels, changes changes asas described described in in the PAM LTR the PRNM LTR for for aa shared by shared both trip by both systems for trip systems for each each APRMAPRM BWR6 plant. GGNS BWR6 plant. GGNS Tech Tech Specs Specs dodo not not include include function shown function shown (after (after any additions or any additions or deletions deletions notes related to notes related to APRMs APRMs that that call call for for removal removal of of per per PRNM PRNM LTR LTR Paragraph Paragraph 8.3 .1 .4) . Add 8.3.1.4). Add aa "2- shorting links or shorting links or references references to to special conditions special conditions out-of-4 Voter" out-of-4 function with Voter" function with twotwo channels channels related related to loss of to loss of all all LPs LPRMs from from the the "other" "other" under under the the "minimum "minimum operable channels" . For operable channels". For RM. Therefore, APRM. Therefore, no related note no related note changes changes are are plants plants with Tech Specs with Tech Specs that include aa footnote that include footnote required.
required.
calling for calling for removing removing shorting shorting links, links, remove remove the the references to references to the footnote related the footnote related to to APRM APRM A A "2-out-of-4 "2-out-of-4 Voter" function with Voter" function with two two channels channels (retain references (retain references for SRM and for SRM and Imo)
IRM) and and delete delete under under the "minimum operable channels" have the "minimum operable channels" have any references any references to APB channels to APRM channels in in the the been been added added asas Function 2.e.
Function 2.e.
footnote. For footnote. For smaller smaller core plants, delete core plants, delete the the notes notes forfor and and references references to to special conditions special conditions related related to to loss loss ofof all all LPRMs LPRMs from from the the "other" "other" APRM.
APRM.
2.
- 2. Review Review action action statements statements to to see see ifif changes changes 2.
- 2. Action statement Action statement changes changes in in the the proposed proposed are required. If the improvements documented are required. If the improvements documented Tech Spec change are consistent with the Tech Spec change are consistent with the PRNM PRNM in in Reference Reference I11I have have notnot been been implemented, implemented, LTR described changes for plants with LTR described changes for plants with then then changes changes willwill likely likely bebe required required to to Improved Tech Specs.
Improved Tech Specs. GGNS GGNS has has previously previously implement implement the the 12-hour 12-hour and and 6-hour 6-hour operation operation switched switched toto the the ISTS ISTS format format..
times times discussed discussed aboveabove for for fewer fewer than than the the minimum minimum required required channels.
channels. If If Improved Improved Tech Tech Specs Specs are are applied applied to to the the plant, plant, action action statements statements remain remain unchanged unchanged..
33.. Revise Revise the the Bases Bases section section as as needed needed to to 3.
- 3. TheThe proposed proposed TechTech Spec Spec Bases Bases changes changes replace replace the the descriptions descriptions of of the the current current 6- 6- or 8-or 8- include include revisions revisions toto the the descriptions descriptions of of the the APRMPRM channel channel systems systems and and bypass bypass capability capability architecture, architecture, consistent consistent with with the the PRNM PRNM LTR-LTR.
with with aa corresponding corresponding description description of of the the 4 APRM system, 2-out-of-4 Voter channels (2 APRM system, 2-out-of-4 Voter channels (2 per per RPS system), and allowed one RPS system), and allowed one APB APRM bypass bypass total.
total.
8.3 .3 .4 8.3.3.4 APRM-Related APRM-Related RPS RPS TripTrip Functions Functions--
Applicable Applicable Modes Modes of of Operation Operation 880f19 of 19
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Response
- 1) APRM
- 1) APB Neutron Neutron FluxFlux -- High Hit h (Setdown)
(Setdown) 1) Tech
- 1) Tech Spec Spec andand Bases Bases changes changes are are Change Tech Change Tech SpecSpec "applicable "applicable modes" entry, if modes" entry, if consistent with consistent with the the PRNM PRNM LTR. LTR.
required, required, to to be be Mode Mode 22 (startup)
(startup).. Delete Delete references references to to actions actions and and surveillance surveillance requirements requirements associated associated with other modes.
with other modes.
Delete any references Delete any references to to notes associated with notes associated with "non-coincidence" mode "non-coincidence" mode and and correct correct notes notes as as required.
required. Revise Revise Bases descriptions as Bases descriptions as required.
required.
- 2) APRM Simulated
- 2) APRM Simulated Thermal Thermal PowerPower -- High High 2)
- 2) The The APRM APRM Flow Flow Biased Simulated Biased Simulated Retain Retain asas is is unless unless this this function function is is being added being added Thermal Thermal PowerPower -- High High function function hashas been been to to replace replace the APRM Flow-biased the APRM Flow-biased NeutronNeutron Flux Flux retained retained andand is consistent with is consistent with the the PRNM PRNM LTR. LTR.
Trip.
Trip. InIn that that case, case, add add requirement requirement for operation for operation in in Mode Mode 11 (RUN)
(RUN) and and addadd oror modify modify Bases Bases descriptions descriptions as as required.
required.
- 3) APB Neutron
- 3) APRM Neutron FluxFlux -- High High 3)
- 3) The The APRM APRM FixedFixed Neutron Neutron FluxFlux -- High High Retain as Retain as is is unless unless this this function function is is being being added added function function hashas been retained and been retained and isis consistent consistent with with to to replace replace the APB Flow-biased the APRM Flow-biased Neutron Neutron Flux Flux the PRNM LTR.
the PRNM LTR .
Trip.
Trip. In that case, In that case, add requirement for operation add requirement for operation in in Mode Mode 11 (RUN)
(RUN) and and add add oror modify modify BasesBases descriptions descriptions as required.
as required.
- 4) APB
- 4) APRM Inon Inop Trip Trip 4)
- 4) The The current current GGNS GGNS TS TS require require this this function function Delete Delete anyany requirements requirements for for operation operation in in modes modes only only in in Modes Modes 1I andand 2.2.
other other than than Mode Mode I1 andand Mode Mode 22 (RUN (RUN and and STARTUP)
STARTUP).. Revise Revise thethe Bases Bases descriptions descriptions as as needed .
needed.
8.3 .4 .1 .4 8.3.4.1.4 APB-Related RPS APRM-Related RPS TripTrip Functions Functions -- Channel Channel Checks/ Instrument Checks/ Instrument Checks Checks a) a) ForFor plants plants without without Channel Channel Check Check a) a) The GGNS Technical The GGNS Technical Specifications Specifications requirements, add once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or requirements, add once per 12 hour or once once per per currently currently include include aa once-per-shift once-per-shift Channel Channel day Channel day Channel CheckCheck or or Instrument Instrument Check Check Check requirement for the APB Functions Check requirement for the APRM Functions requirement requirement for for the the three three APRM APRM flux flux based based (except (except forfor Inop)
Inop).. The The APRM APRM Function Function Channel Channel functions. No functions. No Channel Channel CheckCheck requirements requirements are are Check Check requirement requirement has has been been changed changed fromfrom once once added added forfor APB APRM Inop function. Plants Inop function. Plants with with per 12 per hours to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to once once per per day day (24 (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) hours).. The The once once per per 1212 hour0.014 days <br />0.337 hours <br />0.002 weeks <br />4.61166e-4 months <br /> hour oror once once perper shift shift requirements requirements new new Channel Channel Check Check SR SR 3.3.1 .1 .19 with 3.3.1.1.19 with aa may may change change them them toto once once perper day day.. frequency frequency of of 24 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> hours has has been been added added toto TS TS 3.3 .1 .1 and 3.3.1.1 and applies applies toto Functions Functions 2.a, 2.a, 2.b, 2.b, 22.d,
.d, 2.e, 2.e, and and 2.f.
2.f.
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b) For plants with 44 full b) For plants with full recirculation recirculation flow flow b) GGNS b) GGNS currently currently uses uses 88 recirculation recirculation flow flow channels and channels and with with Tech Tech Specs Specs thatthat call call for for daily daily transmitters . Associated transmitters. Associated surveillances surveillances have have been been or other channel check requirements for flow or other channel check requirements for flow included in included those for in those the APRM for the APRM Flow Biased Flow Biased comparisons under comparisons under APBAPRM Flow Flow Biased Biased Simulated Thermal Simulated Thermal Power Power -- High High andand thethe OPRM OPT Simulated Thermal Power Simulated Thermal Power Trip,Trip, delete those delete those Upscale functions (the latter because of the Upscale functions (the latter because of the requirements . Move requirements. Move any any note note reference reference related related OPT trip OPRM trip enable enable function) function).. The The proposed proposed to verification to verification of of flow flow signals signals to to Channel Channel Technical Specification Technical Specification and and Bases changes Bases changes for for Functional Test Functional entry.
Test entry. the recirculation the recirculation flow related SRs flow related SRs areare consistent consistent with the with the PRNM PRNM LTR LTR but but with some expansion with some expansion to to clarify that the clarify that recirculation flow the recirculation flow functions functions also also support support the the OPRM OPT Upscale Upscale function function triptrip enable.
enable .
8.3.4.2 .4 8.3.4.2.4 APRM-Related RPS APRM-Related RPS Trip Functions -- Channel Trip Functions Channel Functional Tests Functional Tests a) Delete a) Delete existing channel functional existing channel functional test test a) a) The The proposed proposed Technical Specification and Technical Specification and requirements and requirements and replace replace withwith aa requirement requirement for for Bases changes Bases changes relatedrelated to to Channel Channel Functional Functional aa Channel Functional Test Channel Functional Test frequency frequency of of each each Tests are consistent Tests are consistent with with the PRNM LTR.
the PRNM LTR.
184 days (6 184 days (6 months) [delete any months) [delete any specific specific requirement related to requirement related to startup startup or or shutdown shutdown except for the except for APRM Neutron the APRM Neutron Flux Flux -- High High (Setdown)
(Setdown) function function as as noted noted in in Paragraph Paragraph 8.3.4.2.2(l) 8.3.4.2.2(1) of of the the PAM PRNM LTR. LTR. Add Add aa notation notation that that both the APB both the APRM channels channels and and the the 2-out-of-4 2-out-of-4 Voter Voter channels channels are are toto be be included included in in the the Channel Channel Functional Functional Test.
Test.
b) b) Add Add aa notation notation for for the the APRM APRM Simulated Simulated b) b) The The proposed proposed Technical Specification and Technical Specification and Thermal Thermal Power Power -- HighHigh function function thatthat the the test shall test shall ases changes Bases changes to to Channel Channel Functional Functional Test Test forfor include include the the recirculation recirculation flow flow input processing, input processing, the the APB APRM functions functions include include aa notation, notation, excluding excluding the flow transmitters.
the flow transmitters . applicable applicable to the Flow to the Flow Biased Biased Simulated Simulated Thermal Thermal PowerPower - - High High (Function (Function 2.d) 2.d) and and thethe CAUTION : Plants CAUTION: Plants that that have have notnot implemented implemented OPRM OPRM Upscale Upscale (Function (Function 2.f), 2J), consistent consistent with with the the APB APRM surveillance surveillance improvements improvements of of the PRNM LTR the PRNM LTR requirements, requirements, that that the the SR SR eference 11 Reference I I of of the the PRNM PRNM LTR, LTR, or or those those that that includes the recirculation flow input processing, includes the recirculation flow input processing, have have continued continued to use aa weekly to use weekly surveillance surveillance of. of excluding excluding the the flow flow transmitters transmitters.. However, However, the the scram contactors, scram contactors, may may need need to to implement implement or or PRNM PRNM LTR LTR includes includes this this notation notation only only in in the the modify modify surveillance surveillance actions actions to to continue continue to to Bases.
Bases. For For the the GGNS GGNS Technical Technical Specification, Specification, provide provide aa once once perper week week functional functional testtest ofof scram scram the the Channel Channel Functional Functional Test Test has has been been added added as as contactors contactors.. (Prior (Prior to to changes changes defined defined in in SR SR 3.3 .1 .1 .20, and 3.3.1.1.20, and hashas been been expanded expanded to to also also Reference Reference 11, 11, the the weekly weekly APRM APRM functional functional test test . apply apply toto the the OPTOPRM UpscaleUpscale function function (to (to cover cover also also provides provides aa weekly weekly test test of of all all automatic automatic OPT OPRM Upscale Upscale trip trip enable) enable)..
scram scram contactors contactors.) .) The The functional functional test test procedure procedure will will be be established established to to test test all all of of the the hardware hardware required required to to produce produce the the trip trip functions, functions, but but notnot to to directly directly re-test re-test software-only software-only (firmware-only}
(firmware-only) logic. logic. TheThe APRM APRM automatic automatic self-test self-test function function monitors monitors the the integrity integrity of of thethe EPROMs EPROMs storing storing allall of of the the firmware firmware so so that that ifif aa hardware hardware fault fault results results in in aa "change" "change" to to the the firmware firmware (software),
(software), that that fault fault will will be be detected detected by by the the self test logic.
self-test logic. TheThe continued continued operation operation of of the the self-test self-test procedures procedures is is 110 0 of of 19 19
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Response
monitored monitored by by the the built-in built-in "watch-dog "watch-dog timer" timer" function, function, so so if if for for some some unforeseen unforeseen reasonreason the the self-test function (lowest self-test function (lowest priority priority in in the the instrument instrument logic) stops running, logic) stops running, that that failure failure also also will be detected automatically . To provide will be detected automatically. To provide further assurance further assurance that that the the self test function self-test function continues to operate, a step will be included continues to operate, a step will be included in in the the APRM APRM ChannelChannel Check Check surveillance surveillance to to confirm confirm that that self test is self-test is still still running running..
.3 .4 .3 .4 8.3.4.3.4 APB-Related APRM-Related RPS RPS Trip,,
Trip Functions Functions -- Channel Channel Calibrations Calibrations a) Replace a) Replace current current calibration calibration interval interval with with a) a) The The proposed Technical Specification proposed Technical Specification and and either either 18 18 or or 24 24 months months except except forfor APB APRM Inop.Inop. ases changes Bases changes related related to to Channel Channel Calibration Calibration Retain Retain Inop Inop requirement requirement as as is is (i .e., no (i.e., no has has been been changed changed to to 24-month interval, with 24-month interval, with nono requirement requirement for for calibration),
calibration). calibration calibration required required for for the Inop Function, the Inop Function, consistent consistent with with the the PRNM PRNM LTR. LTR.
b) Delete b) Delete any any requirements requirements for for flow flow calibration calibration b) b) Consistent Consistent with with thethe PAM PRNM LTR LTR and calibration and calibration ofof the the 66 second second time time constant constant requirements, the proposed Technical requirements, the proposed Technical separate separate from from overall overall calibration calibration of of the the APB APRM Specification Specification and and Bases changes add Bases changes add aa notation notation Simulated Thermal Simulated Power -- High Thermal Power High function function.. applicable applicable to to the Channel Calibration the Channel Calibration for for the the APB APRM Flow Flow Biased Simulated Thermal Biased Simulated Thermal Power Power --
High High function function to to exclude exclude requirements requirements to to calibrate the calibrate the recirculation recirculation flow flow transmitters transmitters..
However, However, the the PRNM PRNM LTR LTR includes includes this this notation notation only only in in the the Bases.
Bases. For For thethe GGNS Technical GGNS Technical Specification, the Specification, the notation notation has has been been included included in in Channel Calibration Channel Calibration SR SR 3.3 .1 .1 .10 . In 3.3.1.1.10. In addition, addition, current SRs current SRs 3.3.1 .1 .16, which 3.3.1.1.16, which verifies verifies thethe simulated thermal simulated thermal power power time time constant, constant, and and 3 .3 .1 .1 .18, which adjusts the flow control 3.3.1.1.18, which adjusts the flow control reference reference card,card, have been deleted have been deleted..
c) Replace c) Replace every every 33 day day frequency frequency for for c) c) The The current current GGNS GGNS Technical Technical calibration of APRM power against thermal calibration of APRM power against thermal Specifications include Specifications include aa "weekly" "weekly" frequency frequency for for power power with day frequency with aa 77 day frequency if applicable .
if applicable. the verification of the verification of APB APRM power power versus versus calculated calculated plant plant thermal thermal powerpower so so no no change change in in that that frequency frequency is is required required to to be be consistent consistent withwith the the PRNM PRNM LTR. LTR.
d) Revise Bases d) Revise text as Bases text as required required.. d) The proposed Technical d) The proposed Technical Specification Specification Bases changes related to Channel Calibrations Bases changes related to Channel Calibrations are consistent with the PRNM LTR.
are consistent with the PRNM LTR.
8.3.4 .4.4 8.3.4.4.4 APB-Related APRM-Related RPS RPS Trip Trip Functions Functions -- Response Response The The proposed proposed Technical Specification and Technical Specification Bases and Bases Time Testing Testing changes related to Response Time Testing (new changes related to Response Time Testing (new SR 3.3 .1 .1 .22 and Table 3.3 SR 3.3.1.1.22 and Table .1 .1-1) 3.3.1.1-1) are consistent are consistent elete response Delete response time time testing testing requirement requirement from from with with thethe justification justification in in the the PRNM PRNM LTR LTR Tech Tech Specs_
Specs oror plant plant procedures, procedures,-as as applicable, applicable, Supplement Supplement 1. 1. _
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Section No. Utility Action Required Vtility Action Required Response
Response
for the for APRM functions.
the APRM functions. Replace Replace it it with with aa Consistent with Consistent with thethe PRNM PRNM LTRs, LTRs, the the only only response time response time testing testing requirement requirement for for the the 2-out-2-out- APRM Function APRM Function to to which which the the SRSR applies applies is is of-4 Voter "pseudo" of-4 Voter "pseudo" function, function, to to include include the the Function 2.e Function 2.e (voter)
(voter).. However, However, while while thethe output solid-state output solid-state relays relays of of the the voter voter channel channel PRNM LTRs PRNM LTRs justified justified reduced reduced response response time time through the through the final final RPS RPS trip channel contactors.
trip channel contactors . testing frequency testing frequency for for Function Function 2.e, 2.e, nono TSTS markups were markups were included included to to implement implement an "n" an "n" Frequency of Frequency of response response time time testing testing shall shall bebe greater than greater than 44 (the(the total total number number of of voter voter determined using determined four 2-out-of-4 using four 2-out-of-4 VoterVoter channels) . Therefore, channels). Therefore, aa note note has has been been added added to to channels, but channels, but tests tests may alternate use may alternate use of 2-out-of-of 2-out-of- the GGNS the GGNS SR Table 3.3 SR Table .1 .1-1 to 3.3.1.1-1 define that to define that 44 Voter Voter outputs outputs provided provided each each APRM/RPS APRM/RPS "n=8" for "n=8" for Function Function 2.e. 2.e.
interfacing relay interfacing relay isis tested tested at least once at least once per eight per eight refueling cycles refueling cycles (based (based on on aa maximum maximum 24 month 24 month The PRNM The PRNM LTR LTR Supplement Supplement 11 justified justified cycle), and cycle), and each RPS scram each RPS contactor is scram contactor is tested tested atat response time response time testing testing at at aa rate rate that tested one that tested one least once least once per four refueling cycles . Each 2-out-per four refueling cycles. Each 2-out- RPS Interface relay every plant operating cycle, RPS Interface relay every plant operating cycle, of-4 Voter of-4 Voter output output shall shall be be tested tested at at no no less than less than with tests with tests using using the the APRM APRM output output for for one one cycle cycle half the half the frequency frequency of the tests of the tests ofof the APRM/RPS the APRMlRPS and the and the OPRM OPRM output output for for the the next next cycle.
cycle. This This interface relays interface relays.. Tests Tests shall alternate such shall alternate such that that yields aa testing yields testing rate once per rate once per 88 operating operating cycles cycles one logic one logic train train for each RPS for each RPS triptrip system system is is tested tested for each for each RPS RPS interface interface relay relay and and once once perper eve every every two every two cycles.
cycles. 16 operating 16 operating cycles cycles forfor the the APRMAPRM or or OPRM OPRM output .
output.
The PRNM modification The modification includes includes redundant redundant APRM trip APRM trip and and redundant redundant OPRM OPRM trip trip outputs outputs from each from each 2-Out-Of-4 2-0ut-Of-4 Voter Voter channel channel.. One One of of the OPRM outputs and one of the APRM the OPRM outputs and one of the APRM outputs are outputs are connected connected in in series series to to the coil of the coil of one one RPS interface RPS interface relay.relay. The The second second OPRM OPRM outputoutput and the and the second second APRM APRM output output from from the the 2-Out-2-0ut-Of-4 Voter Of-4 Voter channel channel are are connected connected in series with in series with the the coil coil toto aa second second RPS RPS interface interface relay.relay. There There are 88 total are total RPSRPS interface interface relays.
relays.
8.3.5 8.3.5.4.4 APRM-Related APRM-Related RPS RPS TripTrip Functions Functions -- LogicLogic System Functional System Functional Testiniz Testing (LSFT)
(LSFT) The GGNS Technical The GGNS Specifications have Technical Specifications have been been vise Tech Revise Tech Specs Specs to to change change the the interval interval forfor changed changed to to delete delete thethe LSFT LSFT requirement requirement from from LSFT LSFT fromfrom 18 18 months months to to 24 24 months months unless unless the the the the existing existing APRM APRM Functions Functions 2.a, 2.a, 2.b, 2.b, 2.c, 2.c, and and utility utility elects elects to to retain retain thethe 18-month 18-month interval interval for for 2.d. New SR 3.3 .1 .1 .21 with a 24-month 2.d. New SR 3.3.1.1.21 with a 24-month plant plant scheduling scheduling purposes.
purposes. Delete Delete any any LSFT LSFT interval, interval, has has been been added added to to TSTS 3.3 .1 .1 and 3.3.1.1 and requirements requirements associated associated with with thethe APRM APRM applied applied to to the the new 2-Out-of-4 Voter new 2-0ut-of-4 Voter function, function, channels channels and and movemove it to the it to the 2-out-of-4 2-out-of-4 Voter Voter APRM APRM Function Function 22.e. .e. ..
channel.
channel. Include Include testing testing of ofthe the 2-out-of-4 2-out-of-4 voting voting logic logic and and anyany existing existing LSFTsLSFTs covering covering RPS RPS relays relays..
8.3 .6 .1 8.3.6.1 APRM-Related APRM-Related RPS RPS TripTrip Functions Functions -- Setpoints Setpoints Add Add to to or or delete delete from from the the appropriate appropriate document document ARTS ARTS is is not not applicable applicable at at GGNS.
GGNS. PRNM PRNM any any changed changed RPS RPS setpoint setpoint information information.. If If setpoints setpoints and and Allowable Allowable Values Values are are re-calculated re-calculated ARTS ARTS is is being being implemented implemented concurrently concurrently with with or or confirmed confirmed using using approved approved setpointsetpoint the the PRNM PRNM modification, modification, either either include include the the methodology methodology.. The The Allowable Allowable Values Values for for the the related related Tech Tech SpecSpec submittal submittal information information with with APRM APRM RPS RPS Functions Functions are are included included in in the the the the PRNM PRNM information information in in the the plant-specific plant-specific Technical Technical Specifications Specifications or or the the COLR, COLR, submittal, submittal, or or reference reference the the ARTS ARTS submittal submittal in in comparable comparable to to what what is is currently currently in in the the GGNS GGNS the the PRNM PRNM submittal.
submittal. In In the the plant-specific plant-specific Technical Technical Specifications Specifications and and consistent consistent with with the the licensing licensin~ submittal, submittal, identify identify whatwhat changes, changes, if if M LTR.
PRNMLTR.
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Section No. Utility Utility Action Action Required Required Response
Response
any, are being implemented and any, are being implemented and identify identify the the basis basis oror method method usedused forfor the the calculation calculation of of setpoints setpoints andand where where the setpoint information the setpoint information or or changes changes willwill bebe recorded recorded..
8.4.1 .4 8.4.1.4 OPT-Related OPRM-Related RPS RPS Trip Trip Functions Functions -- Functions Functions An An OPRM OPRM Upscale Function has Upscale Function been added has been added to to Covered Covered by by Tech Tech Specs Specs the the GGNS Technical Specification GGNS Technical Specification as as an an "APB "APRM Function" Function" (Function (Function 2J) consistent with 2.f) consistent with Add Add the OPRM Upscale the OPRM Upscale function function as as anan "APRM "APRM PRNM PRNM LTR Supplement 1, LTR Supplement 1, Appendix Appendix H.
function" function" in in the the RPS Instrumentation "function" RPS Instrumentation "function" Additions Additions to to the the Technical Technical Specification Specification Bases s table.
table. Also Also addadd the the related surveillance related surveillance for for Function 2.f have also Function 2.fhave also been been incorporated incorporated requirements requirements and, and, ifif applicable, applicable, the the related related consistent the PAM with the consistent with PRNM LTR.LTR.
setpoint, and the related descriptions in setpoint, and the related descriptions in the the bases bases The The PRNM PRNM LTR LTR Supplement Supplement I1 included included somesome sections. Perform analysis necessary to sections. Perform analysis necessary to additional wording for additional wording for Function Function 2.e 2.e (voter)
(voter) toto establish establish setpoints setpoints for for the the OPT OPRM Upscale Upscale trip. trip.
address address independent independent votingvoting of the OPT of the OPRM and and Add Add discussions discussions related related to the OPRM to the OPT function function APB APRM signals signals..
in in the the Bases Bases for the APB for the APRM Inop Inop andand 2-out-of-4 2-out-of-4 Voter functions .
Voter functions.
NOTE:
NOTE: The The markups markups in in Appendix Appendix H H ofof Supplement Supplement 1I to the PRNM to the PRNM LTR LTR showshow the the OPT OPRM Upscale Upscale as as an an APB APRM sub-function.
sub-function.
However, However, individual individual plants plants may determine that may determine that for for their their particular particular situation, situation, addition addition of of the the OPRM OPRM to to the the RPS Instrumentation table RPS Instrumentation table separate from the APB, or as a separate Tech separate from the APRM, or as a separate Tech Spec, better meets their needs. In those cases, Spec, better meets their needs. In those cases, the the basis basis elements elements of of the the Tech Tech SpecSpec as as shown shown in in this this Supplement Supplement would would remain, remain, but the specific but the specific implementation implementation would would be be different.
different.
8.4.2 .4 8.4.2.4 OPRM-Related OPRM-Related RPS RPS Trip Trip Functions Functions -- MinimumMinimum A minimum A minimum operable operable channels requirement of channels requirement of Number Number of of Operable Operable OPT OPRM Channels Channels three, three, shared shared byby both both trip systems has trip systems has been been included included in in the the Technical Specification for Technical Specification for the the For the OPT For the OPRM functions added (Section functions added (Section 8.4.1),8 .4 .1),
OPRM Upscale Function (Function 2J) . This OPRM Upscale Function (Function 2.f). This include include in in the the OPT OPRM Tech Tech Spec Spec aa "minimum "minimum addition, as addition, as well well as as addition addition of Required Actio, of Required Action operable operable channels" channels" requirement requirement for for three three OPT OPRM statements and statements and Bases descriptions, is consistent Bases descriptions, is consistent channels, channels, shared shared by by both both trip system trip systems.
ith the with PRNM LTR the PRNM LTR and LTR Supplement and LTR Supplement 11..
Add Add the same action the same action statements statements as for th as for the ever, to However, to make make thethe Required Required Action Action APB Neutron Flux - High function for OPRM APRM Neutron Flux - High function for OPT statements more statements consistent with more consistent with the the intent of the intent of the Upscale function . In Upscale function. In addition, addition, addadd aa newnew action action LTR, a note has been added to Required Action LTR, a note has been added to Required Action statement statement for for OPT OPRM Upscale Upscale function function J .2 stating J.2 stating that that LCO LCO 33.0.4(c)
.0.4(c) is is applicable.
applicable. LCO LCO unavailable unavailable per per Paragraph 8.4.2.2 of Paragraph 8.4.2.2 of the the PRNM PRNM 3 .0.4 was revised in GGNS Technical 3.0.4 was revised in GGNS Technical LTR.
LTR. Specifications Amendment Specifications Amendment 175 175 to to reflect reflect NRC-NRC-approved changes approved changes regarding regarding Mode Mode changechange Revise the Revise the Bases section as Bases section as needed needed to to addadd limitations via limitations via BWROG BWROG TSTF-359, TSTF-359, "Increased "Increased descriptions of descriptions of the the 4-OPT 4-0PRM system system with with 2-out-2-out- Flexibility Flexibility in in Mode Mode Restraints."
Restraints."
of-4 output of-4 output Voter channels (2 Voter channels (2 per RPS Trip per RPS Trip System),
System), and allowed one and allowed one OPRM OPRM bypassbypass total total..
Although applying LCO Although applying LCO 3.0.4(c) 3.0.4(c) is is not not included included in in the the NUMAC NUMAC PRNM PAM LTR Supplement 1, LTR Supplement 1, it it is is consistent with the consistent with the intent intent of of Required Required Action Action
.2. Inclusion J.2. Inclusion of Action J.2 of Action J.2 is is intended intended to allow to allow 13 of 19 13 of 19
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Response
orderly identification orderly identification and and Implementation Implementation of of aa resolution plan resolution plan for for an an unanticipated unanticipated design design problem with problem with the the OPRM OPT system system without without undue undue impact impact on on normal plant operation.
normal plant operation . The The LCO LCO 3 .0.4(c) application 3.0.4(c) application does does notnot eliminate eliminate the the requirement to requirement to restore restore thethe OPRM OPRM Upscale Upscale function to function to OPERABLE OPERABLE status status within within aa 120- 120-day period.
day period. Applying Applying LCO LCO 3.0.4(c) 3 .0.4(c) does, does, however, allow however, allow the the plant plant to to start up with start up with the the alternate detect and alternate detect and suppress suppress provision provision of of Action Action J.2 in J.2 effect during in effect during thethe 120-day 120-day period.
period.
8.4.3 .4 8.4.3.4 OPRM-Related RPS OPRM-Related RPS Trip Functions --
Trip Functions A GGNS-specific Modes A GGNS-specific Modes of Operation of Operation Applicable Modes Applicable Modes of of Operation Operation requirement of requirement of~ > 24%
24% RTP,RTP, consistent consistent with the with the PRNM PRNM LTR LTR Supplement Supplement 1I has has been been included included in in Add the Add the requirement requirement for for operation operation of of the OPRM the OPRM the the Technical Technical Specification Specification alongalong with with Upscale function Upscale function inin Mode Mode 11 (RUN)
(RUN) when when associated associated BasesBases descriptions.
descriptions.
Thermal Power Thermal Power is is ~
> 25%
25% RTP, RTP, and and add add Bases Bases descriptions descriptions as required .
as required.
8.4.4 .1 .4 8.4.4.1.4 OPT-Related RPS OPRM-Related RPS Trip Functions -- Channel Trip Functions Channel Check Check A new Channel A new Channel Check Check requirement requirement of of once once perper Add once Add once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per 12 hour or or once once per per day day Channel Channel day day (24 (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />),
hours), SR 3.3 .1 .1 .19, has SR 3.3.1.1.19, been added.
has been added. It It Check Check or or Instrument Instrument Check Check requirements requirements forfor the the is is applied applied to the OPRM to the OPT Upscale Upscale function, function, OPRM Upscale OPRM Upscale function.
function. consistent consistent with with the PRNM LTR.
the PRNM LTR.
8.4.4.2.4 8.4.4.2.4 OPT-Related RPS OPRM-Related RPS Trip Trip Functions Functions -- Channel Channel Functional Functional TestTest Add Channel Functional Add Channel Functional TestTest requirements with requirements with aa requirement requirement forfor aa test test frequency frequency ofof every AA new new Channel Channel Functional Functional Test Test requirement requirement 184 every 184 with wwith aa test test frequency frequency of of every every 184 days (Table 184 days (Table days (6 days (6 months),
months), including including the the 2-out-of-4 2-out-of-4 Voter Voter 33.3.1.1-1) has has been been added added to to TS TS 33.3.1.1
.3 . 1 . 1 as as SR SR function..
function.
3.3.1 .1 .20 for 3.3.1.1.20 for the OPT Upscale the OPRM Upscale and and 2-Out-Of 2-0ut-Of 44 Voter Voter Functions Functions consistent consistent withwith thethe PRNMPAM LTR, LTR, Supplement Supplement 1. 1. The The third third note note to to SRSR 3.3 .1 .1 .20 (not included in the PRNM LTR) 3.3.1.1.20 (not included in the PRNM LTR) clarifies clarifies that that the the SRSR also also applies applies toto the the flow flow input input function, function, except except the the flow flow transmitters transmitters..
Add Add aa "confirm "confirm auto-enable auto-enable region" region" surveillance surveillance New New "confirm auto-enable region" "confirm auto-enable region" surveillance surveillance on on aa once once per per outage outage basis basis up up to to 24 24 month month requirement, requirement, SR SR 3.3 .1 .1 .23, has 3.3.1.1.23, has been been addedadded to to intervals intervals..
TS TS 3.3 .1 .1 to 3.3.1.1 to require require confirmation confirmation that that thethe OPRM OPRM Upscale Upscale trip trip output output auto-enable auto-enable (not (not bypassed) bypassed) setpoints setpoints remain remain correct.
correct. The The SR SR Bases Bases wording wording is is consistent consistent withwith the the LTRLTR..
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0000-0102-0888-RO 0000-0102-0888-RO Grand Gulf Grand Gulf Specific Specific Responses Responses Required Required by by NUMAC NUMAC PRNM PRNNI Retrofit Retrofit Topical Topical Report Report Section No.
Section No. Utility Action Utility Action Required Required Response
Response
8 .4.4.3.4 8.4.4.3.4 OPRM-Related RPS OPRM-Related RPS Trip Trip Functions Functions -- Channel Channel Calibration Calibration Add calibration Add calibration interval interval requirement requirement of of every every 2424 Channel Calibration Channel Calibration SR SR 3.3.1.1.10
.3 has 3
.10
.1,1 has been been months for months for the OPT Upscale the OPRM Upscale function.
function. applied to applied to the the OPRM OPRM Upscale Upscale function function to to be be consistent with consistent with the PRNM LTR the PRNM LTR Supplement Supplement 1. 1.
Revise Bases Revise Bases text as required.
text as required . The frequency The frequency ofSR of SR 3.3.1.1.10
.3,1 has 3
.10
.1 has been been changed from changed from 184 184 daysdays toto 24 months, consistent 24 months, consistent with the with the LTR LTR..
8.4.4.4 .4 8.4.4.4.4 OPT-Related RPS OPRM-Related Trip Functions RPS Trip Functions -- Response
Response
Time Testing Time Testing Modify as Modify necessary the as necessary the response response time time testing testing See See response response to to 8.3.4.4.4.
8 .3 .4 .4.4. That That response response alsoalso procedure procedure for the 2-out-of-4 for the 2-out-of-4 VoterVoter function function to to addresses OPT .
addresses OPRM.
include the include the Voter OPT output Voter OPRM output solid-state solid-state relays relays as part of as part of the the response response time tests, time tests, alternating testing alternating testing of of the Voter OPT the Voter OPRM outputoutput with the with Voter APRM the Voter APRM output.
output.
8.4.5.4 8.4.5.4 OPT-Related RPS OPRM-Related Trip Functions RPS Trip Functions -- Logic Logic The The LSFT LSFT surveillance surveillance (new (new SR SR 33.3.1.1.21)
.3 .1 .1.21} for for System Functional System Testin-eg (LSFT)
Functional Testing (LSFTJ the OPT Upscale the OPRM Upscale FunctionFunction is is aa test test of the 2-of the 2-Out-Of-4 Out-Of-4 VoterVoter only, only, consistent consistent with the PRNM with the PRNM Add Add requirement requirement for for LSFT LSFT everyevery refueling refueling LTR LTR.. Consistent Consistent with with the PRNM LTR the PRNM LTR cycle, 18 cycle, 18 or or 24 24 months months at at the the utility's utility's option option Supplement Supplement 1, 1, revision revision of of the the related related plant plant based based onon which which best best fits fits plant plant scheduling.
scheduling. procedures procedures to to include include testing testing ofof the the OPT OPRM Upscale Upscale triptrip outputs outputs from from the the 2-Out-Of-4 2-0ut-Of-4 Voter Voter is required . The procedure changes are made as is required. The procedure changes are made as part of the normal modification process .
part of the normal modification process.
