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 GNRO-2009-00054 November 3, 2009 leer Regulatory Commission ATTN : Document Control Desk Washington, DC 20555
Dear Sir or Madam :
contains PROPRIETARY information SUBJECT :
License Amendment Request Power Range Neutron Monitoring System Upgrade Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29 Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) proposes to revise the Grand Gulf Nuclear Station (GGNS) Technical Specifications (TS) to reflect the installation of the digital General Electric - Hitachi (GEH) Nuclear Measurement Analysis and Control (NUMAC)
Power Range Neutron Monitoring (PRNM) System. The following TS (and associated TS Bases, if applicable) and Operating License (OL) sections are affected by this change :
0 OL Section 2.C(2), Technical Specifications 0
TS 1.1, Definitions 0
TS 3.2.4, Fraction of Core Boiling Boundary (FC88)
I*
TS 3.3.1.1, Reactor Protection System (RPS) Instrumentation TS 3.3.1.3, Period Based Detection System (PBDS)
TS 3.10.8, Shutdown Margin (SDM) Test - Refueling 0
TS 5.6.5, Core Operating Limits Report (COLR)
Entergy plans to replace the existing analog Average Power Range Monitor (APRM) subsystem of the existing Neutron Monitoring System with the more reliable, digital NUMAC PRNM System during the spring 2012 refueling outage. This modification will simplify management and maintenance of the system.
The PRNM System design retrofit also includes an Oscillation Power Range Monitor (OPRM) capability, which implements a GEH version of the Boiling Water Reactor Owners' Group (BWROG) Option III detect-and-suppress long-term reactor core stability solution When Attach Entergy Operations, Inc.
P. 0. Box 756 Port Gibson, MS 39150 Michael A. Krupa Director, Extended Power Uprate Grand Gulf Nuclear Station Tel.
(601) 437-6684 ent 5 is removed from Letter, Entire Document is NON-PROPRIEATRY Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150 Michael A. Krupa Director, Extended Power Uprate Grand Gulf Nuclear Station Tel. (601) 437-6684 contains PROPRIETARY information GNRO-2009-00054 November 3, 2009 u.s. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
License Amendment Request Power Range Neutron Monitoring System Upgrade Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29
Dear Sir or Madam:
Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) proposes to revise the Grand Gulf Nuclear Station (GGNS) Technical Specifications (TS) to reflect the installation of the digital General Electric - Hitachi (GEH) Nuclear Measurement Analysis and Control (NUMAC)
Power Range Neutron Monitoring (PRNM) System. The following TS (and associated TS Bases, if applicable) and Operating License (OL) sections are affected by this change:
OL Section 2.C(2), Technical Specifications TS 1.1, Definitions TS 3.2.4, Fraction of Core Boiling Boundary (FCBB)
TS 3.3.1.1, Reactor Protection System (RPS) Instrumentation TS 3.3.1.3, Period Based Detection System (PBDS)
TS 3.10.8, Shutdown Margin (SDM) Test - Refueling TS 5.6.5, Core Operating Limits Report (COLR)
Entergy plans to replace the existing analog Average Power Range Monitor (APRM) subsystem of the existing Neutron Monitoring System with the more reliable, digital NUMAC PRNM System during the spring 2012 refueling outage. This modification will simplify management and maintenance of the system.
The PRNM System design retrofit also includes an Oscillation Power Range Monitor (OPRM) capability, which implements a GEH version of the Boiling Water Reactor Owners' Group (BWROG) Option III detect-and-suppress long-term reactor core stability solution When Attachment 5 is removed from Letter, Entire Document is NON-PROPRIEATRY
GNRO-2009-00054 Page 2 methodology. The OPRIVI provides automatic detection and suppression of reactor thermal-hydraulic instabilities through monitoring neutron flux changes. This license amendment request (LAR) adds an OPRM Upscale function to the Reactor Protection System (RPS) Instrumentation TS, thereby implementing the Option III reactor stability solution. With installation of the NUMAC PRNM System, the GGNS stability licensing basis will transition from Enhanced Option I-A to Option 111.
Following installation of the NUMAC PRNM System, GGNS will operate with the new OPRM Upscale function (TS Table 3.3.1.1-1 Function 2.f) in an "indicate only" mode for an initial monitoring period for a minimum of 90 days not to exceed one fuel cycle, as discussed in the LAR. GGNS will implement Backup Stability Protection (BSP) measures specified in BWROG document OG-02-0119-260, GE to BWROG Detect and Suppress // Committee, "Backup Stability Protection (BSP) for Inoperable Option /// Solution," as an alternate method for detecting and suppressing instabilities until the OPRM Monitoring Period has been successfully completed. The NRC approved the use of the BSP measures for the alternate method for Monticello as documented in its Safety Evaluation.
Reactor stability compliance using this method relies upon operator action to :
0 Avoid regions where instability may occur, 0
Exit such regions when necessary, and Detect an actual instability and take mitigating action by manual means.
Following review and evaluation of operating data from the monitoring period, Entergy will enable the OPRM Upscale function. Details of the monitoring period are provided in the LAR. provides the LAR, which contains a description of the proposed changes, the technical evaluation, and associated no significant hazards determination and environmental evaluation. Attachment 2 provides a copy of GEH Nuclear Energy Report GE-NE-0000-0102-0888, Grand Gulf Nuclear Station - Plant Specific Responses Required by NUMAC PRNM Retrofit Plus Option /// Stability Trip Function Topical Report (NEDC-32410P-A), for N RC review in conjunction with the proposed LAR. Attachment 3 provides marked-up Operating License and TS pages indicating the proposed changes. Attachment 4 provides the associated draft marked-up TS Bases pages for information only. provides a proprietary version of GEH Nuclear Energy Report 0000-0107-7607-P, Grand Gulf Nuclear Station - Grand Gulf PRNM Upgrade Project Option Ill Stability Deviations, which provides the technical basis for several deviations from the traditional Option III stability solution design established by the BWR Owners' Group.
Pursuant to 10 CFR 2.390, GEH has requested this report be withheld from public disclosure ;
the associated affidavit is provided following the report. Attachment 6 provides a non-proprietary version of the report.
Entergy has evaluated the proposed LAR in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c). We have determined that this change involves no significant hazards consideration. The bases for this determination are included in Attachment 1.
This letter contains commitments as identified in Attachment 7.
GNRO-2009-00054 Page 2 methodology. The OPRM provides automatic detection and suppression of reactor thermal-hydraulic instabilities through monitoring neutron flux changes. This license amendment request (LAR) adds an OPRM Upscale function to the Reactor Protection System (RPS) Instrumentation TS J thereby implementing the Option III reactor stability solution. With installation of the NUMAC PRNM System, the GGNS stability licensing basis will transition from Enhanced Option I-A to Option III.
Following installation of the NUMAC PRNM System, GGNS will operate with the new OPRM Upscale function (TS Table 3.3.1.1-1 Function 2.f) in an "indicate only" mode for an initial monitoring period for a minimum of 90 days not to exceed one fuel cycle, as discussed in the LAR. GGNS will implement Backup Stability Protection (BSP) measures specified in BWROG document OG-02-0119-260, GE to BWROG Detect and Suppress II Committee, ({Backup Stability Protection (BSP) for Inoperable Option III Solution," as an alternate method for detecting and suppressing instabilities until the OPRM Monitoring Period has been successfully completed. The NRC approved the use of the BSP measures for the alternate method for Monticello as documented in its Safety Evaluation.
Reactor stability compliance using this method relies upon operator action to:
Avoid regions where instability may occur, Exit such regions when necessary, and Detect an actual instability and take mitigating action by manual means.
Following review and evaluation of operating data from the monitoring period, Entergy will enable the OPRM Upscale function. Details of the monitoring period are provided in the LAR. provides the LAR, which contains a description of the proposed changes, the technical evaluation, and associated no significant hazards determination and environmental evaluation. Attachment 2 provides a copy of GEH Nuclear Energy Report GE-NE-0000-01 02-0888, Grand Gulf Nuclear Station - Plant-Specific Responses Required by NUMAC PRNM Retrofit Plus Option III Stability Trip Function Topical Report (NEDC-32410P-A), for NRC review in conjunction with the proposed LAR. Attachment 3 provides marked-up Operating License and TS pages indicating the proposed changes. Attachment 4 provides the associated draft marked-up TS Bases pages for information only. provides a proprietary version of GEH Nuclear Energy Report 0000-0107-7607-P, Grand Gulf Nuclear Station - Grand Gulf PRNM Upgrade Project Option III Stability Deviations, which provides the technical basis for several deviations from the traditional Option III stability solution design established by the BWR Owners' Group.
Pursuant to 10 CFR 2.390, GEH has requested this report be withheld from public disclosure; the associated affidavit is provided following the report. Attachment 6 provides a non-proprietary version of the report.
Entergy has evaluated the proposed LAR in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c). We have determined that this change involves no significant hazards consideration. The bases for this determination are included in Attachment 1.
This letter contains commitments as identified in Attachment 7.
GNRO-2009-00054 Page 3 Entergy plans to submit an LAR to support an extended power uprate (EPU) at GGNS in accordance with GEH Licensing Topical Report (LTR) NEDC-33004P-A, Constant Pressure Power Uprate. The NRC's Safety Evaluation Report approving NEDC-33004P-A contains a restriction that prohibits a licensee from submitting certain types of LARs in parallel with the EPU LAR. This PRNM System LAR falls within that restriction ; therefore, Entergy is submitting this LAR prior to the EPU LAR.
Entergy requests NRC approval of the PRNMS LAR prior to submitting the EPU LAR, which is currently scheduled for July, 2010. Entergy will implement the approved PRNMS LAR prior to startup from the 2012 refueling outage.
If you have any questions or require additional information, please contact Mr. Guy Davant at (601) 368-5756.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on November 3, 2009.
Sincerely, MAK/ghd Attachments :
1.
License Amendment Request - Power Range Neutron Monitoring System Upgrade 2.
GE Hitachi Nuclear Energy Report GE-NE-0000-0102-0888, Grand Guff Nuclear Station - Plant-Specific Responses Required by NUMAC PRNM Retrofit Plus Option /// Stability Trip Function Topical Report (NEDC-3247OP-A) 3.
Marked-Up Operating License and Technical Specification Pages 4.
Draft Marked-Up Technical Specification Bases Pages (For Information Only)
- 5.
GE Hitachi Nuclear Energy Report 0000-0107-7607-P-RO, Grand Gulf Nuclear Station - Grand Gulf PRNM Upgrade Project Option /// Stability Deviations (Proprietary Version) with Affidavit Supporting Request to Withhold from Public Disclosure
- 6.
GE Hitachi Nuclear Energy Report 0000-0107-7607-NP-Rl, Grand Gulf Nuclear Station - Grand Gulf PRNM Upgrade Project Option /// Stability Deviations (Non-Proprietary Version)
- 7.
Licensee-Identified Commitments GNRO-2009-00054 Page 3 Entergy plans to submit an LAR to support an extended power uprate (EPU) at GGNS in accordance with GEH Licensing Topical Report (LTR) NEDC-33004P-A, Constant Pressure Power Uprate. The NRC's Safety Evaluation Report approving NEDC-33004P-A contains a restriction that prohibits a licensee from submitting certain types of LARs in parallel with the EPU LAR. This PRNM System LAR falls within that restriction; therefore, Entergy is submitting this LAR prior to the EPU LAR.
Entergy requests NRC approval of the PRNMS LAR prior to submitting the EPU LAR, which is currently scheduled for July, 2010. Entergy will implement the approved PRNMS LAR prior to startup from the 2012 refueling outage.
If you have any questions or require additional information, please contact Mr. Guy Davant at (601) 368-5756.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on November 3, 2009.
Sincerely, MAKlghd Attachments:
1.
License Amendment Request - Power Range Neutron Monitoring System Upgrade 2.
GE Hitachi Nuclear Energy Report GE-NE-0000-01 02-0888, Grand Gulf Nuclear Station - Plant-Specific Responses Required by NUMAC PRNM Retrofit Plus Option III Stability Trip Function Topical Report (NEDC-32410P-A) 3.
Marked-Up Operating License and Technical Specification Pages 4.
Draft Marked-Up Technical Specification Bases Pages (For Information Only) 5.
GE Hitachi Nuclear Energy Report 0000-0107-7607-P-RO, Grand Gulf Nuclear Station - Grand Gulf PRNM Upgrade Project Option III Stability Deviations (Proprietary Version) with Affidavit Supporting Request to Withhold from Public Disclosure 6.
GE Hitachi Nuclear Energy Report 0000-01 07-7607-NP-R1, Grand Gulf Nuclear Station - Grand Gulf PRNM Upgrade Project Option III Stability Deviations (Non-Proprietary Version) 7.
Licensee-Identified Commitments REMOVED
GNRO-2009-00054 Page 4 cc :
Mr. Elmo E. Collins, Jr.
Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 612 East Lamar Blvd., Suite 400 Arlington, TX 76011-4005 U. S. Nuclear Regulatory Commission ATTN :
Mr. C. F Lyon, NRR/DORL (w/2)
ATTN :
ADDRESSEE ONLY Courier Delivery Only Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378 Dr. Ed Thompson, MD, MPH Mississippi Department of Health P. 0. Box 1700 Jackson, MS 39215-1700 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 GNRO-2009-00054 Page 4 cc:
Mr. Elmo E. Collins, Jr.
Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 612 East Lamar Blvd., Suite 400 Arlington, TX 76011-4005 U. S. Nuclear Regulatory Commission ATTN:
Mr. C. F. Lyon, NRR/DORL (w/2)
ATTN:
ADDRESSEE ONLY ATTN:
Courier Delivery Only Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378 Dr. Ed Thompson, MD, MPH Mississippi Department of Health P. O. Box 1700 Jackson, MS 39215-1700 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150
bcc:
OUTLOOK MAIL :
DISTRIBUTION IS ALL ELECTRONIC Barfield, A. D. (GG-ENG)
Browning, J. G. (GG-GMPO)
Caery, J. V. (GG-TRNG)
Christian, K. J. (W3-NSA)
Ford, B. S. (ECH-NS&L)
GGN CENTRAL FILE (171)
GGN PLANT LICENSING James, D. E. (ANO-NSA)
Lorfing, D. L. (RBS-PL)
McCann, J. F. (WP-NS&L)
Murillo, R. J. (W3-PL)
Perino, C. L. (GG-NSA)
Richardson, C. J. (ECH-EPU)
Roberts, J. C. (RBS-NSA)
Saunders, S. A. (ECH-EPU)
Higginbotham, K. (GG-OPS)
OTHER:
File (LRS_DOGS Directory - GNRI or GNRO) bcc:
OUTLOOK MAIL:
DISTRIBUTION IS ALL ELECTRONIC Barfield, A. D. (GG-ENG)
Browning, J. G. (GG-GMPO)
Caery, J. V. (GG-TRNG)
Christian, K. J. (W3-NSA)
Ford, B. S. (ECH-NS&L)
GGN CENTRAL FILE (171)
GGN PLANT LICENSING James, D. E. (ANO-NSA)
Lorfing, D. L. (RBS-PL)
McCann, J. F. (WP-NS&L)
Murillo, R. J. (W3-PL)
Perino, C. L. (GG-NSA)
Richardson, C. J. (ECH-EPU)
Roberts, J. C. (RBS-NSA)
Saunders, S. A. (ECH-EPU)
Higginbotham, K. (GG-OPS)
OTHER:
File (LRS_DOCS Directory - GNRI or GNRO)
ATTACHMENT 1 G N RO-2009-00054 LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE ATTACHMENT 1 GNRO*2009*00054 LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE to GNRO-2009-00054 Page 1 of 41 SECTION TITLE PAGE TABLE OF CONTENTS 3.1 Current GGNS Neutron Monitoring System Description............................4 3.2 NUMAC PRNM System Hardware Description..........................................6 3.3 Changes to the Reactor Stability Solution Licensing Basis........................ 7 4.0 TECHNICAL ANALYSES......................................................................... 11 4.1 OL Section 2.C(2), Technical Specifications............................................12 4.2 TS 1.1, Definitions.................................................................................... 13 4.3 TS 3.2.4, Fraction of Core Boiling Boundary (FCBB)...............................13 4.4 TS 3.3.1.1, Reactor Protection System (RPS)Instrumentation................13 4.4.1 Changes to Limiting Conditions for Operation (LCO} 3.3.1.1 Actions......13 4.4.2 Changes to Surveillance Requirements (SRs}.........................................15 4.4.3 Changes to TS Table 3.3.1.1-1, Reactor Protection System Instrumentation......................................................................................... 20 4.5 TS 3.3.1.3, Period Based Detection System............................................ 28 4.6 TS 3.10.8, Shutdown Margin (SDM) Test - Refueling.............................. 28 4.7 TS 5.6.5, Core Operating Limits Report (COLR)......................................29 4.8 Conclusion................................................................................................ 29
5.0 REGULATORY ANALYSIS
...................................................................... 30 5.1 Applicable Regulatory Requirements and Guidance................................ 30 5.1.1 10 CFR Part 50......................................................................................... 30 5.1.2 NRC Safety Evaluation and NUMAC PRNM LTR Requirements............. 31 5.1.3 GGNS PRNM System Deviations from the NUMAC PRNM LTR
............. 33 1.0 DESCRIPTION........................................................................................... 3 2.0 PROPOSED CHANGES
............................................................................ 3 3.0 BACKGROUND
.......................................................................................... 4 to GNRO-2009-00054 Page 1 of 41 TABLE OF CONTENTS Conclusion 29 TECHNICAL ANALYSES 11 10 CFR Part 50 30 REGULATORY ANALySiS 30 PAGE TITLE Applicable Regulatory Requirements and Guidance 30 TS 3.3.1.3, Period Based Detection System 28 TS 3.10.8, Shutdown Margin (SDM) Test - Refueling 28 TS 5.6.5, Core Operating Limits Report (COLR) 29 NRC Safety Evaluation and NUMAC PRNM LTR Requirements 31 GGNS PRNM System Deviations from the NUMAC PRNM LTR 33 Current GGNS Neutron Monitoring System Description 4
OL Section 2.C(2), Technical Specifications 12 TS 1.1, Definitions 13 TS 3.2.4, Fraction of Core Boiling Boundary (FCBB) 13 TS 3.3.1.1, Reactor Protection System (RPS) Instrumentation 13 Changes to Limiting Conditions for Operation (LCO) 3.3.1.1 Actions 13 Changes to Surveillance Requirements (SRs) 15 Changes to TS Table 3.3.1.1-1, Reactor Protection System Instrumentation 20 NUMAC PRNM System Hardware Description 6
Changes to the Reactor Stability Solution Licensing Basis 7
DESCRIPTION 3
PROPOSED CHANGES 3
BACKGROUND 4
SECTION 1.0 2.0 3.0 3.1 3.2 3.3 4.0 4.1 4.2 4.3 4.4 4.4.1 4.4.2 4.4.3 4.5 4.6 4.7 4.8 5.0 5.1 5.1.1 5.1.2 5.1.3 to GNRO-2009-00054 Page 2 of 41 SECTION TITLE PAGE 5.1.4 GGNS Option III Stability Solution Deviations from the BWROG Stability LTR............................................................................................. 33 5.1.5 Setpoint Methodology
............................................................................... 34 5.2 No Significant Hazards Determination...................................................... 36 5.3 ental Consideration................................................................... 38 6.0 PRECEDENCE
......................................................................................... 39
7.0 REFERENCES
........................................................................... 39 to GNRO-2009-00054 Page 2 of 41 SECTION TITLE PAGE 5.1.4 GGNS Option III Stability Solution Deviations from the BWROG Stability LTR 33 5.1.5 Setpoint Methodology 34 5.2 No Significant Hazards Determination 36 5.3 Environmental Consideration 38 6.0 PRECEDENCE 39
7.0 REFERENCES
39 to GNRO-2009-00054 Page 3 of 41 1.0 DESCRIPTION LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE Pursuant to 10 CFR 50.90, Entergy Operations, Inc. {Entergy} proposes to revise the Grand Gulf Nuclear Station {GGNS} Operating License {OL} and Technical Specifications (TS) to reflect the installation of the digital General Electric - Hitachi (GEH} Nuclear Measurement Analysis and Control (NUMAC) Power Range Neutron Monitoring {PRNM} System. The proposed changes (described in Section 4.0, below) are consistent with the NRC-approved GEH Licensing Topical Report (LTR} NEDC-3241 OP-A, Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option /// Stability Trip Function, Volumes 1 and 2, including Supplement 1 (References 1 and 2), referred to here-in collectively as the NUMAC PRNM LTR. The NUMAC PRNM LTR provides the primary technical basis for the proposed changes. The NRC approved the design and application of the NUMAC PRNM LTR via References 3 and 4.
Entergy and GEH evaluated the proposed GGNS-specific PRNM System installation against the requirements of the NUMAC PRNM LTR and associated NRC Safety Evaluations. GEH developed a plant-specific comparison report GE-NE-0000-0102-0888, Grand Gulf Nuclear Station - Plant-Specific Responses Required by NUMAC PRNM Retrofit Plus Option /// Stability Trip Function Topical Report (NEDC-32410P-A), (Reference 5), which is provided in. The deviations from the NUMAC, PRNM LTR are identified in Section 5.1.3, below.
Entergy plans to replace the analog Average Power Range Monitor {APRM} subsystem of the existing Neutron Monitoring System at GGNS with the more reliable digital NUMAC PRNM System during the spring 2012 refueling outage.
The NUMAC PRNM System design includes an Oscillation Power Range Monitor {OPRM) capability, which implements a GEH version of the Boiling Water Reactor Owners' Group (BWROG} Option III detect-and-suppress long-term reactor core stability solution methodology. With installation of the OPRM and approval of this License Amendment Request {LAR), GGNS will transition from currently implemented Enhanced Option I-A stability solution to Option 111.
2.0 PROPOSED CHANGES The following OL and TS sections, and associated TS Bases sections are affected by this change :
" OL Section 2.C(2), Technical Specifications TS 1.1, Definitions TS 3.2.4, Fraction of Core Boiling Boundary (FCBB)
- TS 3.3.1.1, Reactor Protection System (RPS) Instrumentation to GNRO-2009-00054 Page 3 of 41 LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE
1.0 DESCRIPTION
Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) proposes to revise the Grand Gulf Nuclear Station (GGNS) Operating License (OL) and Technical Specifications (TS) to reflect the installation of the digital General Electric - Hitachi (GEH) Nuclear Measurement Analysis and Control (NUMAC) Power Range Neutron Monitoring (PRNM) System. The proposed changes (described in Section 4.0, below) are consistent with the NRC-approved GEH Licensing Topical Report (LTR) NEDC-32410P-A, Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function, Volumes 1 and 2, including Supplement 1 (References 1 and 2), referred to here-in collectively as the NUMAC PRNM LTR. The NUMAC PRNM LTR provides the primary technical basis for the proposed changes. The NRC approved the design and application of the NUMAC PRNM LTR via References 3 and 4.
Entergy and GEH evaluated the proposed GGNS-specific PRNM System installation against the requirements of the NUMAC PRNM LTR and associated NRC Safety Evaluations. GEH developed a plant-specific comparison report GE-NE-0000-01 02-0888, Grand Gulf Nuclear Station - Plant-Specific Responses Required by NUMAC PRNM Retrofit Plus Option III Stability Trip Function Topical Report (NEDC-32410P-A), (Reference 5), which is provided in. The deviations from the NUMAC PRNM LTR are identified in Section 5.1.3, below.
Entergy plans to replace the analog Average Power Range Monitor (APRM) subsystem of the existing Neutron Monitoring System at GGNS with the more reliable digital NUMAC PRNM System during the spring 2012 refueling outage.
The NUMAC PRNM System design includes an Oscillation Power Range Monitor (OPRM) capability, which implements a GEH version of the Boiling Water Reactor Owners' Group (BWROG) Option III detect-and-suppress long-term reactor core stability solution methodology. With installation of the OPRM and approval of this License Amendment Request (LAR), GGNS will transition from currently implemented Enhanced Option I-A stability solution to Option III.
2.0 PROPOSED CHANGE
S The following OL and TS sections, and associated TS Bases sections are affected by this change:
OL Section 2.C(2), Technical Specifications TS 1.1, Definitions TS 3.2.4, Fraction of Core Boiling Boundary (FeBB)
TS 3.3.1.1, Reactor Protection System (RPS) Instrumentation to GNRO-2009-00054 Page 4 of 41 0
TS The proposed changes support GGNS' replacement of the existing analog APRM subsystem, excluding the associated focal Power Range Monitor (LPRM) detectors and cables, with the NUMAC microprocessor-based PRNIVI System. This digital upgrade includes an OPRIVI Upscale function, which detects and suppresses reactor power instabilities through LPRM flux TS 3.3-1.3 5.
upper cable sp replaces th exceptions, leav upgra instrumen 0.8, Shutdown Margin (SDM) Test -- Refueling The planned modification involves replacing the existing eight APRM instrument channel modules of power range monitor electronics with four channels of NUMAC PRNM System hardware. The existing equipment is located in multi-bay panels in the main control room and ding room in the GGNS Control Building. The modification removes g power range monitor equipment within the panels but, with minor s the plant cabling and interfaces undist The modification provides redundancy to the LPRIVI detector power supply hardware and also the recirculation flow signal processing electronics. Unlike the current analog Lion, the new digital instrumentation is not vulnerable to instrument setpoint drift.