8.4.6.1 8.4.6.1 OPT-Related OPRM-Related RPS RPS Trip Trip Functions Functions -- Setpoints Setpoints There There areare four four "sets" "sets" of of OPT related setpoints OPRM related setpoints and and adjustable adjustable parameters parameters:: a) a) OPT OPRM trip auto-trip auto-Add Add setpoint information to setpoint information to the appropriate the appropriate enable enable (not (not bypassed) bypassed) setpointssetpoints for for STP STP and and document document and and identify identify in in the the plant-specific plant-specific drive drive flow; flow; b) b) period period based based detection detection algorithm algorithm submittal submittal the the basis basis oror method method usedused for for the the (PBDA)
(PBDA) confirmation confirmation count count andand amplitude amplitude calculation calculation and and where where thethe setpoint setpoint information information setpoints setpoints;; c) c) PBDA PBDA tuning tuning parameters; parameters; and and d)d) will will be be recorded recorded.. growth growth raterate algorithm algorithm (ORA) (GRA) and amplitude and amplitude based based algorithm algorithm (ABA) (ABA) setpoints setpoints..
The The first set, the first set, the setpoints setpoints forfor the the "auto-enable" "auto-enable" region region forfor OPRM, OPRM, as as discussed discussed in in the the Bases Bases for for Function Function 21, 2.f, will will be be treated treated asas nominal nominal setpoints setpoints with with nono additional additional margins margins added.
added. The The deadband for these setpoints is established so deadband for these setpoints is established so that it increases the enabled region once the that it increases the enabled region once the enabled enabled region region is is entered entered.. TheThe settings settings areare defined defined plant plant procedures procedures..
The The second second set, set, thethe PBDA PBDA trip trip setpoints, setpoints, willwill be be established established in in accordance accordance with with the the BWROG BWROG LTR LTR 32465-A 32465-A methodology, methodology, previously previously reviewed and approved by the NRC, reviewed and approved by the NRC, and and will will be be documented in the COLR.
documented in the COLR.
The The third third set, set, the the PBDAPBDA "tuning" "tuning" parameter parameter 15 15 of of 19 19
0000-0102-0888-RO 0000-0102-0888-RO Grand Grand Gulf Gulf Specific Specific Responses Responses Required Required by by NUMAC NUMAC PRNMPRNM Retrofit Topical Report Retrofit Topical Report Section No.
Section No. Utility Utility Action Action Required Required Response
Response
values, will be established in values, will be established in accordance accordance withwith and controlled by GGNS procedures, within the and controlled by GGNS procedures, within the limits established in the BWROG LTRs, or as limits established in the BWROG LTRs, or as documented in documented in this this submittal, submittal, and and documented documented in the GGNS Core Operating Limits Report.
in the GGNS Core Operating Limits Report.
The fourth The fourth set, set, the the GRA GRA and and ABA ABA setpoints, setpoints, consistent with consistent with the BWROG submittals, the BWROG submittals, will will bebe established as established as nominal nominal values values only, and only, and controlled by controlled by GGNS procedures .
GGNS procedures.
8.5 .1 .4 8.5.1.4 APRM-Related APRM-Related Control Control Rod Rod Block Block Functions Functions-- ARTS is ARTS is not not applicable applicable at at GGNS GGNS..
Functions Covered by Tech Specs Functions Covered by Tech Specs GGNS Technical GGNS Specifications currently Technical Specifications currently dodo not not If If ARTS ARTS will will be implemented concurrently be implemented concurrently with with contain any contain any APB APRM rod rod block functions.
block functions.
the the PRNM modification, include PRNM modification, include oror reference reference those changes in those changes in the the plant-specific plant-specific PRNM PRNM submittal.
submittal. Implement Implement the applicable portion the applicable portion of of the the above described changes above described changes via via modifications modifications to to the the Tech Tech Specs Specs and and related procedures and related procedures and documents documents.. In In the the plant-specific plant-specific submittal, submittal, identify functions currently identify functions currently in in the plant Tech the plant Tech Specs Specs and and which, which, if any, changes if any, changes are being are being implemented implemented.. For For any functions deleted any functions deleted fromfrom Tech Tech Specs, Specs, identify identify where where setpoint setpoint andand surveillance surveillance requirements requirements will will be be documented documented..
NOTE: A utility may choose not to delete NOTE: A utility may choose not to delete some some or all of the items identified in the PRNM LTR or all of the items identified in the PRNM LTR from from thethe plant plant Tech Tech Specs Specs..
8.5 .2.4 8.5.2.4 APRM-Related APRM-Related Control Control Rod Rod Block Block Functions Functions -- See 8.5.1.4 See 8.5 .1 .4 above.
above. No No additional additional confirmation confirmation Minimum Minimum Number Number of of Operable Operable Control Control Rod Rod of action of action required required relative relative to minimum operable to minimum operable Block Channels Block Channels channels as channels as shown shown in in the the Technical Technical Change Change the the minimum minimum number number of of APRM APRM Specifications beyond Specifications beyond that required by that required by 8.5.1.4 8.5 .1 .4 channels channels to to three, three, if APRM functions if APRM functions are are above.
above.
retained retained in in Tech Tech Specs Specs.. No No additional action is additional action is required relative to minimum operable channels required relative to minimum operable channels beyond beyond that required by that required by Paragraph Paragraph 8.5 .1 .4 of 8.5.1.4 of the the PRNM PRNMLTR. LTR.
8.5.3 8.5.3.4.4 APRM-Related APRM-Related Control Control Rod Rod Block Functions --
Block Functions See 8.5.1.4 See 8.5 .1 .4 above.
above. NoNo additional additional confirmation confirmation Ax*licable Applicable Modes Modes of of Operation Operation of of action action required required relative relative to applicable modes to applicable modes No No action required relative action required relative to modes during to modes during of of operation operation as as shown shown in the Technical in the Technical which which the the function function must must be available beyond be available beyond Specifications beyond Specifications beyond thatthat required required byby 8.5.1 8.5.1.4 .4 that that required required by by Paragraph 8.5 .1 .4 of Paragraph 8.5.1.4 of the the PRNM PRNM above.
above.
LTR unless APRM functions are retained in LTR unless APRM functions are retained in Tech Specs and include operability requirements Tech Specs and include operability requirements for for Mode Mode 5. 5. InIn that that case, case, delete delete such such requirements.
requirements.
8.5 .4.1 .4 8.5.4.1.4 APB-Related Control APRM-Related Control Rod Rod Block Block Functions Functions -- GGNS Technical Specifications GGNS Technical currently do Specifications currently not do not Required Required Surveillances Surveillances and and Calibration Calibration - contain contain any APB rod any APRM rod block block functions, functions, or or any any Channel Check Channel Check Channel Check Channel Check requirements requirements for for the the RBM RBM rod rod 16 of 16 of 19 19
0000-0102-0888-RO 0000-0102-0888-RO Grand Grand Gulf Specific Responses Gulf Specific Responses Required Required by by NUNUC NUMAC PRNM PAM Retrofit Retrofit Topical Topical Report Report Section Section No. No. Utility Utility Action Required Action Required Response
Response
Delete any requirements for instrument Delete any requirements for instrument or or block block functions functions.. Therefore, Therefore, no no change change to to GGNS GGNS channel checks related to PBM and, where channel checks related to RBM and, where Technical Specifications is Technical Specifications is required required to to applicable, applicable, recirculation recirculation flowflow rodrod block block implement implement the the PRNM PRNM LTRLTR requirements requirements.. The The functions functions (non-ARTS (non-ARTS plants),
plants), andand APRM APRM RBM is not applicable to GGNS.
RBM is not applicable to GGNS.
functions functions.. Identify Identify in in the the plant-specific plant-specific PRNM PRNM submittals submittals if any checks if any checks are are currently currently included included in Tech Specs, in Tech Specs, andand confirm confirm that that they they are are beingbeing deleted.
deleted.
8.5 .4.2 .4 8.5.4.2.4 APB-Related APRM-Related Control Control RodRod Block Block Functions Functions -- GGNS Technical GGNS Technical Specifications Specifications currently currently do do not not Required Required Surveillances Surveillances and and Calibration Calibration -- contain any contain any APB APRM rod block functions rod block functions..
Channel Channel Functional Functional Test Test Change Channel Change Channel Functional Functional Test Test requirements requirements to to identify identify aa frequency frequency of of every 184-days (6 every 184-days (6 months) months)..
In In the the plant-specific plant-specific licensing licensing submittal, submittal, identify identify current current Tech Tech Spec Spec test test frequencies frequencies that that will will be be changed changed to 184 days to 184 days (6(6 months) months)..
8.5 .4 .3 .4 8.5.4.3.4 APB-Related APRM-Related Control Control Rod Rod Block Block Functions Functions-- GGNS Technical GGNS Technical Specifications currently do Specifications currently do not not Required Surveillances Required Surveillances and and Calibration Calibration -- contain contain any any APRM APRM rodrod block block functions functions Channel Calibrations Channel Calibrations Change channel Change calibration requirements channel calibration requirements to to identify aa frequency identify frequency of of every every 2424 months months.. In In the the plant-specific licensing submittal, plant-specific licensing submittal, identify identify current current Tech Tech Spec Spec test test frequencies frequencies that that will will be be changed to changed to 24 24 months.
months.
8.5 .4.4 .4 8.5.4.4.4 APRM-Related APRM-Related Control Control Rod Block Functions Rod Block Functions -- GGNS GGNS Technical Technical Specifications Specifications currently currently do do not not Required Required Surveillances Surveillances and and Calibration Calibration -- contain contain any any APB APRM rodrod block block functions functions..
Response
Response Time Time Testing Testing None.
None.
8.5 .5 .4 8.5.5.4 APRM-Related APRM-Related Control Control Rod Rod Block Block Functions Functions -- GGNS GGNS Technical Technical Specifications Specifications currently currently do do not not Required Surveillances and Calibration -- Logic Required Surveillances and Calibration contain any APB rod block functions .
contain any APRM rod block functions.
System Functional System Functional Testing Testing (LSFTj (LSFT)
None.
None.
8.5 .6 .1 8.5.6.1 APB-Related APRM-Related Control Control Rod Rod Block Block Functions Functions-- ARTS ARTS isis not not applicable applicable to to GGNS.
GGNS.
Required Required Surveillances Surveillances and and Calibration Calibration --
Set-points Setpoints Add Add to to or or delete delete from from the appropriate document the appropriate document any any changed changed control control rodrod block block setpoint setpoint information information.. If If ARTS ARTS is is being being implemented implemented concurrently concurrently with with the PRNM modification, the PRNM modification, either include the either include the related related Tech Tech Spec Spec submittal submittal information information with with the the PAM PRNM information information in in the the plant-specific plant-specific submittal, submittal, or or reference reference the the ARTS ARTS submittal submittal in in the the PAM PRNM submittal submittal.. In In the the plant-plant-specific specific submittal, submittal, identify identify what what changes, changes, if if any, any, are are being being implemented implemented and and identi identify thethe basis basis or or 1177 ofof 1919
0000-0102-0888-RO 0000-0102-0888-RO Grand Gulf Grand Gulf Specific Specific Responses Responses Required Required by by NUMAC NUMAC PRNM PAM Retrofit Retrofit TopicalTopical Report Report Section No.
Section No. Utility Action Utility Action Required Required Respons
Response
method used' for calculation of method used for calculation of setpoints setpoints and and where the where the setpoint setpoint information information or or changes changes will will be recorded.
be recorded.
8.6 .2 8.6.2 Shutdown Margin Shutdown Margin Testing Testing -- Refaelinj!4 Refueling Technical Specification and Technical Specification and Technical Technical As As applicable, applicable, revise revise thethe Shutdown Shutdown MarginMargin Specification Bases Specification Bases changes changes to Specification to Specification Testing Testing -- Refueling Refueling (or equivalent Tech (or equivalent Tech Spec)
Spec) 3 .10.8, Shutdown 3.10.8, Shutdown Margin Margin (SDM)
(SDM) Test- Test -
LCO(s),
LCO(s), action action statements, surveillance statements, surveillance Refueling Refueling havehave beenbeen made made by adding APRM by adding APRM requirements requirements and and Bases Bases as as required required to be to be Function Function 2.e 2.e to to LCO 3.10.8 and LCO 3.10.8 and SR SR 3.10 3.10.8.1 . .
.8.1 ..
consistent consistent with the APRM with the APRM Tech Tech Spec Spec changes changes implemented for implemented for PRNM.
PRNM.
None' None Slir-04ftwil Specification 3.4.1, Recirculation Loops nm Changes are Changes included in are included in the the proposed proposed Tech Tech Spec Spec O -Perating Operating Bases for LCO 3.4 .1 . Deleted statements related Bases for LCO 3.4.1. Deleted statements related No No action identified in action identified in the the PRNM PRNM LTR. LTR. to Fraction to Fraction of Core Boiling of Core Boiling Boundary Boundary and and PBDS PBDS and Reference 4 (NEDO 32339-A).
and Reference 4 (NEDO 32339-A).
These changes, These although not changes, although directly addressed not directly addressed in the in PRNM LTR, the PRNM LTR, are are consistent consistent withwith the the remainder of remainder the PRNM of the PRNM modification modification and and implementation implementation of the Option of the option III III Stability Stability Solution.
Solution.
None None Core Core Operating Operating LimitsLimits Report Report Specification Specification 5.6.55 .6 .5 has has been been modified modified to to require require the setpoints the setpoints for for APB Function 22.f(OPRM APRM Function .f (OPRM Reporting Reporting requirements requirements SectionSection 5.6.5 does not 5.6.5 does not Upscale)
Upscale) to to be be included included in in the COLR.
the COLR.
currently currently address address the the OPT OPRM..
9.1.3 9.1.3 Utility Quality Utility Quality Assurance Assurance Program Program Quality Quality assurance assurance requirements requirements for work for work performed performed at at GGNS GGNS are are defined defined and described and described As As part part of of the the plant-specific plant-specific licensing licensing submittal, submittal, in GGNS Quality in GGNS Quality Assurance Assurance Program Program ManualManual..
the the utility utility should should document document the the established established program program that that is is applicable applicable to to the the project project For For the the PRNM PRNM modification, modification, GGNS GGNS has has modification. The submittal should also modification. The submittal should also contracted with GEH to include the following contracted with GEH to include the following document document for for the the project what scope project what scope isis being being PRNM PRNM scope:
scope: 1) 1) design, design, 2) 2) hardware/
hardware/ software, software, performed performed by by the the utility utility and and what what scope scope is is being being 3)
- 3) licensing licensing support, support, 4) 4) training, training, 5) 5) O&M O&M supplied supplied by by others.
others. ForFor scope scope supplied supplied by by manuals manuals and and design design documentation, documentation, 6) 6) EMIR EMI/RFI FI others, others, document document the the utility utility actions actions taken taken or or qualification qualification of of equipment, equipment, and and 7) 7) PRNMS PRNMS planned planned to to define define or or establish establish requirements requirements for for setpoint setpoint calculations.
calculations.
the the project, proj ect, toto assure assure those those requirements requirements are are compatible compatible with with the the plant-specific plant-specific configuration.
configuration. On-site On-site engineering engineering work work to to incorporate incorporate the the Actions Actions taken taken or or planned planned by by the the utility utility to to assure assure GEH GEH provided provided design design information information into into an an compatibility compatibility of of the the GEHGEH quality quality program program with with Engineering Engineering ChangeChange (EC) (EC) or or to to provide provide any any the the utility utility program program should should also also be be documented.
documented. supporting, supporting, interface interface design design changes changes will will be be performed performed per per requirements requirements of of applicable applicable GGNS GGNS Utility Utility planned planned level level of of participation participation in in the the procedures procedures.. Modification Modification work work to to implement implement overall V&V process for the project should be overall V&V process for the project should be the the design design change change will will bebe performed performed per per GGNS GGNS documented, along with utility plans for documented, along with utility plans for procedures or GGNS-approved contractor procedures or GGNS-approved contractor software software configuration configuration management management and and procedures procedures.. GGNSGGNS participates participates in in appropriate appropriate provision provision to to support support any any required required changes changes afterafter reviews of GEH's design and V&V program reviews of GEH's design and V&V program for for delivery delivery should should be be documented.
documented. the the PRNM PRNM modification.
modification.
1188 of of 19 19
0000-0102-0888-RO 0000-0102-0888-RO Grand Grand Gulf Specific Responses Gulf Specific Responses Required by NUMAC Required by NUMAC PRNM Retrofit Topical PRNM Retrofit Topical Report Report Section Section No.
No. Utility Utility Action Action Required Required Response
Response
For software For delivered in software delivered in the the form form of hardware of hardware (EPROMs), GGNS (EPROMs), GGNS intends intends toto have have GEH GEH maintain post maintain delivery configuration post delivery configuration control control of of the actual source the actual source code and handle code and handle any any changes changes..
GGNS handles any GGNS handles any changes changes in the EPROMs in the EPROMs as as hardware changes under hardware changes its applicable under its applicable hardware hardware modification modification procedures.
procedures.
19 of 19
GE GE Hitachi Hitachi Nuclear Energy II Nuclear Energy 0000-0103-7166-RO 0OOO-0103-7166-RO
Title:
Grand Gulf
Title:
Grand Gulf Nuclear Nuclear Station Station NUMAC NUMAC PRNM PRNM LTR Deviations LTR Deviations Originator Originator:: F.G.
F.G . Novak Novak Verified Verified I T-QEH External I GEH External Date:
Date: 9/4/09 9/4/09 II Sheet Sheet 1I of7 of 7 Appendix Appendix A A Grand Grand Gulf Gulf Nuclear Nuclear Station Station NUMAC NUMAC' PRNM PRNM LTR Deviations LTR Deviations A-I
GE GE Hitachi Hitachi Nuclear Energy II Nuclear EnerfVJ 0000-0103-7166-RO 0OOO-0103-7166-RO
Title:
Grand Gulf
Title:
Grand Gulf Nuclear Nuclear Station Station NUMACNUMAC PRNM PRNM LTR LTR Deviations Deviations Originator:
Originator: F.G.F.G. Novak Novak Verified Verified II II GEH GEH External External Date: 9/4/09 Date: 9/4/09 ISheet Sheet 22 of of77 Grand Grand Gulf Gulf Nuclear Nuclear Station Station NUMAC NUMAC PRNM PRNM LTR LTR Deviations Deviations Grand Grand Gulf Gulf Nuclear Nuclear Station Station (GGNS)
(GGNS) will will be be submitting submitting aa license application for license application for the the implementation implementation of of Power Power Range Range Neutron Monitor (PRNM)
Neutron Monitor (PRNM).. The The bases for the bases for license application the license application are are the referenced documents the referenced documents in in the the relevant relevant licensing licensing topical topical reports reports (Reference (Reference 1-3). 1-3).
The The PRNM PRNM developed developed for GGNS has for GGNS three deviations has three deviations fromfrom the the referenced referenced documents documents.. These These are are summarized summarized in in Table Table 1I and and discussed discussed in detail below.
in detail below. The licensing topical The licensing topical reports reports explicitly explicitly allow for plant-to-plant allow for plant-to-plant variation variation of of some some features features.. These These are are not addressed herein.
not addressed herein.
Table Table 1. 1 . GGNS GGNS NUMAC NUMAC PRN PRNM M LTR Deviations LTR Deviations a.
- a. PRM Upscale APRM Upscale / OPT OPRM Upscale Upscale function function OPT OPRM Upscale Upscale Improved Improved operating operating OPT Upscale //
OPRMUpscale voted voted separately separately from from the the function function voted voted with with flexibility flexibility Inop Function APRM Inop Function APRM Inop Inop function function the APB Inop the APRM Inop Logic Lo ic function function b.
- b. OPT OPRM Pre-Trip Pre-Trip Alarm if Alarm any instability if any instability Alarm Alarm if the period if the period Delete Delete function that function that Alarm Alarm algorithm algorithm exceeds exceeds defined defined based algorithm based algorithm does does not afford timely not afford timely alarm alarm setpoints setpoints.. exceeds exceeds defined defined operator operator action.
action.
alarm alarm setpoints set oints..
C.
- c. Recirculation Recirculation Flow Flow The The PCI PCI uses Total uses 22 Total The The PCI PCI uses uses 4 Total 4 Total Safety functions Safety functions are are not not Processing Processing Flow signals Flow for the signals for the Flow Flow Flow Flow signals for the signals for the affected; design was affected; design was Comparison.
Comparison. Flow Flow Comparison Comparison.. reviewed reviewed andand approved approved for for all plants in all plants in original original report.
re ort.
A-2
GE Hitachi GE Hitachi Nuclear Energy II Nuclear Energy 0000-0103-7166-RO 0OOO-0103-7166-RO
Title:
Title: Grand Gulf Nuclear Station NUMAC PRNM Grand Gulf Nuclear Station NUMAC PRNM LTR LTR Deviations Deviations Originator Originator:: F.G. F.G . Novak Novak Verified Verified I,"- 1 GEH GEH External External Date : 9/4/09 Date: 9/4/09 I 1 Sheet Sheet 33 of 7 of7 Technical Justifications Technical Justifications a.
- a. APRM APRM Upscale Upscale // OPRM OPRM Upscale Upscale // APRM APRM Inop Inop Function Function Logic Logic Licensing Licensing Topical Topical Report Report NEDC-324 NEDC-32410P-A I OP-A Supplement Supplement 1 1 (Reference (Reference 3) 3) Section Section 8.4 .1 .3 8.4.1.3 describes describes the the logic logic wherein wherein the the OPT OPRM Upscale Upscale function function is is voted voted separately separately from from the the APB APRM Inop lnop function function.. That That is,is, anan APB APRM Inop lnop in in one one APB APRM channel channel and and anan OPT OPRM Upscale Upscale in in another another will will result result inin two two half trips in half-trips in each each of the 2-out-of-4 of the 2-out-of-4 voter voter channels, channels, but but no no RPS RPS trips.
trips.
Designed Designed this this way, way, when when an an APB APRM chassis keylock switch chassis keylock switch is is placed placed in in the the "INOP" "lNOP" position,position, the the APB APRM upscaleupscale trip trip signal signal sentsent to to the the 2-out-of-4 2-out-of-4 voter voter channels channels is is set set to trip . However, to trip. However, the the OPT OPRM trip output from trip output from that that chassis chassis continues continues to to be be processed processed normally normally.. Typically Typically this this logic logic is is of of no no consequence consequence because because if if anan APBAPRM chassischassis (affecting (affecting both both thethe APB APRM and OPT channels) and OPRM channels) is is declared declared inoperable, inoperable, the the APB APRM bypass bypass can can be be used used to to bypass bypass both both thethe APB APRM and and OPT OPRM trips trips from from thatthat channel, channel, whichwhich in in turn tum modifies modifies the the logic logic in in the 2-out-of-4 voter the 2-out-of-4 voter toto be be aa 2-out-of-3 2-out-of-3 vote vote of of both both the the APB APRM and and OPTOPRM trips from the trips from the remaining remaining 33 channels.
channels . However, However, if if the the need need to to declare declare aa second second APB/OPT APRM/OPRM channel channel inoperable inoperable arises when another arises when another APRM/OPRM APRM/OPRM channel channel is is already already bypassed bypassed (and (and cannot cannot be be returned returned to to service service within within the allowed out the allowed out ofof service service time),
time), it it is is necessary necessary to to place place thethe APBAPRM and and OPT OPRM outputsoutputs from from the second channel the second channel in in the the tripped tripped condition condition to satisfy Technical to satisfy Technical Specification Specification requirements requirements.. If If the the APB APRM channel channel is still is still sufficiently sufficiently functional functional to to process process trip trip outputs, outputs, placing placing the the keylock switch in keylock switch in the the INOP INOP position position will will force force aa trip trip for for the the APBAPRM channel, channel, but but not not for for the the OPT OPRM channel.channel. OtherOther action, action, such such as as disconnecting disconnecting aa fiber-optic fiber-optic cablecable to to the the 2-out-of-4 2-out-of-4 voters voters or or removing removing power power fromfrom the the APB APRM
- chassis, chassis, is necessary to is necessary to satisfy satisfy the the requirement requirement to to place place thethe OPT OPRM channelchannel in in the the tripped tripped condition.
condition.
The The automatic automatic APB APRM Inop lnop trip trip is is intended intended to to provide provide aa trip trip when when the the APB APRM channel channel is is known known to to be be incapable incapable of of providing providing aa trip trip based based on on normal normal functions.
functions. This This trip trip occurs occurs immediately immediately even even though though the the Technical Technical Specification Specification requirements requirements allow allow aa period period of of time time for for action action.. The The automatic automatic trip trip isis provided provided to to assure assure that that conditions conditions that that may may disable disable the the APB APRM trip trip function function do do not not go go undetected undetected.. Since Since the the OPT OPRM trip trip function function is is implemented implemented in in the the same same equipment equipment as as the the APB trip APRM function, conditions trip function, conditions that that could could disable disable the the APB APRM trip trip function function would would likely likely disable disable the OPT trip function as well .
the OPRM trip function as well.
For the For the Grand Grand Gulf PRNM, the GulfPRNM, the OPT OPRM UpscaleUpscale function function is is combined combined with with the the APB APRM lnop Inop function function as as the the OPT OPRM channelchannel input input to to bebe voted. That is, voted. That is, an an APB APRM Inop lnop in in one one APRMAPB channel channel and an and an OPT OPRM Upscale Upscale in in another another will will result result inin RPS RPS triptrip outputs outputs from from allall four four 2-out-of-4 2-out-of-4 voter voter channels . Again this logic is typically of no consequence because if an APB chassis (affecting channels. Again this logic is typically of no consequence because if an APRM chassis (affecting both both thethe APB APRM and and OPT OPRM channels) channels) is declared inoperable, is declared inoperable, the the APB APRM bypassbypass can can be be used used to to bypass bypass bothboth the the APB APRM and and OPT OPRM trips trips from from that that channel, channel, whichwhich in in turn tum modifies modifies the the logic logic in in the the 2-out-of-4 2-out-of-4 voter voter toto bebe aa 2-out-of-3 2-out-of-3 vote vote ofof both both the the APB APRM and and OPT OPRM trips trips from from the the A-3
GE GE Hitachi Hitachi Nuclear Nuclear Energy Energy I 0000-0103-7166-RO 0OOO-0103-7166-RO Title
Title:
- Grand Grand Gulf Gulf Nuclear Nuclear Station Station NUMAC NUMAC PRNM PRNM LTR LTR Deviations Deviations Originator:
Originator: FF.G. .G Novak Novak Verified Verified I 1 GEH External GEH External Date:
Date: 9/4/09 9/4/09 Sheet 44 of lSheet of77 remaining remaining 33 channels channels.. This design allows This design allows using using the the APRM APRM chassis chassis keylockkeylock switchswitch to to place place APRM and OPRM outputs from a second channel in the tripped condition when another APRM and OPRM outputs from a second channel in the tripped condition when another APRM/OPRM APRM/OPRM channel channel is is already already bypassed bypassed (and (and cannot cannot be be returned returned to service within to service within the the allowed allowed out out of of service service time) time) without without havinghaving to to resort resort to to other other actions actions such such as disconnecting aa fiber-optic as disconnecting fiber-optic cable cable to to the the 2-out-of-4 2-out-of-4 voters voters or or removing removing power power from from the the APRMAPRM chassis chassis..
For For the the GGNS GGNS PRNM, PRNM, the the Supplement Supplement 11 (Reference (Reference 3) 3) Bases Bases are are changed changed as follows..
as follows 1.
- 1. Page Page H-12 H-12:: change change the the second second paragraphparagraph as as shown shown below below.
The The APRMAPRM System System is is divided divided into into four four APRM APRM channels channels and and four four 2- 2-out-of-4 out-of-4 voter voter channels channels.. Each Each APRM APRM channel channel provides provides inputs inputs to to each each of of the the four four voter voter channels channels.. The The fourfour voter voter channels channels are are divided divided into into two two groups groups of of two two each,each, with with each each group group of of two two providing providing inputs inputs to to oneone RPS RPS trip trip systemsystem.. The The system system is is designed to designed to allowallow one one APRMAPRM channel, channel, but but no no voter voter channels,channels, to to be be bypassed bypassed.. A A triptrip from from any anyone one unbypassed unbypassed APRM APRM will will resultresult in in a a "half-trip" "half-trip" in in allall four four of of the the voter voter channels, channels, but but no no trip trip
^' nFl:lRCt::ioRS inputs inputs to to either either RPS RPS trip trip system system.. A APRP1 t::ri~ r Ineb_ 4 ~0 2.
a, 2 . B, 2. c, aREl 2. El are eot::eEl iREle~eREleftt::l) :Ersm OPRP1 ~seale Fl:lftct::ioR 2.:E. ~Here:ESre, aft) F~RCt::ioR 2.a, 2.B, 2.c, or 2.d t::riIj3 :EJfaM aft)' t::lua liftB)'f3aSseei }\PRP1 cftaftRels luill Jfesl:lle ift a I~ .+4 N ~ I1 ~ ~ T /'\ ~ ~+a M W ~ r1 M M I\ ~ M . T.41 1 H ~ 7
- El:lIl t::ri~ ~ 7^l 1 Y'1 iR eacH A ~
O:E '~ ~ Ih t::fte :Eol:lr eOt::eF cHaRRels, veRicH iR t::l:lrH resl:lles ift t::,,;a el?iIj3 iftIj3eles iftea eaeft RPG el?iIj3 S) seeM la§ie cRaBBel (AI, A2, El, aBd E2). Similarl), a Fl:lftct::ioR 2.:E t::ri~
- Eram aft) euua elftB)Ij3aSseei APRP1 eftaftftels uuill l?eslile ift a :Eelll t::ri~ :Erom eack O:E t::Re :Eol:lr eot::er cHaBBels. Three Three of of thethe four f our APRM APRM channels channels and and all all four four of of the the voter voter channels channels are are required required to to be be OPERABLE OPERABLE to to ensure ensure that that no no singlesingle failure failure will preclude aa will preclude scram scram on on a valid signal a valid signal.. In In addition, addition, to provide adequate to provide adequate coverage coverage of of the the entireentire core, core, consistent consistent with with the the design design bases bases for for the the APRMAPRM Functions Functions 22.a, .a, 22.b, .b, and and 22.d, .d, at least [20]
at least [20] LPRM LPRM nputs, with inputs, with at at least least [three][three] LPRM LPRM inputs inputs from from each each of of the the four four axial axial levels levels at at which which the the LPRMs LPRMs are are located, located, must must be be operable operable for for each each APRM APRM channelchannel.. For the For the OPRM OPRM Upscale, Upscale, Function Function 22.f, .f, LPRMs are LPRMs are assigned assigned to to "cells" "cells" of of [4] [4] detectors detectors.. A minimum of A minimum of
[later]
[later] cells, cells, each each with with aa minimum minimum of of [2] [2] LPRMs, LPRMs, must must be be OPERABLE for OPERABLE for the the OPRM Upscale Function OPRM Upscale Function 22.fto .f to be be OPERABLE.
OPERABLE .
Replaced deleted text Replaced deleted text with with the following:
the following:
Since APRM Since APRM trip trip FunctionsFunctions 22.a, .a, 22.b, .b, 22.d .d and and 22.f .f are implemented are implemented in in the the samesame hardware,hardware, these these trip trip Functions Functions are are combined combined with with APRM APRM Inop Inop trip trip Function Function 22.c. .c . Any Any Function Function 22.a, .a, 22.b, .b, 22.c .c or or 2.d 2 .d trip from trip from any any two two unbypassed unbypassed APRM APRM channels channels will will result result in in aa full full trip trip in in eacheach of of thethe four four voter voter channels, channels, which which in in turnturn results in results in two two trip trip inputs inputs into into each each RPS RPS trip trip system system logic logic channel (Al, channel (Al, A2, A2, Bl, B1, andand B2). B2) . Similarly, Similarly, any any Function Function 22.c .c or or 2 .f trip 2.f trip from from any any two unbypassed APRM two unbypassed APRM channels channels will will result result in in aa full trip full trip from from each each of of the the four four voter voter channels.
channels .
A-4
GE GE Hitachi Hitachi Nuclear Nuclear Energy EnerfDJ II 0000-0103-7166-RO 0OOO-0103-7166-RO Title
Title:
- Grand Grand Gulf Gulf Nuclear Nuclear Station Station NUMAC NUMAC PAM PRNM LTR LTR Deviations Deviations Originator Originator:: F.G.
F.G. Novak Novak Verified Verified II II GEH GEH External External '_ Date: 9/4/09 Date: 9/4/09 I1 Sheet Sheet 55 of7 of 7
- 2. Page H-13
- 2. Page H-13:: For For Function Function 2.e, 2.e, change change the I st sentence the 1st sentence of the 3rd of the 3rd paragraph paragraph to to the the following. "The 2-Out-Of-4 Voter Function votes APB Functions 2 .a, 2 .b, and following. "The 2-0ut-Of-4 Voter Function votes APRM Functions 2.a, 2.b, and 2.d2.d independently independently of of Function Function If." 2.f."
4,111 OPRM
- b. OPRM 11I Pre-Trip Pre-Trip Alarms Alarms Licensing Topical Licensing Topical Report Report NEDC-324 NEDC-32410P-A I OP-A (Reference (Reference 1) 1) paragraph .3 .3 .1 .2 states paragraph 33.3.3.1.2 states that that the the OPT provides OPRM provides an oscillation pre-trip an oscillation alarm when pre-trip alarm when one one ofof the the instability instability algorithms (period algorithms (period
- based, based, amplitude amplitude based, based, or or growth growth based) based) for for an an operable operable OPRMOP cell has cell has exceeded exceeded user user defined defined setpoints . The GGNS PAM design will provide the OPT pre-trip alarm when the Period setpoints. The GGNS PRNM design will provide the OPRM pre-trip alarm when the Period Based Based Algorithm Algorithm for for an an operable operable OPRMOPRM cell cell has has exceeded exceeded user user defined defined setpoints setpoints..
The pre-trip The pre-trip Alarms Alarms are intended to are intended to alert the operator alert the operator of developing instability of aa developing event so instability event so that that manual actions manual actions to avoid aa reactor to avoid reactor scram scram can can be attempted. The be attempted. OPRM Licensing The OPRM Licensing Topical Topical Reports (References 4-6) do not require . pre-trip alarms .
Reports (References 4-6) do not require .pre-trip alarms.
For Option For Option III,111, the the OPRM OPRM cell cell signals signals are are analyzed analyzed by by the the Period Period Based Based Algorithm Algorithm (PBA), (PBA), the the Amplitude Amplitude Based Based Algorithm Algorithm (ABA),
(ABA), and and thethe Growth Growth Rate Rate Algorithm Algorithm (GRA). Automatic (GRA). Automatic protection protection is actuated if is actuated if any one of anyone of the the three algorithms meets three algorithms meets itsits trip trip conditions.
conditions . However, However, only only the PBA is required to provide protection of the Safety Limit Minimum Critical Power Ratio the PBA is required to provide protection of the Safety Limit Minimum Critical Power Ratio (SLMCPR) for (SLMCPR) for anticipated anticipated reactor reactor instabilities instabilities.. TheThe other other two two algorithms algorithms (ABA (ABA and and GRA)
GRA) are are included as included as defense-in-depth defense-in-depth..
The PBA The amplitude trip PBA amplitude setpoint is trip setpoint is the the relative relative power level, or power level, or peak peak over average (PIA),
over average (PIA), at which at which the OPRM cell generates a trip signal, provided the required number of Successive Confirmation the OPRM cell generates a trip signal, provided the required number of Successive Confirmation Counts (SCCs)
Counts (SCCs) has has been reached. The been reached. The following following two two conditions conditions must must both both be met for be met for at least at least one cell one cell in an OPT in an OPRM channelchannel to result in to result in aa PBA-based PBA-based channel channel trip.
trip.
1 . The
- 1. Successive Confirmation The Successive Confirmation Count Count (SCC) reaches or (SCC) reaches or exceeds exceeds the SCC trip the SCC trip setpoint.
setpoint.
2.
- 2. The The cellcell relative relative power power level, level, oror peak peak over over average (P/A), signal average (PIA), signal reaches reaches or or exceeds exceeds the the amplitude amplitude trip trip setpoint.
setpoint.
The The GRA GRA and and ABA ABA are are designed designed to to detect detect large, fast growing large, fast growing oscillations.
oscillations. UnlikeUnlike the the PBA, PBA, the the ABA ABA and and GRA GRA tripstrips dodo not not require require aa minimum minimum number number of of SCCs SCCs to to generate generate aa trip trip signal signal..