Period Based Detection System (PBDS)
Core Operating Limits Report (COLR)
This LAR addresses changes to the OL, TS Limiting Conditions of Operation (LCOs},
Surveillance Requirements (SRs}, and RPS APRM functions as, justified in the NUMAC LTR. These changes are identified and discussed in Section 4.0, below. provides marked-up OL and TS pages indicating the proposed changes. provides the associated draft TS Bases pages for information only.
3.1 Current GGNS Neutron Monitoring System Description The current Neutron Monitoring System at Source Range Monitors (SR Intermediate Range Monitors FIRM}
2.
3.
4.
5.
Of the above subsystems, only consists of five subsystems :
Local Power Range Monitors (LPRM)
Average Power Range Monitors (APRM)
Traversing In-Core Probe (TIP) e APRM subsystem is affected by this proposed to GNRO-2009-00054 Page 4 of41 TS 3.3.1.3, Period Based Detection System (PBDS)
TS 3.10.8, Shutdown Margin (80M) Test -- Refueling TS 5.6.5, Core Operating Limits Report (COLR)
The proposed changes support GGNS' replacement of the existing analog APRM subsystem, excluding the associated Local Power Range Monitor (LPRM) detectors and cables, with the NUMAC microprocessor-based PRNM System. This digi~al upgrade includes an OPRM Upscale function, which detects and suppresses reactor power instabilities through LPRM flux monitoring.
The planned modification involves replacing the existing eight APRM instrument channel modules of power range monitor electronics with four channels of NUMAC PRNM System hardware. The existing equipment is located in multi-bay panels in the main control room and the upper cable spreading room in the GGNS Control Building. The modification removes and replaces the existing power range monitor equipment within the panels but, with minor exceptions, leaves the plant cabling and interfaces undisturbed.
The modification provides redundancy to the LPRM detector power supply hardware and also upgrades the recirculation flow signal processing electronics. Unlike the current analog instrumentation, the new digital instrumentation is not vulnerable to instrument setpoint drift.
This LAR addresses changes to the OL, TS Limiting Conditions of Operation (LCOs),
Surveillance Requirements (SRs), and RPS APRM functions as justified in the NUMAC PRNM LTR. These changes are identified and discussed in Section 4.0, below. provides marked-up OL and TS pages indicating the proposed changes. provides the associated draft TS Bases pages for information only.
3.0 BACKGROUND
3.1 Current GGNS Neutron Monitoring System Description The current Neutron Monitoring System at GGNS consists of five subsystems:
1.
Source Range Monitors (SRM) 2.
Intermediate Range Monitors (IRM) 3.
Local Power Range Monitors (LPRM) 4.
Average Power Range Monitors (APRM) 5.
Traversing In-Core Probe (TIP)
Of the above subsystems, only the APRM subsystem is affected by this proposed change.
to GNRO-2009-00054 Page 5 of 41 The APRM subsystem has eight APRM channels ; each channel receiving input signals from a number of LPRIVI channels. Four APRM channels are associated with each trip system of the Reactor Protection System (RPS).
Each APRM channel uses :
(1)
Electronic equipment that averages the output signals from a selected set of LPRMs ;
(2)
Trip units that (3)
Signal readout equipment.
ctuate automatic devices ; and The APRM channels supply signals to the RIPS, the Rod Control and Information System (RC&IS), and the core monitoring computer. The RPS and RC&IS process the APRM inputs to initiate reactor scrams and manage control rod manipulations (e.g., control rod blocks), respectively. The core monitoring computer uses LPRM flux values for its calculations.
Each APRM channel receives two flow signals representative of reactor recirculation drive flow. The flow signals are sensed from two pairs of elbow taps, one in each recirculation loop.
One APRM channel in each RPS division contains a Period-Based Detection System (PBDS} card that takes input from A-, B-, and C-level LPRMs in the associated APRM.
The PBDS is a defense-in-depth feature of the Option E-I-A core stability solution.
(See Section 3.3, below, for more information pertaining to Option E-I-A.) The PBDS analyzes the incoming LPRM signals individually to detect power oscillations consistent with neutron ic/thermal-hyd rau lic instability. Upon detecting power oscillations, control room annunciators alarm to indicate the need for operator action, as required.
Also in support of the Option E-I-A stability solution, the APRMs are used to determine the Fraction of Core Boiling Boundary (FCBB}. FCBB is the ratio of power generated in the lower four feet of the reactor core to the power required to produce saturated boiling of the coolant entering the fuel channels. FCBB is established to ensure the core remains stable during normal reactor operations when operating in certain regions of the power/flow map. FCBB is controlled in accordance with TS 3.2.4, Fraction of Core Boiling Boundary (FCBB).
Each APRM contains a digital Flow Control Trip Reference card (FCTR} that generates the flow-referenced scram and rod-block trip setpoints as a function of aligned reactor recirculation drive flow. The digital FCTR card provides a drive flow alignment feature to convert and compensate for changes in the reactor total core flow-to-recirculation drive flow relationship. The FCTR also performs real-time reactor recirculation drive flow signal validation. The purpose of the validation process is to provide adequate assurance that credible failures in the drive flow are detected and result in a conservative response from the FCTR. The drive flow signal is tested for upscale and downscale failures. Any detected failure of the drive flow signal causes the FCTR to generate a failsafe output. This output causes a reactor scram signal to be generated by the corresponding Neutron Monitoring System channel. to GNRO-2009-00054 Page 5 of 41 The APRM subsystem has eight APRM channels; each channel receiving input signals from a number of LPRM channels. Four APRM channels are associated with each trip system of the Reactor Protection System (RPS).
Each APRM channel uses:
(1)
Electronic equipment that averages the output signals from a selected set of LPRMs; (2)
Trip units that actuate automatic devices; and (3)
Signal readout equipment.
The APRM channels supply signals to the RPS, the Rod Control and Information System (RC&IS), and the core monitoring computer. The RPS and RC&IS process the APRM inputs to initiate reactor scrams and manage control rod manipulations (e.g., control rod blocks), respectively. The core monitoring computer uses LPRM flux values for its calculations.
Each APRM channel receives two flow signals representative of reactor recirculation drive flow. The flow signals are sensed from two pairs of elbow taps, one in each recirculation loop.
One APRM channel in each RPS division contains a Period-Based Detection System (PBDS) card*that takes input from A-, B-, and C-Ievel LPRMs in the associated APRM.
The PBDS is a defense-in-depth feature of the Option E-I-A core stability solution.
(See Section 3.3, below, for more information pertaining to Option E-I-A.) The PSDS analyzes the incoming LPRM signals individually to detect power oscillations consistent with neutronic/thermal-hydraulic instability. Upon detecting power oscillations, control room annunciators alarm to indicate the need for operator action, as required.
Also in support of the Option E-I-A stability solution, the APRMs are used to determine the Fraction of Core Boiling Boundary (FCBB). FCBB is the ratio of power generated in the lower four feet of the reactor core to the power required to produce saturated boiling of the coolant entering the fuel channels. FCBB is established to ensure the core remains stable during normal reactor operations when operating in certain regions of the power/flow map. FCBB is controlled in accordance with TS 3.2.4, Fraction of Core Boiling Boundary (FCBB).
Each APRM contains a digital Flow Control Trip Reference card (FCTR) that generates the flow-referenced scram and rod-block trip setpoints as a function of aligned reactor recirculation drive flow. The digital FCTR card provides a drive flow alignment feature to convert and compensate for changes in the reactor total core flow-to-recirculation drive flow relationship. The FCTR also performs real-time reactor recirculation drive flow signal validation. The purpose of the validation process is to provide adequate assurance that credible failures in the drive flow are detected and result in a conservative response from the FCTR. The drive flow signal is tested for upscale and downscale failures. Any detected failure of the drive flow signal causes the FCTR to generate a failsafe output. This output causes a reactor scram signal to be generated by the corresponding Neutron Monitoring System channel.
to GNRO-2009-00054 Page 6 of 41 The APRM subsystem utilizes four safety-related functions, which provide input into the RPS. These functions are identified in TS Table 3.3.1.1-1, Reactor Protection System Instrumentation, and listed in the table below.
TS APRM Function Name Neutron Flux-High, Setdown Fixed Neutron Flux - Hi I nop Flow Biased Simulated Thermal Power - High 3.2 NUMAC PRNM System Hardware Description (1)
Detects a thermal-hydraulic instability in the reactor core ;
(2)
Alarms on small power oscillation magnitudes ; and TS APRM Function Designation 2.a 2.b 2.c 2.d The proposed NUMAC PRNM System consists of four APRM/OPRM channels, each performing APRM and OPRM functions, and four 2-Out-Of-4 Voter channels. The modification removes and replaces the existing power range monitor equipment located in multi-bay panels in the main control room and the upper cable spreading room in the GGNS Control Building. With minor exceptions, the modification leaves the plant cabling and interfaces undisturbed. One APRM/OPRM channel chassis contains both APRM and OPRM channel circuitry.
As with the current system, the general APRM function averages LPRM information and, using a combination of predefined criteria and criteria based on inputs from the recirculation drive flow functions, compares average neutron flux and Simulated Thermal Power to specified limits.
The recirculation drive flow signal processing, which was previously accomplished using the FCTR within the APRM control panels, is now integrated into the APRM circuitry in the new NUMAC PRNM System design. The proposed modification utilizes the current recirculation drive flow channel configuration. See Section 3.1, above, for a description of the recirculation drive flow channel.
The OPRM is a microprocessor-based monitoring and protection system that :
(3)
Initiates action to suppress an oscillation prior to exceeding safety limits.
The OPRM monitors the outputs from selected LPRMs and provides inputs to the RPS to initiate suppression actions.
Each 2-Out-Of-4 Voter channel (Al, A2, B1, and 132) receives input from the four APRM/OPRM channels. Voter Channels Al and A2 input to RIPS Trip System A, while B1 and B2 input to RIPS Trip System B. A reactor trip occurs when at least two 2-Out-Of-4 Voter channels (one in each RPS trip system) confirms a trip condition is to GNRO-2009-00054 Page 6 of 41 The APRM subsystem utilizes four safety-related functions, which provide input into the RPS. These functions are identified in TS Table 3.3.1.1-1, Reactor Protection System Instrumentation, and listed in the table below.
TS APRM Function TS APRM Function Name Designation Neutron Flux - High, Setdown 2.a Fixed Neutron Flux - High 2.b Inop 2.c Flow Biased Simulated Thermal Power - High 2.d 3.2 NUMAC PRNM System Hardware Description The proposed NUMAC PRNM System consists of four APRM/OPRM channels, each performing APRM and OPRM functions, and four 2-0ut-Of-4 Voter channels. The modification removes and replaces the existing power range monitor equipment located in multi-bay panels in the main control room and the upper cable spreading room in the GGNS Control Building. With minor exceptions, the modification leaves the plant cabling and interfaces undisturbed. One APRM/OPRM channel chassis contains both APRM and OPRM channel circuitry.
As with the current system, the general APRM function averages LPRM information and, using a combination of predefined criteria and criteria based on inputs from the recirculation drive flow functions, compares average neutron flux and Simulated Thermal Power to specified limits.
The recirculation drive flow signal processing, which was previously accomplished using the FCTR within the APRM control panels, is now integrated into the APRM circuitry in the new NUMAC PRNM System design. The proposed modification utilizes the current recirculation drive flow channel configuration. See Section 3.1, above, for a description of the recirculation drive flow channel.
The OPRM is a microprocessor-based monitoring and protection system that:
(1)
Detects a thermal-hydraulic instability in the reactor core; (2)
Alarms on small power oscillation magnitudes; and (3)
Initiates action to suppress an oscillation prior to exceeding safety limits.
The OPRM monitors the outputs from selected LPRMs and provides inputs to the RPS to initiate suppression actions.
Each 2-0ut-Of-4 Voter channel (A1, A2, B1, and B2) receives input from the four APRM/OPRM channels. Voter Channels A1 and A2 input to RPS Trip System A, while 81 and B2 input to RPS Trip System B. A reactor trip occurs when at least two 2-0ut-Of-4 Voter channels (one in each RPS trip system) confirms a trip condition is to GNRO-2009-00054 Page 7 of 41 being sensed by two or more APRM/OPRM channels. For example, if any two of the four APRM/OPRM channels sense an APRM or OPRM trip condition, each sends a corresponding signal to the 2-Out-Of-4 Voters. Each Voter processes the signal, determines at least two APRM/OPRM channels sense a trip condition, and then sends a trip signal to its corresponding RIPS trip system, resulting in a plant scram.
When one APRM/OPRM channel is bypassed, the voting trip logic becomes 2-out-of-3., The Voter channels cannot be bypassed.