During fast growing oscillation events, the trips will occur very early in the event with little During fast growing oscillation events, the trips will occur very early in the event with little time time for for effective effective operator operator action. Consequently, GRA action. Consequently, GRA and and ABA ABA pre-trip alarms are pre-trip alarms are not provided in not provided in the the GGNS GGNS PAM PRNM design.
design.
A-5
GE GE Hitachi Hitachi Nuclear Nuclear Energy Energy F I 0000-0103-7166-RO 0OOO-0103-7166-RO w"~
Title:
Title: Grand Grand Gulf Gulf Nuclear Station NUMAC Nuclear Station NUMAC PRNM PRNM LTR LTR Deviations Deviations _Originator:
Originator: F.GF.G.. Novak Novak Verified Verified I I 7GEH External GEH External Date:
Date: 9/4/09 9/4/09 I1 Sheet Sheet 66 of7 of 7 c.
- c. Recirculation Recirculation Flow Flow Process Processing Licensing Topical Report Licensing Topical NEDC- 32410P-A Report NEDC-3241 OP-A Volume Volume I1 (Reference (Reference 1) 1) and Supplement I1 and Supplement (Reference 3)
(Reference Section 33.2.3.2.2
- 3) Section .2.3 .2 .2 provide provide aa Description Description of of (flow (flow processing) processing) Logic Logic in in the PRNM the PRNM System System for for plants plants with with 44 FlowFlow Channels Channels and and 88 Transmitters Transmitters.. Statement Statement (c) (c) explains explains that each that each APRM sends its total flow signal to two PRNM Communication Interface (PCI) chassis for APRM sends its total flow signal to two PRNM Communication Interface (PCI) chassis for thethe BWR6.
BWR6. Statement Statement (d) explains that (d) explains the PCI that the PCI chassis chassis compares compares two two total total flows, flows, one from each one from each of of two two APRMs, APRMs, and and that alarms are that alarms are issued issued if if the the flow flow differs differs by by more more thanthan aa user-entered user-entered value.value.
In In the the replacement replacement system system at GGNS, each at GGNS, each PCI PCI willwill compare compare all all four four total total flows flows.. One One total flow total flow signal is from the APB chassis in the same channel and one is from the LPG in the other signal is from the APRM chassis in the same channel and one is from the LPRM in the other channel belonging channel belonging to to the the same same RPS RPS triptrip system system.. The The other two flow other two flow signals signals are are provided provided by by thethe other other PCI PCI chassis chassis men When the the PCI PCI determines determines that that the flow differs the flow differs by by more more than than the the user-entered user-entered
- value, value, itit will will transmit transmit this status to this status to its its associated associated APB, APRM, which which will issue the will issue the alarm alarm as as described described.
In In order order toto make make all all four four total flow signals total flow signals available available at at each each PCIPCI chassis, chassis, fiberfiber optic optic communication communication between between all all four four PCI PCI chassis chassis willwill bebe established. Licensing Topical established. Licensing Topical Report Report NEDC-324 NEDC-32410P-A I OP-A Supplement Supplement 11 (Reference (Reference 3) 3) Figure Figure E.1 E.1.7.7 (BWR (BWR 6, Larger Core),
6, Larger Core), which which illustrates illustrates thethe APRM/PCI APRM/PCI configuration configuration block block diagram, diagram, is is amended amended to to include include aa dotted dotted line line (fiber-optic) network between the PCI chassis . Additionally, Figure E .1 .7 is also amended to (fiber-optic) network between the PCI chassis. Additionally, Figure E.1.7 is also amended to show show that each APB that each APRM chassis chassis communicates communicates with with thethe PCI PCI in in the the same same channel, channel, and and each each LPG LPRM chassis communicates with chassis communicates with the PCI belonging the PCI belonging to to the the other channel in other channel in the the same same RPS RPS trip trip system system..
There There is is no.
no effect effect onon any any APB APRM hardware hardware..
By By using using all four total all four total flow flow signals, signals, the the logic logic is is the the same same as as that that described described in Reference 1I for in Reference for allall plants plants with with aa similar similar configuration configuration (4 (4 Flow Flow Channels Channels and and 88 Transmitters),
Transmitters), and and inin Reference Reference 33 for for non-BWR6 non-BWR6 plants plants with with aa similar similar configuration configuration.. The The communication communication network network between between the the PCIPCI chassis chassis agrees agrees conceptually conceptually with with Figure Figure E.3.6 E.3.6 of of Reference Reference 3. 3. Additionally, Additionally, by providing all by providing all four four flow signals for comparison, the logic satisfies what is discussed in Licensing Topical Report flow signals for comparison, the logic satisfies what is discussed in Licensing Topical Report NEDC-32410P-A NEDC-32410P-A (Reference (Reference 1) 1) Section 8 .3 .4.1 .2, where Section 8.3.4.1.2, where it it is explained that is explained that anyany requirement requirement for for aa daily flow comparison daily flow comparison check check is deleted from is deleted from surveillances surveillances and and replaced replaced by by the the automatic automatic comparison comparison of of all all four four total total recirculation recirculation flow flow values.
values. It is noted It is noted thatthat the the justification justification (Section (Section 8.3.4 .1 .3) explicitly calls out comparison logic that includes all four channels.
8.3.4.1.3) explicitly calls out comparison logic that includes all four channels.
Incorporating Incorporating this this logic logic hashas nono affect affect on any safety on any functions .
safety functions.
A-6
GE Hitachi GE Hitachi Nuclear Energy I Nuclear Energy 0000-0103-7166-RO 0OOO-0103-7166-RO Title : Grand
Title:
Grand Gulf Gulf Nuclear Nuclear Station Station NUMAC NUMAC PRNM PAM LTR LTR Deviations Deviations riginator : F.G.
Originator: F .G. Novak Novak Verified Verified II I GEH External I GEH External Date : 9/4/09 Date: 9/4/09 I1 Sheet Sheet 77 of7 of 7 References References 1 . NEDC-3241
- 1. NEDC-32410P-A OP-A Volume Volume 1, 1, "Nuclear "Nuclear Measurement Measurement Analysis Analysis and Control Power and Control Power Range Range Neutron Monitor (NUMACPRNM)
Neutron Monitor (NUMAC PAM) Retrofit Retrofit Plus Plus Option Option III III Stability Stability Trip Trip Function,"
Function,"
October, 1995.
October, 1995 .
- 2. NEDC-32410P-A Volume Volume 22 ----Appendices, Appendices, "Nuclear "Nuclear Measurement Analysis and Measurement Analysis Control and Control over Range Neutron Monitor (NUMAC PAM) Retrofit Plus Option III Stability Trip Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip unction," October, Function," October, 1995.
1995.
3 . NEDC-32410P-A
- 3. NEDC-32410P-A Supplement Supplement 1, 1, "Nuclear "Nuclear Measurement Measurement Analysis Analysis and Control Power and Control Range Power Range Neutron Monitor (NUMAC Neutron Monitor (NUMAC PRNM)PAM) Retrofit Retrofit Plus Plus Option Option III III Stability Trip Function,"
Stability Trip Function,"
November, 1997 .
November, 1997.
A-7
ATTACHMENT ATTACHMENT 3 3 GNRO-2009-00054 GNRO-2009-Q0054 MARKED-UP OPERATING MARKED-UP OPERATING LICENSE LICENSE A D AND TECHNICAL SPECIFICATION PAGES TECHNICAL SPECIFICATION PAGES to GNRO-2009-00054 OPERATING LICENSE Page 1 of 20 GGNS GGNS OPERATING LICENSE (b)
(b) SERI SERI is is required required to to notify notify thethe NRC NRC in in writing writing prior prior to to any any change change in in (i)
(i) the the terms terms or or conditions conditions of of any any new new oror existing existing sale sale or lease or lease agreements agreements executed exe~uted as as part part of of the the above above authorized authorizeC :.; uf..nl,-,.~o.=- transactions transact_Lons.~ . \ j-1 i i1 i) *.the the GGNS GGNS Unit Unit 11 operating operating agreement, agreement, (iii) (iii) the the existing property existing property insurance insurance coverage coverage for for GGNSGGNS Unit Unit 11 that that would would materially materially alteralter the the representations representations and and conditions conditions set set forth forth in in the the Staff's Staff's Safety Safety Evaluation Evaluation Report Report dateddated December December 19, 19, 19881988 attached attached to Amendment No to Amendment No.. 54 54..
In In addition, addition, SERI SERI is is required required to notify the to notify the NRC NRC of of any any action action by by a a lessor lessor oror other successor in other successor in interest interest to to SERI SERI that that maymay have have an an effect effect on on the the operation operation of of the facility .
the facility.
C C.. The The license shall be license shall be deemeddeemed to to contain contain and and is is subject subject to to the conditions specified the conditions specified in in the the Commission's regulations set Commission's regulations forth in set forth in 10CFR 10CFR ChapterChapter II and and isis subject subject to to all all applicable applicable provisions provisions of of the the Act and Act and toto the the rules, regulations, and rules, regulations, and orders orders of of the the Commission Commission now now oror hereafter hereafter in in effect; effect ; and and is is subject subject to to the additional conditions the additional conditions specified specified or or incorporated incorporated below below::
(1)
(1) Maximum Power Maximum Level Power Level Entergy Entergy Operations, Operations, Inc Inc.. iiss authorized authorized to to operate operate the facility at the facility at reactor reactor core power levels core power levels not not in in excess of excess of 3898 3898 megawatts megawatts thermal thermal (100(100 percent percent power) power) in accordance with in accordance with the conditions specified the conditions specified herein herein..
(2)
(2) Technical S_peCif ca Technical Specifica~ions4 -'-- ions The Technical The Specifications contained Technical Specifications contained in in Appendix Appendix A A and the and the Environmental Environmental ProtectionProtection Plan contained in Plan contained in Appendix Appendix B, B, asas revised revised throughthrough Amendment Amendment No No.. 182 182 are are hereby incorporated hereby incorporated into into this license . Entergy this license. Entergy Operations, Operations, Inc. Inc . shall shall operate operate the the facility facility in in accordance with accordance with the the Technical Technical Specifications Specifications and and the the Environmental Protection Environmental Protection Plan. Plan .
The eurveillance Requireffients (~ (SR5~ forftf Die:'5el Bie5ei-Generator 12 contained in the Technic~l Specifications
!~steel belew, and listed a4;Ei aie not belovJ, are net required j~e ut'ifed to te be-- perforItted r-tf--forme iffiRlediately upon implcr-nentation of e!ff ArfteI1eb:rt~nt Pffftendment No. No . 169.
+/--6-9t The eRs listed belolOJ shall be successfully deILt01l5 traLed at the neHt regularly 3cheduled performance.
SR 3.9.1.9, SR 3.9.1.10, a&& anei SR SR 3 .8 .1 .14 3.9.1.14 4 Amendment No. ~ __
Attachment 3 to to GNRO-2009-00054 GN RO-2009-00054 Page Page 2 of 20 2 of 20 INSERT A - Exception During During Cycle Cycle 19, GGNS may 19, GGNS may conduct monitoring of conduct monitoring of the the Oscillation Oscillation Power Range Monitor Power Range Monitor (OPRM).
(OPRM). During During this this time, time, the OPRM Upscale the OPRM function (Function 2.f of Technical Upscale function (Function 2.f of Technical Specification Table 3.3.1 Specification Table .1-1) may 3.3.1.1-1) may bebe disabled and operated disabled and operated in an "indicate in an only" mode "indicate only" mode atat which which time time technical technical specification specification requirements would not requirements would not apply.
apply. During During such such time, time, Backup Backup Stability Stability Protection measures will Protection measures will be implemented via be implemented via GGNS GGNS procedures procedures to to provide provide an an alternate alternate method method toto detect detect and and suppress reactor core suppress reactor core thermal thermal hydraulic instability oscillations hydraulic instability oscillations..
Attachment 3 Attachment 3 to to Definitions Definitions GNRO-2009-00054 GNRO-2009-00054 1.1 Page 3 Page 3 of of 20 20 1 .1 1.1 Definitions Definitions DOSE EQUIVALENT DOSE EQUIVALENT 1-131 1-131 be those be those listed listed in in Federal Federal Guidance Guidance Report Report (FGR) (FGR)
(continued)
(continued 11, "Limiting 11, "Limiting Values Values of of Radionuclide Radionuclide Intake Intake and and Air Concentration Air Concentration and and Dose Conversion Factors Dose Conversion Factors for for Inhalation, Submersion, and Ingestion," X989 .
Inhalation, Submersion, and Ingestion," 1989.
EMERGENCY EMERGENCY CORE COOLING CORE COOLING The ECCS The EeCS RESPONSERESPONSE TIME TIME shall shall be be that that time time interval interval SYSTEM (ECCS)
(ECCS) RESPONSE RESPONSE from when from when the monitored parameter the monitored parameter exceeds exceeds its its ECCS ECCS TIME initiation setpoint initiation setpoint at at the the channel channel sensor sensor until until the the ECCS ECCS equipment equipment is is capable capable of of performing performing its its safety function (i .e ., the valves travel safety function (i .e., the valves travel to to their their required required positions, positions, pump pump discharge discharge pressures pressures reach reach their required their required values~ values, etc etc.)..) . Times Times shall include shall include diesel generator diesel generator starting starting and sequence loading and sequence loading delays, delays, where where applicable applicable.. The The response response time time may may be measured by means of any series of sequential, .
be measured by means of any series of sequential, overlapping, overlapping, or or total total steps steps so so that that the the entire entire response response time time is is measured measured..
END END OF OF CYCLE CYCLE The The EOC-RPT EOC-RPT SYSTEM SYSTEM RESPONSE RESPONSE TIME TIME shall shall be be that that RECIRCULATION RECIRCULATION PUMP PUMP TRIP TRIP time interval time interval from from initial initial movement movement of of thethe (EOC-RPT)
CEOC-RPT) SYSTEM SYSTEM RESPONSE associated turbine associated turbine stop stop valve valve or or the the turbine turbine TIME TIME control valve to complete suppression of control valve to complete suppression the of the electric arc electric between the arc between the fully fully open open contactscontacts of of the recirculation recirculation pump circuit breaker pump circuit breaker.. The The response response time time may may be be measured measured by by means means of of any any serf series es of of sequenti sequential, al , overt overlapping, appi hg, or or total total steps steps so that the entire response so that the entire response time is measured, time is measured, except except for for the the breaker breaker arc arc suppression suppression time, time, whi which is not is not measured measured but but isis validated validated to to conform conform to to thethe manufacturer's design manufacturer's value..
design value FRACTION OF fA@; FC88 SMall be tAe rat; a ~ a of
- of th tAc PpOlh'er W F CORE BOILIN6 9generated e n e ra a t e in the lo 'd er 44. :EfQQt
. gf thQ actjv- active BOUNDARY A(FCBB) 4 00~ \t eacten 1-1 e re@
eOt to tM@ ~ow@r ,@qu; -j - \re@d to \.1 4 ~rocluee bul k to pro-due-,
saturated
~SdLur-, CJLL'U UUf boiling of tile I I fly Ul fit! UUU I d IL, t~flutr cooldtiL ellter illy
- tilE. Fuel illy LIlt: -
ehaRRels. T~e core op ~oiliAg 6ai34i9 g beuftclary is the axial W 15 IA . I 1A U I e1 e'lati on of core average bul k saturati 019 above tAe i.: I,Q.e be bottoffi45 ffl ef of thet~e aC-tiH,Ae active ri-eaetep reactor Geple coro.;
ISOLATION ISOLATION SYSTEM SYSTEM The The ISOLATION ISOLATION SYSTEM SYSTEM RESPONSE RESPONSE TIME TIME shall shall be be that that
RESPONSE
RESPONSE TIMETIME time time intervalinterval from from when when the the monitored monitored parameter parameter exceeds exceeds its its isolation isolation initiation initiation setpoint setpoint at at the the channel channel sensor sensor until until thethe isolation isolation valves valves travel travel to to their their required required positions positions.. The The response response time time (continued)
GRAND GRAND GULF GULF 11.0-3
.0-3 Amendment No Amendment No.. +4+, 145 _
Attachment Attachment 33 to to GNRO-2009-00054 GNRO-2009-00054 Page 4 Page 4 of of 20 20 33.2
.2 POWER DISTRIBUTION POWER DISTRIBUTION LIMITS LIMITS 3.2.4 Fraction of'F Gt1ra ;43, i Cors Boiling PlIg Boyndary t(FC88j F{nilYtfl,V~t/ I:C . C ThQ FCBB ~hall as < 1.0.
Appl TfARTI TTV APPLICABILITY* i A t t1 eRe 5 t ric ted R~ 9 i 0 I' a5 Thermal POl,t/sr : ~igh, Allo\lable n ii
~~sGified iinn # h e COLR.
the rQ1 0 ACTIONS ACTIONS CQbfDITION CONDITION REQUIRED ACTION COMPLeTION HM-E A... FeBS ngt \-lithin liFAit U Restore FCBB to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 4forr raacng rea~ons # he-
& other '.Ji th i n 1i mi t .
than than -an an I'm unexpected Y
Q C1r+
t n
lO~a of :Eaddwatn
]acs feedwaterr heating gr ~nexpected reductign in Gore
~
B-B-.. gequired R. Actionp;;--and wi-p ?.d--A~-til ~ lFAFAediately associitQd Completion an Ti~e of Condition A Region.
nott W" I+lQt.
IFRFAediately foll oln'i ng ~
Q-f-el~~~~~d of Restricted
- ~ Region Value to
" ~~~Io-oH"
..... 'v'al ue.
(continued)
GRANDD GULF GULF 3.2-4 3 . 2-4 Amendment No Amendment No..
Attachment 33 to Attachment to GNRO-2009-00054 GNRO-2009-00054 Page 55 of Page of 2020 ACTIONS CQblDITION REQUIRED ACTION COMPL£TION HM-f 8- (cent i nlsted)
- - - - - - ---+'r~'+-HOTI-fll.E---N geq'lirQd Action B.l and geqlsti rQQ Act; on 8 2 shall bQ comp co~pleted if thi~
I1 l i r " i Condition i~ QntirQd due to an unQxpQctQd oo-f 1loss of f.a. gr feed\elatQr e a- t i n g Op-'~',T°~'~'
heating er unQxpQctQd ° red'lction in cor~
llOJ.Ah r " s i FeES not within lil+lit v- v d'lQ to an 'lnQxpQctQdd a.-
loss of fQQdwatQr heating or unQxpQctQd a- d- w a- t -Q n iin r-reduction A- cor~
=e llOJ.Ah GRAND GlIlF
Attachment Attachment 33 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 66 of of 20 20 SURVEILLANCE REQUIREMENTS 5URVElL LA ~~ CE FQF-Qllr-hlr-y FREQUE~~CY
., "4,j '. , ,
~ 3.2.4.1 ----------- Nuir----------------
.* .. ---------------NOTE--------------------
Net re~uirecl to be perforffied until 15 ffiiAutes 441 after
- F entp-cAtry in intoa th the RestP4 Restricted Regien 4if4 eAtry was 1:the
.1 0 P;~ p ~ A I ; :z :
-11.1 H pe Ile result of an I I",
~-ed ttraRsient.
u~expected ea ig t" "9 P1 Yt Ver4 ;Fy ~- . 0. 24 ROUfS Orlee w'i tltii fl 15 ffliAutes followirlg uflexJ'eeted traflsieflt GRANO GULF
Attachment 3 to to G N RO-2009-00054 GNRO-2009-00054 Page Page 77 of of 20 20 RPS RPS Instrumentation Instrumentation 33.3.1.1
.3 .1 .1 33.3
.3 INSTRUMENTATION INSTRUMENTATION 3 .3 .1 .1 3.3.1.1 Reactor Protection System Reactor Protection System (RPS)
(RPS) Instrumentation Instrumentation NCO LCO 33.3.1.1
.3 .1 .1 The RPS instrumentation The RPS instrumentation for for each each--..--~-L.--""""''''''~'~.~~,~. . . . . . . . . . . . . . ~--...
shall shall bebe OPERABLE OPERABLE.. --------------------NOTE----- "-------------
~()lrE:-------------------
Not applicable
~ot applicable for for Functions Functions 2.a, 2.a, 2.b, 2 .b, 22.c,
.c, 2.d, 2.d, or or 2 2.f..f.
APPLICABILITY::
APPLICABILITY According According to to Table 3 .3 .1 1-Table 3.3.1.1-1 --------"--------------------------------------
ACTIONS ACTIONS
" _----- " _ "" ----- " _ "" _ ._------ -N ------------------------------
~----------------------N E-Separate Condition entry Separate Condition entry isis allowed allowed f each channel .
- ----------------------------y-------- - ----------------------
CONDITION CONDITION REQUIRED CTION COMPLETION COMPLETION TIME TIME AA.. One or One or more more required required A .1 Place ch nnel in in 12 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> hours channels channels inoperable inoperable.. trip .
OR A.2 A-2 Place associated Place associated trip trip 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 12 hours system system in in trip trip..
BB.. One or One more Functions or more Functions BB.1
.1 Place channel Place channel iin one n one hours fi6 hours with one with one or or more more trip system in trip system trip..
in trip reqUired channels required channels inoperable inoperable in in both both OR OR trip systems trip systems..
BB.2
.2 Place P1 one trip ace one trip system system 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 6 hours in trip.
in trip .
c.
C. One One or or more more Functions Functions e.l C .1 Restore Restore RPS RPS trip trip 11 hourhour with RPS with RPS trip trip capability.
capability .
capability capability not not maintained.
maintained .
(continued)
(continued)
GRAND GRAND GULF GULF 3 .3- 1 3.3-1 Amendmentndment NoNo.. -tre- -
Attachment 3 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 8 8 of of 20 20 RPS Instrumentation RPS Instrumentation 3,3 .I .1 3.3.1.1 ACTIONS ACTIONS continued)
(continued)
CONDITION CONDITION REQUIRED REQUIRED ACTIONACTION COMPLETION TIME COMPLETION TIME DD.. Required Action and ReqUired Action and D .1 0.1 Enter Enter thethe Condition Condition Immediately Immediately associated associated Completion Completion referenced referenced in in Time of Time of Condition Condition A, A, Table 3 .3 .1 .1-1 for Table 3.3.1.1-1 for B, or C not met, B, or C not met. the channel .
the channel.
EE.. As As required required by by E-1 E.1 Reduce Reduce THERMAL THERMAL POWERPOWER 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> hours Required Action D ReqUired Action .1 0.1 to to <
< 40%
40% RTP RTP..
and referenced in and referenced in Table Table 33.3.1.1-1.
.3 .1 .1-1 .
FF.. As As required required by by F .1 F.l Reduce THERMAL POWER Reduce THERMAL POWER 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> hours Required Required Action Action D0.1.1 to to << 25% RTP .
25% RTP.
and and referenced referenced in 1n Table 33.3.1.1-1.
Table .3 .1 .1-1 .
GG.. As required As required by by GG.I
.1 Be Be inin MODE MODE 22.. 66 hours7.638889e-4 days <br />0.0183 hours <br />1.09127e-4 weeks <br />2.5113e-5 months <br /> hours Required ReqUired Action Action D0.1.1 and and referenced referenced in in Table Table 33.3.1.1-1.
.3 .1 .1-1 .
HH.. As As required required by by H .1 H.1 Be Be inin MODE MODE 33.. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 12 hours Required Required Action Action 00.1.1 and and referenced referenced in in Table Table 33.3.1.1-1.
.3 .1 .1-1 .
II .. As As required required by by I .1 1.1 Initiate Initiate actionaction to to Immediately Immediately Required Required Action Action D0.1.1 fully insert all fully insert all and and referenced referenced in in insertable control insertablp control Table 33.3.1.1-1.
Table .3 .1 .1-1 . rods in:
rods in -, core care cells Jcell s containing containing one one or or more more fuel fuel assemblies assemblies..
F~-------.Y.-INSERT INSERT B B -- New New Conditions Conditions JJ and and K K with Required Actions with Required Actions GRAND GRAND GULF GULF 33.3-2
.3- 2 Amendment No .
Amendment No.~---
Attachment 3 to to GNRO-2009-00054 GNRO-2009-00054 Page 99 of Page of 20 20 INSERT INSERT B B- - New New Conditions Conditions J J and and KK with with Required Required Actions Actions J.
J. As required by As required by Required Action Required Action J.1 J.1 Initiate alternate Initiate alternate method method toto 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 12 hours D.1 0.1 and referenced in and referenced in detect and suppress detect and suppress thermal thermal Table Table 3.3.1 .1-1 .
3.3.1.1-1. hydraulic instability hydraulic instability oscillations oscillations..
AND AND JJ.2
.2 -________NOTE_
NOTE-------- ._ ._ .__
LCO 3.0.4.b LCO 3.0.4.b is is not not applicable applicable..
Restore required channels Restore required channels to to 120 days 120 days OPERABLE.
K K~ Required Required Action and associated Action and associated K.1 K.1 Reduce Reduce THERMAL THERMAL POWER POWER 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> hours Completion Time Completion Time ofof Condition Condition JJ to < 24%
to < 24 % RTP.
RTP.
not met.
not met.
Attachment Attachment 3 3 to to RPS Instrumentation RPS Instrumentation GNRO-2009-00054 GNRO-2009-00054 3 .3 .1 .1 3.3.1.1 Page 10 Page 10 of of 20 20 SURVEILLANCE SURVEILLANCE REQUIREMENTS REQUIREMENTS (continued)
(continued)
SURVEILLANCE SURVEILLANCE FREQUENCY FREQUENCY SR 3 .3 .1 .1 .10 3.3.1.1.10 ------------------ NOTES ---------------
NOTES------------------
- 1. Neutron detectors are Neutron detectors excluded are excluded.
- 2. For Function For Function 2.a, 2 .a, not not required required toto be be performed when performed when entering entering MODE 2 from MODE 2 from MODE 1 MODE 1 until until 12 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> hours after a entering r entering MODE MODE 22..
- 3. For Function Function 22.d,
.d, APRM APRM recirculation recirculation flow transmitters are flow transmitters are excluded.
excluded .
~ For function 2.d, tAe digital components of the flew eont,ol t, ip reference cards are exelud~d.
Perform CHANNEL Perform C L CALIBRATION.
CALIBRATION (continued)
(continued)
ND GULF GRAND GULF 3 .3-4a 3.3-4a Amendment Amendment No. -+4+-----l
Attachment Attachment 3 3 to to RPS RPS Instrumentation Instrumentation GNRO-2009-00054 GNRO-2009-00054 3 .3 .1 .1 3.3.1.1 Page Page 11 of 20 11 of 20 SURVEILLANCE RE SURVEILLANCE REQUIREMENTS UIREMENTS (continued)
(continued)
SURVEILLANCE SURVEILLANCE FREQUENCY FREQUENCY SR 3 .3 .1 .1 .15 3.3.1.1.15 ------------------ NOTES ------------------
NOTES------------------
1.
1 . Neutron detectors are Neutron detectors are excluded excluded..
22.. For For Functions Functions 3,4, 3, 4, and and 55 inin
.3 .1 .1-1, the Table 33.3.1.1-1, the channel channel sensors sensors may may be be excluded.
excluded .
33.. For For Function Function 6, 6, "n" un" equals equals 44 channels channels for the purpose of determining the for the purpose of determining the STAGGERED TEST STAGGERED TEST BASISBASIS Frequency.
Frequency .
Verify the Verify RPS RESPONSE the RPS RESPONSE TIME TIME is within is within 18 18 months months on on aa 1limits, imits. STAGGERED TEST STAGGERED TEST Deleted BASIS BASIS SR SR 3 .3 .1 .1 .16 3.3.1.1.16 V r4 -Y : m, .4, FPO 18 ffle jq ::~ 6 S mOfltl'is SR SR 3.3.1.1.17 3 .3 .1 .1 .17 Perform APRM Perform APRM recirculation recirculation flow flow 18 months 18 months transmitter transmitter calibration calibration..
SR 3 .3 .1 .1 .18 d Sib t e w e (5 mi:r
- 1. '. . e me M Oflee W4
'vv'itl9ifl I
- 1
- 6 if 4. . . :7 7I e a rd, a Mfo to Peaet i, flow . A ays after da)'5 aft, r rreaer-Ii a e h4ftg ft9 qtJ 4 14 16 r i tim eC1uilibrium eeOflditioflS am 444:4
., . " s Deleted foll I. I ('jOW';
I
-,I Ull 04-ft. "99 refut 1 4.-ftg refueliFig outage INSERT C - New SRs 3 .3 .1 .1 .19, 3.3 .1 .1 .20, 3.3.1 .1 .21, 3.3.1 .1 .22, and 3 .3.1 .1 .23
~ GULF GULF 33.3-5a
.3-5a Amendment No Amendment No. ~
Attachment 3 toto GNRO-2009-00054 GN RO-2009-00054 Page 12 Page 12 ofof 2020 INSERT C INSERT C- - New New SRs .3.1 .1 .19, 3.33.1 .1 .20, 3.3.1 .1 .21, 3.3.1 .1 .22, and SRs 3-3.3.1.1.19,3.33.1.1.20,3.3.1.1.21,3.3.1.1.22, and 3.3.1 .1 .23 3.3.1.1.23 SR SR 3.3.1 .1 .19 3.3.1.1.19 Perform Perform CHANNEL CHANNEL CHECK CHECK.. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 24 hours SR 33.3.1.1.20 SR .3.1 .1 .20 ---------------------
- - - - - - - - - - - - - - - - - - - - - NOTE NOTE ------------------------
1 . For
- 1. For Function Function 2.a, not required 2.a, not required to be performed to be performed when when entering entering MODE MODE 22 from from MODEMODE 1 1 until until 12 hours after 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering entering MODE MODE 2. 2.
2.
- 2. For Functions For Functions 2.a, 2.a, 2.b, 2.b, and and 2.c, 2.c, the the APRM/OPRM APRM/OPRM channels channels and and the 2-Out-Of-4 Voter channels are the 2-0ut-Of-4 Voter channels are included included in in the the CHANNEL CHANNEL FUNCTIONAL TEST.
FUNCTIONAL TEST.
3.
- 3. For For Functions Functions 2.d 2.d and and 2.f, 2.f, the the APRM/OPRM APRM/OPRM channels channels and and the the 2-Out-Of-4 2-0ut-Of-4 Voter channels plus Voter channels plus the the flow flow input input function, function, excluding the excluding the flow flow transmitters, transmitters, are are included included inin the the CHANNEL CHANNEL FUNCTIONAL FUNCTIONAL TEST TEST..
Perform Perform CHANNEL CHANNEL FUNCTIONALFUNCTIONAL TEST TEST.. 184 184 days days SR 3.3.1.1.21 SR 3.3 .1 .1 .21 Perform Perform LOGICLOGIC SYSTEM SYSTEM FUNCTIONAL FUNCTIONAL TEST TEST.. 24 months 24 months SR SR 3.3.1 .1 .22 3.3.1.1.22 - - .______
-- - - - - - - - -._- -._______NOTE__
- - - - - - - NOTE - - -._______
For For Function Function 2.e,2.e, "n""n" equals equals 88 channels channels for for the the purpose purpose of of determining the determining the STAGGERED STAGGERED TEST TEST BASIS BASIS Frequency.
Frequency. Testing Testing APRM APRM and and OPRM OPRM outputsoutputs shall shall alternate.
alternate.
Verify Verify the the RPS RPS RESPONSE RESPONSE TIME TIME is within limits.
is within limits . 24 months on 24 months on aa STAGGERED STAGGERED TEST TEST BASIS BASIS SR SR 3.3 .1 .1 .23 3.3.1.1.23 Verify Verify OPRM OPRM is is not not bypassed bypassed when when APRM APRM Simulated Simulated Thermal Thermal 24 months 24 months Power Power is is greater greater thanthan or or equal equal toto 29%
29% RTPRTP and recirculation drive and recirculation drive flow flow isis less less than than 60%60% of of rated rated recirculation recirculation drive drive flow flow..
Attachment Attachment 33 to to RPS RPS Instrumentation Instrumentation GNRO-2009-00054 GNRO-2009-00054 3 .3 .1 .1 3.3.1.1 Page Page 13 13 of of 20 20 Table Table 33.3.1.1-1
.3 .1 .1-1 (page(page 1 1 of of 3)3)
Protection System Reactor Protection Reactor Instrumentation System Instrumentation APPLICABLE CONDITIONS MODES OR MODES OR REQUIRED REQUIRED REFERENCED REFERENCED OTHER CHANNELS CHANNELS FROM FROM SPECIFIED SPECIFI D PER TRIP TRIP REQUIRED REQUIRED SURVEILLANCE SURVEILLANCE ALLOWABLE ALLOWABLE FUNCTION FUNCTION CONDITIONS SYSTEM ACTION 0.1 D .1 REQUIREMENTS VALUE VALUE
- 1. Intermediate Intermediate Range Range Monitors Monitors aa.. Neutron Flux-High Neutron Flux-High 22 33 H H SR SR 3 .3 .1 .1 .1 3.3.1.1.1 <
~ 122/125 122/125 SR SR 3 .3 .1 .1 .3 3.3.1.1.3 divisions divisions ofof SR, SR 3 .3 .1 .1 .12 3.3.1.1.12 full scale full scale SR SR 3 .3 .1 .1 .13 3.3.1.1.13 sea) 5(a) 33 1 SR SR 3 .3 .1 .1 .1 3.3.1.1.1 122/125
~ 1221125 SR SR 3 .3 .1 .1 .4 3.3.1.1.4 divisions divisions ofof SR SR 3.3.1.1.12 3 .3 .1 .1 .12 full scale full scale SR SR 3 .3 .1 .1 .13 3.3.1.1.13
- b. Inop 2 3 H SR SR 3 .3 .1-1 .3 3.3.1.1.3 NA SR SR 33.3.3 ..1.1.13
.1 .1 .13 sea) SR SR 33.3.1.1.4
.3 .1 .1 .4 NA NA SR SR 33.3.1.1.13
.3 .1 .1 .13
- 2. Average Power Range Monitors
- a. Neutron Flux-High, 2 SR SR ~ . ~ . i . i_.
Setdown GR SR ; . ; . iI . .;
SR SR 3 .3 .1 .1 .7 SR SR, 3 .3 .1 .1 .10 SR SR ;. ;. I. I. I
- b. Fixed Neutron Flux-High SR 3,3 .1 .1 .2 SR 3 .3 .1 .1 .7 SR ; . ;.i . ~~.
SR 3 .3 .1 .1 .1(
SR 9 .3 .1
- c. I nop 1,2 SR
- d. Flow Biased Flow Biased Simulated Simulated 3 G SR--3-,9 SR 3.3.1.1.1 . 1.1 . i Thermal Power Thermal Power -- High High SR 33.3.1.1.2 SR .3 .1 .1 .2 SR 33.3.1.1.7 SR .3 .1 .1 .7 SR SR 93.3.1.1.8
. ; . i . 1-4 .
SR 33.3.1.1.10 SR, .3 .1 .1 .1 n
SR 3.3.1.1.13 INSERT D - New APRIVI Functions 2.e and 2J C 0 Ij 11 SR 3.3.1.1.16 SR 3.3.1.1.16 SR SR 3 .3 .1 .1 .17 3.3.1.1.17 SR SR 3.3.1.1.18 W . ; . i . i. I (continued)
(continued)
((a) a) Withth anyany control control rod rod withdrawn withdrawn from from a core core cell cell containing containing one one or or more more fuel assemblies..
fuel assemblies (b)
(b) !leviable All o\~'aBl e Val eified Val ues spec; fi ed in i 19 the tRe GG6R GOLR.. Allewable All o'..'abl e Va!He Val ue FRedi fi cati OR Feeuir-ed FnedifieatieH f'eql:1i red by By tAe the GG~R ue GOLR Eiue to Feduetiens f'cdl:1ctioAS 119
' feedwater may be teFflperat~re fflay eedwatep, tempepatHpe be delayed delayed for ;6,F ~p to 12 12 ~ours.
heHps .
Two-Loop operation : 0 .65W + 62 .9% RTP and < 113% RTP Single-Loop Operation : 0.65W + 42 .3% RTP INSERT E - New Table Notes (c), (d), (e), and (f)
GRAND GRAND GULF GULF 3 .3-6 3.3-6 Amendment No.