H has modified the NUMAC PRNM System design from that described in the NUMAC PRNM LTR to have the APRM/OPRM channel send an OPRM Upscale trip and an APRM Inop trip to all four 2-Out-Of-4 Voters when the associated channel key switch is placed in the "INOP" position. As a result, an OPRM Upscale trip in one channel and an APRM Inop trip in another channel results in RPS trip outputs from all four 2-Out-Of-4 Voter channels. This deviation from the previously-approved NUMAC PRNM System design and licensing basis is identified in Section 5.1.3, below, and discussed within Appendix A of Attachment 2 (Reference 5).
N The NUMAC PRNM System utilizes the four safety-related APRM functions of the existing GGNS power range monitoring system logic (identified in Section 3.1, above),
as well as the existing LPRM detector signal processing, LPRM averaging, and APRM reactor trips, and adds two new functions that support the Option 111 stability solution ;
these are : (1) a 2-Out-Of-4 Voter function (new APRM Function 2.e) ; and (2) an OPRM Upscale function (new APRM Function 2.f).
As discussed in the NUMAC PRNM LTR (References 1 and 2) and recognized by the C in its Safety Evaluations approving the LTR (References 3 and 4), this modification has no impact on the control rod block instrumentation governed by TS 3.3.2.1, Control Rod Block Instrumentation, for a BWR/6 plant that has implemented Improved Technical Specifications (ITS). GGNS is such a plant ; therefore, TS 3.3.2.1 not affected.
In addition as noted in Section 2.3.3.5 of the NUMAC PRNM LTR, the Average Power Range Monitor, Rod Block Monitor, and Technical Specifications Improvement Program (ARTS) is not applicable to the BWR/6 design and, therefore, not applicable to GGNS.
3.3 Changes to the Reactor Stability Solution Licensing Basis Under certain conditions, BWRs are susceptible to coupled neutronic/
thermal-hydraulic instabilities. These instabilities are characterized by periodic power/flow oscillations. Compliance with the stability licensing criteria of 10 CFR 50 Appendix A, General Design Criterion (GDC} 10, Reactor Design, and GDC 12, Suppression of Reactor Power Oscillations, can be achieved either by preventing or by detecting and suppressing stability-related reactor power oscillations prior to exceeding fuel design limits.
If these power/flow oscillations become large enough, the fuel cladding integrity Minimum Critical Power Ratio (MCPR} Safety Limit could be challenged. to GNRO-2009-00054 Page 7 of 41 being sensed by two or more APRM/OPRM channels. For example, if any two of the four APRM/OPRM channels sense an APRM or OPRM trip condition, each sends a corresponding signal to the 2-0ut-Of-4 Voters. Each Voter processes the signal, determines at least two APRM/OPRM channels sense a trip condition, and then sends a trip signal to its corresponding RPS trip system, resulting in a plant scram.
When one APRM/OPRM channel is bypassed, the voting trip logic becomes 2-out-of-3. The Voter channels cannot be bypassed.
GEH has modified the NUMAC PRNM System design from that described in the NUMAC PRNM LTR to have the APRM/OPRM channel send an OPRM Upscale trip and an APRM Inop trip to all four 2-0ut-Of-4 Voters when the associated channel key switch is placed in the "INOP" position. As a result, an OPRM Upscale trip in one channel and an APRM Inop trip in another channel results in RPS trip outputs from all four 2-0ut-Of-4 Voter channels. This deviation from the previously-approved NUMAC PRNM System design and licensing basis is identified in Section 5.1.3, below, and discussed within Appendix A of Attachment 2 (Reference 5).
The NUMAC PRNM System utilizes the four safety-related APRM functions of the existing GGNS power range monitoring system logic (identified in Section 3.1, above),
as well as the existing LPRM detector signal processing, LPRM averaging, and APRM reactor trips, and adds two new functions that support the Option III stability solution; these are: (1) a 2-0ut-Of-4 Voter function (new APRM Function 2.e); and (2) an OPRM Upscale function (new APRM Function 2.f).
As discussed in the NUMAC PRNM LTR (References 1 and 2) and recognized by the NRC in its Safety Evaluations approving the LTR (References 3 and 4), this modification has no impact on the control rod block instrumentation governed by TS 3.3.2.1, Control Rod Block Instrumentation, for a BWR/6 plant that has implemented Improved Technical Specifications (ITS). GGNS is such a plant; therefore, TS 3.3.2.1 is not affected.
In addition as noted in Section 2.3.3.5 of the NUMAC PRNM LTR, the Average Power Range Monitor, Rod Block Monitor, and Technical Specifications Improvement Program (ARTS) is not applicable to the BWR/6 design and, therefore, not applicable to GGNS.
3.3 Changes to the Reactor Stability Solution Licensing Basis Under certain conditions, BWRs are susceptible to coupled neutronic/
thermal-hydraulic instabilities. These instabilities are characterized by periodic power/flow oscillations. Compliance with the stability licensing criteria of 10 CFR 50 Appendix A, General Design Criterion (GDC) 10, Reactor Design, and GDC 12, Suppression of Reactor Power Oscillations, can be achieved either by preventing or by detecting and suppressing stability-related reactor power oscillations prior to exceeding fuel design limits. If these power/flow oscillations become large enough, the fuel cladding integrity Minimum Critical Power Ratio (MCPR) Safety Limit could be challenged.
to GNRO-2009-00054 Page 8 of 41 The BWROG developed several long-term stability solution options for detecting and suppressing core instability events, which are documented in NEDO-31960-A, BWR owners' Group Long-Term Stability Solutions Licensing Methodology, and associated Supplement 1 (Reference 6). The option currently implemented at GGNS is referred to as Enhanced Option I-A (E-I-A} and was approved by the NRC in GGNS TS Amendment 141 (Reference 7). For this option, the existing APRM Flow Biased Simulated Thermal Power - High function (TS Table 3.3.1.1-1 Function 2.d) gravid a preemptive reactor scram to prevent power/flow oscillations that could lead to rossly violating the operating domain.
Option E-I-A is not currently licensed for use with the NUMAC PRNM System The NUMAC PRNIVI System design uses a different, more general stability control approach and includes an OPRM Upscale function, referred to as Option III in the BWROG long-term stability solution methodology (Reference 6). The NUMAC PRNIVI LTR discusses implementing the OPRIVI functions within the PRNIVI equipment.
The traditional Option III solution employs three different software algorithms running on the NUMAC PRNM microprocessor computer platform to automatically detect and suppress reactor thermal-hydraulic instabilities : (1) an Amplitude-Based algorithm ; (2) a Growth-Rate algorithm ; and (3) a Period-Based Detection algorithm.
The Amplitude-Based algorithm discriminates between true stability-related neutron flux oscillations and other flux variations that may be expected during plant operation.
The primary objectives of this algorithm are to :
(1)
Provide a sufficiently low amplitude trip setpoint such that margin to the MCPR Safety Limit is maintained ; and (2)
Identify stability-related neutron flux oscillations and discriminate against "false" signals from other expected plant evolutions.
The Growth-Rate algorithm follows the same logic as the Amplitude-Based algorithm, except that a trip is initiated if the relative signal value exceeds a specified growth-rate setpoint.
The Period-Based Detection algorithm is based on the observation that the neutron flux of an unstable core oscillates with a well-defined period and that the neutron flux of a stable core is characterized by random noise. Detecting the inception of thermal-hydraulic instability is confirmed by several consecutive, equal periods which results in an alarm signal. The oscillation amplitude is then compared against a trip setpoint.
Meeting both conditions (both a sustained period and increasing signal amplitude) results in a channel trip signal.
A similar Period-Based Detection algorithm is currently utilized by Option E-l-A, as discussed in Section 3.1. to GNRO-2009-00054 Page 8 of 41 The BWROG developed several long-term stability solution options for detecting and suppressing core instability events, which are documented in NEDO-31960-A, BWR Owners' Group Long-Term Stability Solutions Licensing Methodology, and associated Supplement 1 (Reference 6). The option currently implemented at GGNS is referred to as Enhanced Option I-A (E-I-A) and was approved by the NRC in GGNS TS Amendment 141 (Reference 7). For this option, the existing APRM Flow Biased Simulated Thermal Power - High function (TS Table 3.3.1.1-1 Function 2.d) provides a preemptive reactor scram to prevent power/flow oscillations that could lead to grossly violating the operating domain.
The NUMAC PRNM System design uses a different, more general stability control approach and includes an OPRM Upscale function, referred to as Option III in the BWROG long-term stability solution methodology (Reference 6). The NUMAC PRNM LTR discusses implementing the OPRM functions within the PRNM equipment.
Option E-I-A is not currently licensed for use with the NUMAC PRNM System.
The traditional Option III solution employs three different software algorithms running on the NUMAC PRNM microprocessor computer platform to automatically detect and suppress reactor thermal-hydraulic instabilities: (1) an Amplitude-Based algorithm; (2) a Growth-Rate algorithm; and (3) a Period-Based Detection algorithm 1.
The Amplitude-Based algorithm discriminates between true stability-related neutron flux oscillations and other flux variations that may be expected during plant operation.
The primary objectives of this algorithm are to:
(1)
Provide a sufficiently low amplitude trip setpoint such that margin to the MCPR Safety Limit is maintained; and (2)
Identify stability-related neutron flux oscillations and discriminate against "false" signals from other expected plant evolutions.
The Growth-Rate algorithm follows the same logic as the Amplitude-Based algorithm, except that a trip is initiated if the relative signal value exceeds a specified growth-rate setpoint.
The Period-Based Detection algorithm is based on the observation that the neutron flux of an unstable core oscillates with a well-defined period and that the neutron flux of a stable core is characterized by random noise. Detecting the inception of thermal-hydraulic instability is confirmed by several consecutive, equal periods which results in an alarm signal. The oscillation amplitude is then compared against a trip setpoint.
Meeting both conditions (both a sustained period and increasing signal amplitude) results in a channel trip signal.
A similar Period-Based Detection algorithm is currently utilized by Option E-I-A, as discussed in Section 3.1.
to GNRO-2009-00054 Page 9 of 41 Of the three algorithms, only the Period-Based Detection algorithm is credited to protect the MCPR Safety Limit against anticipated thermal-hydraulic instabilities. The Amplitude-Based and Growth-Rate algorithms are provided for defense-in-depth.
The Option III configuration replaces GGNS' Option E-I-A as the long-term stability solution required by NRC Generic Letter 94-02, Long-Term Solutions and Upgrade of Interim Operating Recommendations for Thermal Hydraulic Instabilities in Boiling Water Reactors (Reference 8).
Unlike ption E-I-A, Option III does not employ FCBB to detect and suppress potential ilities. FCBB is discussed in Section 3.1, above.
The OPRM Upscale function (new APRM Function 2.f) is added to TS 3.3.1.1, Reactor Protection System (RPS) Instrumentation, to implement Option III (see Section 4.4.3.7, below).
Following NUMAC PRNM System installation and startup from the 2012 refueling outage, the OPRM will operate in an "indicate only" mode for an initial monitoring period. The purpose of the monitoring period is to ensure the OPRM algorithms perform according to design specifications. The OPRM Monitoring Period is discussed below.
OPRM Monitoring Period Section 8.4 of the NUMAC PRNM LTR discusses an OPRM Monitoring Period during which time the OPRM Upscale trip function is not connected to RPS. The LTR designates the duration of this monitoring period to be one operating cycle after which the function will be connected to RPS.
Both the NRC staff and the industry recognized that a possibility of problems with the OPRM algorithms, system performance in an actual plant environment, hardware problems, etc., existed. Considering stability events are infrequent occurrences, the NRC Safety Evaluation for the NUMAC PRNM LTR contains the following provision :
"The OPRM function will be monitored during the first full fuel cycle to ensure the OPRM algorithms perform according to the design specifications. During this monitoring period, the OPRM trip capabilities will be deactivated, but the OPRM alarms and indications will be provided to the operators. Upon completion of this initial surveillance phase, the OPRM trip functions will be enabled, and the licensee will submit to the NRC technical specification changes that address the OPRM functions."
Entergy recognizes the potential for identifying an intractable problem during the OPRM Monitoring Period, but based upon current industry / GEH experience with the NUMAC PRNM System, considers such a problem unlikely.
Although the NUMAC PRNM System with the OPRM Upscale trip function has now been operating at several plants for several years without any indication of an OPRM design problem, Entergy believes it remains prudent to assume that a design problem may still exist in the OPRM Upscale function. Therefore, to minimize operational risk to GNRO-2009-00054 Page 9 of 41 Of the three algorithms, only the Period-Based Detection algorithm is credited to protect the MCPR Safety Limit against anticipated thermal-hydraulic instabilities. The Amplitude-Based and Growth-Rate algorithms are provided for defense-in-depth.
The Option III configuration replaces GGNS' Option E-I-A as the long-term stability solution required by NRC Generic Letter 94-02, Long-Term Solutions and Upgrade of Interim Operating Recommendations for Thermal Hydraulic Instabilities in Boiling Water Reactors (Reference 8).