Amendment No . ~,
+4+, ~ 4-6-9
Attachment 3 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 14 14 of of 20 20 INSERT INSERT D D -- New New APRMAPRM Functions Functions 2.e 2.e and and 2.f 2.f
- e. 2-Out-Of-4 Voter 2-0ut-Of-4 Voter 1,2 1,2 22 H H SR 3.3 .1 .1 .19 SR3.3.1.1.19 NA NA SR SR 3.3 .1 .1 .20 3.3.1.1.20 S R 3.3 .1 .1 .21 SR3.3.1.1.21 SR SR 3.3 .1 .1 .22 3.3.1.1.22 3(C) f.f. OPRM Upscale OPRM Upscale >
~ 24%
24% RTP RTP 3(c) J S SRR 3.3 .1 .1 .7 3.3.1.1.7 (f)
(f)
S R 3.3 SR . 1 . 1 .10 3.3.1.1.10 (d), (e)
SR 3.3 SR .1 .1 .19 3.3.1.1.19 SR 3.3 SR .1 .1 .20 3.3.1.1.20 SR 3.3 SR .1 .1 .23 3.3.1.1.23 INSERT INSERT E E -- New New Table Table Notes (c), (d),
Notes (cl, (e), and (dl, (el, and (f) (f)
(c) Each channel provides Each channel provides inputs inputs to to both both trip systems .
trip systems.
(d)
(d) If If the the as-found as-found channel channel setpoint setpoint isis outside outside its its predefined predefined as-found as-found tolerance, tolerance, then then the the channel channel shallshall bebe evaluated evaluated to to verify verify that that itit is functioning as is functioning as required before returning required before returning the the channel channel to to service.
service.
(e)
(e) The instrument channel The instrument setpoint shall channel setpoint shall be reset to be reset to a a value that is value that is within within the the as-left as-left tolerance tolerance aroundaround the Nominal Trip the Nominal Trip Setpoint Setpoint (NTSP}(NTSP) at the completion at the completion of of the the surveillance surveillance;; otherwise, otherwise, the channel shall the channel shall be be declared inoperable . Setpoints declared inoperable. Setpoints more more conservative conservative that the NTSP that the NTSP are are acceptable acceptable providedprovided that the as-found that the as-found and as-left and as-left tolerances tolerances apply apply to the actual to the actual setpoint implemented in setpoint implemented in the Surveillance procedures the Surveillance procedures to to confirm channel performance. The NTSP and the methodologies used to determine the confirm channel performance. The NTSP and the methodologies used to determine the as-found as-found and as-left tolerances and as-left tolerances are are specified specified in in the the Technical Technical Requirements Requirements Manual. Manual.
(f) The The Allowable Allowable ValueValue for for the the OPRM Upscale Period-Based OPRM Upscale Period-Based Detection Detection algorithm algorithm is is specified specified in in the COLR.
the COLR.
Attachment 3 to Attachment GNRO-2009-00054 GNRO-2009-00054 flB-&S Page 15 of 20 Page 3.3.1.3 3 .3 3.3 INSTRUMENTATION 3.3.1.3 Period Based DeteetioA System (PBDS) bf8 3 .31 3.3.1.3 ln-r~r One cRenAel of PBDSr-instrumeAtation l -r ;rlrcsrrr~- - n sRall
,~-n-n-~-~ be OPERABLE.
w0--cn-- I -ro-c~
AND a .
Each OPERABLE chaAnel of PBDS in~truffientatioA shall not
- -nd; ld 4 cate Iii Iii DRR a1a A arm.
" L_tI'S +4 J1 1 ~ ~ '^I 1 Y'li 1Y1 l T9 t H -TI-'
4, a'TfT1'.
T CD r., ., .. .G' APPLICABILITY: TfIER~~AL l'~L- PO~~ER P191 "All aAd amd core r flow 1 64 w i A t1ge Rcstri cted Regi on specified in the COLR,
, ~. r " .~
THERMAL TR F ,- Rl mll A" POWER andd t9 core flow in the Monitored Region specified in the COLR.
/\(T I O~! S CONDITION REQUIRED ACTION CO~1PLETION T+M£
- \. AFlY OPERABLE p.e.g.£ Place the reactor Immediately ehaFlFlel iFldieating mode switch in the Hi Hi OR Alarm shutdown position.
- 8. Requi red PBOS channel B-:4 inoperable while in the Restricted Region.
Iffifficdiately (Coflt;flueel)
GRAND D GULF 33.3-13a
.3-13a Amendment Amendment No. ~ I
Attachment 33 to Attachment to GNRO-2009-00054 GNRO-2009-00054 ~
Page Page 16 16 of 20 of 20 3.3.1,3 ACTIONS rn CONDITION N 11 ~N REQUIRED ACTION COMPLETIONN ~
E-QWRI-9 B. (conti nued ~ B-:4 Place the reactor I I+lRH~) d i ~ tel y mode s',Ji tc h in the shutdo'n1n position.
- c. Required PBDS chaflnei G-.-+/- Initiate action to 15 min61tes inoperable 'n'hi 1e in exit the Monitored the Monitored Reg;ofl. Region.
SURVEILLANCE REQUIREMENTS SURV E; I LL/\~JC E FREQUENCY 5-R 3.3.1.3.1 12 h061rs
&R 3.3.1.3.2 Perforffi GHANN~L G~~GK. 12 h06lPS
&R 3.3.1.3.3 MnIn 24 R:lonths s GRA~~D GULF 3.3 13b Amendment ~ ~
Attachment 3 to to GNRO-2009-00054 GNRO-2009-00054 SDM Test-Refueling SDM Test---Refueling 33.10.8
.10 .8 Page Page 1717 of of 20 20 33.10
.10 SPECIAL OPERATIONS OPERATIONS 33.10.8
.10 .8 Shutdown Margin Shutdown Margin (SDM)(SOH) Test--Refueling Test-Refueling LCO LCO 3.10.8 3 .10 .8 The reactor The reactor modemode switch switch position specified specified in in Table Table 11.1-1
.1-1 MODE 55 may for MODE for may be be changed changed toto include the the startup/hot startup/hot standby standby position, and position, and operation operation considered considered not not to to be be in MODE 2, in MODE 2, to to allow SDM allow SOH testing, testing, provided provided the the following following requirements requirements are are met::
met
- a. LCO 33.3.1.1, LCO "Reactor Protection
.3 .1-1, "Reactor System (RPS)
Protection System {RPS}
Instrumentation," MODE Instrumentation," MODE 22 requirements requirements for Function 22.a for Function
~2.c of Table 2 .q-of .3-1 .1-1 ;
Table 33.3.1.1-1;
- b. CO 33.3.2.1,
.3 .2 .1, "Control "Control RodRod Block Instrumentation,"
Block Instrumentation,"
~~-~~ MODE 2 requirements for Function 1l.b MODE 2 requirements for Function of
.b of Table Table 3 .3 .2 .1-1 .
3.3.2.1-1, OR 22.. Conformance Conformance to to the the approved approved control control rod sequence fo rod sequence for the the SDM SOH test test isis verified verified by second licensed by aa second licensed operator or operator or other other qualified qualified member member of the technical of the technical staff; staff;
- c. Each withdrawn control rod shall be coupled to the associated associated CRD CRD;;
- d. All All control control rodrod withdrawals withdrawals during out of during out of sequence sequence control rod control moves shall rod moves shall be be made in single made in single notch notch wi thdrawal mode withdrawal mode;;
- e. No other No other CORE ALTERATIONS are CORE ALTERATIONS are inin progress progress;; and and
~ 1520 psig..
APPLICABILITY::
APPLICABILITY MODE 55 with MODE with the the reactor reactor mode mode switch switch in in startup/hot startup/hot standby standby position..
position GRAND GULF GULF .10-19 3.10-19 3 Amendment No No.. ~ ____
3 to Attachment to GNRO-2009-00054 GNRO-2009-00054 SDM Test--Refueling SOM Test-Refueling Page 18 Page 18 of of 20 20 3 .10 .8 3.10.8 ACTIONS ACTIONS CONDITION CONDITION REQUIRED ACTION REQUIRED ACTION COMPLETION TIME COMPLETION TIME
_____NOTE______ . .___
*-----NOTE----------- ------------- NOTE ------------
NOTE------------
Separate Condition entry Separate Condition entry Inoperable control Inoperable control rods rods may may is allowed is allowed forfor each each be be bypassed bypassed in in RAGS RACS inin control control rod rod.. accordance with accordance with SRSR 3.3.2.1.9, 3 .3 .2 .1 .9,
if required, if required, to to allow allow rtion of insertion of inoperable inoperable AA.. One control rod One control rod not not control control rod rod and continued and continued coupled to coupled to its its operation operation..
associated CRD associated eRD.. -----------------------------
A .1 A.1 Fully Fully insert insert 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> hours inoperable inoperable control control rod .
rod.
AND A .2 A.2 Disarm the Disarm the associated associated 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> hours CRD .
CRD.
BB.. One One oror more more ofof the the I B.1 B Place Place the reactor the reactor I mmed i atel y Immediately above above requirements requirements not not mode mode switch switch in in the the met for reasons met for reasons other other I shutdown shutdown or or refuel refuel than than Condition Condition AA.. position position..
SURVEILLANCE SURVEILLANCE RE REQUIREMENTS SURVEILLANCE FREQUENCY SR SR 33.10.8.1
.10 .8 .1 Perform Perform thethe MODE MODE 22 applicable applicable SRs SRs for for According According to to LCO leO 33.3
.3 .1 .1, Functions
.1.1, Functions 22..aa -and- 22..c,of c of the the applicable applicable Table Table 33.3.1.1-1.
.3-1 .1-1 . SRs SRs (continued)
GRAND GRANO GULFGULF 33.10-20
.10- 20 Amendment Amendment No No.. -t21r _
to to G NRO-2009-00054 GNRO-2009-00054 Reporting Requirements Reporting Requirements Page 19 Page 19 of of 20 20 5 .6 5.6 55.6
.6 Requi resents Reporting Requirements 55.6.2
.6 .2 Annual Radiological Environmental Operating Report (continued) (con need) results are results are not not available available for for inclusion inclusion with with the the report, report, the the report shall report shall be be submitted submitted noting noting andand explaining explaining the the reasons reasons for for the missing results.
the missing results . The missing The missing data data shall shall be be submitted submitted in in a a supplementary report supplementary report as soon as as soon as possible.
possible .
55.6.3
.6 .3 Radioactive Effluent Release Report The Radioactive The Radioactive Effluent Effluent Release Release Report Report covering covering the the operation operation of of the unit during the previous calendar year shall be submitted by the unit during the previous calendar year shall be submitted by May May 11 of of each each year year.. The report shall The report shall include include aa summary summary of of the the quantities quantities of radioactive liquid of radioactive liquid and gaseous effluents and gaseous effluents and and solid solid waste released waste released from from thethe unit unit.. The material provided The material provided shall shall be be consistent consistent with with the objectives outlined the objectives outlined in in the the ODCMaDCM and and process process control program and control program and inin conformance conformance with with 10 10 CFR CFR 50 .36a and 50.36a and 10 10 CFRCFR Appendix I, 50, Appendix I, Section Section IV .B .1 .
IV.B.l.
55.6.4
.6 .4 Deleted Deleted 55.6.5
.6 .5 Core Operating Core Operating Limits Limits Report Report (COLR) tCOLR)
- a. Core operating Core operating limits shall be limits shall be established established prior prior to to each each reload reload cycle, cycle, or or prior prior to to anyany remaining remaining portionportion of of aa reload reload cycle, and shall be documented in the COLR for the cycle, and shall be documented in the COLR for the following :
following:
1)
- 1) LCO LCO 3.2.1, 3 .2 .1, Average Average Planar Linea Planar Linear Heat at Generation Generation Rate Rate (APLHGR),
(APLHGR),
2)
- 2) LCO LCO 33.2.2, .2 .2, Minimum Critical Power Minimum Critical Power Ratio (MCPR),
Ratio (MCPR),
3)
- 3) LCO 33.2.3, LCO .2 . 3 . Lin a r Heat Linear Heat Generation Generation Rate Rate ((LHGR),
LHGR) ,
4)
- 4) LeO 3.2.4, Fraction of Core PBoiliR9 e i ~ ij~t BouAdary IQ, i m od a ity ((FGBB),
F G 81 LQI )
5)
- 5) LCO LCO 33.3.1.1,.3 . 1 .1, RPS RPS Instrumentation, Instrumentation, Table Table 33.3.1.1-1
.3 .1 .1-1 ffUAction 1 i 19 tc i H 2.d, aAd A
6)
- 6) ~ nR 1~ sz 1 .1 "1 (continue RA ~D GULF GGRAND GULF 55.0-18
.0-18 Amendment No Amendment No.. +§..7.,
15 ;, -+/-:6:t:::. __
Attachment .33 to Attachment to GNRO-2009-00054 GNRO-2009-00054 age 20 Page 20 of of 20 20 Reporting Requ Requirements eats 5 .6 5.6 5 .6 5.6 Reporting Reporting Requirement Requirements 5.6.5 Core Opera .t.inq Limits Operating Limits Report Report (COLRY (continued)
(COLR) (continued) 21..
21 NEDE-33383-P, "GEXL97 Correlation NEDE-33383-P, "GEXL97 Applicable to Correlation Applicable to ATRIUM-ATRIUM-100 Fuel Fuel,"" Global Global Nuclear Nuclear Fuel Fuel..
22 22.. EMF-CC 074(P)(A), Vol EMF-CC-074(P)(A), Volume 4. "BWR Stability Analysis Assessment Assessment of of STAIF STAIF with with Input Input from from M1 ROBURN-B2,
MICROBURN-B2",
Siemens Power Corporation, Richland WA.
Siemens Power Corporation, Richland, EMF-2292(P)(A>, "ATRIUM-10
- 23. EMF-2292(P)(A), "ATRIUM-10 Appendix Appendix KK Spray Spray Heat Heat Transfer Coefficients",
Transfer Siemens Power Coefficients, Siemens Power Corporation, Corporat Richland . WA Richland, WA..
24..
24 NEOE-24011 -P-A, General Electric Standard NEDE-24011 Standard Application for Reactor Fue (GESTAR for Reactor Fuel (GESTAR-11) .
1 ~ II) .
- c. The core The core operating operating limits shall be limits shall determined such be determined such thatthat all all applicable limits applicable limits (e.g., fuel thermal (e .g ., fuel mechanical limits, thermal mechanical limits, core car hydraulic limits, thermal hydraulic thermal limits, Emergency emergency Core Cooling Systems Core Cool (ECCS) limits, nuclear (ECCS) limits, limits such nuclear limits such as as SDM, transient analysis SDM, transi limits, and accident analysis limits) limits, and accident analysis limits) of the safety of the safety analysis analysis aree met.
me dd.. The The COLR, COLR, including including any any midcycle midcycle revisions reV1S1ons or sup or supplements, eat shall shall be be provided provided upon upon issuance issuance for each reload for each reload ccycle to to the NRC.
25 . NEDO-31 NEDO-31960-A, "BWR 11BWR Owners' Owners' Group Long-Term Stability Group Long-Term Solutions Stability Solutions Licensi Licensing Methodology" Methodology"
- 26. NE "Reactor Stability 0-32465-A, "Reactor NEDO-32465-A, Detect and Stability Detect and Suppress Solutions Suppress Solutions tic n ing Basis Licensing Methodology and Basis Methodology and Reload Reload Applications" Applications" GRAND GULF LF 55.0
.0-21 21 Amendment Am endmen t No No.. ~,
.p.J. J -::::tt:9::- __
ATTACHMENT ATTACHMENT 4 4 GN RO-2009-00054 GNRO-2009-00054 DRAFT DRAFT MARKED-UP MARKED-UP TECHNICAL SPECIFICATION BASES TECHNICAL SPECIFICATION BASES PAGES PAGES (FOR (FOR INFORMATION INFORMATION ONLY)
ONLY)
Attachment Attachment 4 4 to to G N RO-2009-00054 GNRO-2009-00054 Page 1 Page 1 of of 49 49 BB 33.2
.2 POWER POWER DISTRIBUTION DISTRIBUTION LIMNSLIMITS BB 33.2.4
.2 .4 Fraetiefl of Cor@ Boi1i"9 Doutida,y (FEBD)
BACKGROUND GeAeral DesigA Criterion 12 re~uire5 ~rotection aof fuel U-@
thermal safety limits from cOflditiofls caused by neutroftic/t~erffial hydraulic instability. Neutronic/thermal-hyclraul i c i Mstabi 1; t; es t @~ul tit' "OW@I osc; 11 at; ons w+ri-eh eo U 1d res u1 t i fl ex c eed; M9 the ~1 CPR Sa f etje Lim i t (S L). ++te HCrR SL eA5ures that at least 99.9% of the fuel rods avoid
~ 01*1*1ngran51 t *t*lonurlMgd
- normal operation and duriMg~ aM anticipated operatio"al OCCUII @llce (ADO) (ref@1 to tl,@ Bases for SL 2.1.1.2).
pr 'a
¬trek--
e s
d 1 am-d-*L.1°ra-re e e,n U a I t e!S ,4 :1.6@ A PQ F-, w (cofttiflu@d)
GRAND GRAND GULF GULF BB 33.2-12
.2 - 12 LDC 98037 LDC 98037
Attachment Attachment 44 to to GNRO-2009-00054 GNRO-2009-00054 F&BB B 3.2.4 Page Page 22 of of4949
&A5f5 ur -
Q A C. F_ ~
%li L e m t 4 iq IU (continued)I I I LA I - , U
- ' )
PPL APPLICABLE Q! T~e analytical method! and a!!umptions u!@d in @!tabli!hing SAFETY ANALYSES 6A .=:xU Mi li- 1 . . a bi a I U!~
rlIlrl Ili IF-S 4:6 t~e boiling
". . e 11 , 414mg 1 1 011M .' ary limit 6boundary 4 t are are pr s mted presented I - 4in I m e" r-Section I) --1 . 9 of
- 11 1 11 Reference l7 Operation wit~ t~e FCBB s 1.0 (i .e., a bulk saturated boiling boundal) 24 feet) is @x~@ct@d to en5Ute 4
- t~at operation rp, r a- i o m w t, within it ;t: 161 i m the
- b 16. , RXR@st, t
- b I- 4.ieted R@gion 1 0, blql w will 41 31 11 Iqlnot, VA ; ,-I r L@sult a t tt ii I,M moub, MeutroMi vi, i ecltl.er
., bije, mu malI --I,ydl L-pl
,yu,.-auaullic i c 4mt :~a6414 iI ,,~tabi
~, Lj I 1 I iI :~y ty u due- :~to Atj 11 I-0 eii1 A:th@r'
- 1. -
--1 steady Ay - tstate
- l: a e tptra ope' ationnor as the rresult 0\ astl+le t1l1 4:11 (54of1 6M an rlxAAGO Qv which iMitiat@s and terminates entirely within the R@strict@d Region. Analysis I - _*1 0 ualso 11 50 C-0 confirms that AGOs initiated f-r-o-m outside t~e Restricted Region (i ..e., f! . , without an initia~
R restri eti on et t r i 't, 41 0 n 0" FCOO) whi el, tel mi "ate e 41i -11 I' ;611 tll@
'M[ M= R@!t, @_ Ist'r 41i eet@d d Reg i e fI are "0 t ex/\Fu\""Uu pected to, "V @ 5 U 1 I =--,U . I, t i "
Ill i " stab 111 .3"uijl 1 1 4i 1 1 4i ty . TI. Ill e ty 11 p@ S of transients f5sp@cifically p - e- a "I11I y 0evaluated v a 'I tt-utterd are 1055 of flow and coolant temperature decrease which are limiting fOl the ORset of instability (R@f. 1).
NRC Policy Statement.
- II (continued)
GRAND GULF QEj 3.2 B ::z~ . 0ZZ - 13~) LOG 98037 Q 0 Q::~ :7
Attachment Attachment 4 4 toto F-BB GNRO-2009-00054 GNRO-2009-00054 Page Page 3 3 of 49 of 49 B 3.2.4 BAS'E-S BA&E5 m ;:b 41mtitd)
(ceMtiliu@d) k'e-APPI 1 G 4, D- I~
l\PPLICAB
- 1. 1 .11, LITYv Tlge FESS limit is au~~d -t e pr to l'Ievel,t v Mt cOle cOI,ditions I,ecessaly for f a r tttete Oflset 16, M s e t aof
- 4. ii I'lstabi M 5t. a b i 11 i4by 1 i ty ar,d tl,el eb) pi @el ude 1geutreFli c/tn@fmal -I,)d, aul1 ii Cc i "stab; 1; ty wi,; 1 e opel at; ng i-n the Restricted Regiol'l Q-4 111~j 4 pp defined A" 4 meA 1A - I u in4 m I COLR.
t~e r-O'
, u , R-.
pewei-Region 1\,:: !3 lull 'Boundary 44C*- .L . .- 99 eted eted Pi eted 0 R, s ;t i.- 4. 1-t -ad (c6t'ltil9ued)
RANO GUI-F GRAND GULF I Qr- QQO::Z LOG ILI, 98037:7 "I'v"
Attachment Attachment 4 to 4 to GNRO-2009-00054 GN RO-2009-00054 F&B-B B 3.2.4 Page Page 4 of 49 4 of 49 r r r APPLIC/\BI Ctl I
t'11RT1LITY TT Operation outside tMe Restricted Re§io~ is ~ot (continued) susceptible sHse 't'.4164e to fl@utroflic/tRelffial Ryd, aulic ili3tability ~
a pp1 i cab1e the r ffi alp 0'04 e r dis t fib uti en 1i fft i t:s 3 U eh f1 ~ t1 CPR are Fflet.
ACTIONS
,14 ; , ; . y f a. r e i i l- -.
d w
r P eti s -lea 1 ",r r
~~"""""~A--'lF-tGHill---+l\o~~~""'d Re g:; 0 " 61e to @I'ltry was cO~5i st@"t w4-H1 fer e"t,) wag ,eeog,,:; fed ~
~~~~~~~~~~d a~d k~OWM to Mot
." r r- ;4 n 4: 1 Y AetioRS to exit the
~~r-R--~Iiiil--jiiPR-Ri~~~ e 'yiR e ~ Fe BB C B rl Mot b@
n F sen-e (coAtinl-AQd)
GRAND GULF 8 3.2 15 LDG 98037
Attachment Attachment 44 to to F&B-B GNRO-2009-00054 GNRO-2009-00054 B 3.2.4 Page 55 of Page of 49 49 A r-:~ G*S ACTION5 I
B.1 a19 aAd B.2
-4 Q (cofltiftuee) d r .6. a , 4, m,,
t g ar P
. le - 1, A 1A -
e e l n in 4m f aAwatfarr t fflpepaie n p t i ffl p d, e w n s .6. 4 14 :t, lb --
ral v a , v e I s u re ( s mi a4 ,
5i gmil H. eamt )
4
" 41 '1: th e IR @ 5t i- i e ttd I~imiulail d Th.
1 . ;, Pffl-a-1 I-G-1 M eH n t-e d 11 s e-f t e t r a i efttY1 f+
1 d 4 n, evemt G-1 a m d i t on 4. d 1 ss 4 me ees a rly 5 I II I, D 7-M d
(COllti k I.-Ul I k, I Hued)
I I U GRAND GULF B 3.2 16 LOG 98037
Attachment Attachment 4 to 4 to F&&B GNRO-2009-00054 GNRO-2009-00054 B 3.2.4 Page Page 6 6 of of 49 49 AG:~
ACT Ii-O4S O~~ S B.l and B.2 nnvy t 7 (coAtiAued)v+rrnr, Exit of the Restricted RegioM caM be accoffiplish@dd by contro~
rod insertion aAd/or recirculation flow iMcreas@3. ActioAS to restartt an idle1 recirculation I"1 Vh fS l^
t
'S h h V1 "1 ~
l LS I"f n '7 L+l h1 r l "R 1
t
`1 A
n loop, withdraw cOMtrol rods 1 8 7 t or reduce recirculation flow ffiay result iM approaeh iM 9 unstable reactor conditioAS and arc not allolvcd to be used to comply \/ith this Required Action. The tiffie required to exit the Restricted RegioM will depend OM existiMg plaMt conditions. Provided efforts are begun without delay and continued until the Restricted Region is exited, operation is acceptable.
SURVE ILLl\NCE ~ 3.2.4.1 REQUIREMENTS 5 af ety a19 a1:)' 5 is.
~~~~oR-R---R-FH+R~~~-fR+~~~~~~~d to ens u re t hat
~~-W-+-+-f-~~+-+-F~~~~~~R--I~0I.fR00M-+--~~F-f'H"~~~F-T-fiW"t s operation.
d (eolititiued)
GRAND GULF B 3.2 17 LOG 98037
Attachment Attachment 44 to to F-&8 G N RO-2009-00054 GNRO-2009-00054 B 3.2.4 Pagee 77 of of 49 49 A5 SURV[ I LL/\NCE ~ 2-:A-:1 3.2.4.1 ',e- iqt-AHqiie4j (coAtiAued)
RtQUIRE;M[NTS C Iiin17P`'I 111 KWP t/\
d REFERENCES h ~J[DO 32339 l\, '--f'~~R-P-~~*~*-+-Y L019g Terffi Sol uti Oft:
E:nhal9ced Optiol9 I A".
GRl\ND GUL~ B 3.2 18 )P 9g0~7 LOG 99P
Attachment Attachment 44 to to GNRO-2009-00054 GNRO-2009-00054 RPS RPS Instrumentation Instrumentation Page Page 88 of of 49 49 .3-1 .1 BB 33.3.1.1 BASES BASES APPLICABLE APPLICABLE 1l.a.
.a . Intermediate Intermediate Range Monitor Monitor (IRM) fIRM) Neutron Neutron Flu Flux--High SAFETY ANALYSES, SAFETY ANALYSES, (continued)
(continued)
LeO, and LCO, and APPLICABILITY APPLICABILITY unexpected reactivity unexpected reactivity excursions excursions.. In In MODE MODE 1, 1, thethe APRM APRM System, the System, the rod withdrawal limiter rod withdrawal limiter (RWL),
(RWl), and and the the RPCRPC protection against provide protection provide against control control rod withdrawal error rod withdrawal error events and events and the IRMs are the IRMs are not required..
not required 1I.b.
.b . Intermediate Range Intermediate Range Monitor-In Monitor--Inop This trip This trip signal signal provides assurance that provides assurance that aa minimum minimum number number of of IRMs are OPERABLE.
IRMs are OPERABLE . Anytime Anytime an an IRM IRM mode mode switch switch is is moved moved to to any position any position other than "Operate,"
other than "Operate," the the detector detector voltage voltage drops below drops below aa preset preset level, level, or module iiss not or aa module not plugged plugged in, in, an inoperative an inoperative triptrip signal signal will will be be received received by by thethe RPSRPS unless the unless IRM is the IRM 1s bypassed bypassed.. Since only one IRM Since only IRM in in each trip system may system may bebe bypassed, only one bypassed, only one IRM IRM in in each each RPSRPS triptrip system may be inoperable without resulting may be inoperable without resulting in an in an RPS RPS trip trip signal signal.-
This Function This Function waswas not not specifically credited in specifically credited in thethe accident accident analysis, but analysis, but itit is retained for is retained for the RPS as the RPS as required by by the NRC approved NRC licensing basis approved licensing basis..
Six channels channels of Intermediate Range of Intermediate Monitor-Inop with Range Monitor--Inop with three channels in channels in each trip system are each trip are required required to to be OPERABLE to to ensure ensure that that no single instrument no single failure will instrument failure will preclude preclude a a scram scram from this Function from this Function on on aa valid valid signal signal..
Since this Since this Function Function 1s is not not assumed assumed 1n in the the safety safety analysis, analysis, there is no Allowable Value for this there is no Allowable Value for this Function Function. .
This Function This Function 1s is required required to to be be OPERABLE OPERABLE wh whenn thethe Intermediate Range Intermediate Range Monitor Monitor Neutron Neutron Flux--High Flux-Hig FunctionFunct i on is i s, required..
required 2 .a . Average 2.a. Average Power Power Range Range Monitor Monitor Neutron Fl ux- H=
Neutron Flux-High, Setdown Setdown The APRM chaAnels recei~e input signals from t~8 10ta1 power range MOAiters (lPRMs) w1t~iA t~e reactor core to provide aR indication of the peweF ~1strlbyti9n aRd 19ca1 power changes. The APRM chaRRels a~erage t~8S8 lPRM sigRals to provide a continuous 1A~1cati9A of a~erage reactor power INSERT A - APRM Subsystem Description ( continued continuedl GRAND RAND GULF GULF 8 3.3-6 B 3 .3-6 Revision No.
Revision No . 0
Attachment 4 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 9 9 of of 49 49 INSERT INSERT A A- - APRM Subsystem Description APRM Subsystem Description Average e Power Power Range Range MonitorMonitor (APRMl The The APRM APRM subsystem subsystem provides provides the primary indication the primary indication of of neutron neutron flux flux within within the the core and core and responds responds almostalmost instantaneously instantaneously to neutron flux to neutron flux increases increases.. The APRMs receive The APRMs receive inputinput signals signals from the local power range monitors {LPRMs} within the reactor core to provide an indication from the local power range monitors (LPRMs) within the reactor core to provide an indication of the power of the distribution and power distribution and local local power power changes.
changes. The The channels channels average average these these LPRM LPRM signals signals to to provide provide a a continuous continuous indication indication of of average average reactor reactor power power fromfrom a a few percent tto few percent greater greater than than RTP.RTP . Each Each APRMAPRM also also includes includes an Oscillation Power an Oscillation Power Range Range Monitor Monitor {OPRM}
(OPRM)
Upscale Function which Upscale Function which monitors monitors small small groups groups of of LPRM LPRM signals signals to detect thermal-hydraulic to detect thermal-hydraulic instabilities.
instabilities.
The The APRM APRM subsystem subsystem is is divided divided into into four four APRM/OPRM APRM/OPRM channels channels and and four four 2-Out-Of-4 2-0ut-Of-4 Voter Voter channels. Each APRM/OPRM channel provides inputs to each of the four voter channels .
channels. Each APRM/OPRM channel provides inputs to each of the four voter channels.
The The four four voter voter channels channels are are divided divided into into two groups of two groups of two each, with two each, with each each group group of of two two providing inputs providing inputs to to one one RPS RPS triptrip system.
system. The The system system is designed to is designed to allow allow oneone APRM/OPRM APRM/OPRM
- channel, channel, but but no no voter voter channels, channels, to to be be bypassed.
bypassed . A A trip trip from any one un-bypassed from anyone un-bypassed APRM/OPRM APRM/OPRM channel channel will will result result in in a a "half-trip" "half-trip" in all four in all four of of the the voter voter channels, channels, but but nono trip trip inputs to inputs to either either RPS RPS trip trip system system.. Since Since APRM Functions 2.a, APRM Functions 2.a, 22.b,
.b, 2.d, 2.d, and and 2.f are 2.f are mplemented in implemented in the the same same hardware, hardware, these these functions functions are are combined combined with with APRM APRM Inop Function Inop Function 2 .c. Any Function 2 .a, 2.b, 2 .c, or 2.d trip from any two unbypassed APRM/OPRM channels 2.c. Any Function 2.a, 2.b, 2.c, or 2.d trip from any two unbypassed APRM/OPRM channels will will result result in in aa full full trip in each trip in each of of the the four 2-Out-Of-4 Voter four 2-0ut-Of-4 channels, which Voter channels, which in in turn turn results results in in two two trip inputs to trip inputs to each each RPS RPS triptrip system system logic logic channel channel (A1, (Al, A2, B1, and A2, B1, 132) . Similarly, and B2). Similarly, anyany Function 22.d Function .d or or 22.f.f trip trip from from anyany twotwo unbypassed unbypassed APRM/OPRM APRM/OPRM channels channels will will result result inin a a full full trip trip from from each each Voter channel . Three Voter channel. Three of of the four APRM/OPRM the four APRM/OPRM channels channels and and allall four four ofof the the voter voter channels channels are required to are required be OPERABLE to be OPERABLE to to ensure ensure that that no no single single failure failure will will preclude preclude a a scram on a valid signal . In addition, to provide adequate coverage of the entire core, scram on a valid signal. In addition, to provide adequate coverage of the entire core, consistent consistent with with thethe design design bases bases for for APRM Functions 22.a, APRM Functions .a, 2.b, 2.b, and 2.d, at and 2.d, least 20 at least 20 LPRM LPRM
- inputs, inputs, with with at at least least three three LPRM LPRM inputs inputs from from each each of of the the four axial levels four axial levels atat which which the LPRMs the LPRMs are are located, located, must must be operable for be operable for each each APRM/OPRM APRM/OPRM channel. channel . For For the the OPRM OPRM Upscale, Upscale, Function Function 22.f, .f, LPRMs LPRMs are assigned to are assigned to "cells" "cells" of detectors . A four detectors.
of four A minimum minimum of of 30 30 cells, cells, each each with with a a minimum minimum of of two two LPRMs, LPRMs, must must be OPERABLE for be OPERABLE for the the OPRM Upscale Function OPRM Upscale Function 2.f 2.f to to be be OPERABLE .
Attachment to 4 to GNR4-2009-00054 GNRO-2009-00054 RPS Instrumentation RPS Instrumentation Page Page 10 10 of of 49 49 BB 3.3.1.1 3,3 .1 .1 BASES BASES APPLICABLE APPLICABLE 22.a.
.a . Average Average Power Power Range Range Monitor Monitor Neutron Neutron Flux-Flux--High.
SAFETY ANALYSES, SAFETY ANALYSES, Setdown (continued)
Setdown (continued)
LCO, LCD, and and APPLICABILITY APPLICABILITY from a few percent to greater than RTP. For For operation operation at at low power low power (i (1.e., MODE 2),
.e ., MODE Average Power the Average 2), the Power Range Range Monitor Monitor Neutron Neutron Flux-High, Flux--High, SetdownSetdown Function Function is is capable capable ofof generating a trip signal that prevents fuel damage resulting generating a trip signal that prevents fuel damage resulting from abnormal operating from abnormal operating transients transients in in this this power power range range. . For For most operation most operation at at low low power power levels, the Average levels, the Average Power Range Power Range Monitor Neutron Monitor Neutron Flux-High, Setdown Function Flux--High, Setdown Function willwill provide provide aa secondary scram secondary scram to to the Intermediate Range the Intermediate Range Monitor Monitor Neutron Neutron Function because Flux--High Function Flux-High because ofof the the relative setpoints .
relative setpoints.
With With thethe IRMs IRMs at Range 99 or at Range or 10, 10, it it is is possible possible that that thethe Average Power Average Power Range Range Monitor Monitor Neutron Neutron Flux-High, Setdown Flux--High, Setdown Function will Function will provide provide the primary trip the primary signal for trip signal for aa corewide corewide increase in increase in power power..
No No specific specific safety safety analyses analyses take take direct direct credit for the credit for the Average Power Range Monltor Average Power Range Monitor Neutron Neutron Flux-High, Flux--High, Setdown Setdown Function . However, Function. However, this this Function Function indirectly indirectly ensures that, ensures that, before before the the reactor reactor mode switch is mode switch is placed placed in the run in the run position, position, reactor reactor power does not power does exceed 25%
not exceed 25% RTP (SL 22.1.1.1)
RTP (SL .1 .1-1) when operating at when operating low reactor at low reactor pressure pressure and low core and low core flow flow..
Therefore, Therefore, it it indirectly indirectly prevents fuel damage prevents fuel damage during during significant reactivity significant reactivity increases with THERMAL increases with POWER THERMAL POWER
<< 25%
25% RTP.
RTP.
The APRM System ;9 d;vided ;nto two groups of eh8"nels with fo~r APRM ehannel inputs to each trip system. The system ;5 designed to allow ofte ehannel in each trip system to be bypassed. Anyone APRM channel 1n a trip system can cause the associated trip system to trip. Six channels of Average Power Range Monitor Neutron Flux==High, Setdewn, with three chlnnels 1n each trip systell are re~uired to be OPERABLE to ensure that no single failure will preclude a seram from this Function on a valid signal. In addition, to provide adequate eaverage af the entire eare, at least 14 LPRM i"p~ts Ire requ;red far eleh APRM ehannel, with at least twa lPRM ,nputs fram each of the feur axial levels at which the DOMS are leeated.
ILPRMs 9.1 .. - lee& ted .
The The Allowable Allowable Value Value is is based on preventing based on preventing significant signifi ant increases in power when THERMAL POWER increases in power when THERMAL POWER isis << 25%
25% RTP-RTP.
(continued)
GRAND GRAND GULF GULF BB 3.3-7 3 .3-7 Revision Revision No. No . 0 0
Attachment to 4 to GNRO-2009-00054 GNRO-2009-00054 Page Page 11 of 49 11 of 49 RPS Instrumentation RPS Instrumentation 3 .3 . 1 .1 B 3.3.1.1 BASES BASES APPLICABLE APPLICABLE .a . Average 22.a. Average Power Power Range Range Monitor Monitor Neutron Neutron Flux-High, Flux--High, SAFETY ANALYSES, ANALYSES, Setdown (continued)
Setdown (continued)
LCO, LCO, and and APPLICABILITY APPLICABILITY The Average The Average Power Power Range Monitor Neutron Range Monitor Neutron Flux-High, Flux--High, Setdown Setdown Function must be Function must be OPERABLE during MODE OPERABLE during MODE 22 when when control control rods rods may may be be withdrawn since the withdrawn since for criticality potential for the potential criticality exits exits..
In In MODE MODE 1, 1, the the Average Average Power Range Monitor Power Range Monitor Neutron Neutron Flux-High Flux--High Function provides protection Function provides protection against against reactivity reactivity transients transients andand the the RWL and RPC RWl and RPC protect protect against control rod against control rod withdrawal withdrawal error error events events..
2.b. Average Power Range Monitor Fixed Neutron Flux--High The APRM thl""els prev;de the p~ima,y iAGieatioA of neutron fl~x within the. eare and respend almest instantaneously te "e~tren fl~x ;nerease5. The Average The Average Power Power Range Range Monitor Monitor Fixed Fixed Neutron Function is Flux-High Function Neutron Flux--High is capable capable of of generating generating aa trip signal to trip signal to prevent prevent fuelfuel damage or excessive damage or excessive RCSReS pressure pressure.. ForFor the overpressurization protection the overpressurization analysis of protection analysis of Reference Reference 2, the Average 2t the Power Range Average Power Range Monitor Monitor Fixed Neutron Fixed Neutron Flux--High Function 1s Flux--H1gh Function i s assumed to terminate assumed to terminate the main steam the main steam isolation valve (MSIV) closure event and,t along with the isolation valve (MSIY) closure event and along with the safety/relief valves safety/relief (S/RVs), limits valves (S/RVs), limits the the peak peak reactor reactor pressure pressure vessel vessel (RPV)
(RPV) pressure pressure to to less less than than the the ASME Code ASHE Code limits . The control rod drop limits. The control rod drop accident accident (CRDA)
(eRDA) analysis analysis (Ref (Ref.. 7) takes credit
- 7) takes credit for for the the Average Average Power Power Range Monitor Range Monitor Fixed Neutron Fixed Neutron Flux-High Flux--H1gh Function to terminate Function to tenminate the CROA .
the eRDA.
The APRM System is divided into two groups of eha"nels with faur APRM ehan"els t"~uttt"g to eaeh trip system. The .
system ;s designed to allow en. ehann.l 1" each trip system te be bYpassed. Any ene APRM ehaftnel in a trip systeM eaR eaus. the associated trip systeM to trip. Six eha""els ef Ayerage Power Range Moniter Fixed Neutron Flux--High with three ehannels in eaen trip systeM apranged 1" a ene eut of three legle are reqHired te be OPERABLE te eASH,e that no single instrument failure* will ppeel~de a seram frsm thiJFunetien Oft a valid 9ignal. In addition, to prsv;de adequate (overage of the entire eere, at least 14 LPRM
- "P~ts are required fer eaeh APRM channel, with at least twe LPRM ;np~ts frOM 8ath af the feur axial levels at w~1ch the LPRMs are leeated.
The The Allowable Allowable Value Value is is based based on the Analytical on the Analytical Limit Limit assumed assumed inn the eRDA analyses.
the CRDA analyses .
(continued)
GRAND GULF GRAND GULF 8B 3.3-8 3 .3-8 Revision Revision No. No . 00
Attachment 4 to to GNRO-2009-00054 GN RO-2009-00054 Page 12 Page 12 of of 49 49 RPS RPS Instrumentation Instrumentation
.3 . 1 .1 BB 33.3.1.1 BASES BASES APPLICABLE APPLICABLE 2.b. Average Power Range Monitor Fixed Neutron Flux--High SAFETY ANALYSES, SAFETY ANALYSES, (continued)
LCO, and LCO, and APPLICABILITY APPLICABILITY The Average The Power Range Average Power Range Monitor Monitor Fixed Fixed Neutron Neutron Flux-High Flux--High Function Function is is required required to to be be OPERABLE OPERABLE inin MODE MODE 11 where where thethe potential potential consequences consequences of of the the analyzed analyzed transients transients could could result result 1n i n the the SLs SLs (e .g ., MCPR (e.g., ReS pressure) and RCS MCPR and pressure) being exceeded. Although the exceeded . Although Average Power the Average Power Range Monitor Fixed Range Monitor Fixed Neutron Flux-Nigh Neutron Function 1s Flux--H1gh Function i s assumed the eRDA assumed iinn the CRDA analysis analysis that 1s that applicable in i s applicable MODE 2, i n MODE 2, the the Average Power Range Average Power Range Monitor Neutron Monitor Neutron Flux-Nigh, Flux--H1gh, Setdown Setdown Function conservatively Function conservatively bounds bounds thethe assumed assumed trip and, together trip and, together with with the the assumed assumed IRM I trips, provides trips, provides adequate protection.. Therefore, adequate protection Therefore, the AveragAverage Power Monitor Power Fixed Neutron Monitor Fixed Neutron Flux-High Function iis Flux--High Function s not not required required iinn MODE MODE Z2..
2.e. Average Power Range Monitor--Inop his Function was not specifically credited i n the accident analysis, but i t i s retained for the RPS as required by the NRC approved licensing basis .
Six ehannels af Average Pewe, Range Men1ter==Inep with three eh~nne1s ;n each trip '1st** are required to he OPERABLE to ensure that no 9;",1. failure w;ll preel~d. a seraM frOM this Funetian an a yalid signal.
There is There no Allowable i s no Allowable ValueValue for for this Function..
this Function This Function This Function 1s i s required required to be OPERABLE to be OPERABLE iinn the MODES where the MODES where the APRM the APRM Functions Functions areare required required..
(continued)
GRAND GRAND GULF GULF 8B 33.3-9
.3-9 Revision No.
Revision No . 00
Attachment 4 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 13 of 49 13 of 49 INSERT INSERT B B Three Three ofof the the four four APRM/OPRM APRM/OPRM channels channels are are required required to be OPERABLE to be OPERABLE for for each each ofof the the APRM Functions. This Function (Inop) provides assurance that the minimum APRM Functions. This Function (Inop) provides assurance that the minimum number number of of channels channels is is OPERABLE OPERABLE..
For For any any APRM/OPRM APRM/OPRM channel, any time channel, any time its mode switch its mode switch is is in in any any position position other other than than "Operate,"
"Operate," a a module module is is unplugged, unplugged, or the automatic or the automatic self test system self-test system detects detects a a critical fault with critical fault with t APRM/OPRM the APRM/OPRM channel, channel, an Inop trip an Inop trip is is sent sent to to all four voter all four channels . Inop voter channels. Inop trips trips fr from two or more more unbypassed unbypassed APRM/OPRM APRM/OPRM channels result in channels result in aa trip output from trip output from all all four four voter voter channels channels toto their their associated associated trip trip system system..
Attachment Attachment 4 to 4 to RPS Instrumentation RPS Instrumentation GNRO-2009-00054 GNRO-2009-00054 B 3 B .3 .1 .1 3.3.1.1 Page 14 of Page 14 of 49 49 BASES BASES APPLICABLE APPLICABLE 2 2.d..d . Avera Average e Power Power Range Ran e Monitor Monitor Flow Flow Biased Biased Simula Simul SAFETY ANALYSES, SAFETY ANALYSES, Thermal Thermal Power Power -- Hi High LCO, LCO, and and APPLICABILITY The The Average Average PowerPower RangeRange MonitorMonitor Flow Flow Bias Bias d d Simulate Simulate (continued)
(continued) Thermal Power Power -- High High FunctionFunction monitors monitors ne tron flux netitron flux to to approximate approximate the THERMAL POWER the THERMAL POWER being being trans trans . erred erred to to the the coolant .
reactor coolant. The APRM neutron neutron flux flux ii electronically electronically filtered filtered with with aa time time constant constant representat representat ve ve of of the the fuel fuel heat transfer dynamics to generate a sign I proportional to heat transfer dynamics to generate a sign 1 proportional to the the THERMAL THERMAL POWERPOWER in in the reactor .
the reactor. The tr The tr level level is is varied varied as a function ction of of recirculation recirculation drive drive flow flow ~ iiss cl clamped amped at at an an upperupper limit limit thatthat is is always always lower lower than than the Average Power the Average Power Range Range Monitor Monitor Fixed Fixed Neutron Neutron Flux Flux -- High High Function Function Allowable Allowable Val ue ue . The Aver age Po \1 erRa t9 9 e ~4 a t9 ito r Flo 'i' Bi a 5 e d Si mu1 ate d Th ermal Po 'n' er - Ii i 9 A Fut'l C t i 0 t'l fo' r 0 v i cl ega 9 e fl era 1 definition of the liceRsed core power/core flow ope, ating domaifl.
The l\ v era 9 e Po 'n' erR a t9 9 e ~4 0 fl ito r Flo" Bi a s ecl Si mu1 ate d The FFflal Th rmal Po 'Ii era- H; 9 A Fu19 C t i 0 fl i S fl 0 t ass 0 cia ted wit M a Pewer limiting iilfflil ing safety saf y systcffiys :~, effl settiflg. Operatiflg 1limits i FR 4 esta-bli,sh establishedd for the 14 t1h licel9sed emse operatifl9 perat 4 A. .g domaifl are d'-..", are used uted to to de vel 0 p the A" era 9 e Po 'tv erRa Rang19 9 e M ~4 0 mi.
19 itotllarr Flo"f F! w B14 Bi agc d4 A Is@ UP Si ffi U 1 ate d The rmal Po ',f e r
- H, ~ i gh, .
4 9 h FFut' a ml e C't.: i4. a f1 m All
-A w aae 1e
~ 1 a ',t e VVal a ~ ttue ~ to
@ fs -LC 0 provide preemptive Freactor e a et- m--. serafR at'ld prevel9t revent qr grosss violation vi latien of the liceAsed operating domain. Operation outside tAe license operatiA9 dOfRain fRay result it'l at'lticipated operatioAal occurrences and postulated acciclct'lts ~
initiated froffi conditions beyoAcl tAo~e assumed in thesefety a na 1:)' 5 is. 0 per at ion ~., i t hi A the 1ice nsed 0 per a t i f1 9 do ffl a i n a 1 s a ens u res c 0 fA P1 i a t9 ce 'ft'i tAG et'l era 1 0es i 9 n CFiterio n 3::-2-;-
nen r-al 0-e-GeAeral ign Criterion DesigA n 112 :2 requires pequipes protection ofa fuel
-rateetia A: ; a th therffial safety ii--it ty limits I - frofR
-P Peffl e di,'Hans caused eot'lditions in eause by neutpeni, e/theeffial, -1tydrau neutroAie/therfRal Aydraulic li c iif1staeility.
I .iqQ.":~ a ~-41i :k y "1 11 Neutronic/thermal-hydraulic instabilities result ifl pO'ffer oscillations w+t+eh eeuld r-result could sult in iA e) l eeedif+g the MCPR SL.
e)(ceeding The apea The area ofof tnethe ecore r ppower wee an .. f! w apera afldflow operatifl9 : lbiftg domain
.4 1
sus ep ti, susceptibleI- e toe neutrot'lic/therma1 hydraulic instability 4AQ ;~064~44-- y ~
- - IUL, I I I %I e an be affected by reactor parafficters such 5ue, . as 6 as reactor- a et, 'A, inlet rj i All 31 et feed\~ater temperature (Ref. 12). T'tt'O compl ete at'ld (continued)
(continued)
GRAND GRAND GULF GULF BB 3 .3- 9a 3.3-9a LDC LDC 98037 98037
Attachment 4 to to GNRO-2009-00054 GNRO-2009-00054 Page 15 Page 1 5 of of 49 49 INSERT INSERT C C (i .e., at lower core flows, the setpoint is reduced proportional to the reduction in power experienced as core flow is reduced with a fixed control rod pattern) but INSERT D INSERT D The The APRMAPRM FlowFlow Biased Biased Simulated Simulated Thermal Thermal Power Power -- High High function function provides provides protection protection against against transients transients where THERMAL POWER where THERMAL increases slowly POWER increases such as slowly (such the loss as the loss of of feedwater feedwater heating event) and protects the fuel cladding integrity by ensuring that the MCPR SL is heating event) and protects the fuel cladding integrity by ensuring that the MCPR SL is not not exceeded exceeded.. DuringDuring these events, the these events, the THERMAL THERMAL POWERPOWER increase does not increase does not significantly significantly lag lag the the neutron flux response neutron flux and, because response and, because ofof a lower trip a lower setpoint, will trip setpoint, will initiate initiate aa scram scram before before the the high neutron high neutron flux scram. For flux scram. For rapid neutron flux rapid neutron flux increase increase events, the THERMAL events, the THERMAL POWER POWER lags lags the the neutron flux and neutron flux and the the APRM APRM Neutron Neutron Flux Flux -- High High function will provide function will provide a a scram scram signal signal before before the the APRM APRM Flow Flow Biased Simulated Thermal Biased Simulated Thermal Power Power -- High High function setpoint is function setpoint is exceeded exceeded..
Attachment Attachment 44 to to RPS Instrumentation RPM Instrumentation GNR(J-2009-00054 GNRO-2009-00054 B B 3.3.1.1 3 .3 .1 .1 Page Page 16 16 ofof 49 49 SASE BASES APPLICABLE PP 1 16 -A IQ, E ~ A Average PO'iter Raflge ~1oflitor Flo'" Biased Simulated tSAFETY ANALYSES, Thermal Power - H+/-gh (continued) e o m t: q. 1 lol LCO, and n
APPLICABILITY A nI T Tv i fldef)endent 3et3 of AverB9c POW@1 Ran9c ~iOI,i tor Flow Bi aged a Si muI1at fMt ate dd Tn e r mul I
- L Il L- rFM B1 P{}we, - II i 91 1 FU" c t i 0 " ,At 1 low a b1e VB 1 Ue!; may 3 I C'OW A31 r-l 1 1 e Vall ii may be sf)ecifiedd 4 in the COLR.
t G-1 9- 1 SjSet 1 (Nla
' 41:1 11 (Normal us mia 1 Tri. Trif)t) RRefereflce f v1 .
Set) provides protection agaiRgt n@utronic/th@fmal hyd\ aulic instability during @xp@ct@d }@BctO} opelating +I-tg condition!.
Set e t 2 (Alternate Trip
- 12 Tfi~ Re lereme-e S'-Set)
Refelence 4 tb) provides pi ptotection against neutronie/thermal hydraulic instability dUI ing 4: a 6
~
y reactor operating conditions requiring added stability g e- m d 4. s g a d d "d 4514 protection on and ig con3ervat;ve with l@~p@ct to Set 1.
t eomtervatbive Feedwater temperature values requiring tl an3ition between floww eamtr controll. tt , trip ' teference cald gets are specified in tne eteremee eal U P Ill COLR, when necessary. In the eveAt of a feedwater 1, . i:
I e4 f ed w- at e r temperature reducti 0", All owabl e Val U@ mod; f; eat; on t-f-r-offi the Normal Trip R@ference Set to tMe Altetnate f-r-:i-p T ri p R f er@mee t, :b Reference Set) as 5f'eci fi @d i " tile COLR i!; } @~ui ,ed to p in r-Q D 4 -
preserve the mar~iR associated ffith the ~oteMtial for the Oflset of fleutraMi cltne, mel =hydt aul i c ; },~tabi 1i ty wh+eh amset f M U*;pAA4 P 11 vil I It tlIIl:;I I U-1 C existed prior to the feeclwat@r t@m~@rature reductioM. ~
Allo\table Value modification r@~uired b; the COLR ma) be del a:t e eJ u p to 12 haur s to a11 0 w t ; me to ad j u ~ tea" den ee k t I*e adjustmeftt of cacR flo'" control trip refe, eMce ~ At tRe w eent"rel t: 11-41sp ref remele eftd of the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period, the Allowable Value modifications A4 Al I pw In I I v W u b+ e lla v 3I ti rm 41 41 41 e atb s must be com~lete for all of the requited channels 01 tne applicable COflditiofl(s) must be eMtered BI,d tMe Re~u;red ActioMS taken. TRe 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time period is aecel'table ~
et -Omt i tal , em . T-H. , 1322 Ll-.aur 4 tt aee r_": a,6 p 1+e bt-ted on the low probability of a flcutroMic/tRerma1 hydraulic probab.414ty lic Ilstall . I Ey CVCMt Bnd the continued plotection plovided by iflstability I
the
'El 16" flow a Mt r a trip refelence cald. 1ft addition, when the a w ecOfltrol 11 t -1 4. 4 r mee eard . Im ad 4. *14 OM feed\tater temf3erature reducti on re3ul t5 in ol'@rati on +n r e t u It ;It t1 4, Am vA Ap --- r, an 4, to) ~, n 1
Q R-e ei tner tMc Restr; cted Reg; at! at the r~{}\ii tat cd Re9i 01', tile 6 r 4: 6 e S :~ b. 4 01- . MOM41a r-ed v ivil, 4.1111=
4 requirements for the Period Based Detection System (LCO Cy a 3.3Gl.3, Period Based Detection SY3t@m (PODS)) plovide added t e e t+t),n m I U Lj V1 Ov I d d de~
f)rotccti on a~ai fl3t Meutl ani e/thel mal I.ydt eaul i c ; J,~teab; 1 i ty urn li c du, iM~ the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time period. t-+l The area of the core power and flow ope) ating domain THe area Of ;t .6. e e r lec!
suseef3ti bl e to flcutre}l'l; c/tnel mal =I'l,draul i c ; li5tabi 1 i ty h
!s e p t-4 affected b)' tMe value of Fraetiol, of Cote 80;li119 BouildalY 4feet,.ed by'y 4:
- 6 iraetion ur tore a-r-y F-r-QQ) and ( LCO 3. 2 *4, FeB B) (Re f. 12). " Set U f3 " aft d ne, mal ( "n 0 n k",v r- 0 ::Z :2 4 , , L, "I 4Q@f .
\1 I\ I "' ': up" Merflial 41 Setuf3") Aver age ra'vcN! r Ra nge ~1on i to r Flow Bi a ~@d 5 i mul Bt@d C .4:tj p "~ Ay @ rag@ 0 I
W I- Diatqps, I-Ail~j u I I I k'%j I F-lAii I I v" Lj I az>=u C4---184; j I Illu I %, d Thermal Power - IfigM FunctioM Allowable Valu@~ al e $p@cifi@d 1141 g 6 11 ~: tjMe :~4 1 L' I M I . mA13 I I Wa b4 e
- 19 the COLR.
(continued)
GRAND GULF B 3.3-9b LDC 9S037
Attachment Attachment 4 to 4 to RPS Instrumentation GNRO-2009-00054 RPS Instrumentation GNRO-2009-00054 B 3.3.1.1 B 3 .3 . 1 . 1 Page 17 of Page 17 of 49 49 BASES BASES APPLICABLE 2-:-6-: Av0 rag 0 P0'n' 0 r Rafl 9e ~4 0fl ito r Flo ',0' Bi as 0 cl Si mu1 ate d SAFETY ANALYSES, The r ffl alP 0 \v e r .. H4-§fl ( c 0 fl t i fl Ucd)
LCO, and
/\PPLIGABILITY The florffial1 ("190fl T L, I I I--- r"I F .M. I f
it rIFl-,j Setup") 'fal ue provi cles protecti on a~a; flst C .4-
'Cup n neutroflic/therffial fie 41:1 . -. . 1 1. .Herfflal - lq,ydrauil Aydraulic i C iNstability by provefltiflg p r a- 4. 4 - n ifl tMe ssusceptible operation : us e- 64e area of tAe o~erati~g domain W'h'heN
. . m operati r at, i. flg outsi cle tRe Restr; cted Regi Ofl spec; f; ed ffi tt:le GOLR 'n'; tt:l tAe rGBB 1 i fRi t flat reCfui roa to be fRet. Wfrefl the "Setup" ';a1 ue ; s sel ected, ffieeti ftg the FCBB 1 imi t provides protection agaiftst iftstability.
"Set" up afl a" RaRe S tup " va 1 ues are selected by operator maNipulation of a Setup buttOfl 019 eaCM flo" cOfltrol trip refereftce cara. Selectioft of the "Setup" value is iflteflcled val tie 1 5 imt mdAe-d only for planned operation ift the Restricted IQ, e stt.- 4 let -a d Re g 4, a m aas Regiofl Is s~ecifiocl ifl the COLR. Operation in ifl tho Resibr4e t
41 11 RostrictedA Region
- V' ed wlth the 1A - -Average-Average PPower w r Raigg Raflge MMOflitor I I 619 4 4:
I I E)j- FI Flow W
- Biaseda p,4 Simulated
\1 fflt ~ a d
+ r The I I rffi alP a
- 4 1 H a Wer
'ft er II W i 9 M 1 . :41 Ell I Fufl
~I dm C t i 0 fl "Sot 11 up" IA r e et uire s t fI e F C BB limit to be mot let amd-1 and 4is met -1 flOt gemerd~4y geflerally eam5i cOflsistel9t 5temt with 190rmal po ',i e r 0 per at i a A
- The Average Power Raflge MOflitor 4 ;~,:, p F- I Flow p I ;
Biased Simulated Qj ;a q - sA !Z4 m .-3 m t e ,A Tho r ffl alP 0'ft' 0 r II i 9h FUACt i 0fl us 0 sat rip 1 eve 1 9C fl C ratcd ~
tho floio' cOfltrol trip refereftcc card based OM ,ecirculation 4-4 I-_ loop drive flow. Proper trip level gefleration as a fUAction p r p p
-1 I_- v --
1
" -- I E,-1 V1 I U -)
of dr i ve flo 'h' r eCf Uire s cl r i ve flo 'v~ ali gfl me19 t . This ; s a! 4 gnffiemt' .
acc?m~lished by selectioA of appropriate dip switch pos1tl019S Oft the floio' cONtrol tri~ refereNce cards (Refer to SR 343.1.1.18). Chaflges iA the core flow to arive flow Hp eepe fUNctioNal relatioAship may vary over the core flow vapy Over operatiflg raN~e. These cRaNges caA result from botA graaual T
I ~,
I I a
- s- e- g r a '14, tj-&-l chal9ges iM recirculation system aRa core compONeNts over t~e &Ver t e reactor life time as well as s~ecific ffiaiRteflaNce performed on these components (e.g., jet pump cleal9ing). j et'. p a ea iq i iq a The APRM System is clivicled il9to two groups of chaAftels with four APR~1 i ApUts to caCM tri p s.:rstem. T~e system is
- E) ~jp APPM j jqM .,J:
e-H 6designed to allow OAe chaAlgel il9 each trip system to be g4anop - e 4jeW I eme e-Mannei In ea- M P
=11prip sy5telfflll bypassecl. AI9Y Ofle APRM chaflflel in a trip system eaft cause the associated ~rip system to trip. Six cRaftnelsof Average Po 'n' erR aAge ~~ 0 191 tor Flo 'h' Bi a 5 ccl Si mu1 ate d T19 er ffi alP owe r High with tMree chaftAels ift each trip system arranged in a (continued)
{continued}
GRAND GULF GRAND GULF B 3.3-9c B 3 .3-9c LDC 98037 LDC 98037
Attachment 44 to Attachment to RPS RPS Instrumentation Instrumentation GNRO-2009-00054 GNRO-2009-00054 BB 33.3.1.1
.3 .1 .1 Page 18 Page 18 of of 49 49 BASES BASES APPLICABLE ARP 1 A9 E ~ Average PO'hler RaFlge Monitor Flo'h' Biased Simulated SAFETY A~I!\LYSES,l AF T4 AWAI-42-E& Therffial POHer :; H-bth (conti nued)
~ i+l4 l\PPlIG,A,E3 APR CA --II lITY
!T-Y E)i;e eut f hr- e LPRMs ape
~PkMs are 19eat located.. EachEach APRM APRM channel channel one total drive flow drive flow signal signal representative representative of of total total core flow .
recirculationn 1loopP dFily, drive -1flow Hew signal signals are are generat generatedd flo un itsS .. 0ne flo 'h' U flit fro mea eAr eeire u1 at ionn 1 W'tJ uni.
provided to each APRM chanFlel. Total e :t a j drive flow is deterffiinod by each APRM by summing up the flow signals pravi dod to the /\PRM froffl the tHO reei reul ati on loops.
\VThe The THERMAL THERMAL POWER POWER time time constant constant based on the fuel heat transfer dynamics and transfer dynamics and provides provides signal proportional to the THERMAL THERMAL POWE POWER.
The The Average Average Power Power Range Range Monitor Monitor Flow Flow Biased Biased Si mul Simulated Thermal Thermal Power Power -- High High Function Function is is required required to to be be OPERABLE OPERABLE iin MODE 11 when MODE when there there is possibility of neutroftie/t~@rmal-the possibility is the hYdr-au!
hydraulic 4c instability.
ilms abil lilty . The The petent4-al potcfltial the SL applicable to high applicable high pressure pressure and and core core fl w w conditions CMCPR SL)
SL) ,
- y protect; 0,
~~~-+-+--FH~~TH-~~I-foIi+tTt-t--ftoIlHi-f''''~~~~'f't'"t-t-H" y eam Y ea FI (5 ee U1
- During MODES 2 and 5, OTHER IRM and APR and 5, OTHER IRM and APR unctions provide Functions provide protection for fuel fuel cladding integrity .
cladding integrity.
generating excessive THERMAL POWER and potentially exceeding INSERT G - New APRM Functions 2 .e and 2J (conti need )
(continued)
GRAND GRAND GULFGULF B 3.3-9d B 3 .3-9d LDC 98037 LDC
Attachment 4 toto 0 NRO-2009-00054 GNRO-2009-00054 Page Page 19 19 ofof 49 49 INSERT INSERT E E The total The total drive drive flow flow signal signal is generated by is generated by the the flow processing logic, flow processing logic, part part of of the the APRM/OPRM APRM/OPRM
- channel, channel, but but summing summing up up the flow calculated the flow calculated from from two two flow flow transmitter transmitter signalsignal inputs, inputs, oneone from from each of the two recirculation loop flows. The flow processing logic OPERABILITY is part of each of the two recirculation loop flows. The flow processing logic OPERABILITY is part of the the APRM/OPRM APRM/OPRM channel channel OPERABILITY OPERABILITY requirements requirements for for this this Function.
Function.
INSERT INSERT F F The clamped Allowable Value is based on analyses that take credit for the Average Power Range Monitor Simulated Thermal Power-High Function for the mitigation of the loss of feedwater heating event.
INSERT INSERT G G- New APRM
- New Functions 2.e APRM Functions 2.e and and 2J 2.f 22.e
.e 2-Out-Of-4 2-0ut-Of-4 Voter Voter The 2-Out-Of-4 Voter The 2-0ut-Of-4 Voter Function provides the Function provides interface between the interface between the APRM Functions, the APRM Functions, including including the OPRM the Upscale Function, and the OPRM Upscale Function, and the final final RPS RPS trip system logic. As such, it is required to trip system logic. As such, it is required to be be OPERABLE in the MODES where the APRM Functions are required and is necessary to OPERABLE in the MODES where the APRM Functions are required and is necessary to support support the the safety safety analysis analysis applicable applicable to to each each of of those Functions. Therefore, those Functions. Therefore, the 2-Out-Of-4 the 2-0ut-Of-4 Voter Function must Voter Function must be be OPERABLE OPERABLE in in MODES MODES 1 1 and and 2. 2.
All four All four voter channels are voter channels are required required to to bebe OPERABLE OPERABLE.. Each Each voter voter channel includes self-channel includes self-diagnostic functions.. If diagnostic functions any voter If any voter channel channel detectsdetects a critical fault a critical fault in its own in its own processing, processing, a a trip trip isis issued issued fromfrom that that voter channel to voter channel to the the associated associated trip trip system.
system.
The 2-Out-Of-4 Voter The 2-0ut-Of-4 Voter Function Function votes votes APRM APRM Functions Functions 2.a, 2.b, and 2.a, 2.b, and 2.d2.d independently independently of of Function Function 2.f. 2.f. The The voter voter also also includes separate outputs includes separate outputs to to RPS RPS for for the the two independently two independently voted voted setssets ofof functions, functions, each each of of which which is is redundant redundant (four (four total total outputs) outputs).. TheThe voter voter Function Function 2.e must be declared inoperable if any of its functionality is inoperable . However, due 2.e must be declared inoperable if any of its functionality is inoperable. However, due toto the the independent voting of APRM trips, and the redundancy of outputs, there may be conditions independent voting of APRM trips, and the redundancy of outputs, there may be conditions where where the the voter voter Function Function 2.e 2.e is inoperable, but is inoperable, but trip capability for trip capability for one one oror more more of of the other the other APRM APRM Functions Functions through through thatthat voter voter is is still still maintained maintained.. This This may may be be considered considered when when determining the determining the condition condition of of other other APRMAPRM Functions resulting from Functions resulting partial inoperability from partial inoperability of of the the Voter Voter Function Function 2.e 2.e redundant redundant (four (four total total outputs) outputs).. The The voter voter Function Function 2.e 2.e must must be be declared declared inoperable inoperable if any of if any its functionality of its functionality is is inoperable inoperable.. However, However, due due to the independent to the independent voting voting of of APRM trips, and the redundancy of outputs, there may be conditions where the voter APRM trips, and the redundancy of outputs, there may be conditions where the voter Function Function 2.e 2.e isis inoperable, inoperable, but but trip trip capability capability for for one one or or more more of the other of the other APRM APRM FunctionsFunctions through through that that voter voter is still maintained is still maintained.. This This maymay be be considered considered when when determining determining the the condition condition of of other other APRM APRM Functions resulting from Functions resulting from partial partial inoperability inoperability of of the the Voter Function 2.e.
Voter Function 2.e.
There There is is no Allowable Value no Allowable Value for for this Function .
this Function.
Attachment 4 to to -
GNRO-2009-00054 GNRO-2009-00054 Page 20 Page 20 of of 4949 2.f.
2.f. Oscillation Power Oscillation Power Range Range Monitor Monitor (OPRM) (OPRM) UpscaleUpscale The The OPRM OPRM Upscale Function provides Upscale Function provides compliance compliance with with GDCGDC 10 and GDC 10 and GDC 12, 12, thereby thereby providing providing protection protection from exceeding the from exceeding fuel MCPR the fuel MCPR safety limit (SL) safety limit (SL) due due to anticipated to anticipated thermal-hydraulic thermal-hydraulic power power oscillations oscillations..
References 13 References and 14 13 and describe three 14 describe three algorithms algorithms for for detecting detecting thermal-hydraulic thermal-hydraulic instability instability related neutron flux oscillations : (1) the Period-Based Detection algorithm ; (2) the Amplitude-related neutron flux oscillations: (1) the Period-Based Detection algorithm; (2) the Amplitude-Based algorithm; Based algorithm ; and and (3)(3) the Growth-Rate algorithm.
the Growth-Rate algorithm. All All three three are implemented in are implemented in the the OPRM OPRM Upscale Function, Upscale Function, but the safety but the analysis takes safety analysis takes credit credit onlyonly for for the Period-Based Detection the Period-Based Detection algorithm.
algorithm. The The remaining remaining algorithms algorithms provide provide defense-in-depth defense-in-depth and and additional protection additional protection against against unanticipated oscillations . OPRM unanticipated oscillations. OPRM Upscale Upscale Function Function OPERABILITY OPERABILITY for for Technical Technical Specification Specification purposes purposes is based only is based only on on the Period-Based Detection the Period-Based Detection algorithm algorithm.. The The Allowable Value for the OPRM Upscale Period-Based Detection algorithm is specified in Allowable Value for the OPRM Upscale Period-Based Detection algorithm is specified the in the COLR..
COLR The OPRM Upscale The OPRM Upscale Function Function receives receives input input signals signals fromfrom the local power the local power range monitors range monitors (LPRMs}, which (LPRMs), which are are combined combined into into "cells" "cells" for for evaluation evaluation by by the the OPRM algorithms.
OPRM algorithms.
The OPRM Upscale The OPRM Upscale Function Function is is required required to to bebe OPERABLE OPERABLE when when the plant is the plant is at at ~> 240/0 24% RTP, RTP, the the region region of of power-flow power-flow operation operation where where anticipated anticipated events could lead events could lead to to thermal-hydraulic thermal-hydraulic instability and instability related neutron and related neutron flux oscillations . Within flux oscillations. Within this this region, region, the the automatic automatic trip trip isis enabled enabled when when THERMAL THERMAL POWER, POWER, as as indicated indicated by by the APRM Simulated the APRM Simulated Thermal Thermal Power, Power, is is
~ 29%
290/0 RTP RTP and and reactor reactor corecore flow, flow, as as indicated indicated by by recirculation recirculation drivedrive flow, flow, isis << 60%
60% of rated of rated
- flow, flow, the operating region the operating region wherewhere actual actual thermal-hydraulic thermal-hydraulic oscillations oscillations may occur. The may occur. The lower lower bound, 24% RTP, is chosen to provide margin in the unlikely event of loss of feedwater bound, 240/0 RTP, is chosen to provide margin in the unlikely event of loss of feedwater heating while heating while the the plant plant is is operating operating below below the the 29%
290/0 automatic automatic OPRM Upscale trip OPRM Upscale trip enable enable point point.. Loss Loss of of feedwater feedwater heatingheating is is the the only only identified identified eventevent that could cause that could reactor power cause reactor power to to increase into increase into the region of the region of concern concern without without operator operator action action..
An An OPRM OPRM Upscale Upscale trip trip is issued from is issued from an an APRM/OPRM APRM/OPRM channel when the channel when the Period-Based Period-Based Detection algorithm Detection algorithm in in that that channel channel detects detects oscillatory changes in oscillatory changes in the the neutron neutron flux,flux, indicated indicated by the by the combined combined signalssignals of of the the LPRM LPRM detectors detectors in in aa cell, cell, with period confirmations with period confirmations and and relative relative cell amplitude exceeding cell amplitude exceeding specified specified setpoints setpoints.. One One oror more more cells cells inin a channel a channel exceeding exceeding the trip conditions the trip conditions will result in will result in aa channel channel trip trip.. An An OPRM OPRM Upscale Upscale trip trip isis also also issued issued fromfrom thethe channel channel if if either either the the Growth-Rate Growth-Rate or or Amplitude-Based Amplitude-Based algorithms algorithms detect detect growing growing oscillatory oscillatory changes changes in in the the neutron neutron flux flux for for one one or or more more cells cells in in that that channel channel..
Three Three of of the four channels the four channels are are required required to to bebe OPERABLE OPERABLE.. Each Each channel channel is is capable capable of of detecting detecting thermal-hydraulic instabilities, by thermal-hydraulic instabilities, by detecting detecting the the related related neutron neutron flux oscillations, and flux oscillations, and issuing issuing a a trip trip signal signal before before the the MCPR MCPR SL SL is is exceeded.
exceeded .
There There is is no no Allowable Allowable ValueValue for for this this function function..