Unlike Option E-I-A, Option III does not employ FCBB to detect and suppress potential reactor core instabilities. FCBB is discussed in Section 3.1, above.
The OPRM Upscale function (new APRM Function 2.f) is added to TS 3.3.1.1, Reactor Protection System (RPS) Instrumentation, to implement Option III (see Section 4.4.3.7, below).
Following NUMAC PRNM System installation and startup from the 2012 refueling outage, the OPRM will operate in an "indicate only" mode for an initial monitoring period. The purpose of the monitoring period is to ensure the OPRM algorithms perform according to design specifications. The OPRM Monitoring Period is discussed below.
OPRM Monitoring Period Section 8.4 of the NUMAC PRNM LTR discusses an OPRM Monitoring Period during which time the OPRM Upscale trip function is not connected to RPS. The LTR designates the duration of this monitoring period to be one operating cycle after which the function will be connected to RPS.
Both the NRC staff and the industry recognized that a possibility of problems with the OPRM algorithms, system performance in an actual plant environment, hardware problems, etc., existed. Considering stability events are infrequent occurrences, the NRC Safety Evaluation for the NUMAC PRNM LTR contains the following provision:
"The OPRM function will be monitored during the first full fuel cycle to ensure the OPRM algorithms perform according to the design specifications. During this monitoring period, the OPRM trip capabilities will be deactivated, but the OPRM alarms and indications will be provided to the operators. Upon completion of this initial surveillance phase, the OPRM trip functions will be enabled, and the licensee will submit to the NRC technical specification changes that address the OPRM functions."
Entergy recognizes the potential for identifying an intractable problem during the OPRM Monitoring Period, but based upon current industry / GEH experience with the NUMAC PRNM System, considers such a problem unlikely.
Although the NUMAC PRNM System with the OPRM Upscale trip function has now been operating at several plants for several years without any indication of an OPRM design problem, Entergy believes it remains prudent to assume that a design problem may still exist in the OPRM Upscale function. Therefore, to minimize operational risk to GNRO-2009-00054 Page 1 0 of 41 and potentially avoid an otherwise unnecessary plant shutdown, Entergy will conduct a monitoring period of the OPRM for a minimum of 90 days not to exceed one fuel cycle after plant startup following the 2012 refueling outage.
The PRNM System configuration during the monitoring period and the monitoring period duration are discussed below.
PRNM System Configuration During the OPRM Monitoring Period, the outputs from the OPRM Upscale 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 of the PRNM System will operate in an "indicate only" mode and will be considered "functional" based upon successfully performing those surveillances that can be performed, or partially performed, prior to startup or on-line as part of post-modification testing, industry experience, and factory acceptance testing of the NUMAC PRNM System. System tuning may be performed as necessary during the OPRM Monitoring Period.
The OPRM Upscale function will not be relied upon to mitigate a stability event during this initial OPRM Monitoring Period ; rather GGNS will implement Backup Stability Protection (BSP) measures specified in BWROG document OG-02-0119-260, GE to BWROG Detect and Suppress // Committee, "Backup Stability Protection (BSP) for Inoperable Option /// Solution, "Reference 9) as an alternate method for detecting and suppressing instabilities until the OPRM Monitoring Period has been successfully completed. The NRC approved the use of the BSP measures for the alternate method for Monticello as documented in its Safety Evaluation (Reference 10).
Reactor stability compliance using this method relies upon operator action to :
0 Avoid regions where instability may occur, Exit such regions when necessary, and Detect an actual instability and take mitigating action by manual means.
The BSP measures will be implemented via plant procedures, consistent with other OPRM license amendments approved by the NRC.
At the end of the OPRM Monitoring Period, Entergy will review the operating data, setpoints, and margins. Once the results are determined to be acceptable, Entergy will enable the OPRM (with applicable SRs met) by connecting it to the RPS trip relays, completing implementation of the hardware changes for this amendment. to GNRO-2009-00054 Page 10 of 41 and potentially avoid an otherwise unnecessary plant shutdown, Entergy will conduct a monitoring period of the OPRM for a minimum of 90 days not to exceed one fuel cycle after plant startup following the 2012 refueling outage.
The PRNM System configuration during the monitoring period and the monitoring period duration are discussed below.
a.
PRNM System Configuration During the OPRM Monitoring Period, the outputs from the OPRM Upscale 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 of the PRNM System will operate in an "indicate only" mode and will be considered "functional" based upon successfully performing those surveillances that can be performed, or partially performed, prior to startup or on-line as part of post-modification testing, industry experience, and factory acceptance testing of the NUMAC PRNM System. System tuning may be performed as necessary during the OPRM Monitoring Period.
The OPRM Upscale function will not be relied upon to mitigate a stability event during this initial OPRM Monitoring Period; rather GGNS will implement Backup Stability Protection (BSP) measures specified in BWROG document OG-02-0119-260, GE to BWROG Detect and Suppress II Committee, "Backup Stability Protection (BSP) for Inoperable Option III Solution," (Reference 9) as an alternate method for detecting and suppressing instabilities until the OPRM Monitoring Period has been successfully completed. The NRC approved the use of the BSP measures for the alternate method for Monticello as documented in its Safety Evaluation (Reference 10).
Reactor stability compliance using this method relies upon operator action to:
Avoid regions where instability may occur, Exit such regions when necessary, and Detect an actual instability and take mitigating action by manual means.
The BSP measures will be implemented via plant procedures, consistent with other OPRM license amendments approved by the NRC.
At the end of the OPRM Monitoring Period, Entergy will review the operating data, setpoints, and margins. Once the results are determined to be acceptable, Entergy will enable the OPRM (with applicable SRs met) by connecting it to the RPS trip relays, completing implementation of the hardware changes for this amendment.
to GNRO-2009-00054 Page 1 1 of 41 b.
Monitoring Period Duration The one-cycle monitoring period in the NUMAC PRNM LTR for the OPRM Upscale function was specified because, at that time, it was a new feature of the RPS. As such, further testing, monitoring, and evaluating the normal modes of operation was considered prudent to ensure this function performed as designed and did not create any unintended consequences. Since originally introduced, GEH NUMAC PRNM systems utilizing Option III with the OPRM Upscale functio have been installed in many plants within the U.S. and overseas, accumulating more than 90 reactor years of fully-armed operation.
4.0 TECHNICAL ANALYSES Based on this operational experience, Entergy believes that having the flexibility to complete the monitoring period after a minimum of 90 days or to continue it up to the end of the fuel cycle is appropriate. Although a slightly different approach, the NRC approved a fixed, 90-day monitoring period for Monticello (Reference 10).
Entergy will notify the NRC when the monitoring period has been successfully completed.
GGNS is a GE BWR/6 large core plant. The proposed OL and TS changes and associated draft TS Bases changes have been developed in accordance with the NUMAC PRNM LTR (except as specified within this LAR). Attachments 3 and 4 provide marked-up pages of the proposed OL and TS changes and corresponding TS Bases changes associated with installing the NUMAC PRNM System, respectively. The draft TS Bases mark-ups, provided for information only, will be issued in accordance with TS 5.5.11, Technical Specification (TS)
Bases Control Program.
As discussed in Section 3.2, above, the NUMAC PRNM System utilizes the four functions of the existing GGNS APRM system logic, including LPRM detector signal processing, LPRM averaging, and APRM reactor trips, and adds two new functions. The new and existing functions are identified in the table below:
TS Function TS Function Name Desiqnation Neutron Flux - High, Setdown (existing) 2.a Fixed Neutron Flux-High (existing) 2.b Inop (existing) 2.c Flow Biased Simulated Thermal Power High (existing) 2.d 2-Out-Of-4 Voter (new) 2.e OPRM Upscale (new) 2.f to GNRO-2009-00054 Page 11 of 41 b.
Monitoring Period Duration The one-cycle monitoring period in the NUMAC PRNM LTR for the OPRM Upscale function was specified because, at that time, it was a new feature of the RPS. As such, further testing, monitoring, and evaluating the normal modes of operation was considered prudent to ensure this function performed as designed and did not create any unintended consequences. Since originally introduced, GEH NUMAC PRNM systems utilizing Option III with the OPRM Upscale function have been installed in many plants within the U.S. and overseas, accumulating more than 90 reactor years of fully-armed operation.
Based on this operational experience, Entergy believes that having the flexibility to complete the monitoring period after a minimum of 90 days or to continue it up to the end of the fuel cycle is appropriate. Although a slightly different approach, the NRC approved a fixed, 90-day monitoring period for Monticello (Reference 10).
Entergy will notify the NRC when the monitoring period has been successfully completed.
4.0 TECHNICAL ANALYSES GGNS is a GE BWR/6 large core plant. The proposed OL and TS changes and associated draft TS Bases changes have been developed in accordance with the NUMAC PRNM LTR (except as specified within this LAR). Attachments 3 and 4 provide marked-up pages of the proposed OL and TS changes and corresponding TS Bases changes associated with installing the NUMAC PRNM System, respectively. The draft TS Bases mark-ups, provided for information only, will be issued in accordance with TS 5.5.11, Technical Specification (TS)
Bases Control Program.
As discussed in Section 3.2, above, the NUMAC PRNM System utilizes the four functions of the existing GGNS APRM system logic, including LPRM detector signal processing, LPRM averaging, and APRM reactor trips, and agds two new functions. The new and existing functions are identified in the table below:
TS Function Name Neutron Flux - High, Setdown (existing)
Fixed Neutron Flux - High (existing)
Inop (existing)
Flow Biased Simulated Thermal Power - High (existing) 2-0ut-Of-4 Voter (new)
OPRM Upscale (new)
TS Function Designation 2.a 2.b 2.c 2.d 2.e 2.f to GNRO-2009-00054 Page 12 of 41 The proposed OL and TS changes pertaining to the NUMAC PRNM System and these functions are identified and described below.
4.1 OL Section 2.C(2), Technical Specifications Section 3.3, above, discusses the OPRM Monitoring Period. Entergy proposes to conduct the OPRM Monitoring Period as directed by the NUMAC PRNM LTR and the NRC beginning at startup from the 2012 refueling outage into Cycle 19 with the following clarifications and modifications :
During the monitoring period, the TS requirements will not apply to the OPRM Upscale function, thereby eliminating the requirement to reduce power to < 24%
RTP after 120 days, as would be required by new Required Action K.1 (see Section 4.4.1.3, below). Also, BSP measures specified in BWROG document OG-02-0119-260 (Reference 9) will be implemented via GGNS procedures to provide an alternate method for detecting and suppressing reactor core thermal hydraulic instability oscillations during the monitoring period. The NRC approved the use of the Backup Stability Protection measures as an acceptable alternate method for Monticello (Reference 10).
(2) The monitoring period will last for a minimum of 90 days and may be completed prior to completing the fuel cycle if analysis of the collected data indicates the OPRM is functioning properly. Upon completing the monitoring period, the OPRM Upscale function will be enabled and subject to all applicable Technical Specification requirements. The NRC approved a 90-day monitoring period for Monticello (Reference 10).
In order to reflect this approach, Entergy proposes to modify OL Section 2.C(2).
Section 2.C(2) currently states in part :
"Entergy Operations, Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Plan."
Specifically, Entergy proposes to add a paragraph to Section 2.C(2) that states :
"During Cycle 19, GGNS may conduct monitoring of the Oscillation Power Range Monitor (OPRM}. During this time, the OPRIVI Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) may be disabled and operated in an
`indicate only' mode at which time technical specification requirements would not apply. During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations."
Entergy has used this approach in the past to identify situations in which certain TS requirements would not apply to specific structures, systems, or components for a limited period of time. to GNRO-2009-00054 Page 12 of 41 The proposed OL and TS changes pertaining to the NUMAC PRNM System and these functions are identified and described below.
4.1 OL Section 2.C(2), Technical Specifications Section 3.3, above, discusses the OPRM Monitoring Period. Entergy proposes to conduct the OPRM Monitoring Period as directed by the NUMAC PRNM LTR and the NRC beginning at startup from the 2012 refueling outage into Cycle 19 with the following clarifications and modifications:
(1)
During the monitoring period, the TS requirements will not apply to the OPRM Upscale function, thereby eliminating the requirement to reduce power to < 24%
RTP after 120 days, as would be required by new Required Action K.1 (see Section 4.4.1.3, below). Also, BSP measures specified in BWROG document OG-02-0119-260 (Reference 9) will be implemented via GGNS procedures to provide an alternate method for detecting and suppressing reactor core thermal hydraulic instability oscillations during the monitoring period. The NRC approved the use of the Backup Stability Protection measures as an acceptable alternate method for Monticello (Reference 10).
(2)
The monitoring period will last for a minimum of 90 days and may be completed prior to completing the fuel cycle if analysis of the collected data indicates the OPRM is functioning properly. Upon completing the monitoring period, the OPRM Upscale function will be enabled and subject to all applicable Technical Specification requirements. The NRC approved a 90-day monitoring period for Monticello (Reference 10).
In order to reflect this approach, Entergy proposes to modify OL Section 2.C(2).
Section 2.C(2) currently states in part:
"Entergy Operations, Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Plan."
Specifically, Entergy proposes to add a paragraph to Section 2.C(2) that states:
"During Cycle 19, GGNS may conduct monitoring of the Oscillation Power Range Monitor (OPRM). During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) may be disabled and operated in an
'indicate only' mode at which time technical specification requirements would not apply. During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations."
Entergy has used this approach in the past to identify situations in which certain TS requirements would not apply to specific structures, systems, or components for a limited period of time.
to GNRO-2009-00054 Page 1 3 of 41 Separate from the above proposal, Section 2.C(2) currently contains a paragraph pertaining to performing SRs related to previous TS Amendment 169. Since the current amendment to the GGNS TS is Amendment 182, this paragraph is no longer applicable. Therefore, Entergy proposes to delete it.
TS 1.1 Definitions TS 1.1 defines the Fractions of Core Boiling Boundary (FCBB). As discussed in Section 4.3, below, this term and its associated TS is being deleted ; therefore, Entergy proposes to delete this definition from TS 1.1.
4.3 TS 3.2.4. Fraction of Core Boiling Boundary (FCBB)
As discussed in Sections 3.1 and 3.3, above, FCBB is a component of the Option E-I-A stability solution that ensures the reactor core remains stable when operating certain regions of the power/flow map. The new Option III stability solution does not use FCBB as a component to detect and suppress potential core instabilities ;
therefore, Entergy proposes to delete TS 3.2.4 in its entirety.
4.4 TS 3.3.1.1, Reactor Protection System (RPS) Instrumentation 4.4.1 Changes to Limiting Conditions for Operation (LCO) 3.3.1.1 Actions New Notes Clarifyinq Required Action A.2 and Condition B In the Actions for TS 3.3.1.1, Entergy proposes to add a new note to Required Action A.2 and also to Condition B. These notes indicate that neither Required Action A.2 nor Condition B apply to new and existing APRM Functions 2.a, 2.b, 2.c, 2.d, or 2.f when placing an associated channel in the tripped condition ; rather, it applies to APRM Function 2.e, only.
See Section 3.2, above, for a detailed description of the NUMAC PRNM system trip logic.
Required Action A.2 is not applicable to the identified APRM functions because, with the new configuration following NUMAC PRNM System installation, inoperability of one APRM/OPRM channel affects both RIPS trip systems. As discussed in Section 3.2, above, each APRM/OPRM channel inputs into the 2-Out-Of-4 Voters for both RPS trip systems. Thus, for an inoperable APRM/OPRM channel, Required Action A.1 must be satisfied and is the only action (other than restoring operability) that will restore the capability to accommodate a single failure. Also, Condition B is not applicable because the inoperability of more than one required APRM/OPRM channel results in the loss of trip capability; thus, in this circumstance, entry is required into Condition C, as well as into Condition A for each channel. to GNRO-2009-00054 Page 13 of 41 Separate from the above proposal, Section 2.C(2) currently contains a paragraph pertaining to performing SRs related to previous TS Amendment 169. Since the current amendment to the GGNS TS is Amendment 182, this paragraph is no longer applicable. Therefore, Entergy proposes to delete it.
4.2 15 1.1, Definitions TS 1.1 defines the Fractions of Core Boiling Boundary (FCBB). As discussed in Section 4.3, below, this term and its associated TS is being deleted; therefore, Entergy proposes to delete this definition from TS 1.1.
4.3 15 3.2.4, Fraction of Core Boiling Boundary (FCBB)
As discussed in Sections 3.1 and 3.3, above, FCBB is a component of the Option E-I-A stability solution that ensures the reactor core remains stable when operating in certain regions of the power/flow map. The new Option III stability solution does not use FCBB as a component to detect and suppress potential core instabilities; therefore, Entergy proposes to delete TS 3.2.4 in its entirety.
4.4 15 3.3.1.1, Reactor Protection System (RPS) Instrumentation 4.4.1 Changes to Limiting Conditions for Operation (LCO) 3.3.1.1 Actions 4.4.1.1 New Notes Clarifying Required Action A.2 and Condition B In the Actions for TS 3.3.1.1, Entergy proposes to add a new note to Required Action A.2 and also to Condition B. These notes indicate that neither Required Action A.2 nor Condition B apply to new and existing APRM Functions 2.a, 2.b, 2.c, 2.d, or 2.f when placing an associated channel in the tripped condition; rather, it applies to APRM Function 2.e, only.
Required Action A.2 is not applicable to the identified APRM functions because, with the new configuration following NUMAC PRNM System installation, inoperability of one APRM/OPRM channel affects both RPS trip systems. As discussed in Section 3.2, above, each APRM/OPRM channel inputs into the 2-0ut-Of-4 Voters for both RPS trip systems. Thus, for an inoperable APRM/OPRM channel, Required Action A.1 must be satisfied and is the only action (other than restoring operability) that will restore the capability to accommodate a single failure. Also, Condition B is not applicable because the inoperability of more than one required APRM/OPRM channel results in the loss of trip capability; thus, in this circumstance, entry is required into Condition C, as well as into Condition A for each channel.
See Section 3.2, above, for a detailed description of the NUMAC PRNM system trip logic.
to GNRO-2009-00054 Page 14 of 41 2
The BSP is an update to the Interim Corrective Actions specified in NRC Bulletin 88-07, Supplement 1, Power Oscillations in Boiling Water Reactors (BWRs).
4.4.1.2 New Condition J and Associated Required Actions J.1 and J.2 In accordance with Section 8.4.2 of the NUMAC PRNM LTR, Entergy proposes to add new Action Statement Condition J for new GPRM Upscale Function 2.f. Condition J addresses a loss of trip capability in both RPS trip systems.
Condition J applies to Function 2.f when, for an OPRM Upscale channel, the Required Actions for Condition A, B, or C are not met within the specified Completion Time. Associated Required Actions are implemented to address Condition J. Specifically, Required Action J.1 is added to initiate an alternate method of detecting and suppressing thermal hydraulic instability conditions within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
This alternate method involves temporarily establishing Backup Stability Protection (BSP} measures specified in BWROG document OG-02-0119-260 (Reference 9}2, and will be controlled by plant procedures. In addition, new Required Action J.2 requires restoring GPRM Upscale trip capability within 120 days. The use of the BSP measures as an alternate method was approved for Monticello by the NRC (Reference 10).
Condition J addresses situations where GPRM Upscale trip capability is not maintained. The most likely reason for such a condition would be a common-mode software error, which would affect the four channels of the OPRM. The NRC staff acknowledged in the Safety Evaluation of the NUMAC PRNM LTR (References 3 and 4) that a significant period of time would be needed to arrange a contract with the GPRM software developer, determine the cause of the error, repair the defect, test the software modification, and implement the software upgrade in the plant.
Pursuant to Condition J, while the GPRM software is being upgraded, the plant would be required by Required Action J.1 to operate under the BSP measures, for up to 120 days. During this time period, GGNS management attention would be focused on restoring GPRM operability because the plant would be operating in a Required Action that would lead to a mandatory power reduction to less than 24% reactor thermal power (RTP} via new Condition K (see Section 4.4.1.3, below) if GPRM operability is not restored within 120 days.
Entergy also proposes a note that states LCO 3.0.4.b is not applicable to new Required Action J.2. This note allows unit restart in the event of a shutdown during the 120-day completion time.
This approach is consistent with the original intent of NUMAC PRNIVI LTR, which is to allow normal plant operations to continue to GNRO-2009-00054 Page 14 of 41 4.4.1.2 New Condition J and Associated Required Actions J.1 and J.2 In accordance with Section 8.4.2 of the NUMAC PRNM LTR, Entergy proposes to add new Action Statement Condition J for new OPRM Upscale Function 2.f. Condition J addresses a loss of trip capability in both RPS trip systems.
Condition J applies to Function 2.f when, for an OPRM Upscale channel, the Required Actions for Condition A, B, or C are not met within the specified Completion Time. Associated Required Actions are implemented to address Condition J. Specifically, Req'uired Action J.1 is added to initiate an alternate method of detecting and suppressing thermal hydraulic instability conditions within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
This alternate method involves temporarily establishing Backup Stability Protection (BSP) measures specified in BWROG document OG-02-0119-260 (Reference 9)2, and will be controlled by plant procedures. In addition, new Required Action J.2 requires restoring OPRM Upscale trip capability within 120 days. The use of the BSP measures as an alternate method was approved for Monticello by the NRC (Reference 10).
Condition J addresses situations where OPRM Upscale trip capability is not maintained. The most likely reason for such a condition would be a common-mode software error, which would affect the four channels of the OPRM. The NRC staff acknowledged in the Safety Evaluation of the NUMAC PRNM LTR (References 3 and 4) that a significant period of time would be needed to arrange a contract with the OPRM software developer, determine the cause of the error, repair the defect, test the software modification, and implement the software upgrade in the plant.
Pursuant to Condition J, while the OPRM software is being upgraded, the plant would be required by Required Action J.1 to operate under the BSP measures, for up to 120 days. During this time period, GGNS management attention would be focused on restoring OPRM operability because the plant would be operating in a Required Action that would lead to a mandatory power reduction to less than 24% reactor thermal power (RTP) via new Condition K (see Section 4.4.1.3, below) if OPRM operability is not restored within 120 days.
Entergy also proposes a note that states LCO 3.0.4.b is not applicable to new Required Action J.2. This note allows unitrestart in the event of a shutdown during the 120-day completion time.
This approach is consistent with the original intent of NUMAC PRNM LTR, which is to allow normal plant operations to continue 2
The BSP is an update to the Interim Corrective Actions specified in NRC Bulletin 88-07, Supplement 1, Power Oscillations in Boiling Water Reactors (BWRs).
to GNRO-2009-00054 Page 15 of 41 during the recovery time from a hypothesized design problem with the Option III algorithms.
Adding this note avoids processing exigent TS changes to allow plant startup if a problem arises with the Option III algorithms during the 120-day completion time of Required Action J.2, while still maintaining plant safety.
An exception to LCO 3.0.4 was not included within the NUMAC PRNIVI LTR, but has been approved in recent NRC Safety Evaluations for activating the OPRM Upscale function at Monticello (Reference 10) and Peach Bottom Units 2 and 3 (Reference 11) via a note that reads, "LCO 3.0.4 is not applicable."
The NRC stated in the Peach Bottom Safety Evaluation that, while not included in the scope of the NUMAC PRNM LTR, the exception to LCO 3.0.4 would allow the plant to restart in the event of a shutdown during the 120-day completion time of the Required Action. The NRC recognized that the original intent "was to allow normal plant operations to continue during the recovery time from a hypothesized design problem with the Option III algorithms."
Entergy revised LCO 3.0.4 in GGNS TS Amendment 175 to reflect NRC-approved changes regarding mode change limitations via BWROG TSTF-359, "Increased Flexibility in Mode Restraints."
Entergy has modified the wording of the approved note to state, "LCO 3.0.4.b is not applicable." The note is applied to Required Action J.2 and reflects standard wording currently reflected in the GGNS TS. Although worded differently from the NRC-approved notes, the intent of the proposed note remains the same.
4.4.1.3 New Condition K and Associated Required Action K.1 4.4.2 Changes to Surveillance Requirements (SRs) 4.4.2.1 SR 3.3.1.1.10 - Channel Calibration In accordance with Section 8.4.3 of the NUMAC PRNM LTR, Entergy proposes to add new Condition K. Condition K requires reducing power to < 24% RTP within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in accordance with Required Action K.1 if Condition J cannot be met (i.e., required number of OPRM channels restored). By requiring this action, the plant would be placed in a condition in which the OPRM Upscale function is not required to be operable (see Section 4.4.3.7.b, below).
Currently, SR 3.3.1.1.10 requires channel calibrations to be performed once every 184 days. This SR applies to APRM Functions 2.a, 2.b, and 2.d, only ; it does not apply to any other RPS instrumentation functions identified in TS Table 3.3.1.1-1. The SR to GNRO-2009-00054 Page 15 of 41 during the recovery time from a hypothesized design problem with the Option III algorithms.
Adding this note avoids processing exigent TS changes to allow plant startup if a problem arises with the Option III algorithms during the 120-day completion time of Required Action J.2, while still maintaining plant safety.
An exception to LCO 3.0.4 was not included within the NUMAC PRNM LTR, but has been approved in recent NRC Safety Evaluations for activating the OPRM Upscale function at Monticello (Reference 10) and Peach Bottom Units 2 and 3 (Reference 11) via a note that reads, "LCO 3.0.4 is not applicable."