Attachment 4 toto G N RC)-2009-00054 GNRO-2009-00054 Page Page 2121 of of 49 49 RPS RPS Instrumentation Instrumentation B3 .3-1-1 B 3.3.1.1 BASES BASES ACTIONS ACTIONS Times, specifies Times, specifies that once aa Condition that once Condition has has been been entered, entered, (continued)
(continued) subsequent divisions, subsequent divisions, subsystems, subsystems, components, components, or or variables variables expressed expressed in the Condition, in the Condition, discovered discovered to to bebe inoperable inoperable or or not not within within limits, limits, will will not not result result iinn separate separate entry entry intointo the the Condition Condition.. Section Section 1.3 also specifies 1 .3 also specifies that that Required Required Actions of Actions of the Condition continue the Condition continue to to apply apply for for each each additional additional failure, failure, with Completion Time with Completion Times based on initial entry entry into into thethe Condition Condition.. However, However, the the Required Required Actions Actions for for inoperable RPS inoperable instrumentation channels RPS instrumentation channels provide provide appropriate appropriate compensatory compensatory measures measures for for separate, separate, inoperable inoperable channels channels.. As As such, such, aa Note Note hashas been been provided provided that allows separate that allows separate Condition entry Condition entry for each inoperable for each inoperable RPS RPS instrumentation instrumentation channel..
channel A.I A and AA.2
.1 and .2 Because Because of of the the di versi t of diversit sensors a sensors available available to provide to provide trip signals and trip signals and the the rr dundancy ijundancy of of the the RPSRPS design, design, an an allowable allowable out out ofof serv serv ee timetime ofof 12 hours has 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> has been been shown shown to be acceptable be acceptable {Ref (Ref.. 99 to permit restoration to permit restoration of of any any channel to inoperable channel inoperable OPERABLE status.
to OPERABLE status . However, However, this this out out of of service time iiss only service time only acceptable acceptable provided provided the the associated Function's inoperable channel Function's inoperable channel iiss iinn one trip system one trip system andand the the Function Function still still maintains maintains RPS RPS trip trip capability capability (refer (refer to to Actions B.l, Required Actions Required B .1, BB.2, and Ce.l
.2, and Bases.)
.1 Bases .) If If the the inoperable channel inoperable channel cannot cannot be be restored restored to to OPERABLE OPERABLE status status within within the the allowable allowable outout ofof service service time, time, the the channel channel or or the the associated trip associated system must trip system must be be placed placed in i n the tripped the tripped condition condition per Required Actions per Required Actions A A.l
.1 and A .2 . Placing and A.2. Placing the inoperable channel inoperable channel iinn trip trip (or the associated (or the associated trip trip system';n system " i n trip) would conservatively compensate for the inoperability trip) would conservatively compensate for the ;noperab1lity, restore restore capability capability to to accommodate accommodate a a single single failure, failure, and and allow operation to continue. Alternately, allow operation to continue . Alternately, if if it it is is not not desired to desired to place the channel place the channel (or (or trip trip system) system in in trip (e .g .,
trip (e.g.,
as in as i n the the case where placing case where placing the the inoperable inoperable channelchannel in i n trip trip would result would result in in a a full full scram),
scram), Condition Condition 0 D must must bebe entered entered and its and its ReqUired Required Action taken..
Action taken #
B.1 B .1 and B .2 and B.2 Condition Condition B B exists exists when, when, forfor anyone any one or or more more Functions, at least least one one required required channel channel is i s inoperable inoperable in i n each each trip trip system . In system. In this this condition, condition, provided provided at least one at least one channel (continued)
GRAND GRAND GULF GULF B8 3.3-19 3 .3-19 Rev i s on No.
Revision No . 0 0
Attachment 4 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 22 of 49 22 of 49 INSERT INSERT H H -- Note Note Description Description As As noted, noted, Action A.2 is Action A.2 not applicable is not to APRM applicable to APRM Functions Functions 2.a, 2.b, 2.c, 2.a, 2.b, 2.c, 2.d, 2.d, or or 2.f.
2.f.
Inoperability Inoperability of of one one required required APRM/OPRM channel affects APRM/OPRM channel affects both both trip systems. For trip systems. For that that condition, condition, Required Required Action Action A.1A.1 must must be be satisfied, satisfied, and is the and is the only only action action (other than restoring (other than restoring OPERABILITY)
OPERABILITY) that that will restore capability will restore capability to to accommodate accommodate a a single failure. Inoperability single failure. Inoperabilityof of more more than than one one required required APRM/OPRM APRM/OPRM channel channel ofof the the same trip function same trip function results results in in loss loss of of trip trip capability and entry capability and into Condition entry into Condition C, C, as as well well as as entry entry into into Condition Condition A A for for each each channel.
channel.
Attachment 4 to to G N RO-2009-00054 GNRO-2009-00054 Page 23 Page 23 of of 49 49 RPS Instrumentation RPS Instrumentation
.3 .1 .1 B 3.3.1.1 B3 BASES BASES ACTIONS ACTIONS and 8B.2 B.11 and .2 (continued) per trip per trip system system is is OPERABLE, OPERABLE, the RPS still the RPS still maintains maintains trip trap capability for capability that Function, for that Function, but cannot accommodate but cannot accommodate ~~~~.~
single failure iinn either slng1e failure either trip trip system system..
Required Actions BB.1 equired Actions .1 and and 8B.Z.2 limit limit thethe time time thethe RP RP sc sd logic for logic for any Function would any Function would not accommodate singe not accommodate sing e failure failure in both trip i n both trip systems systems (e .g ., one-out-of-one (e.g., one-out-of-one aand arrangement for one-out-of-one arrangement one-out-of-one for aa typical typical four four annel annel Function)
Function).. The The reduced reduced reliability reliability of of this this gic a i c arrangement was arrangement was not evaluated in not evaluated in Reference Reference 99*for or thethe 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> hour Time . Within Completion Time.
Completion Within the G6 hour hour allowance, allowance, the the associated Function associated Function will will have have allall required channels either required channels ei the OPERABLE or OPERABLE or iinn
- trA-~in in any combination) in any combination) in one one trip system.
system Completing on Completing on of-5'ese 0 nese Requ Required Actions restores i red Actions restores RPS RPS to to an equivalent equivalent liability liability level level as as that that evaluated evaluated in in Reference Reference 9, which justified 9, which justified aa 12 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> hour allowable allowable ou out of service time as service time presented in as presented Condition A.
in Condition A* The trip system The trip system 1n the more i n the more degraded degraded state state should should be be placed placed i1nn trip or, or, alternatively, all alternatively, all the the inoperable channels in inoperable channels i n that that triptrip system should system should be be placed placed i1nn trip (e .g ., a trip (e.g., a trip trip system system with with two inoperable two channels could inoperable channels could be be iinn aa more more degraded degraded state state than aa trip than trip system system withwith four channels, iiff the inoperable channels, four inoperable the two inoperable channels inoperable channels are are iinn the same Function the same Function while the the four four channels are inoperable channels inoperable all in are all i n different Functions) . The different Functions). The decision as decision as to which trip to which system is trip system is in the more in the degraded more degraded state should state should be be based based on prudent judgment on prudent judgment and and current current plantplant conditions (i .e ., what conditions (1.e., what MODE MODE the the plant plant is 1s in) in).. If this If this action action would would result result iinn aa scram scram or or rec i rcul ati on pump recirculation pump trip, iit t iiss permissible permissible to to place place thethe other trip system other trip system or its or its inoperable channels 1n inoperable channels i n trip trip..
The 66 hour7.638889e-4 days <br />0.0183 hours <br />1.09127e-4 weeks <br />2.5113e-5 months <br /> The Completion Time hour Completion Time is 1s judged acceptable based on the judged acceptable on remaining remaining capability capability to trip, the to trip, diversity of the diversity of the the sensors sensors available to provide the trip signals, the low probability available to provide the trip s1gnals, the low probability of extensive of extensive numbers numbers of of iinoperabilities noperabi l i t i es affecting affecting all all diverse Functions, and the low probability of diverse Functions, and the low probability of an event an event requiring requiring the the initiation initiation of of aa scram scram..
Alternately, if Alternately, if itit 1s not desired is not desired to to place the the inoperable channels channels (or one trip (or one trip system) system) iinn triptrip (e .g ., as (e.g., as i1nn the the case case where where placing placing the inoperable channel the inoperable channel or associated trip or associated trip (continued)
GRAND GULF GRAND GULF BB 33.3-20
.3-20 Revision Revision No No.. 00
Attachment to 4 to RPS Instrumentation RPS Instrumentation GNRO-2009-00054 GNRO-2009-00054 B B 33.3.1.1
.3 . 1 .1 Page Page 24 24 of of 49 49 BASES BASES ACTIONS ACTIONS 8B.1 and BB.2'
.1 and .2 , (continued)
(continued) system in trip would result in a scram or RPT), -Condition 'Condition D0 must be entered and its Required Action taken .
Required ed Action e.l Action C .1 is is intended intended to to ensure that appropriate ensure that appropriate actions are actions are taken taken if .ultiple, inoperable, if multiple, onus inoperable, untripped Aped channels within channels within the same trip the same trip system system for for the the same same Function Function result result in in the Function not the Function not maintaining maintaining RPS RPS trip trip capability capability..
'AA Function Function is considered to is considered to bebe maintaining maintaining RPS RPS trip trip capability capability when sufficient channels when sufficient channels areare OPERABLE OPERABLE or or inin trip trip (or (or the the associated associated trip trip system system is is in in trip),
trip), such such that that both both trip systems trip systems willwill generate trip signal g~nerate aa trip from the s1gna1 from the given given
- Function Function on on a a valid valid s1gna1.
signal . For*the Forthe typical typical Function Function with with one-out-of-two taken one-out-of-two taken twice twice logic and the logic and the IRM and APRM IRM and APRM Functions, this Functions, this would would require require both both trip trip systems systems to have one to have one channel OPERABLE channel OPERABLE or or in in trip trip (or (or the the associated associated trip trip system system in trip) in trip).. For Function 66 (Main For Function (Main Steam Steam Isolation Isolation Valve--Closure), this Valve-Closure), this would would require require both both trip systems to to have each channel associated have each channel associated with with the the MSIVs MSIVs in in three three MSLs MSLs (not necessarily (not necessarily the same MSLs the same MSLs forfor both both trip trip systems),
systems),
OPERABLE or 1n trip OPERABLE or in trip (or (or the the associated associated trip trip system system in trip)..
in trip)
For Function For Function 9 9 (Turbine (Turbine Stop Stop Valve Valve Closure, Closure, Trip Trip Oil Oil Pressure--Low), this Pressure-Low), this would would require require both both trip trip systems systems to to have have three channels, three channels, each each OPERABLE OPERABLE or or in in trip trip (or (or the the associated associated trip system trip system in trip)..
in trip)
The Completion The Completion TimeTime 1s is intended intended to allow the to allow operator time the operator time to evaluate and repair any discovered inoperabi 1 i ties . The to evaluate and repair any discovered inoperabilities. The hour Completion 11 hour1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> Completion Time Time isis acceptable acceptable because because it minimizes it minimizes risk while risk while allowing allowing time time for restoration or for restoration tripping of or tripping of channels .
channels.
D.l Required Required Action Action D 0.1.1 directs entry into directs entry into the the appropriate appropriate Condition referenced Condition referenced in in Table Table 33.3.1.1-1. The applicable
.3 .1 .1-1 . The applicable Condition specified Condition specified in in the the table table isis Function Function andand MODE MODE oror other specified other specified condition dependent and condition dependent and may may change change as as th the Required Action of Required Action of aa previous previous Conditiob Condition is is completed.
completed . Each Each time time anan inoperable inoperable channel channel hashas not not met met any Required Required Action Action (continued)
GRAND GULF GRAND GULF BB 33.3-21
.3-21 Revision No Revision No.. 00 to to GNRO-2009-00054 GNRO-2009-00054 Page 25 of Page 25 of 49 49 INSERT INSERT II -- Note Description Note Description As As noted, noted, Condition Condition B B is is not not applicable to APRM applicable to APRM Functions Functions 2.a, .c, 22.d, 2 .b, 22.c, 2.a, 2.b, .d, or or 2.f.
2.f.
Inoperability of one Inoperability of one required required APRM/OPRM APRM/OPRM channel affects both channel affects trip systems both trip systems and and isis not not associated associated with with aa specific specific trip trip system, system, asas are are the the APRM 2-Out-Of-4 Voter APRM 2-0ut-Of-4 Voter and other non-and other non-APRM/OPRM APRM/OPRM channels channels forfor which which Condition Condition B B applies.
applies. ForFor an inoperable APRM/OPRM an inoperable APRM/OPRM
- channel, channel, Required Action A.1 Required Action must be A.1 must be satisfied, and is satisfied, and the only is the only action action (other (other than than restoring restoring OPERABILITY)
OPERABILITY) that will restore that will restore capability capability to accommodate a to accommodate a single single failure.
failure. Inoperability Inoperabilityof of more than one required APRM/OPRM channel of the same trip function results in loss of trip more than one required APRM/OPRM channel of the same trip function results in loss of trip capability capability and and entry into Condition entry into Condition C,C, as as well well asas entry entry into Condition A into Condition A for for each each channel.
channel.
Because Conditions Because Conditions A A and and C C provide provide Required Required Actions Actions that are appropriate that are appropriate for for the the inoperability of inoperability of APRM APRM Functions 2.a, 22.b, Functions 2.a, .b, 22.c,
.c, 22.d,
.d, and 2.f, and and 2.f, and these these functions functions are are not not associated associated with specific trip with specific trip systems systems asas are the APRM are the APRM 2-Out-Of-4 2-0ut-Of-4 VoterVoter and other non-APRM and other non-APRM
- channels, channels, Condition Condition B B does does notnot apply.
apply.
Attachment Attachment 4 4 to to RPS Instrumentation RPS Instrumentation GNR4-2009-00054 GNRO-2009-00054 3 .3 .1 .1 B 3.3.1.1 B
Page 26 Page of 49 26 of 49 BASES BASES ACTIONS ACTIONS D .1
- 0.1 (continued)
(continued) of Condition A, of Condition B, or A, B, or C, and the C, and the associated Completion Time associated Completion Time has expired, has expired, Condition Condition DD will will be entered for be entered that channel for that channel and provides and provides for for transfer transfer to appropriate subsequent the appropriate to the subsequent Condition Condition..
E.l, F.l, G.l, aRG H.l If the channel If the channel(s) (s) isis not restored to not restored to OPERABLE OPERABLE 'status or
'status or placed in trip placed in trip (or (or the the associated associated trip trip system system placed placed in in trip) - within the allowed trip)' within the allowed Completion Completion Time, Time, the the plant plant must must be be placed in a MODE or placed in a MODE or other other specified specified condition condition in in which which the the LCO does LeO does not apply . The not apply. Times are reasonable, Completion Times The Completion reasonable based on operating based on operating experience, experience, to to reach reach the the specified specified condition condition from from full full power conditions 1n power conditions in anan orderly manner and without challenging plant systems . In and without challenging plant systems. addition, the In addition, the Completion Completion
- of Required' '
of Required '41.1%191 en E .1 J- S consistent with E.1 ts consistent with the Completio, Time the Completio Time provided prOVided /ih LCOLeO 3.3 .2-.'2 "MINIMUM "MINIMUM CRITICAL CRITICAL POWER RATIO POWER RATIO (( CPR).-
CPR) ."
1.1 If the If channel(s) is the channel(s) not restored is not restored to to OPERABLE status or placed placed in trip (or the associated trip system in trip (or the associated trip system placed in trip) within the allowed Compl-etion Time, the trip) within the allowed Completion Time, the plant plant must must be be placed in a MODE or other specified condition in which the placed in a MODE or other specified condition in which the LCO does not LCO does apply . This not apply. is done This 1s done byby immediately immediately initiating initiating action to action fully insert to fully insert allall insertable control rods lnsertable control rods in in core core cells containing cells containing one one or or more more fuel assemblies . Control fuel assemblies. Control rods rods in core cells 1n core containing no cells containing no fuel fuel assemblies assemblies do not affect do not affect INSERT J - New Required the the reactivity reactivity of of the the core core and therefore, not are, therefore, and are, not required required Actions J .1 and J .2 to be to inserted . Action be inserted. Action must must continue continue until until all inoperable all insertable control rods control rods in in core core cells containing one cells containing one oror more more fuel a ssemblies are assemblies are fully fully inserted.
inserted . Subsequently, Subsequently, if if the the manual manual scram channels scram channels are are inoperable, inoperable, the the reactor reactor modemode switch switch isis locked in locked in the shutdown position the shutdown position to prevent ;nadvertent to prevent inadvertent control control rod withdrawal rod withdrawals.
SURVEILLANCE SURVEILLANCE As noted at As noted at the the.begs nning of beginning the SRs, of the S the SRs SRs for for each each RPS RPS EQUIREMENTS REQUIREMENTS instrumentation instrulDentation Function Function 'areare located located in the the SRs column of SRs column of Table Tab1e 3.3 .33*1*1-1.
.1 .1- 1 . .
(continued)
(cont;nued)
GRAND GULF GRAND GULF 8B 33.3-22
.3-22 Revision Revision No. 1
Attachment 4 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 27 27 ofof 49 49 INSERT INSERT JJ ---New New Reauired Actions J.1 Required Actions J.1 and and J.2 J.2 If OPRM If OPRM Upscale Upscale triptrip capability capability is is not not maintained, maintained, Condition Condition JJ exists.
exists. Reference Reference 15 15 justified justified use of alternate methods to detect and suppress oscillations for a limited period of time . The use of alternate methods to detect and suppress oscillations for a limited period of time. The alternate alternate methods methods are are procedurally procedurally established established consistent consistent with with the the guidelines guidelines identified identified in in Reference Reference 16 16 requiring requiring manual manual operator operator action action to to scram scram the plant if the plant if certain certain predefined predefined events events occur.r. The 12-hour allowed The 12-hoUr allowed action action time time is is based based on engineering judgment on engineering judgment to to allow orderly allow orderly transition transition to to the the alternate alternate methods methods whilewhile limiting limiting the period of the period of time time during during which which no no automatic automatic or or alternate alternate detect detect and and suppress suppress trip capability is trip capability is formally formally in in place.
place. Based Based on on the the small small probability of probability of an an instability instability event event occurring occurring at at all, all, the the 1212 hours0.014 days <br />0.337 hours <br />0.002 weeks <br />4.61166e-4 months <br /> hours is is judged judged to be reasonable to be reasonable..
J.2 The The alternate method to alternate method detect and to detect and suppress suppress oscillations implemented in oscillations implemented in accordance accordance with with JJ.1
.1 was evaluated (Reference 15) based on use up to 120 days only . The evaluation, based on was evaluated (Reference 15) based on use up to 120 days only. The evaluation, based on engineering engineering judgment, concluded that judgment, concluded that the likelihood of the likelihood of an an instability instability event event that that could could not be not be adequately handled by adequately handled by the alternate methods the alternate methods during during this this 120-day period was 120-day period negligibly small.
was negligibly small .
The The 120-day 120-day periodperiod isis intended intended to to be be an an outside outside limit limit toto allow allow forfor the the case case where where design design changes changes or or extensive extensive analysis might be analysis might be required required to to understand understand or or correct correct some some unanticipated unanticipated characteristic characteristic of of the the instability instability detection detection algorithms algorithms or equipment.. This or equipment This action action is is not not intended intended and was not evaluated as a routine alternative to returning failed or inoperable equipment to and was not evaluated as a routine alternative to returning failed or inoperable equipment to OPERABLE OPERABLE status status.. Correction Correction of routine equipment of routine equipment failurefailure oror inoperability inoperability is is expected expected to to normally normally be accomplished within be accomplished within the the completion completion times times allowed allowed for for Actions Actions forfor Conditions Conditions A A and and BB..
LCO 33.0.4.b LCO .0 .4.b is is not not applicable applicable to to J.2 J.2 to to allow uni re allow unit tart in restart in the the event event of of aa shutdown shutdown during during the the 120-day completion 120-day completion time.time.
Attachment Attachment 44 to to RPS RPS Instrumentation Instrumentation GNRO-2009-00054 GNRO-2009-00054 BB 33.3.1.1
.3 . 1 .1 Page 28 Page 28 of of 49 49 BASES BASES SURVEILLANCE SURVEILLANCE The Surveillances are The Surveillances are modified modified by by aa Note Note toto indicate indicate that, that, REQUIREMENTS REQUIREMENTS when aa channel channel is placed in is placed in anan inoperable inoperable status solely solely for for (continued)
(continued) performance of performance of required Surveillances, entry required Surveillances, entry into into associated Conditions Conditions andand Required Required Actions Actions maymay be delayed for be delayed for up up to to hours, provided 66 hours7.638889e-4 days <br />0.0183 hours <br />1.09127e-4 weeks <br />2.5113e-5 months <br />, the associated provided the associated Function Function maintains maintains triptrip capability.. Upon capability Upon completion completion of the Surveillance, of the Surveillance, or or expiration expiration of of the the 66 hour7.638889e-4 days <br />0.0183 hours <br />1.09127e-4 weeks <br />2.5113e-5 months <br /> hour allowance, allowance, the the channel must be channel must be returned to OPERABLE LE status status or or the the applicable applicable Condition Condition entered and entered and Required Actions taken Required Actions taken.. This Note is This Note is based based on on the RPS reliability analysis the RPS reliability analysis (Ref . 9) (Ref. 9) assumption assumption of of the the average average time time required required to to perform perform channel surveillance .
channel surveillance. That That analysis demonstrated that the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> testing allowance do analysis demonstrated that the 6 hour testing allowance does not significantly not reduce the significantly reduce probability that the probability that the the RPS willwill trip trip when when necessary necessary.~
SR 3.3.1.1.1 ~~
Performance Performance of of the the CHANNEL CHANNEL CHECK CHECK eAee evepy 12 once every houps ensures 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that that aa gross gross failure failure of instrumentation has of instrumentation has not not occurred.
occurred . A A
CHANNEL CHECK is CHANNEL CHECK normally aa comparison is normally comparison of of the parameter the parameter indicated icated on one channel on one channel to to aa similar parameter on similar parameter on other other channels.
channels . It is It is based based on on the the assumption assumption that instrument channels channels monitoring monitoring the same parameter the same parameter should should read read approximately approximately the same value the same value.. Significant Significant deviations deviations between instrument channels the instrument between the could be channels could be an indication of an indication of excessive instrument drift excessive instrument drift on one on one of of the the channels channels or or something even more something even serious.. A more serious A CHANNEL CHECK will detect CHANNEL CHECK gross gross channel failure ; thus, it is key to verifying channel failure; thus, it is key to verifying the the strumentation continues to operate properly between each instrumentation continues to operate properly between each CHANNEL CHANNEL CALIBRATION.
CALIBRATION .
Agreement criteria Agreement criteria are are determined determined by by the the plant staff based plant staff based on a on a combination combination of of the the channel channel instrument instrument uncertainties, uncertainties, including indication and including indication readability.. If and readability If aa channel channel is is outside outside the criteria, it the criteria, it may may bebe an an indication indication that the that the instrument has instrument has drifted drifted outside outside itsits limit.
limit .
The agreement The agreement criteria criteria include include an an expectation expectation of of overlap overlap when transitioning when transitioning between between neutron neutron fluxflux instrumentation.
instrumentation .
The The overlap overlap between between SRMs SRMs and and IRMs must be IRMs must be demonstrated demonstrated prior p to withdrawing SRMs from the fully inserted to withdrawing SRMs from the fully inserted position position since since indication is indication is being being transitioned transitioned from from SRMs SRMs toto the the IRMs.
IRMs .
This will This will ensure ensure that that reactor reactor power power will will not not be be increased increased into a into a neutron neutron flux flux region region without without adequate adequate indication.
indication . The The (continued)
(continued)
GRAND GRAND GULF GULF B 3.3-23 B 3 .3-23 LDC LDC 06007 06007
Attachment Attachment 44 to to RPS RPS Instrumentation Instrumentation GNRO-2009-00054 GNRO-2009-00054 BB 3.3.1.1 3 .3 .1 .1 Page 29 Page 29 of of 49 49 BASES SURVEILLANCE SURVEILLANCE SR 3.3.1.1.1 REQUIREMENTS overlap overlap between between IRMsIRMs and and APRMs APRMs isis of concern when of concern when reducing reducing power into power the IRM into the IRM range range.. On On power power increases, the increases, the system system design will prevent design will prevent further further increases increases (by (by initiating initiating aa rod rod block) if adequate overlap is not .maintained .
block) if adequate overlap is not.maintained.
Overlap between IRMs IRMs and and APR APRMs exists when sufficient IRMs and APRMs and APRMs concurrently concurrently have on-scale readings have on-scale readings such such thatthat the the transition transition between between MODEMODE I1 and and MODE MODE 22 can can be made without be made without either APRM either APRM downscale downscale rod rod block, block, oror IRM IRM upscale upscale rod rod block block..
Overlap between SRMs Overlap between SRMs and IRMs similarly and IRMs similarly exists exists when, when, prior prior to withdrawing the to withdrawing the SR.Ms SRMs from from the the fully fully inserted position, inserted position, IRMs are above IRMs are above 2140 2/40 on on range range 11 before before SRMs SRMs have have reached reached the the upscale upscale rod rod block block..
If If overlap for a overlap for a group group of of channels channels isis not not demonstrated demonstrated (e.g., IRM/APRM IRM/APRM overlap),
overlap), the reason for the reason for the the failure failure of of the the illance should veillance should be determined and be determined and the the appropriate appropriate chan l(s) s) that are required that are required inin the the current current MODE MODE or or conditl should be declared inoperable.
haul d be declared inoperable .
The The Frequency Frequen is based is upon operating based upon operating experience that experience that demonstrates channel failure is rare .
demonstrates channel failure is rare. The CHANNEL The CHANNEL CHECKCHECK supplements supplements less less formal, but more formal, but frequent, checks more frequent, checks of of channels during channels during normal normal operational operational useuse ofof the the displays displays associated associated with with thethe channels channels required required by the LCO by the LCO..
E The Frequency of once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for SR 3.3.1 .1 .19 is based on the improved processing and reduced drift of the digital equipment in combination with four fully redundant flow transmitter channels and improved failure detection (Reference 15).
Cc o n t ing e d (continued)
GRAND GULF GRAND GULF B 33.3-23a B .3-23a LDC 06007 LDC 06007 1,
Attachment Attachment 4 4 to to GNRO-2009-00054 GNRO-2009-00054 RPS Instrumentation RPS Instrumentation BB 3.3.1.1 3 .3 .1 .1 Page 30 Page 30 of of 49 49 BASES BASES SURVEILLANCE SURVEILLANCE SR 3.3.1.1.10, SR 3 .3 .1 .1 .10, SR SR 3 .3 .1 .1 .12 and 3.3.1.1.12 and SR SR 3 .3 .1 .1 .17 3.3.1.1.17 REQUIREMENTS (continued)
(continued)
Note Note 33 to to SR SR 3.3.1.1.10 3 .3 .1 .1 .10 sta,tes states that that the the APRM APRM recirculation recirculation flow transmitters flow transmitters are excluded from are excluded from CHANNEL CHANNEL CALIBRATION CALIBRATION of of Function Function 2.d, 2 .d, Average Average Power Power Range Range Monitor Monitor Flow Flow Biased Biased Simulated Thermal Simulated Thermal Power Power -- High. High . Calibration Calibration of of thethe flow flow transmitters is performed transmitters is performed on an 18-month frequency (SR on an IS-month frequency (SR 3.3.1.1.17). Note 1 4: e 4 45to SR
-d SIR 3.3.1,1.10 3 31 - 1 31 IQ, 5 ~,. a t e s states t, h a the that t, th le d
dig; 41 tal coefflp gi, t1a ffI po AeAt s ef neHts 0 f the the flo~; f 1 ew co eent At Pei r 0 1 ttprip . ,, -, ref ere nee ecar d
--Pferrenee are excluded froffl CIIAN~~EL CALIBRATION of Function 2.d, Average Power Range MOAitor Flow Biased Sifflulated Therfflal POiier IIi gh.. The analog 1141gh aAalog autput output potent; patent.i.-Affl-eteps offleters of the flo',,'
A' control eanti , al trip tpip refereAce P f r nee eapd, card are ape AOt net excluded.
The flow eamtl control , al trip trip refereAce Peferemee eap. card," has aA an 'autofflatic au'Eefflatie self self test t. s-t-f eat ure 'vv' h; ch per i ad i cally t est s the har dtv; are tv; hie h per for ms the Ir"i'44la! a!
t"Me digital algorithm.t-itQ ExclusioA Ex It s lan of 1 . 1.1 of the 1 ti- digital
-, s~imital
" - ~ j - , cOfflpoAeAts eefflp a m e n t--s of the flowW eentpe! cOAtrol trip tripv reference P feeeigee card e Pd from
.11 f Feffl cHANINE4--
CHANNEL 1 11 .1 A I- I B R T
CALIBRATION 6
1 L -A I off FUAction e F i m e 41: J. m 122 2.d . di isi s based on the
~1:14 s 'd eig t1h, e conditions e e i9d i t, i -1 required to perforffl tMe test aAd the likelihood of a chaAge INSERT K -
in the sstatus :~ a u 5 a of these s components e a ffl pa m en t s not m t being 1:4 e I n g detected.
44 e :t e ;t a s~
Note Description The Frequency The Frequency of of , SR 3 .3 .1 .1 .12 and SR 3.3.1.1.12 and SR SR for S R 3 .3 . 1 . 1 .10 3 .3 .1 .1 .17 is base 3.3.1.1.17 is based upon the assumption of the magnitude u on the assumption of the magnitude of of equipment drift equipment drift in in thdth setpoint setpoint analysis analysis..
INSERT L - Frequency of SR 3.3 .1 .1 .10 (continued)
Cconti n-u-ed )
GRAND GULF GRAND GULF B 33.3-27a B .3-27a LDC 98037 LDC 98037 1
Attachment 4 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 31 31 ofof 49 49 INSERT INSERT K K- - Note Note Description Description for for SRSR 3.3.1 .1 .10 3.3.1.1.10 SR SR 3.3. 1 . 1 .10 for 3.3.1.1.10 for thethe designated designated function function is is modified modified by by two two Notes Notes as as identified identified in in Table Table 33.3.1.1-1.
.3.1 .1-1 . TheThe first Note requires first Note evaluation of requires evaluation of channel channel performance performance for for the condition where the condition where the the as-found as-found settingsetting for for the the channel setpoint is channel setpoint is outside outside its its as-found as-found tolerance tolerance but but conservative conservative with with respect respect to the Allowable to the Allowable ValueValue.. Evaluation Evaluation of of channel channel performance performance will will verify verify that that thethe channel channel will will continue continue to to behave behave in accordance with in accordance safety analysis with safety assumptions and analysis assumptions and the the channel performance assumptions channel performance assumptions in in the the setpoint setpoint methodology methodology.. The The purpose purpose of of the the assessment is to ensure confidence in the channel performance prior to returning the assessment is to ensure confidence in the channel performance prior to returning the channel channel to to service service.. The performance of The performance of these channels will these channels will be be evaluated evaluated underunder the station's the station's Corrective Corrective Action Program.. Entry Action Program Entry into the Corrective into the Corrective Action Action Program Program will ensure required will ensure required review review and and documentation documentation of of the the condition condition to to establish establish aa reasonable reasonable expectation expectation for for continued continued OPERABILITY OPERABILITY..
The The second second Note Note requires requires that the as-left that the as-left setting setting for for the the channel channel be be within within the the as-left as-left tolerance tolerance of of the the Nominal Nominal Trip Trip Setpoint Setpoint (NTSP}.
(NTSP). Where Where aa setpoint setpoint more more conservative conservative than than the the NTSP NTSP is is used in the plant surveillance procedures, the as-left and as-found tolerances, as applicable, used in the plant surveillance procedures, the as-left and as-found tolerances, as applicable, will be applied will be applied to to the the surveillance surveillance procedure procedure setpoint.
setpoint. This This will will ensure ensure that that sufficient sufficient margin margin to to the Safety Limit the Safety Limit and/or and/or Analytical Analytical LimitLimit isis maintained maintained.. If If the the as-left channel setting as-left channel cannot be setting cannot be returned to returned to aa setting setting within within thethe as-left tolerance of as-left tolerance of the the NTSP, NTSP, then then the the channel shall be channel shall be declared inoperable. The declared inoperable. The second second Note Note also requires that also requires that NTSP NTSP and and thethe methodologies methodologies for for calculating calculating the the as-left as-left and and the the as-found as-found tolerances tolerances be be inin the Technical Requirements the Technical Requirements Manual Manual..
INSERT L INSERT L- - Frec luency off SR Frequency SR 3.3.1 .1 .10 3.3.1.1.10 The Frequency of The Frequency of 2424 months months for for SRSR 3.3. 1 . 1 .10 is 3.3.1.1.10 is based based upon upon thethe justification justification provided provided in in Reference 15.
Reference 15. TheThe onlyonly analog analog components components involved involved with main signal with main signal processing processing are are input input isolation amplifiers (one isolation amplifiers (one per per LPRM LPRM and and oneone per per flow flow input),
input), aa sample-and-hold sample-and-hold circuit, circuit, andand an an analog-to-digital analog-to-digital (AID} (AID) converter converter.. These These analog analog components components are are highly highly reliable reliable and and veryvery stable stable with with virtually virtually no no drift drift.. In In addition, addition, the the sample-and-hold sample-and-hold circuit and AID circuit and AID converters converters are are tested tested as as part of part of the the automatic automatic self test.
self-test.
The The processing processing hardware hardware for for the the APRM APRM Functions Functions is digital and is digital and has has nono drift.
drift. One One of of the the most most sensitive sensitive signals, signals, the the flow processing, is flow processing, is automatically automatically compared compared between channels . Any between channels. Any digital failures will digital failures will be be identified identified by by thethe automatic automatic self-test, self-test, CHANNEL CHANNEL CHECK, CHECK, or or in in very very rarerare cases cases by by the the CHANNEL CHANNEL FUNCTIONAL FUNCTIONAL TEST. TEST.
The The automatic automatic self-test includes steps self-test includes steps that that check check the the performance performance and and accuracy accuracy of of the the sample sample and and holdhold circuits circuits and and thethe AID AID converters, converters, and and the the related processing . Self-test related processing. Self-test logiclogic also also periodically periodically tests tests thethe input input amplifiers amplifiers and and processing processing for for accuracy accuracy.. In In addition, addition, CHANNEL CHANNEL FUNCTIONAL FUNCTIONAL TESTS TESTS includeinclude an an automated automated "cal "cal check" check" which which willwill check check the the performance performance of of all all ofof the analog amplifiers the analog amplifiers and and the entire processing the entire processing loop. loop .
The The combined combined improvement improvement justifies justifies the the factor-of-four factor-of-four increaseincrease in in calibration calibration interval, interval, particularly particularly in that the in that the calibration calibration will will actually actually be be checked checked at at the the CHANNEL CHANNEL FUNCTIONAL FUNCTIONAL TEST and TEST and self-test self-test frequencies frequencies..
Attachment Attachment 4 4 to to RPS Instrumentation RPS Instrumentation GNRO-2009-00054 GNRO-2009-00054 BB 33.3.1.1
.3 .1 .1 Page 32 Page 32 of of 49 49 BASES BASES ILLANCE SURVEILLANCE SR SR 3 .3 .1 .1 .15 3.3.1.1.15 (continued)
(continued)
REQUIREMENTS EQUIREMENTS RPS RESPONSE ONSE TIME TIME tests tests are are conducted conducted on on an an 18 18 month month STAGGEREDD TEST TEST BASISBASIS.. Note Note 33 requires requires STAGGEREDSTAGGERED TEST TEST BASIS BASIS Frequency to be determined based on 4 channels per tri Frequency to be determined based on 4 channels per trip system, system, in lieu of in lieu of the the 8 8 channels channels specified specified in in Table Table 33.3.1.1-1
.3 .1 .1-1 for for the the MSIV Closure Function.
MSIV Closure Function . This This Frequency Frequency is is based based on on the the logic logic interrelationship interrelationships of the various channels required channels required to to produce produce an an RPS scram signal.
RPS scram signal Therefore, staggered Therefore, staggered testing results in testing results in response response time time verification verification of of these these devices devices every every 18 18 months months.. This This Frequency Frequency is is consistent consistent with with thethe typical typical industryindustry refueling ref u cycle and is based upon plant operating experience, which cycle and is based upon plant operating experience, shows that hat random failuresfailures of instrumentation components of instrumentation components causing serious time degradation, but causing serious time degradation, but notnot channel channel fai failure, are infrequent .
are infrequent.
SR 3.3.1.1.16 The A\/erage P-e-w-e-P Range Man; tor Flo',,' Bi ased Siffiul ated Ther~al P-e-w-e-P - ~igh Function i9et4 uses am 1 eetraf4c filter aA electroAic 4~4 11 41:11--1 4 r- t 4-t circuit to generate generate a signa~ proportional to tAc core TW R I THERMAL I ~ froffi the APRM i9eutp n neutron ~ si em a 4-. ~
s;gAa1.
44 1 t -r circuit G4 Peu , 11 is I- P I- e, s e nt " 4 Y e of the fuel heat tran~fer
+6 reprqsentative 4-filter dynaFR; as that produce the rel F 1 ati en a- t, 4 oAshi 4 p p bet'yt'een I e ': w the neutron M e d trtfl
~n
~ and the core T~ERMAL POWER. The filter time COM5taMt FAW
~ 6 be verified to ensure tMat the chaAAcl is accurately aeetir y reflecting th es4 P d p the desired aF a t F.
parameter.
~ ~requeney of 18 ffionths is based OR eRgiReer;n9 jud~m@nt and reliability of the cOffiponcAts.
~ 3.3.1.1.18 The /\verage P-e-w-e-P Range Moni tor Flo'y/ 8; ased Si ffiul ated TherFRal P-e-w-e-P ~igh FUAction uses a trip level geMerated by
-r the flo'., control ttri r- 4 9 Fe,erenee preference card based or; tMe reci raul ati on 1cop dri'le =R-ew-. The dri ve flo'h' i 5 adj usted aee ZI -
by a digital algorithm according 9 to selected s 1 e t-k ~ d
- f+ew I IV ali g nFA en t dip 5 in' i t c h 55 e t tin19 9 5 * +R4-s SR 5 e t 5 t t1 e flo ~,W (continued)
GRAND GRAND GULF GULF B B 3.3-29a 3 .3-29a LDC 98037 98037
Attachment Attachment44to to RPS RPS Instrumentation Instrumentation GNRO-2009-00054 GNRO-2009-00054
.3 .1 . 1 BB 3.3.1.1 Page Page 33 33 of of49 49 BASES BASES SURVEILLANCE SURVEILLANCE ~ 3.3.1.1.18 e e 19 tv i 19 a 4)
((continued)
REQUIREMENTS REQUIREMENTS control tr-iiq GgHtrnp! trip i-ef i-eigee ear reference ,~ to card to ensufle ensure tRe drive flow alignment used results in tAe appropriate trip level being generated froffi the digital cOffiponents of tRe card.
ie PF The queney ef Frequency of eneeonce kllawingfollowiR9 a refueling outage is based on the expectati on that any chaNge in tRe core flow to dri'o e flow functional relationsRip during polter operetion would be gradual and that maintenance on recirculation 5y~tem and coro components 'v/hi ch ffiay i ffipaet the rel at; on5Mi p h expected to be perforfficd during refuclil9~ outages. +fl completion time of 7 days after reacl=l;ng equilibrium conditions is based on plant cOflditiol9s required to pel fotm the test and engineering judgffleflt of tRc time lequiled to collect and analyze the necessary flo~f data and tl=le tim@
required to adjust and cheek the adjustment of e~eh flow control trip refereRce card. The completion time of 7 days after reaching equilibrium conditioAs is acceptable bB~ed on the 10\,,' probabij, 114iIV low pr-a--ba ty of a neutron; e/tRermal hydl aulI i c 4-444 t8bi.14Y eyen-t-.
instability event.
REFERENCES EFERE CES 1. UFSAR, Fi g INSERT M - New SRS 3.3.1 .1 .20, 3.3.1 .1 .21
- 4. UFSAR, Chapter 15.
- 6. 23842, "Continuous NEDO-23842, "Continuous Control Control Rod Withdrawal in Rod Withdrawal in the the Startup Range,"
Startup Range," April April 18, 18, 1978.
1978 .
- 7. Section 15.4.9.
UFSAR, Section 15 .4 .9 .
(conti nued)
(continued)
GRAND GRAND GULF GULF 3 .3-29b BB 3.3-29b LDC 98037 LDC 98037
Attachment 4 to to GNRO-2009-00054 GNRO-2009-00054 Page 34 Page 34 of of 49 49 INSERT M INSERT M- - New New SRs 3.3.1 .1 .20, 3.3.1 .1 .21, 3.3.1 .1 .22, and SRs 3.3.1.1.20,3.3.1.1.21,3.3.1.1.22, and 3.3.1 .1 .23 3.3.1.1.23 SR SR 3.3 .1 .1 .20 3.3.1.1.20 A
A CHANNEL CHANNEL FUNCTIONAL FUNCTIONAL TEST TEST is performed on is performed on each required channel each required channel to to ensure ensure that that thethe entire entire channel channel will will perform perform the intended function the intended function..
For the For the APRM Functions, this APRM Functions, this test test supplements supplements the the automatic automatic self-testself-test functions functions that that operate operate continuously in continuously in the the APRM/OPRM APRM/OPRM and and voter channels . The voter channels. The CHANNEL FUNCTIONAL TEST CHANNEL FUNCTIONAL TEST covers the covers the APRM/OPRM APRM/OPRM channels channels (including recirculation flow (including recirculation processing --
flow processing applicable to
-- applicable to Function 2 .b only), the 2-Out-Of-4 Voter channels, and the interface connections into the RPS Function 2.b only), the 2-0ut-Of-4 Voter channels, and the interface connections into the RPS trip trip systems systems from from the the voter voter channels.
channels. Any setpoint adjustment Any setpoint adjustment shall shall bebe consistent consistent with with the the assumptions assumptions of of the the current plant specific current plant setpoint methodology.
specific setpoint methodology .
The The 184184 day day Frequency Frequency of of SRSR 3.3 .1 .1 .20 is 3.3.1.1.20 is on the reliability on the reliability analysis analysis of of Reference Reference 15. 15.
(NOTE (NOTE:: Actual Actual voting voting logic logic ofof the the 2-Out-Of-4 2-0ut-Of-4 Voter Voter Function Function is as part is as part of of SR 3.3.1 .1 .21 .)
SR 3.3.1.1.21.)
Note Note 1 1 is is provided provided for for APRM Function 2.a APRM Function 2.a that that requires requires this this SRSR to to be be performed performed within within 1212 hours0.014 days <br />0.337 hours <br />0.002 weeks <br />4.61166e-4 months <br /> of hours of entering entering MODE MODE 2 2 from from MODE MODE 11.. Testing Testing of of the the MODEMODE 22 APRM APRM Function Function cannot cannot be be performed performed in in MODE MODE 1 1 without without utilizing utilizing jumpers jumpers or or lifted lifted leads leads.. This Note allows This Note allows entryentry into into MODE MODE 22 from from MODEMODE 11 if if the the associated associated Frequency Frequency is is not not metmet perper SR SR 3.0 .2 .
3.0.2.
Note Note 22 is provided for is provided for APRM Functions 2.a, APRM Functions 2.a, 2.b, and 22.c 2.b, and .c to to clarify that the clarify that the APRM/OPRM APRM/OPRM channels and channels and 2-Out-Of-4 2-0ut-Of-4 Voter Voter channels channels are included in are included in the the CHANNEL CHANNEL FUNCTIONAL FUNCTIONAL TEST. TEST.
Note Note 33 is is provided provided for for APRM APRM Functions Functions 22.d .d and 2.f to and 2.f to clarify clarify that that the the APRM/OPRM APRM/OPRM channels channels and the and the 2-Out-Of-4 2-0ut-Of-4 Voter Voter channels channels plus plus the the flow flow input input function, function, excluding excluding the the flow flow transmitters, transmitters, are are included included in in the the CHANNEL CHANNEL FUNCTIONAL FUNCTIONAL TEST TEST..
SR 33.3.1.1.21 SR .3 .1 .1 .21 The The LOGIC LOGIC SYSTEM SYSTEM FUNCTIONAL FUNCTIONAL TEST TEST for for APRM APRM Function Function 22.e .e simulates simulates APRM APRM and and OPRM trip conditions at the 2-Out-Of-4 Voter channel inputs to check all combinations of OPRM trip conditions at the 2-0ut-Of-4 Voter channel inputs to check all combinations two of two tripped inputs to the 2-out-of-4 logic in the voter channels and APRM-related redundant RIPS tripped inputs to the 2-out-of-4 logic in the voter channels and APRM-related redundant RPS relays relays.. The The test test isis only required to only required to include include the the voting voting logiclogic of of the the 2-Out-Of-4 2-0ut-Of-4 Voter Voter channels channels and and RPS-RPS' relays relays notnot tested tested as as part part ofof the the CHANNEL CHANNEL FUNCTIONAL FUNCTIONAL TEST. TEST.
The 24-month Frequency The 24-month Frequency is is based based on on thethe justification justification that that virtually virtually all all of of the the equipment equipment is is tested tested by by thethe CHANNEL CHANNEL FUNCTIONALFUNCTIONAL TESTS. TESTS . The periodic LPRM The periodic calibrations (every LPRM calibrations (every 2000 2000 full full power power hours) hours) provide provide an an indirect indirect testtest of LPRM interfaces of LPRM interfaces including including detectors detectors.. The The design design of of the the equipment equipment allows allows virtually all testing virtually all testing and and routine routine adjustments adjustments to to be be performed performed with with no no changes to the configuration (e.g ., no disconnecting wires), so the risk of problems caused by changes to the configuration (e.g., no disconnecting wires), so the risk of problems caused by the the normal operation of normal operation of the the system system is is greatly greatly reduced reduced..
SR .3 .1 .1 .22 SR 33.3.1.1.22 This This SR SR ensures ensures that that the the individual channel response individual channel response times times for for Function Function 2.e 2.e are less than are less than or or equal equal to to the the maximum maximum values assumed in values assumed in the the accident accident analysis analysis.. This This test test may may be be performed performed in one in measurement or one measurement or in in overlapping overlapping segments, segments, with verification that with verification that all all associated associated components components are are tested tested.. The The RPS RESPONSE TIME RPS RESPONSE acceptance criteria TIME acceptance criteria are are included included in in the the applicable applicable plant plant procedures.
procedures.
Attachment 4 to to GNRO-2009-00054 GNRO-2009-00054 Page 35 Page 35 ofof 4949 RPS RPS RESPONSE RESPONSE TIME TIME for the APRM for the APRM 2-Out-Of-4 2-0ut-Of-4 Voter Voter Function Function 2.e includes the 2.e includes the output output relays of relays of the the votervoter and and thethe associated associated RPS RPS relays relays and contactors. (The and contactors. (The digital digital portion portion of of the the APRM APRM and and 2-Out-Of-4 2-0ut-Of-4 Voter Voter channels channels are are excluded excluded from from RPS RESPONSE TIME RPS RESPONSE TIME testing testing because self-testing because self-testing and and calibration calibration checks checks the the time time base base of of the the digital electronics .
digital electronics.
Confirmation of the time base is adequate to assure required response times Confirmation of the time base is adequate to assure required response times are are met.
met.
Neutron detectors are Neutron detectors excluded from are excluded from RPS RPS RESPONSE RESPONSE TIME TIME testing testing because because the the principles principles of of detector detector operation operation virtually ensure an virtually ensure an instantaneous instantaneous response response time.) time.)
APRM APRM and and OPRMOPRM RESPONSE RESPONSE TIME TIME tests tests are conducted on are conducted on aa 24 24 month month STAGGERED STAGGERED TEST TEST BASISBASIS.. The The Note requires the Note requires the STAGGERED STAGGERED TEST TEST BASIS BASIS to to be be determined determined based based on on 4
4 channels channels of of APRM outputs and APRM outputs and 4 4 channels channels of of OPRM OPRM outputs, outputs, (total (total "n" "n" == 8)8) being being tested tested onon an alternating basis. This allows the STAGGERED TEST BASIS Frequency for Function 2.e an alternating basis. This allows the STAGGERED TEST BASIS Frequency for Function 2.e to to be be determined determined based based on on 8 8 channels channels rather rather than than the the 4 4 actual actual 2-Out-Of-4 2-0ut-Of-4 Voter Voter channels.
channels.
The The redundant redundant outputs outputs from from the the 2-Out-Of-4 2-0ut-Of-4 Voter Voter channel channel (2 (2 for for APRM APRM trips trips and and 2 2 for for OPRM OPRM trips) trips) are are considered considered part part of of the the same channel, but same channel, but the the OPRM OPRM and and APRMAPRM outputsoutputs are are considered to considered to be be separate channels for separate channels for application application of of SR SR 33.3.1.1.22,
.3.1 .1 .22, so so "n" "n" == 8.8. The The note note further requires that further requires that testing testing of of OPRM OPRM and and APRMAPRM outputsoutputs fromfrom aa 2-Out-Of-4 2-0ut-Of-4 Voter Voter be be alternated alternated.. In In addition addition to to these these commitments, commitments, Reference Reference 15 require that 15 require that thethe testing testing of of inputs inputs to to each each RPS RPS Trip Trip System System alternat alternate.
Combining these Combining these frequency requirements, an frequency requirements, an acceptable acceptable test test sequence sequence is is one one that:
that:
a.
- a. Tests Tests each each RPS RPS triptrip system system interface interface every every otherother cycle, cycle, b.
- b. Alternates Alternates testing testing APRMAPRM and and OPRM OPRM outputsoutputs from from any any specific 2-Out-Of-4 Voter specific 2-0ut-Of-4 Voter channel, channel, and and
- c. Alternates Alternates between between divisions divisions at at least least every every otherother test test cycle.
cycle.
Each Each testtest ofof an an APRM APRM or or OPRM OPRM output output teststests each each of of the redundant outputs the redundant outputs fromfrom thethe 2-Out-2-0ut-Of-4 Of-4 Voter Voter channel channel for for that Function and that Function and eacheach of of the the corresponding corresponding relays relays in in the the RPS RPS..
Consequently, each Consequently, each of of the the RPS RPS relays relays is is tested tested everyevery fourth fourth cycle.
cycle. The The RPSRPS relayrelay testing testing frequency is twice the frequency justified by Reference 15 .
frequency is twice the frequency justified by Reference 15.
SR SR 33.3.1.1.23
.3 .1 .1 .23 This This SR ensures that SR ensures that scrams scrams initiated initiated from from OPRM OPRM Upscale Upscale Function Function 2.f 2.f will will not not bebe inadvertently bypassed when THERMAL POWER, as indicated by the APRM Simulated inadvertently bypassed when THERMAL POWER, as indicated by the APRM Simulated Thermal Thermal Power Power is is greater greater than than or or equal equal to to 29%
29% RTP RTP and and core core flowflow as indicated by as indicated by recirculation drive recirculation drive flow flow is is less less than than 60% 0 60 k rated rated flow.
flow. ThisThis normally normally involves involves confirming confirming the the bypass bypass setpoints setpoints.. Adequate Adequate margins margins for for the instrument setpoint the instrument methodologies are setpoint methodologies are incorporated incorporated into into the actual setpoint.
the actual setpoint. The The actual surveillance ensures actual surveillance ensures that that the the OPRM OPRM Upscale Upscale Function Function is is enabled enabled (not (not bypassed) bypassed) for the correct for the correct values values of of APRM APRM SimulatedSimulated ThermalThermal PowerPower and recirculation drive flow. Other surveillances ensure that the APRM Simulated Thermal and recirculation drive flow. Other surveillances ensure that the APRM Simulated Thermal Power and Power and recirculation recirculation flow flow properly properly correlate correlate with with THERMAL THERMAL POWER POWER and and core core flow, flow, respectively respectively..
If any If any bypass bypass setpointsetpoint is is non-conservative non-conservative (i(Le., .e ., the OPRM Upscale the OPRM Upscale function function is is bypassed bypassed when when APRMAPRM Simulated Simulated Thermal Thermal Power Power is is greater greater than than or equal 29%
or equal 29% RTP RTP and recirculation and recirculation drive drive flow flow is is less less than than 60%600/0 of rated flow),
of rated flow), thenthen the the affected affected channel channel is is considered considered inoperable inoperable for for the the OPRM OPRM Upscale Upscale function.
function. Alternatively, Alternatively, the the bypass bypass setpoint setpoint may may be be adjusted adjusted to place to place to to GNRO-2009-00054 GNRO-2009-00054 Page Page 36 36 of of 49 49 the channel the channel inin a conservative condition a conservative condition (non-bypassed)
(non-bypassed).. If If placed in "non-bypassed,"
placed in "non-bypassed," this this SR SR is is met met and the channel and the channel isis considered considered OPERABLE OPERABLE..
The The Frequency Frequency of of once once every every 24 24 months months is is based based on engineering judgment on engineering recognizing that judgment recognizing that the actual the actual values values are stored digitally, are stored digitally, so there is so there is no no drift, drift, and that any and that hardware failures any hardware failures that that ffect these affect these setpoints setpoints will most likely will most likely be be detected detected by the automatic by the automatic self-test self-test function function..
Attachment 4 Attachment 4 to to GNRO-2009-00054 GNRO-2009-00054 RPS RPS Instrumentation Instrumentation BB 3.3.1.1 3 .3 .1 .1 Page 37 Page 37 of of 49 49 BASES REFERENCES 8. Letter, P.
Letter, P . Check Check (NRC)(NRC) to to G. Lamas (NRC),
G . Lainas (NRC), "BWR" (continued)
(continued) Scram Discharge Scram Discharge SystemSystem Safety Safety Evaluation,"
Evaluation,"
December 1, December 1, 1980, 1980, as as attached attached to to NRC NRC Generic Generic LetterLetter dated December dated 9, December 9, 1980 . 1980.
- 9. NEDO-30851-P-A, "Technical NEDO-30851-P-A, "Technical Specification Specification Improvement Improvement Analyses for Analyses for BWRBWR Reactor Reactor Protection Protection System,"
System,"
Mar March 1988.
10 .
- 10. NEDO-32291-A, "System NEDO-32291-A, System Analyses Analyses for for Elimination Elimination of of Selected Selected Response Response Time Time Testing Testing Requirements,"
Requirements," October October 1995 .
1995.
11 .
- 11. GNRI-97/00181, Amendment GNRI-97/00181, Amendment 133 133 toto the the Operating Operating License.
12 .
- 12. NEDO-32339-A, "Long NEDO-32339-A, "Long Term Stability Solution:
Term Stability Solution : Enhanced Enhanced Option Option I-A."I-A 13.
- 13. NEDO-31960-P-A, NEDO-31960-P-A, "BWR "BWR Owners' Owners' GroupGroup Long-Term Long-Term Stability Stability Solution Solution Licensing Licensing Methodology,"
Methodology," and Supplement 1.
and Supplement 1.
14.
- 14. NEDO-32465-P-A, NEDO-32465-P-A, "BWR "BWR Owners' Owners' GroupGroup Reactor Reactor Stability Detect and Stability Detect and Suppress Suppress Solutions Solutions Licensing Licensing Basis Basis Methodology Methodology forfor Reload Reload Applications" Applications" 15.
- 15. NEDC-3241 NEDC-32410-P-A,O-P-A, "Nuclear Measurement Analysis "Nuclear Measurement Analysis and and Control Control --
Power Power Range Range Neutron Neutron Monitor Monitor (NUMAC (NUMAC PRNM)
PRNM) Retrofit Plus Option Retrofit Plus III Option III Stability Stability Trip Trip Function,"
Function," Vols 1 and 2, Vols 1and 2, and and Supplement Supplement 1 1 16 16.. BWR BWR Owners' Owners' Group Group Letter, Letter, LL.. A.
A. England England toto the NRC, M the NRC, M.. JJ.. Virgilio, Virgilio, "BWR Owners' Group Guidelines for Stability Interim Corrective Action,"
"BWR Owners' Group Guidelines for Stability Interim Corrective Action,"
June June 6,6, 1994 1994
- 17. TSTF-493, TSTF-493, "Clarify "Clarify Application Application of of Setpoint Setpoint Methodology Methodology for for LSSS LSSS Functions" Functions" GRAND GRAND GULF GULF BB 33.3-30
.3-30 LDC 98031 LDC 98037
Attachment Attachment 4 4 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 38 38 of of 49 49 BB 3.3 3 .3 INSTRUMENTATION INSTRUMENTATION BB 33.3.1.3
.3 . 1 . 3 P@rio6 Based D@tection System (PODS)
-8 A rl- W., G R '9 ~D lvl 1 ic 4msta,6 14 14 try .
5 ur 5 ib,6, a t a I t 11 ea 5 41:1 Q, Q, . IM f :bl-l f 1 A e. I r ads n
Bases for 0
2 .3 .3 ~2 +
4' 4.
I ty p
---,I idi ation of 5bi d
Q s '1: 1.- i le ;I, IQ d i A:5 t r Uffi e t9wttata : iion
'I on 1Aoo+f......tF-fh;w;e. . . . . . ~~~-f¥I-Ao~F-A-f~
,_V115 I 5tS of ttriO CRBFlFH!l g" Q lq iq IQ 4 Q ~Eaiiit-fc-"h~~~lii?r---+'~"""'-~~~
U'S are e tlimua~',y
- - - 4. 1- - - - . . 4. - - 1~1 -C "I U7, i C 4- L, hi 1 . . 11 C UFU T- 07 1 4-t t f-eatui TH s if-test GRAND GRAND GULF GULF B 3.3-39aa LOG 98037
Attachment Attachment 44 to to
~
GGNRO-2009-00054 N RO-2009-00054 B 3.3.1.3 Page Page 39 39 of of 49 49 BACK 8ACl<GgOUND
__PQ_ I-IND fblncti t 1-eonss are executed duri ng tft.e4-r allocated port; on of tfle (continblQQ) QXQcbltive lGGp sequence. ee .
R Any rn self test nr t failure iAdieati~g
, . " t-8-1 function lo~~ of critical tie n -u4 results - ; ; a eeontro1 in e t,~ I rOOffl r,
a -~a=!
alarm.
alffl-.
ThQ inopQrable condition is also displayed by an iAdicati~g light on the card front panel. A manually initiated intQrnil tQ£t 6equence re"'T'~'~' a h ~be can Te aactuated t . u tT~.-d n~ , "#-rw yia via laa recessed ~
b'tttQn. ~ internal Ltest st econsists en ists of sifflulatiflg a-i-tt-ffil ftftd inopQrable cGnditions to verify card OPtRA8ILITY.
OQicriptions of the PBOS are provided in References 1 and 2.
is not postulated ~
~~~~~~~~~~+-~~~licinstability outside
~1--+o~--P'I-~~~d Reg i 0 i9
- Per i 0 die
~~~~~~~d into the t~erfflal hydraulic froffi external sources such as
~~~~s and the pressure ftftd
~ perturbations efrfl flux to oscillate within ~
for neutronie/thermal hydraulic of such oscillatioRs ~ ~
~ algorithm of the PBDS a~d
~~~.~. DR Alarffl. ,= - n of Actuation 4 t, thee
~ l P the Restrictedd Region aAd the the prese~ee of a source r- -1 t A e T core and are not iAdicatioAs ef
~~~~~~~~~~~lic instability.
APPlICAalE SAFETY ANALYSES at Qd
-t h -t ~t-y contrQ~ appl i ed +-I.~~i...-fII.~~~~
3 2.4, "Fraction
-b-1-a- -h~e d Q~tibli~hQd to prevent inatability d-p- g e ty d~ring - n om IM, e R t
. 4, ed OpQrstion ~.~~~~~~
inatability Q ~
~ analyzed ...., . ~~~;w;;u.;:.
spQcificilly evaluated tQmpQratYre decrease inatability.
(continued)
GRAN b LOG 98037
Attachment 44 to Attachment to P-&&5 GNRO-2009-00054 GNRO-2009-00054 B 3.3.1.3 Q :~ . ::z 1 Page 40 40 ofof 49 49 LJ I - . L .
Page BASES T 4 -1 ADDl lr- 4 Q' E APPLICABLE
- I I I ~ 11 - L, L- TAe .- ii~itial L- Q - iqi
-1
- ~
1 .
a
. . .44, :Hlams a53um@d co~ditiot9s M attdfn i~ tRe analysis ~
F T--y ANALYSES SAFETY I a hl a I v!z r- ~S
- .,f - I Ij I- Pems as reasonably ma 6
.14-y e-a conservative e --e rwm,~4 w a~d tRe immediate post eveAt reactor r e-a e ~-r 1E e a (continu@d)
Mt il M t 1 eamdi,A,ans cOt9ditions are sigAificantly stable. Ilowever, ~
11 weve, . ~ assuffied assuffled iAitial conditions do not bound @acR individual paraffieter 1
~ impacts -e t--s stability performancee (Ref. R 3. .)/ . TAe 1.).
1 T6 PBDS I"
0 Q Q!~
1 -11 iAstrumet9tation provides t~ee operator verai:,&r ~ w+t+ aft an iAdieation imAieat4en tRat conditions consistent 1-111 1 ".1 1 ., "_-,it ~ W+-t+ a ~;gnificant u ~, I ~J . . 4 44 -
-Iq I I I , t degradation +ft tAe stability icy performance of the reactor ~ Ras occurred aAd tRe potential for imffiinent ~ of tgeutrot9ic/tRermal-Rydraulic instability ffiay exist. SUCR cORditioAS are only i- a- i 41 -c 4. m a y m a :y lo X, 41 5.
postulated to result from events it9itiated ~ iAitia1
.4- . . 1 4- - A 4-I T- ="a-M.
r I r CvCM 1 . il m 4 '1: 4 a cOAditiot9s beyot9d the eot9ditions assumed in tRe safety s .6. t m d t1h. earidlit'HIPIA .!s attufflt-d im 41:116, saf e+
'I aAalysis (refer to Section 4, Ref. 1). f+:te PODS Iii Iii ~
an I ys 4 E r f-e-r : a S-j le 4. -n -d . R lew f 13 4- .
DQQ!Z I uul) setpoint of 2 ffiot9itored LPRMs with 11 or more successive confirmation counts is 3elected to provide adequate n eaum is sel 4: d- 41: pr vi-d, ad quatle indication of degraded stability p@rformat9ce (refer ~ ++y pr4I F- . rfm ari e to Section 5, Ref. 1).
TRe PODS Ras no i et . 4, n at9d is not a3suffied ~
a n d, 4 S i fUAction during ~ accide~t or traR5ie~t 6, a 1 4-S a ~ a 1yy s is. II 0 'vf e tv er, i"-A-t1il--footr++~"'H'I+'H+-+-Ft-fiil-S the 0191 Y i ~ di cation erf 5 I f7 . i. tildi. eat"i 8, the i mm i ~ en t ~ Ao=F---I=HilH+=F'-t'I-A~~r:-FHi~t-P\-f-~lrf'-R-lI~ 1i c i~stability ty during n in regions of the operating domain potentially t MtHally to instability. TRerefore, the PODS "aLQl9%S is included i
s m~ ~
- 1 Speeificatio~s.
One PODS chantgel ~~~~~~
reactor tgeutton
". . a-
~ - r;": a 11 4 -+H 1
requires reactor sue H i. : ,6,a":, :b .6, !--i4 -, H 4 Ell Rl A 1. a r .fn .,
is not actuated -0 B, B, IS 4. m ttl: r t i mi nt. tt+.o n e I-, a m m e4- .
APPLICABILITY ~~~~~~~~~~~~~*~n cAaRnels ~
operation iM either ~ Hte-r
~~~~~~~d Region 3peeified it9 tRe d R - ~j " - " 5 p e 4, c 4. d- 4. n 44te A-R-t1iil~F-"+-A-n ~ the PODS tli Iii DR Al arm e-f 4:6 e ppn ~ Wi 1 .
-14i
.1 QQ Al a .
.rM e+
E
~~~~I'I++Ff~~F-="l-f'\n n eM6Mt,el -;:s not allo'Qiied i-n a n m I t Mv A4 L, -130wed u I I (eoJ9tiMued)
LOG 98037 Q r-
"j",
Q Q Q ::Z :7 Illv"
Attachment Attachment 44 to to GNRO-2009-00054 GNRO-2009-00054 Page Page 41 41 ofof 4949 APPLICABILITY p L -I C A -B -I L I-T Y thQ R@ tpiGt d Rea gQatrictQd ' i n or the ~onitored Region p d RRegion. Operation ~
(cQntinuid) ~ prQgions Q a o4p,& i~ ~Ysceptible l e to instability .1 (refer y (r- fp-r t to t4+e the r
Bases for lCO 3,2.4 and Section 44 94 of RRef. e4 . 1r 7-1). OP[RABILITY 11 P RA 1 -T T of it lQa~t ono PBDS 4ps one RRf1C ,. FiAR4 pt instru~entation n ehann channe~ and operation pei-ati, ein hi; th no i ndi cati on of a PBDS f:fi f:fi DR /\1 a PAl froFA aAy R RA QPtRA8lE P~QS instrYmentation n ehann channe~ i--, is ttherefore her e required during operitionn in in th these Se ~~~~-,
regions.
~y Mffl-a Red 6y ARRM oww R il --
(RR A) gia4a e bi t "-n Up of At py th R S46 G t- d n-.- Hewe yep ,
that ape Ret 4 de~ t When thQ APRM ~Jeutron ~ - Up Upscalea e COFitrol nt.pel fte.ej Block ~etpoints ~~~~~" the applicable setpoints used to genQrite n t e r 4 r bbouFldary to tthe interior t e a n dT-H-y of f the 4te t,r RQ~triGted con t ra11ed ap eentp@14ed ope rat on ion \,'itA i n tfl.e Ro,tricted R@ai ~~~9!
the t h setpoi s t nt ss aarer- e "Setup" tfl.e 4- k RRe~tricted tr-irt d R alQ, ~~~y remains defined by the norffia~
Region ARRM
~ FIQW Flo\t' Bi eiaiGedd ~ - Upscale Control Rod Block setpointg .
PiraR-leters a-MQ-tQ a+
the th reactor PQ a_ G controls, confirR-lition rQsaonably W-Y The M iqit r- d Region ~*~~~~~~~~
T kQ Monitored this LeO is 1 ~4 + ;@ I ly established analytically tei-iiis ef th efflal, f.TO'We'f' and,core
~ However, unlike d MonitorQd Region boundar fflem i4lered 15-Y
~ instrYmentation B 3.3 39d LOG 98037
Attachment Attachment 44 toto P-&&S GNRO-2009-00054 GNRO-2009-00054 B 3.3.1.3 Page 42 Page 42 of of 49 49 baum4ftr-y APPLICABILITY r e ~ ion \jtl e.Mfl. 4:try.
V.,
~, I ,Y A .
. Tt=I ere f 0 Ie, :kt 6t=I @ 44OM4 11 .1 ~1 0 fl ito
.-. I 4:0 red I d Reg R-e ion b0 U fl cl a ry t-s-g (cofltiflu@a) clefi fled im i fl terms terffl -F of t"tt=lermB~
6 11 r al p~ w r amd, ilrlG ear@ cere -fwd-. fl O*ut. +fl-e
~~ofli 4:tored MaMi 11 1 1 d R,~ Region j *, - bounclal 6A . .iq
" " u" Y f for r :~
tlt=li 64 5 I . . I 5 LCO OV AJ:)~l 4 p p i ecabi a 1 i ty y +-s-4--a specifiedei. f 4 ed 1 ift tMe COLR.
Operation outgide the Restricted Region afld the ~10flitored Region is flot susce~tible to fleutroflic/tM@fmal Ryclraulic instability @@ven v 0 M uund@r
. .I
- d - - extreme I-_ I @ x t r efFre postulated eOflditiofls. eandlilt,14 MS .
ACTIONS d
"iffle e
-r t- -* -
Sel*affl-. I It I Z, ble d G, mp-l't"41AIn l
to tRc of reaete-r seram .
8.1 Bfld B.2 Flow Siagedd Simulated IS 4 ffl t 1 at 1 1 d- Th @ r mi a-1 P-o-we-r TM@rmBl F: ti n e- 4: +ttn1 I to ILCO 3.3.1.1, 1,%J I I . L . J. I ~ 3.3.1.1 I Ll I I I 1
I .
3 1, 3
I -- I I FI- tt M : +tfl
'I ~~~~~~~~. ~ tRe gtability cOrltrol eemtrm applied a-pplHed (r@f@r to LCO 3.2.4) to b@ met.
.& - I-r 1-1) 0 C- of-)
4-Ca
~~~~~n ~ tRc stability cOfltlo1 met ;I:d6i 11 V .
I I y eemtral fffl.et, reactor tRermal Ayclraulic:1, 16. r a ~ - .6. y d 1,- A l.- I, i C
~~~*~n iM tt=le R@stlieted Regiofl. ~
~~~~~~ ifloperabl@, tRc ability to mOflitor 1F-f'Hii---F\'~~;;...;;r. -ftol for i mm i I., e rt t (; fl set of t e*
fHiI-t+F-f~~+-'fi-tI'TfiPtl~-+--~~rH 1i c i fI S tab i 1i t y a gar e 3 u1t of lic I'MM itabi llity at a r f-5tilt 0-f TRerefore, action ~ &e FM u 5 15--e F-A-~~--"F-I'Hii-~~~~ d Reg i 0 fl
- Wfl4-1-e
!-+++¥--..-++1Up~gHc:lo.Jila"""l-Qe C(5 Mt r 0 1 .1ffTej (COl rei I.,ued).4 N B 3.3 3ge LOG 9S837
Attachment Attachment 44 to to P-B-8-5 GNRO-2009-00054 GNRO-2009-00054 8 3.3.1.3 Page Page 43 of 49 43 of 49 ACTIO~~S B+eek setpoil9tss are "Setup," operation il9 the Restricted RegioM may be cOMfirmed by use of plaMt parameters such as reaete-r reactor ~ aNG core fl e(,,4 a'Ite; 1 ebl e at the reactor e fl i:AI col'ttrols.
Region caR be accomplishedd by c019trol
- n flow i19creases. Actiol'ts efts to 0 f5 t a-rt ~~~--f'I-j~~+H-~.~ n 1 00 p, it i t 19 cl raw eo 19 t r 01 r-e-eJ-s may result il9 uuRstable M st e reactor to to be used toa eampiy comply ~
~-fiiilIIo\!~~~~~~~d Reg; on w4+i depeAd Provided efforts are be~un t:tfTt4-1 the Restr; cted Reg; on 4-s-
~~~~t-fo++ee b-a-s-e-J 0 fI the +ew ~ rob a19 i 1; t y stability performance the re~uired P80S eha191gel ReC1ui red Acti on .
- d by a Note that spec; fi es that i19itiation to exit the Restricted Region ~
appl i es if the APR~1 54-flmul at@d S1 te d Tlgermal flo-we-r -
Iii SI9 FUMcti on . Operati on ; r; thee Restri Rl e fit 4 etedete i eted RegioR without Flow Biased Simulated r- 4 Ij I mul a :~
I d
- T6 Thermal 1 1 . rffla-1 Pow flo-we-r Iii 919 FUflcti on " MI'14, cates umeamtr
, i Mdi eatel uflcofltroll ed ed ~ i-ft-t:.e trte Restri cted Re§i Ofl.. U"corltroll M.e- M:': r edd efl-t-f-:y "ti- i 5s eem COM!;1 stent 5: 41 mt vi; tR tf:le occurreMce d traMS; erlts, wlq WRi4,-6-eM, ffi combil9ation of stability col'ttrols ~ met may result . degradation of stability ty performal'tce.
~~ I, @ M t fl e APR~1 Flux Up !5 eale Con t t 01 Rod 810ck setpoi I,ts ~il---A~~~~" uflcontroll edd efl-t-f-:y ~
the Restricted R@gion d ~~~'t by reeei~t of ~~- a valid a I +d
~ Iffiffiediate n ~ RREA is valid ~
iRdicatess am I I IdA ae afl actual iMto the Re3trieted R@gion ma) be performed ffitrtout Immecliate eOflfirmation cOMstitutes observation that I a m ~arameters iffifflediately available at, p~lal'tt a ~
t~@ r@aetor A VS /S e a M trtr~
a etor eontrols . . , r@actore a e+tw ~ aand vidl eore flow~ a w -) ~ ar reasoRa19ly eemsi 5temt cOflsistel'tt efl-t-f-:y iflto 4:6e Q S :~p4pi:-
t~e Restricted Region.
ixe g ivig .
B 3.3 39f +9-f LOG 98037
Attachment Attachment 44 to to P-BB£ GNR4-2009-00054 GNRO-2009-00054 8 3.3.1.3 Page Page 44 44 of of 49 49 ACTIONS 9T- I Q4LS'z B.1 and B.2 (continued) 19til
~ iffifficdiate ilm-Ffl- iate confirmation may also constitute recognition that plant that plant papaffletl-ers paraffieters ape are rapi,dlyrapidly changing during fr transient (e.g., a recirculation pump trip~ ~ 4 1 , 4- 4 4- N -A, 4 e h ee-~~
Peasenably Fesu reasonably result in entry into the Restricted Region.