The NRC stated in the Peach Bottom Safety Evaluation that, while not included in the scope of the NUMAC PRNM LTR, the exception to LCO 3.0.4 would allow the plant to restart in the event of a shutdown during the 120-day completion time of the Required Action. The NRC recognized that the original intent "was to allow normal plant operations to continue during the recovery time from a hypothesized design problem with the Option III algorithms."
Entergy revised LCO 3.0.4 in GGNS TS Amendment 175 to reflect NRC-approved changes regarding mode change limitations via BWROG TSTF-359, "Increased Flexibility in Mode Restraints."
Entergy has modified the wording of the approved note to state, "LCO 3.0.4.b is not applicable." The note is applied to Required Action J.2 and reflects standard wording currently reflected in the GGNS TS. Although worded differently from the NRC-approved notes, the intent of the proposed note remains the same.
4.4.1.3 New Condition K and Associated Required Action K.1 In accordance with Section 8.4.3 of the NUMAC PRNM LTR, Entergy proposes to add new Condition K. Condition K requires reducing power to < 240/0 RTP within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in accordance with Required Action K.1 if Condition J cannot be met (Le., required number of OPRM channels restored). By requiring this action, the plant would be placed in a condition in which the OPRM Upscale function is not required to be operable (see Section 4.4.3.7.b, below).
4.4.2 Changes to Surveillance Requirements (SRs) 4.4.2.1 SR 3.3.1.1.10 - Channel Calibration Currently, SR 3.3.1.1.10 requires channel calibrations to be performed once every 184 days. This SR applies to APRM Functions 2.a, 2.b, and 2.d, only; it does not apply to any other RPS instrumentation functions identified in TS Table 3.3.1.1-1. The SR to GNRO-2009-00054 Page 16 of 41 also has four notes clarifying application of the SR to APRIVI Functions 2.a and 2.d.
Sections 8.3.4 and 8.4.4.3 of the NUMAC PRNM LTR provide justification for performing channel calibrations on new and existing APRIVI Functions 2.a, 2.b, 2A and 2.f once every 24 months.
Based on this justification and because SR 3.3. 1. 1.10 only applies to APRIVI Functions 2.a, 2.b, 2A and 2.f, Entergy proposes to change the frequency of SR 3.3. 1. 1.10 from "once every 184 days" to "once every 24 months."
In addition to the change in frequency, Note 4 is deleted. Note 4 currently states, "For Function 2.d, the digital components of the flow control trip reference cards are excluded." As discussed in Section 3.2, above, the function performed by the FCTRs have been integrated into the APRIVI circuitry. With this change, the FCTRs are removed ; therefore, Note 4 is no longer applicable and is deleted.
4.4.2.2 SR 3.3.1.1.16 - Simulated Thermal Power Time Constant To support the current Option E-I-A stability solution at GGNS, APRIVI Function 2.d uses a simulated thermal power time constant.
SR 3.3.1.1.16 requires the simulated thermal power time constant to be calibrated once every 18 months. This SR applies to APRIVI Function 2.d, only ; it does not apply to any other RPS instrumentation functions identified in TS Table 3.3.1.1-1.
Section 8.3.4.3 of the NUMAC PRNM LTR provides justification for deleting the requirement to check the simulated thermal power time constant. Based on this justification, Entergy proposes to delete SR 3.3.1.1.16 in its entirety.
4.4.2.3 SR 3.3.1.1.18 - Recirculation Flow Control Trip Reference To support the current Option E-I-A stability solution utilized at GGNS, APRIVI Function 2.d uses a trip level generated by the FCTRs based on recirculation loop drive flow. (The FCTRs are discussed in Sections 3.1 and 3.2, above.) SR 3.3.1.1.18 requires adjusting the FCTRs. This SR applies to APRIVI Function 2.d, only ;
it does not apply to any other RPS instrumentation functions identified in TS Table 3.3.1.1-1.
As discussed in Sections 3.2 and 4.4.2.1, above, the NUMAC PRNM System with Option III removes this equipment. Therefore, Entergy proposes to delete SR 3.3.1.1.18 in its entirety. to GNRO-2009-00054 Page 16 of 41 4.4.2.2 4.4.2.3 also has four notes clarifying application of the SR to APRM Functions 2.a and 2.d.
Sections 8.3.4 and 8.4.4.3 of the NUMAC PRNM LTR provide justification for performing channel calibrations on new and existing APRM Functions 2.a, 2.b, 2.d, and 2.f once every 24 months.
Based on this justification and because SR 3.3.1.1.10 only applies to APRM Functions 2.a, 2.b, 2.d, and 2.f, Entergy proposes to change the frequency of SR 3.3.1.1.10 from "once every 184 days" to "once ev~ry 24 months."
In addition to the change in frequency, Note 4 is deleted. Note 4 currently states, "For Function 2.d, the digital components of the flow control trip reference cards are excluded." As discussed in Section 3.2, above, the function performed by the FCTRs have been integrated into the APRM circuitry. With this change, the FCTRs are removed; therefore, Note 4 is no longer applicable and is deleted.
SR 3.3.1.1.16 - Simulated Thermal Power Time Constant To support the current Option E-I-A stability solution at GGNS, APRM Function 2.d uses a simulated thermal power time constant.
SR 3.3.1.1.16 requires the simulated thermal power time constant to be calibrated once every 18 months. This SR applies to APRM Function 2.d, only; it does not apply to any other RPS instrumentation functions identified in TS Table 3.3.1.1-1.
Section 8.3.4.3 of the NUMAC PRNM LTR provides justification for deleting the requirement to check the simulated thermal power time constant. Based on this justification, Entergy proposes to delete SR 3.3.1.1.16 in its entirety.
SR 3.3.1.1.18 - Recirculation Flow Control Trip Reference To support the current Option E-I-A stability solution utilized at GGNS, APRM Function 2.d uses a trip level generated by the FCTRs based on recirculation loop drive flow. (The FCTRs are discussed in Sections 3.1 and 3.2, above.) SR 3.3.1.1.18 requires adjusting the FCTRs. This SR applies to APRM Function 2.d, only; it does not apply to any other RPS instrumentation functions identified in TS Table 3.3.1.1-1.
As discussed in Sections 3.2 and 4.4.2.1, above, the NUMAC PRNM System with Option III removes this equipment. Therefore, Entergy proposes to delete SR 3.3.1.1.18 in its entirety.
to GNRO-2009-00054 Page 17 of 41 4.4.2.4 New SIR 3.3.1.1.19 - Channel Check Currently, SIR 3.3.1.1.1 requires channel checks to be performed once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for those functions identified in TS Table 3.3.1.1-1. Included in these functions are existing APIRM Functions 2.a, 2.b, and 2.d.
Sections 8.3.4.1 and 8.4.4.1 of the NUMAC PRNM LTR provide justification for performing channel checks on new and existing APIRM Functions 2.a, 2.b, 2A 2.e, and 2.f on a frequency of once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Because other RPS instrumentation functions identified in TS Table 3.3.1.1-1 require a channel check once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per SIR 3.3.1.1.1, the frequency of this SIR cannot be changed.
To implement this change, Entergy proposes to add new SIR 3.3.1.1.19, which requires a channel check once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and to apply it to new and existing APIRM Functions 2.a, 2.b, 2-d, 2.e, and 2.f, only. With this change, current SIR 3.3.1.1.1 no longer applies to the existing APRIVI Functions 2.a, 2.b, and 2.d, but remains applicable to the other identified functions.
4.4.2.5 New SIR 3.3.1.1.20 - Channel Functional Test Currently, SRs 3.3.1.1.3 and 3.3.1.1.8 require channel functional tests to be performed once every 7 days and 92 days, respectively, for those functions identified in TS Table 3.3.1.1-1. Included in these functions are existing APIRM Functions 2.a, 2.b, 2.c, and 2.d.
SIR 3.3.1.1.3, which applies to APIRM Function 2.a, contains a note that allows the channel functional test to be postponed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when entering Mode 2 from Mode 1.
Sections 8.3.4.2 and 8.4.4.2 of the NUMAC PRNM LTR provide justification for performing channel functional tests on new and existing APIRM Functions 2.a, 2.b, 2.c, 2.d, 2.e, and 2.f on a frequency of once every 184 days. Because SRs 3.3.1.1.3 and 3.3.1.1-.8 apply to other RPS instrumentation functions identified in TS Table 3.3.1.1-1, the frequencies of these SRs cannot be changed.
To implement this change, Entergy proposes to add new SIR 3.3.1.1.20, which requires a channel functional test once every 184 days, and to apply it to new and existing APIRM Functions 2.a, 2.b, 2.c, 2A 2.e, and 2.f, only. With this change, current SRs 3.3.1.1.3 and 3.3.1.1.8 no longer apply to the existing APIRM Functions 2.a, 2.b, 2.c, and 2.d but remain applicable to the other identified functions.
Also in accordance with Section 8.3.4.2 of the NUMAC PRNM LTR, SIR 3.3.1.1.20 includes the following notes : to GNRO-2009-00054 Page 17 of 41 4.4.2.4 4.4.2.5 New SR 3.3.1.1.19 - Channel Check Currently, SR 3.3.1.1.1 requires channel checks to be performed once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for those functions identified in TS Table 3.3.1.1-1. Included in these functions are existing APRM Functions 2.a, 2.b, and 2.d.
Sections 8.3.4.1 and 8.4.4.1 of the NUMAC PRNM LTR provide justification for performing channel checks on new and existing APRM Functions 2.a, 2.b, 2.d, 2.e, and 2.f on a frequency of once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Because other RPS instrumentation functions identified in TS Table 3.3.1.1-1 require a channel check once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per SR 3.3.1.1.1, the frequency of this SR cannot be changed.
To implement this change, Entergy proposes to add new SR 3.3.1.1.19, which requires a channel check once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and to apply it to new and existing APRM Functions 2.a, 2.b, 2.d, 2.e, and 2.f, only. With this change, current SR 3.3.1.1.1 no longer applies to the existing APRM Functions 2.a, 2.b, and 2.d, but remains applicable to the other identified functions.
New SR 3.3.1.1.20 - Channel Functional Test Currently, SRs 3.3.1.1.3 and 3.3.1.1.8 require channel functional tests to be performed once every 7 days and 92 days, respectively, for those functions identified in TS Table 3.3.1.1-1. Included in these functions are existing APRM Functions 2.a, 2.b, 2.c, and 2.d.
SR 3.3.1.1.3, which applies to APRM Function 2.a, contains a note that allows the channel functional test to be postponed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when entering Mode 2 from Mode 1.
Sections 8.3.4.2 and 8.4.4.2 of the NUMAC PRNM LTR provide justification for performing channel functional tests on new and existing APRM Functions 2.a, 2.b, 2.c, 2.d, 2.e, and 2.f on a frequency of once every 184 days. Because SRs 3.3.1.1.3 and 3.3.1.1.8 apply to other RPS instrumentation functions identified in TS Table 3.3.1.1-1, the frequencies of these SRs cannot be changed.
To implement this change, Entergy proposes to add new SR 3.3.1.1.20, which requires a channel functional test once every 184 days, and to apply it to new and existing APRM Functions 2.a, 2.b, 2.c, 2.d, 2.e, and 2.f, only. With this change, current SRs 3.3.1.1.3 and 3.3.1.1.8 no longer apply to the existing APRM Functions 2.a, 2.b, 2.c, and 2.d but remain applicable to the other identified functions.
Also in accordance with Section 8.3.4.2 of the NUMAC PRNM LTR, SR 3.3.1.1.20 includes the following notes:
to GNRO-2009-00054 Page 18 of 41 For Function 2.a, not required to be performed when entering Mode 2 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 2.
2.
For Functions 2.a, 2.b, and 2.c, the APRM/OPRM channels and the 2-Out-Of-4 Voter channels are included in the channel functional test.
3.
For Functions 2.d and 2.f, the APRM/OPRM channels and the 2-Out-Of-4 Voter channels plus the flow input function, excluding the flow transmitters, are included in the channel functional test.
Because the 2-Out-Of-4 Voter is included in the channel functional test for the other APRM functions, Function 2.e does not require a separate channel functional test.
4.4.2.6 New SIR 3.3.1.1.21-Logic System Functional Test Currently, SIR 3.3.1.1.13 requires a logic system functional test (LSFT} to be performed once every 18 months for those functions identified in TS Table 3.3.1.1-1. Included in these functions are existing APIRM Functions 2.a, 2.b, 2.c, and 2.d.
Sections 8.3.5 and 8.4.5 of the NUMAC PRNM LTR provide justification to :
Delete the LSFT requirement from existing APIRM Functions 2.a, 2.b, 2.c, and 2.d ; and Apply an LSFT requirement to new APIRM Function 2.e, requiring performance once every 24 months.