~or uncontrolled ~ into the Restricted Region w+tfl tft required4 PBDS instrumentation channei inoperable, tft abilit~ to to fflpni ffionitor :~ econditions e n id ilt. -*. - s indicating the potential I p -A '. : ent. 4 a 1 ~
I iffiffiinent ~ of neutronic/thermal hydraulic I i c iinstability
. m s : . a b 4 14. '.-- y 4 ~ -5r lostest and H t i 19 H .,4 operation is not justified.
and continued I Therefore, u i Fe d A Required o t il e n B.2 Action 2 Frequires e qu i i--~ immediate Fflffl e reactor scram.
reaeter sepa-ffl-.
in In the h Meni .teppd Region Monitored Hi Hi DR Alarm
-D IQ, -A 1 -a-m providese r a v il dl indication of degraded indi,eatien performance. Operation ~
th the Men;Moni-mod tored" Regi on ~.~M::t'5'ee-~t-t:rte to neutrot9i c/tt1ermal-Hyar-auii hydraulic Iinstability postulated conditions exceeding t-h-e-s-e pre vi 0 U sly the s af ety ana 1:)' sis . W+-tfl tft required PBDS channel * , the ability to monitor conditions indicating
- 1 for imminent a~ M fs et d+ of instability is lest. Therefore, exit the Monitored Region.
Actions to restart
- n loop, witt1draw control rods or reduce n flo'fi! ma:)' resul t ffi approaching unstable conditionss and are not allowed to be used to comply Required "-d Action.
14, e 'E. il e ft . Exit of the Monitored Region ~*~~~~~~d by eOt9trol rod iMsertion and / 0 r r ccire u1 ation H0,,, e '0' e r, act i 0 MS w-h-i-e+l reduce recirculation provided the Fraction of Core Bo; 1; ng Boundar i 5 reeentl y ('v49 thi n 1 -p 4 ffi;nutcs) verified Recent Rl e e n -t verification yep9 9--a n of FC8B
~ ATe.:&-; provi des e that Hi th the PBDS i Moverab floperabl e,
- H I-pl aiqlq q! anned decreasese r- e a s c:-,- *
- n ~ f+e.w shoul fil-dd metTe-t result r- u 1 t in significant
- n of core st stability a 11-1 4-4 perforffiance.
(coAtinu@d)
B 3.3 399 LOG 98037
Attachment Attachment 4 4 to to fl&8.5 GNRO-2009-00054 GNRO-2009-00054 8 3.3.1.3 Page Page 45 of 49 45 of 49 4A4-E-S ACTIONS G.l (continued)
The sspecified I f 4-e-d GCompletion ell, m 1. -et. n Ximp v riffle of IS. miAllte-,
A4 3F ffliMutes eM~ur@s timely Ili,-- I-Y E) F) e r-rato ope a r aeti et g' en on to e)(i t the reg; on COl9 Si stel9t '09'; tM tMe 1 ow probability that -a tl Peaet
- reactor c019clitions exceed the ;"iti6~
md4i,eigs assuffl conditions assumed i,infq tthe 1Q. safetly safety analysis. The time requi wiped red te to exi,t, e><; t tlq,"the IMOA .H4,tared
~4ofli Ped Regi 019 'vi; 11 clel'efld etn Provided efforts are begun
\,,1 i t hi n 15 ffi; nut es a Ad co At i 19 Ued Uti til t 19 e ti 0 19 ito red Reg ion ii s5 e)( - X, 4i ted, e-d-, 0 per a t ion i 5 ace e pta b1e bas e eI 019 t 19 e 1 0 'vi Pp babi probability 1 lit y of a transient wft+efl de~rades stability 1 .
pe f P an e eeeup performance oceurritig simultafleously w4-t+l tRc reefuired PB-Et5 channe~ inap inoperable. r 6-1-e .
SUR'IE I LLI'JJCE ~ 3.3.1.3.1 REQU I R~J4ENTS Ouri ng Bur-4igg operati patien on ~.~~ioo-of+I~~~-Ao Region z' Tt PBDS Hi U4 the PQQ ~U4 Hi 19 conditionsdi I ti v I eigs eeigsisteig COflsistent t neutronie/thermal hydraul*c 19 i PE)iqi.e4i:
hepffl r 4. e at. 4, a n 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> provides e m ea n alarm during operation ~.~~~~~~~
Monitored RegioR.
forffial; but morc frequcflt 5t, a t.i i s 4 (1 tI r 1 Mg operation.
SR 3.3.1.3.2 a gpe i i9di, eat-i-en uffient e !,,A,,,, -1 a- i, e n e a 1919, 1 S 9 afl 44 G H 1: C-K- will! d-eiEl-e el-S 8 3.3 39h LOG 98037
Attachment 44 to Attachment to P-BB-5 G N RO-2009-00054 GNRO-2009-00054 B 3.3.1.3 Page 46 Page 46 of of 49 49 SURVEILLANCE &R 3.3.1.3.2 (coMtiMued)
REQU I RE~i ENTS verifyiMg the iM5tl umentation A 1 IA A
- 11 IaS . l . .l 4Y1 A 1A t t`
+4 A continues to operate properly
/
between each CIIA~~NELL FUNCTIONAL ~~-L TE =Ff:-&f-.-. A9reement cri teri a are determinedd by the ~lant ~ -F A-~~-t 5~ff 6~ on
~ e~r~- a-~~-ice combinationn e4 e*
- 6 n n1n+1
't~e c~annel instrument W1rtA 1 t unc@rtainti@s, u t, a wil te-s . including
- 4. : i. m 1 a i-n~a ~. -erg c1 indication; and readability.
TRe 12 ~our FreetueMcy ;5 based on o~erating eXJgerieflce t-ITa-t ri n mom Strait d@ffloflstrat@s A /R chanMel failure is rare. Tfte CIIANNEL 6++E--K sUJ9pl@ments e m t s less -fformal, a , but 11i 41:1 more freetuent, e~eeks frt chann@ls cluring E~ r +Itg norma~r al opera-- . use of the displays oJgerational n . A associ ated ~ tH M
s I"1 IIR 'S
,~ r
~R r: v ri t~e channel s reCfui red b)' the LCO.
M 4Y it1 A
&R 3.3.1.3.3
---G A CHANNELH A*N-F~ FUNCTIONAL F G -H dA L T-E-£1 ~.i+--A-i~~wa-d for the PBDS to en5ure that the entire perform the intended functi on. TRe CItA~~NEL L T-E-£1 for the PBDS i nel udes manuai initiation A h 'kA' IA a test seetuence &ft6 A h I'V 1 1 A Ih A A verification of approJ9riate and inop conditions ~
reported.
PPerform8flce °fram e e of a11 8 CIIANNEL ~ ~H-+-+++t'tH*L T-E-£1 at a Fr@queflcy ef 24 months y-e- verifies=F=ps ~~~~~~e of t1ge PBDS ana associ ated ei feui try. ~ilIr--+-~~~Y eons; clers the 191 ant conclitioMs feetuired test, the ease of performing the test, ~~~++~~~~d of a change in the 19 6-e system or or - component effl~t s ta statu5$ The alarm circuit is designed 11-aM~ e=rg t~~t 4 Is d e
to operate ~ sufficient accuracy 8fl W1 151- SH44 signal amplitude ~an~d~~~ . . considering environment, initiai calibration y ~ (Ref. 2).
REFERENCES ~ NEOO 32339 A, ~,,~~~~~~. ~Q~y LOR9 T@rmSolutioR:
FEnRanced
-l-, a-e-ee-d Option
~ NEOC 32339P A, ~~-A ,
t
, "hRe-aear '~ ~y
'~
ra f-e-Ffn Solution:
S e l-t t a End 8 e A 1
-1A.
' ° A n
B 3.3 39; LOC 98037
Attachment Attachment 4 to 4 to Recirculation Recirculation Loops Loops Operating Operating GNRO-2009-00054 GNRO-2009-00054 B 3.4.1 B 3 .4 .1 Page 47 Page of 49 47 of 49 BASES BASES APPLICABLE APPLICABLE margins margins during during abnormal abnormal operational operational transients transients (Ref. 2),
(Ref . 2),
SAFETY ANALYSES SAFETY ANALYSES which are which are analyzed analyzed in in Chapter Chapter 15 15 of of thethe UFSARUFSAR.
(continued)
(continued)
A plant A specific LOCA plant specific analysis has LOCA analysis has beenbeen performed performed assumingassuming only one operating recirculation loop .
only one operating recirculation loop. This analysis has This analysis has demonstrated demonstrated that, that, in in the the event event of LOCA caused of aa LOCA caused by by aa pipe pipe break break in in the the operating operating recirculation recirculation loop, loop, the Emergency the Emergency Core Cooling ling System System responseresponse will will provide provide adequate adequate core cooling, provided provided the the APLHGR requirements are APLHGR requirements are modified modified accordingly accordingly (Ref (Refo. 3). 3) .
The transient The transient analyses analyses of of Chapter Chapter 15 15 ofof the the UFSARUFSAR have have also also been been performed performed for for single recirculation loop single recirculation loop operation operation (Ref (Ref.. 3) 3) and and demonstrate demonstrate sufficient sufficient flow flow coastdown coastdown characteristics to maintain fuel thermal margins characteristics to maintain fuel thermal margins duringduring the the abnormal abnormal at ono operational transientsTents analyzed provided the analyzed provided the MCPR MCPR requirements are requirements modified . The are modified. The APLHGR APLHGR and and MCPR MCPR limits limits for for single loop single loop operation operation are specified in are specified in the the COLR.COLR .
Recirculation Recirculation loops loops operating satisfies Criterion operating satisfies Criterion 2 2 of the of the NRC Policy NRC Statement .
Policy Statement.
LC LCOO Two Two recirculation recirculation loops loops are are normally normally required required to b inn to be operation with their flows matched within the limits operation with their flows matched within the limits specified in specified in SR 3 .4 .1 .1 to SR 3.4.1.1 to ensure ensure that that during during aa LOCA LOCA caused caused by by aa break break of of the piping of the piping of one one recirculation recirculation loop loop thethe assumptions ons of of thethe LOCA analysis are LOCA analysis are satisfied.
satisfied . I Alternatively, Alternatively, with with only only one one recirculation recirculation loop loop in in operation, modifications to on, modifications to the required APLHGR the required APLHGR limitslimits (LCO 3.2.1, "AVERAGE AVERAGE PLANAR PLANAR LINEARLINEAR HEAT HEAT GENERATION GENERATION RATE RATE (APLHGR)"), MCPR limits (LCO MCPR limits RCO 3.2.2, 3 .2 .2, "MINIMUM "MINIMUM CRITICAL CRITICAL POWER POWER RATIO RATIO (MCPR)",(MCPR)", and and APR~4 Flo'" 8; ased 5; fflul ated TMermal Powe,-
WA 1 17 U_-L]
High, W; k ALLOWABLE A Value (LCD 3.2.4, "Fraction of Core 80iling 99 undaFY (K~, LCO Boundary" Cl=CBB), 3 .3 .1 .1, "RPS LCO 3.3.1.1, "RPS Instrumentation",
Instrumentation" ; and f, a :2 11 w e ,-4 0 .4 Q Q - t - - _* - r. ,
LCO IL-1,V 3.3.1.3,
- Z 3 :~ "P@tiod I I I
, p - -4 Detection Based U DOZ-=u LJI= t=t~ lull System" J y _111h!111 A QQRQ 4-(PBDS))
krDul))) mustmust be be applied applied to allow continued to allow continued opera cons stmt with operation consistent with the assumptions assumptions of of References.
Reference~ 3 3 ~.
The LCO The LCO is is modified modified by by aa Note Note which which allowsallows up up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 12 hour before before having having to to putput in in effect effect the the required required modifications modifications to to required red limits after limits after a a change in the reactor change in the reactor operating operating conditions conditions from from two two recirculation recirculation loops loops operating operating to to single single recirculation loop operation .
recirculation loop operation. If the required limits are If the required limits are (continued)
(continued)
GRAND GRAND GULF GULF B 3 .4-3 B 3.4-3 LDC 98037 LDC 98031
Attachment Attachment 44 to to Recirculation Loops Operating Recirculation Loops Operating GNRO-2009-00054 GNRO-2009-00054 BB 3.4.1 3 .4 .1 Page 48 Page 48 of of 49 49 BASE BASES (continued)
(continued)
REFERENCES REFERENCES 1. UFSAR, UFSAR, Section Secti on 66.3.3.7.
.3 .3 .7 .
.4 .1 .1 .
- 4. "Reactor Stability 1Long NEOO 32339 A, "Reaete 11 C' 4-Ij I'luo I v emg Term . 1, ut, 4 Term SSolution: 1 1-1 .
EAhaAced O~tien ~
- 5. Deleted De 1eted GRAND GULF GRAND GULF BB 33.4-8
.4-8 LDC 98037 LDC 98037
Attachment Attachment 44 to to GNRO-2009-00054 GNRO-2009-00054 SDM Test SOM Refueling Test--Refueling BB 3.10.8 3 .10 .8 Page Page 49 49 of of 49 49 ASES BASES APPLICABLE APPLICABLE eRDA analyses CROA analyses assume assume that that the the reactor operator follows reactor operator follows SAFETY SAFETY ANALYSES ANALYSES prescribed withdrawal sequences .
prescribed withdrawal sequences. For SDM For SDM tests tests performed performed (continued)
(continued) within these defined sequences, the analyses of References 1 within these defined sequences, the analyses of References 1 and 22 are and are applicable applicable.. However',
However, for for some sequences developed some sequences developed for the for the SDMSOM testing, testing, the the control control rod patterns assumed rod patterns assumed in the safety analyses of References 1 and safety analyses of References 1 and 2 2 may may not not be met .
be met.
Therefore, special CRDA Therefore, special CRDA analyses, analyses, performed performed in in accordance with i th an NRC approvea an NRC approved mmethodology, are required i to demonstrate demonstrate that that the the SDM SDM test test sequence will will not not result result in in unacceptable table consequences consequences s should a CRDADA occur occur during during the the testing.. For testing For the the purpos purpose of this test, protection protection provided provided by by the the normally normally required required M MODE 5 applicable applicable LCOs, LCOs, in in addition addition to to the the requirements requirements of in this lCO, will maintain normal normal test test operations operations as as well well as pos as postulated accidents within accidents within the the bounds bounds of the of the appropriate appropriate safety safety analyses (Refs (Refs.. 1I andand 2).2) . In In addition to addition to the the added added requ cements for ,the requirements the Rod Rod Pattern Pattern Controller Controller (RPC (RPC), APRM, and control control rod rod coupling, coupling, the the single single notch notch withdrawal withdrawal mode mode is pacified for is specified for outout ofof sequence sequence withdrawals.. Requiring withdrawals Requiring the th singleingle notch notch withdrawal withdrawal mode mode withdrawal steps limits withdrawal limits steps to to a single notch, h, which which limits limits inserted reactivity, inserted reactivity, and all and allows adequate monitoring i ng ofof changes in neutron fl changes in neutron flux, which may occur during the tes occur during the test.
As described As described in LCO 33.0.7, in LCO .0 .7, compliance compliance with with Special Special O'perations LCOs is Operations LCOs is optional,t optional and and therefore, therefore, no criteria of no criteria of the NRC the ARC PolicyPolicy Statement Statement apply apply. . Special Special Operations Operations LCOs LCOs provide provide flexibility flexibility to to perform perform certain certain operations operations by by appropriately modifying appropriately modifying requirements requirements of of other other LCOsLCOs.. AA discussion discussion of of the the criteria criteria satisfied satisfied for the other for the other LCOs LeOs is is provided in provided in their their respective respective Bases. Bases .
LLCO 0 described in As described As in LCO LCO 33.0.7,
.0 .7, compliance compliance with with this Special this Special Operations LCO Operations lCO 1s is optional.
optional . SOH SDM tests tests may may bebe performs performe while while in in MODE MODE 2, 2, in in accordance accordance with Table 1.1-1, with Table 1 .1-1, wit wit.Wuut sting this meeting Special Operations this Special Operations LCO LCO oror its its ACTION.
ACTION. For For SDMSDM tests performed while tests performed while in MODE 5, in MODE 5, additional additional re re cements rements must be must be met met to to ensure ensure thatthat adequate adequate protecti protecti against against potential ial reactivity reactivity excursions excursions is is avai1ab avail a .. ToTo provide provide additional scram additional scram protection, protection, beyond beyond the ormally required the ormally required IRMs, the Ids, the APRMs APRMs are are also also required required ttt OPERABLE OPERABLE (LCO 3 .3 .1 .1,
{lCO 3.3.1.1, Functions Functions 2 .a 2.a ~ 2.
2.e as though as though the the reactor reactor were were in in MODE MODE 2 2.. Because Because m iple control Mm `ti pie control rods rods will will be be thdrawn withdrawn w and and the the reactor reactor w w 11 11 potentially potentially become become critica critical, the approved control the approved control rod rod wiwi hdrawal hdrawal sequence sequence must must bebe enforced by enforced by the the RPC (LCO (LCO 33.3.2.1,
. .2 .1, Function Function 1b, MODE 2),
Ib, MODE 2), oror continued GRAND GULF B 3.10-33 Revision No. 0
ATTACHMENT ATTACHMENT 66 G NRO-2009-00054 GNRO-2009-00054 GE GE HITACHI HITACHI NUCLEAR NUCLEAR ENERGY ENERGY REPORT 0000-0107-7607-NP-R1 REPORT 0000-0107-7607-NP-R1 GRAND GULF GRAND GULF NUCLEAR NUCLEAR STATION-GRAND STATION - GRAND GULF GULF PRNM UPGRADE PROJECT PRNM UPGRADE PROJECT OPTION III STABILITY OPTION III STABILITY DEVIATIONS DEVIATIONS (NO -PROPRIETARY VERSION)
(NON-PROPRIETARY VERSION)
GE Hitachi GE Hitachi Nuclear Energy Nuclear Energy P.O. Box 780 P.O. Box 780 Castle Hayne 3901 Castle 3901 Hayne Rd Rd Wilmington, NC 28402 Wilmington, NC 28402 0000-0107-7607-NP-R1 0000-0107-7607-NP- Rl DRF 0000-0102-6642 DRF 0000-0102-6642 Revision Revision 11 Class III Class III October 2009 October 2009 Non-proprietary Non-proprietary Version Version Grand Grand Gulf Gulf Nuclear Station Nuclear Station Grand Grand Gulf Gulf PRNM Upgrade Project PRNM Upgrade Project Option-Option III III Stability Stability Deviations Deviations Principal Principal Contributor Contributor Juswald Vedovi Juswald Vedovi Principal Verifier Principal Verifier Alan Alan Chung Chung Approving Approving Manager Manager Erik Kirstein Erik Kirstein
0000-0107-7607-NP-R1 OOOO-Ol07-7607-NP-Rl GEH GEH NON-PROPRIETARY NON-PROPRIETARY INFORMATION INFORMATION REVISION
SUMMARY
REVISION
SUMMARY
Rev Required Changes to Achieve Revision I1 Editorial Editorial change change:: the the header header was was modified modified from "GEH Proprietary from "GEH Proprietary Information" to "GEH Information" to "GEH Non-Proprietary Information" since this is the Non-Proprietary version of the report .
Non-Proprietary Information" since this is the Non-Proprietary version of the report.
0000-0107-7607-NP-R1 0000-0107-7607-NP-Rl GEH GEH NON-PROPRIETARY NON-PROPRIETARY INFORMATIONINFORMATION INFORMATION NOTICE INFORMATION NOTICE This This is is aa non-proprietary non-proprietary version version of the document of the document GE-NE-0000-0 I 07-7607-NP-RO, which GE-NE-0000-OI07-7607-NP-RO, which has has the proprietary the proprietary information information removed. Portions of removed. Portions the document of the document thatthat havehave been been removed removed are are indicated indicated byby an an open and closed open and bracket as closed bracket as shown shown here here ((
(( )).
)).
IMPORTANT IMPORTANT NOTICE NOTICE REGARDING REGARDING CONTENTS CONTENTS OF OF THIS REPORT THIS REPORT PLEASE READ PLEASE READ CAREFULLY CAREFULLY The The information information contained contained in in this this document document is furnished for is furnished the purpose for the purpose to to support the NRC support the NRC review of review of the the Grand Grand Gulf Gulf Nuclear Station license Nuclear Station license application application forfor implementation implementation of of the the power power range range neutron monitor. The neutron monitor. only undertakings The only undertakings of GEH with of GEH with respect respect to to information information in this in this document document are contained in are contained in contracts contracts between between GEH GEH andand the the parent parent company company of of Grand Grand Gulf Gulf Nuclear Nuclear Station, Station, and and nothing nothing contained contained in in this this document document shallshall bebe construed construed as as changing changing thosethose contracts contracts.. The The use use of this information of this information by anyone other by anyone other than than those those participating participating entities entities and and forfor any any purposes purposes other other than than those those for for which which itit is intended is is intended is not not authorized; authorized; and and with with respect respect toto any any unauthorized unauthorized use, GEH makes use, GEH makes no representation or no representation or warranty, warranty, and assumes no and assumes no liability as to liability as the to the completeness, completeness, accuracy, accuracy, oror usefulness usefulness ofof the the information information contained contained in in this document.
this document.
Copyright Copyright GE GE Hitachi Hitachi Nuclear Nuclear Energy Energy Americas Americas 2009 2009 ii
0000-0107-7607-NP-R1 OOOO-Ol07-7607-NP-Rl GEH NON-PROPRIETARY GEH NON-PROPRIETARY INFORMATION INFORMATION Grand Gulf Grand Gulf Option Option III III Stability Stability Deviations Deviations Grand Grand Gulf Gulf Nuclear Nuclear Station (GGNS) will Station (GGNS) will submit submit aa license application for license application the implementation for the implementation of of Power Power Range Neutron Monitor Range Neutron (PAM) using Monitor (PRNM) using the Long Term the Long Term Stability Stability Solution Solution Option Option III.
111. The The basis for basis for the the license license application application isis contained contained in in the relevant licensing the relevant licensing topical topical reports (References reports (References I1 -- 6) and Safety
- 6) and Safety Communications Communications (References (References 77 -12). 12).
The The special Long Term special Long Term Stability Stability Solution Option III Solution Option developed for III developed for GGNS GGNS has two deviations has two deviations from from the the referenced documents . Each referenced documents. Each deviation deviation is is justified justified asas being being conservative relative to conservative relative the to the relevant licensing relevant licensing documents documents as as is summarized in is summarized in Table Table 1.1. A A more more detailed detailed discussion discussion of the of the justification justification is presented below.
is presented below .
Technical Technical Justifications Justifications::
The The justifications justifications for for these two deviations these two deviations in in Table Table 1I are are provided below .
provided below.
a) Base Period a) Base Period Definition Definition forfor PBDA PBDA The The Option Option III III licensing licensing basis basis defines defines thethe base base period period asas the the average average of all successively of all successively confirmed confirmed periods periods (Reference (Reference 1).1). The The GGNS GGNS OptionOption III defines the successive base period III defines the successive base period asas equal equal to to the the previous previous period period that that isis within within PBDA PBDA T min and Tmin and Tm,,,,
Tmax limits.
limits. T Tma, max is is defined defined as the as the oscillation oscillation periodperiod upper upper time time limit for the limit for the Period Based Detection Period Based Algorithm (PBDA)
Detection Algorithm (PBDA) whilewhile T Tmin min is is defined defined as as the the oscillation oscillation period period lower lower time time limit limit for for the the PBDA PBDA.. (( ((
)) Therefore,
)) Therefore, thisthis change change doesdoes notnot significantly significantly increase increase thethe frequency frequency of of spurious spurious scrams scrams duringduring normal normal operation, operation, precluding precluding any any anomalous anomalous oscillatory oscillatory behavior behavior with with aa
- Page 1 -
0000-0107-7607-NP-R1 0000-0 107-7607-NP-R1 GEH NON-PROPRIETARY GEH INFORMATION NON-PROPRIETARY INFORMATION frequency frequency range range typical typical of of thermal-hydraulic thermal-hydraulic instability, instability, or adversely impact or adversely impact the the plant plant ability ability to to provide SLMCPR protection provide SLMCPR protection..
This change This change is is conservative relative to conservative relative to the the Option Option IIIIII licensing licensing basis.
basis.
b) b) Period Period Tolerance Tolerance Offset Offset The period The period tolerance offset is tolerance offset is aa feature to maximize feature to maximize the ability of the ability of the the PBDA PBDA to to recognize recognize thethe initiation of oscillations following a fast flow runback event. ((
initiation of oscillations following a fast flow ronback event. ((
))
)) TheThe comparison comparison is based on a simulated instability event and shows that the indicated signal will confirm is based on a simulated instability event and shows that the indicated signal will confirm successive confirmation counts successive confirmation counts much much sooner sooner with with the period tolerance the period tolerance offset. ((
offset. ((
)) Therefore, this
)) Therefore, this change change doesdoes not not significantly significantly increase increase the the likelihood likelihood ofof spurious spurious scram scram or or adversely impact the adversely impact the plant plant ability ability to to provide provide SLMCPR SLMCPR protection.
protection.
This This change change is is conservative conservative relative relative to the Option to the Option III III licensing licensing basi basis.
- Page 2 -
0000-0107-7607-NP-R1 0000-0107-7607-NP-Rl GEH NON-PROPRIETARY GEH ON-PROPRIETARY INFORMATION INFORMATION References References 1 . NEDO-31960-A
- 1. NEDO-31960-A Supplement Supplement 1, 1, "BWR "BWR Owners' Owners' Group Group Long-Term Stability Solutions Long-Term Stability Solutions Licensing Methodology,"
Licensing November 1995.
Methodology," November 1995.
2 . NEDO-31960-A,
- 2. NEDO-31960-A, "BWR "BVV-R Owners' Owners' Group Group Long-Term Stability Solutions Long-Term Stability Licensing Solutions Licensing Methodology," November Methodology," November 1995.1995 .
- 3. NEDO-32465-A, "Reactor
- 3. NEDO-32465-A, "Reactor Stability Stability Detect Detect and and Suppress Suppress Solutions Solutions Licensing Licensing Basis Basis Methodology for Methodology Reload Applications,"
for Reload Applications," August 1996 .
August 1996.
4 . NEDC-32410P-A
- 4. NEDC-32410P-A Volume Volume 1, 1, "Nuclear "Nuclear Measurement Measurement Analysis and Control Analysis and Control Power Range Power Range Neutron Monitor Neutron Monitor (NUMAC (NUMAC PRNM) PAM) Retrofit Retrofit Plus Plus Option Option III Stability Trip III Stability Trip Function,"
Function,"
October 1995 .
October 1995.
- 5. DC-324 I OP-A Volume
- 5. NEDC-32410P-A Volume 22 -- -- Appendices, Appendices, "Nuclear Measurement Analysis "Nuclear Measurement Analysis and Control and Control Power Power Range Range Neutron Neutron Monitor SUMAC PRNM)
Monitor (NUMAC Retrofit Plus PRNM) Retrofit Plus Option Option III III Stability Trip Stability Trip Function,"
Function," October 1995.
October 1995.
6.
- 6. NEDC-32410P-A, Supplement 1, NEDC-32410P-A, Supplement 1, "Nuclear "Nuclear Measurement Analysis and Measurement Analysis Control Power and Control Power Range Neutron Monitor Range Neutron Monitor (NUMAC (NUMAC PRNM) PAM} Retrofit Retrofit Plus Plus Option III Stability Option III Trip Stability Trip Function,"
Function," November November 1997.1997.
7.
- 7. Safety Safety Communication Communication 02-09, "Stability Option 02-09, "Stability Option III III Trip Trip Adequacy Adequacy forfor Instability During Instability During Fast Fast Transients," July 26, Transients," July 2002 .
26, 2002.
8.
- 8. Safety Safety Communication Communication 02-21, 02-21, "Stability Option III:
"Stability Option III: OPT OPRM Tmin Tmin Specification,"
Specification,"
November November 22, 2002 .
22,2002.
9.
- 9. Safety Safety Communication Communication 03-20,03-20, "Stability "Stability Option Option III III Period Period Based Detection Algorithm Based Detection Algorithm Allowable Allowable Settings,"
Settings," October October 4, 4, 2003 2003..
10.
- 10. Safety Safety Communication Communication 03-02, "Stability Option 03-02, "Stability Option III III OPT OPRM ArmedArmed Region Boundary,"
Region Boundary,"
February February 17, 2003 .
17,2003.
11 11.. Safety Safety Communication Communication 07-18 07-18 Rev. Rev. l,"OPRM 1,"OPRM Armed Armed Region Region Boundary,"
Boundary," October 19, October 19, 2007.
2007.
- 12. Safety
- 12. Safety Communication Communication 07-19 07-19 Rev. l,"OPRM Armed Rev. 1,"OPRM Armed Region Region Boundary,"
Boundary," October October 19,19, 2007.
2007.
13 13.. NEDC-33075P-A NEDC-33075P-A RevisionRevision 6, 6, "General "General Electric Electric Boiling Boiling Water Water Reactor Reactor Detect Detect and and Suppress Suppress Solution Solution -- Confirmation Confirmation Density,"
Density," January January 2008 2008..
- Page 3 -
0000-0107-7607-NP-RI 0000-0107-7607-NP-Rl GEH NON-PROPRIETARY GEH INFORMATION NON-PROPRIETARY INFORMATION Table 1 . GGNS Table 1. GGNS Option Option III III Deviations Deviations aa Base Period definition Base Period definition Average of Average of all all The previous The previous Conserv Conservative for PBDA forPBDA successively successively successively confirmed successively confirmed confirmed confirmed periods periods period (Reference 13) period (Reference 13)
(Reference ce 1) 1)
b Period Tolerance Period Tolerance Not aa solution Not solutio (( Conservativ Conservative Offset Offset feature .
feature.
11 following
)) following aa fast flow fast flow reduction reduction event event
- 13) .
(Reference 13).
(Reference
- Page 4-
0000-0107-7607-NP-R1 0000-0107-7607 -NP-Rl GEH GEH NON-PROPRIETARY NON-PROPRIETARY INFORMATION INFORMATION Figure 1. Effect Figure 1. Effect of eriod Tolerance of Period Tolerance Offset on the Offset on the Successive Confirmation Count Successive Confirmation Count Response*
Response*
((
))
- (( ))
- Page 5 -
ATTACHMENT ATTACHMENT 77 G N RO-2009-00054 GNRO-2009-00054 LICENSEE-IDENTIFIED LICENSEE-IDENTIFIED COMMITMENTS COMMITMENTS
Attachment 7 to to GNRO-2009-00054 GNRO-2009-00054 Page 11 of Page 2 of 2 LICENSEE-IDENTIFIED LICENSEE-IDENTIFIED COMMITMENTS COMMITMENTS The The following following tabletable identifies identifies those actions committed those actions committed to to by by Entergy Entergy in in this this document.
document. Any Any other statements other statements in in this this submittal submittal are are provided provided for for information information purposes purposes and and are are not not considered to considered to be be regulatory commitments .
regulatory commitments.
TYPE SCHEDULED (Check one)
COMMITMENT COMPLETION NE- CONTINUING DATE TIME COMPLIANCE (If Required)
ACTION 11.. Entergy Entergy will will conduct conduct aa monitoring monitoring periodperiod of the of the Following Following OPRM for OPRM for aa minimum minimum of of 90 90 days days not not toto completion completion of of the the exceed exceed oneone fuelfuel cycle cycle after after plant plant startup startup OPRM Monitoring OPRM Monitoring following following the the 20122012 refueling refueling outage outage to to be be Period Period successfully completed successfully completed priorprior toto enabling enabling the the OPRM.
OPRM.
2.
- 2. During the During the OPRM OPRM Monitoring Period, the Monitoring Period, the During During thethe OPRM OPRM outputs from outputs from the OPRM Upscale the OPRM Upscale function function willwill Monitoring Period Monitoring Period not be connected to the RPS trip output relays not be connected to the RPS trip output relays while while the the OPRM OPRM alarmsalarms and and indications indications will will be be provided provided to to the the operators operators..
3.
- 3. Entergy Entergy will perform OPRM will perform OPRM surveillances surveillances that that Prior to Prior to and and during during can be can be performed, performed, or or partially performed, prior partially performed, prior the the OPRM OPRM to startup from to startup from thethe 2012 2012 refueling refueling outage outage or or Monitoring Period Monitoring Period on-line on-line as as part part ofof post-modification post-modification testing, testing, industry experience, industry experience, and and factory factory acceptance acceptance testing of the testing of the NUMAC NUMAC PRNM PRNM System.System.
4.
- 4. During the During the OPRM OPRM Monitoring Monitoring Period, Period, the the During During thethe OPRM OPRM OPRM Upscale function will not be relied upon OPRM Upscale function will not be relied upon Monitoring Period Monitoring Period to mitigate aa stability to mitigate event; rather stability event; rather GGNS GGNS will will implement Backup implement Backup Stability Stability Protection Protection (BSP) (BSP) specified specified inin BWROG BWROG documentdocument OG OG 02-0119-02-0119-260, 260, GE GE toto BWROG BWROG Detect Detect andand Suppress Suppress // /I Committee, "Backup Committee, "Backup Stability Protection (BSP)
Stability Protection (aSP) for for Inoperable Inoperable Option Option ///
11/ Solution,"
Solution," as as an an alternate alternate method method for for detecting detecting and and suppressing suppressing instabilities instabilities until the OPRM until the OPRM Monitoring Monitoring Period Period has has been been successfully successfully completed completed..
5.
- 5. The The BSP BSP measures measures will will be be implemented implemented via via plant procedures .
plant procedures.
to to G NRO-2009-00054 GNRO-2009-00054 Page Page 2 2 of of 22 TYPE--_
SCHEDULED Check one COMMITMENT COMPLETION ONE- DATE CONTINUING TIME COMPLIANCE (If Required)
ACTION 6.
- 6. At the At the end end ofof the the OPRM OPRM Monitoring Monitoring Period, Period, Completion of Completion of the the Entergy will Entergy will review review the the operating operating data, data, OPRM Monitoring OPRM Monitoring setpoints, setpoints, andand margins.
margins . OnceOnce the the results are results are Period Period determined determined to to be be acceptable, acceptable, EntergyEntergy will will enable enable thethe OPRM OPRM (with (with applicable applicable SRs SRs met) met) by connecting itit to by connecting to the RPS trip the RPS trip relays .
relays.
7.
- 7. Entergy will Entergy will notify the NRC notify the NRC when when the the OPRM OPRM Completion of Completion the of the Monitoring Monitoring Period Period hashas been been successfully successfully OPRM OPRM Monitoring Monitoring completed completed.. Period Period 8.
- 8. The Period-Based Detection The Period-Based Detection algorithm algorithm "tuning" "tuning" parameters parameters will will be be established established in in accordance accordance with with GGNS GGNS procedures procedures as part of as part of the system the system setup and calibration, setup and calibration, and will be and will defined in be defined in plant procedures plant procedures..
9.
- 9. The Period-Based Detection The Period-Based Detection algorithm algorithm trip trip setpoint setpoint will be documented will be documented in in the the COLR.
COLR.
10 10.. Administrative Administrative controls controls will be provided will be provided for for manually manually bypassing bypassing the the APRM APRM 1/ OPRM OPRM channels channels or or protective protective functions, functions, and and forfor controlling controlling access access to to the the APRM APRM I/ OPRM OPRM panel panel and and channel bypass switch channel bypass switch..
11 11.. Documenting Documenting the the HFE HFE review review will will bebe included included Prior Prior to to startup startu p in in the the final final design design packages packages for for the the PRNM PRNM from from the the 2012 2012 System System and and available available on-site on-site for for NRC NRC refueling refueling outage outage inspection inspection..
12 12.. The The TRM TRM willwill be be revised revised to to reflect reflect thethe NTSP NTSP Prior Prior to to startup startup and and methodologies methodologies used used to to determine determine the the as-as- from the 2012 from the 2012 found found andand as-left as-left tolerances tolerances prior prior toto startup startup refueling outage refueling outage from from the the 2012 2012 refueling refueling outage outage..
13.
- 13. GGNS GGNS calibration calibration procedures procedures for for APRM APRM Prior Prior to to startup startup Functions Functions 2.a,2.a, 2.b, 2.b, 2.d, 2.d, and and 2.f 2.f will will bebe revised revised from from the the 2012 2012 to to reflect reflect the the instructions instructions given given in in new new Notes Notes refueling refueling outage outage (d)
(d) and and (e).
(e).