Because other RPS instrumentation functions identified in TS Table 3.3.1.1-1 require an LSFT once every 18 months per SIR 3.3.1.1.13, the frequency of this SIR cannot be changed. Therefore, to implement this change, Entergy proposes to :
Delete SIR 3.3.1.1.13 from Table 3.3.1.1-1 for existing APIRM Functions 2.a, 2.b, 2.c, and 2.d ; and b.
Add new SIR 3.3.1.1.21, which requires performing an LSFT once every 24 months, and apply it to APIRM Function 2.e.
With these changes, current SIR 3.3.1.1.13 no longer applies to existing APIRM Functions 2.a, 2.b, 2.c, and 2.d, but remains applicable to the other identified functions. to GNRO-2009-00054 Page 18 of 41 4.4.2.6 1.
For Function 2.a, not required to be performed when entering Mode 2 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 2.
2.
For Functions 2.a, 2.b, and 2.c, the APRM/OPRM channels and the 2-0ut-Of-4 Voter channels are included in the channel functional test.
3.
For Functions 2.d and 2.f, the APRM/OPRM channels and the 2-0ut-Of-4 Voter channels plus the flow input function, excluding the flow transmitters, are included in the channel functional test.
Because the 2-0ut-Of-4 Voter is included in the channel functional test for the other APRM functions, Function 2.e does not require a separate channel functional test.
New SR 3.3.1.1.21 - Logic System Functional Test Currently, SR 3.3.1.1.13 requires a logic system functional test (LSFT) to be performed once every 18 months for those functions identified in TS Table 3.3.1.1-1. Included in these functions are existing APRM Functions 2.a, 2.b, 2.c, and 2.d.
Sections 8.3.5 and 8.4.5 of the NUMAC PRNM LTR provide justification to:
Delete the LSFT requirement from existing APRM Functions 2.a, 2.b, 2.c, and 2.d; and Apply an LSFT requirement to new APRM Function 2.e, requiring performance once every 24 months.
Because other RPS instrumentation functions identified in TS Table 3.3.1.1-1 require an LSFT once every 18 months per SR 3.3.1.1.13, the frequency of this SR cannot be changed. Therefore, to implement this change, Entergy proposes to:
a.
Delete SR 3.3.1.1.13 from Table 3.3.1.1-1 for existing APRM Functions 2.a, 2.b, 2.c, and 2.d; and b.
Add new SR 3.3.1.1.21, which requires performing an LSFT once every 24 months, and apply it to APRM Function 2.e.
With these changes, current SR 3.3.1.1.13 no longer applies to existing APRM Functions 2.a, 2.b, 2.c, and 2.d, but remains applicable to the other identified functions.
to GNRO-2009-00054 Page 19 of 41 4.4.2.7 New SR 3.3.1.1.22 - Response Time Testing Currently, SR 3.3.1.1.15 requires response time testing to be performed once every 18 months on a staggered basis for those functions identified in TS Table 3.3.1.1-1. Included in these functions are existing APRM Functions 2.b and 2.d.
Section 8.3.4.4 of the NUMAC PRNM LTR provides justification to Delete the response time testing requirement from existing APRM Functions 2.b and 2.d; and Apply a response time testing requirement to new APRM Function 2.e, requiring performance once every 24 months on a staggered basis. (Although the NUMAC PRNM LTR discusses applying staggered testing to the 2-Out-Of-4 Voter function, it provides no specific changes to the SRs or Bases to define the testing requirements.)
Because other RPS instrumentation functions identified in TS Table 3.3.1.1-1 require a response time test once every 18 months per SR 3.3.1.1.15, the frequency of this SR cannot be changed.
Therefore, to implement these changes, Entergy proposes to :
Delete SR 3.3.1.1.15 from Table 3.3.1.1-1 for existing APRM Functions 2.b and 2.d.
- b.
Add new SR 3.3.1.1.22, which requires performing response time testing once every 24 months on a staggered basis, and apply it to APRM Function 2.e.
Add a note to SR 3.3.1.1.22 that defines the testing requirements by stating :
"For Function 2.e, W equals 8 channels for the purpose of determining the STAGGERED TEST BASIS Frequency.
Testing APRM and OPRM outputs shall alternate."
Adding this note was approved by the NRC in the Safety Evaluation for Monticello (Reference 10) and Brunswick Units I and 2 (Reference 12).
With these changes, SR 3.3.1.1.15 no longer applies to existing APRM Functions 2.b and 2A but remains applicable to the other identified functions. to GNRO-2009-00054 Page 19 of 41 4.4.2.7 New SR 3.3.1.1.22 - Response Time Testing Currently, SR 3.3.1.1.15 requires response time testing to be performed once every 18 months on a staggered basis for those functions identified in TS Table 3.3.1.1-1. Included in these functions are existing APRM Functions 2.b and 2.d.
Section 8.3.4.4 of the NUMAC PRNM LTR provides justification to:
Delete the response time testing requirement from existing APRM Functions 2.b and 2.d; and Apply a response time testing requirement to new APRM Function 2.e, requiring performance once every 24 months on a staggered basis. (Although the NUMAC PRNM LTR discusses applying staggered testing to the 2-0ut-Of-4 Voter function, it provides no specific changes to the SRs or Bases to define the testing requirements.)
Because other RPS instrumentation functions identified in TS Table 3.3.1.1-1 require a response time test once every 18 months per SR 3.3.1.1.15, the frequency of this SR cannot be changed.
Therefore, to implement these changes, Entergy proposes to:
a.
Delete SR 3.3.1.1.15 from Table 3.3.1.1-1 for existing APRM Functions 2.b and 2.d.
b.
Add new SR 3.3.1.1.22, which requires performing response time testing once every 24 months on a staggered basis, and apply it to APRM Function 2.e.
c.
Add a note to SR 3.3.1.1.22 that defines the testing requirements by stating:
"For Function 2.e, 'n' equals 8 channels for the purpose of determining the STAGGERED TEST BASIS Frequency.
Testing APRM and OPRM outputs shall alternate."
Adding this note was approved by the NRC in the Safety Evaluation for Monticello (Reference 10) and Brunswick Units 1 and 2 (Reference 12).
With these changes, SR 3.3.1.1.15 no longer applies to existing APRM Functions 2.b and 2.d, but remains applicable to the other identified functions.
to GNRO-2009-00054 Page 20 of 41 4.4.2.8 New SR 3.3.1.1.23 - Verify PRM not Bypassed In accordance with Section 8.4.4.2 in Supplement 1 of the NUMAC PRNM LTR, Entergy proposes new SR 3.3.1.1.23 to verify that the OPRM auto-enable setpoints are correctly set. SR 3.3.1.1.23 applies to new APRM Function 2.f (see Section 4.4.3.7, below).
This verification is to be performed once every 24 months.
New SR 3.3.1.1.23 verifies APRM Function 2.f is not bypassed when the APRM Simulated Thermal Power is > 29% RTP and the recirculation drive flow is < 60% of rated recirculation drive flow.
The settings for this auto-enable (not-bypassed) region have been determined for GGNS and are established as nominal setpoints only, as described in the proposed TS Bases markup and designated in SR 3.3.1.1.23.
4.4.3 Changes to TS Table 3.3.1.1-1, Reactor Protection System Instrumentation Four functions are currently included under the APRM heading (Function 2) in TS Table 3.3.1.1-1 :
0 Neutron Flux - High, Setdown (Function 2.a) 0 Fixed Neutron Flux - High (Function 2.b)
I*
Inop (Function 2.c) 0 Flow Biased Simulated Thermal Power - High (Function 2A).
Installing the NUMAC PRNM System requires modifying the TS table by adding two new APRM functions :
I*
2-Out-Of-4 Voter (new Function 2.e) and I*
OPRM Upscale (new Function 2.f)
These were previously discussed in Section 3.2, above.
For each of the new and existing APRM functions, corresponding changes are required to TS Table 3.3.1.1-1 to reflect the following criteria, as applicable :
Applicable Modes or Other Specified Conditions Required Channels per Trip System Conditions Referenced from Required Action D.1 0
Surveillance Requirements Allowable Values to GNRO-2009-00054 Page 20 of 41 4.4.2.8 New SR 3.3.1.1.23 - Verify OPRM not Bypassed In accordance with Section 8.4.4.2 in Supplement 1 of the NUMAC PRNM LTR, Entergy proposes new SR 3.3.1.1.23 to verify that the OPRM auto-enable setpoints are correctly set. SR 3.3.1.1.23 applies to new APRM Function 2.f (see Section 4.4.3.7, below).
This verification is to be performed once every 24 months.
New SR 3.3.1.1.23 verifies APRM Function 2.f is not bypassed when the APRM Simulated Thermal Power is ~ 29%
RTP and the recirculation drive flow is < 600/0 of rated recirculation drive flow.
The settings for this auto-enable (not-bypassed) region have been determined for GGNS and are established as nominal setpoints only, as described in the proposed TS Bases markup and designated in SR 3.3.1.1.23.
4.4.3 Changes to TS Table 3.3.1.1-1, Reactor Protection SYstem Instrumentation Four functions are currently included under the APRM heading (Function 2) in TS Table 3.3.1.1-1:
Neutron Flux - High, Setdown (Function 2.a)
Fixed Neutron Flux - High (Function 2.b)
Inop (Function 2.c)
Flow Biased Simulated Thermal Power - High (Function 2.d).
Installing the NUMAC PRNM System requires modifying the TS table by adding two new APRM functions:
2-0ut-Of-4 Voter (new Function 2.e) and OPRM Upscale (new Function 2.f)
These were previously discussed in Section 3.2, above.
For each of the new and existing APRM functions, corresponding changes are required to TS Table 3.3.1.1-1 to reflect the following criteria, as applicable:
Applicable Modes or Other Specified Conditions Required Channels per Trip System Conditions Referenced from Required Action 0.1 Surveillance Requirements Allowable Values to GNRO-2009-00054 Page 2 1 of 41 Entergy proposes the following changes and additions to TS Table 3.3.1.1-1 :
4.4-3.1 Addition of New Notes to Clarify Requirements for APRM Functions In accordance with Section 8.3.2.4 of the NUMAC PRNM LTR, reflect the new NUMAC PRNM System configuration (i.e., the identified APRM/{JPRM channel provides inputs to both RPS trip systems) by adding new Note (c). Note (c) states :
Apply this note to APRM Functions 2.a, 2.b, 2.c, 2.d, and 2.f, as identified in the individual sections, below.
b.
Reflect application of actions to address the industry setpoint methodology issue as documented in TSTF-493, Clarify Application of Setpoint Methodology for LSSS Functions, (Reference 13) by adding new Notes (d) and (e), as follows :
i)
Note (d) states :
'Each channel provides inputs to both trip systems."
"If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service."
Note (e) states :
"The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP} at the completion of the surveillance ;
otherwise, the channel shall be declared inoperable.
Setpoints more conservative than the NTSP are acceptable provided the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures to confirm channel performance.
The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in the Technical Requirements Manual."
Apply these notes to the channel calibration SR 3.3. 1. 1.10 listings for APRM Functions 2.a, 2.b, 2.d, and 2.f, as identified in the individual sections, below.
Refer to Section 5.1.5, below, for additional discussion of the setpoint methodology issue. to GNRO-2009-00054 Page 21 of 41 Entergy proposes the following changes and additions to TS Table 3.3.1.1-1:
4.4.3.1 Addition of New Notes to Clarify Requirements for APRM Functions a.
In accordance with Section 8.3.2.4 of the NUMAC PRNM LTR, reflect the new NUMAC PRNM System configuration (Le., the identified APRM/OPRM channel provides inputs to both RPS trip systems) by adding new Note (c). Note (c) states:
"Each channel provides inputs to both trip systems."
Apply this note to APRM Functions 2.a, 2.b, 2.c, 2.d, and 2.f, as identified in the individual sections, below.
b.
Reflect application of actions to address the industry setpoint methodology issue as documented in TSTF-493, Clarify Application of Setpoint Methodology for LSSS Functions, (Reference 13) by adding new Notes (d) and (e), as follows:
i)
Note (d) states:
"If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service."
ii)
Note (e) states:
"The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the cha'nnel shall be declared inoperable.
Setpoints more conservative than the NTSP are acceptable provided the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures to confirm channel performance.
The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in the Technical Requirements Manual."
Apply these notes to the channel calibration SR 3.3.1.1.10 listings for APRM Functions 2.a, 2.b, 2.d, and 2.1, as identified in the individual sections, below.
Refer to Section 5.1.5, below, for additional discussion of the setpoint methodology issue.
to GNRO-2009-00054 Page 22 of 41 C.
In accordance with Section 8.4.6.1 of the NUMAC PRNM LTR, add new Note (f) to denote that the Allowable Value is contained in the Core Operating Limits Report {COLR}. Note (f) states :
"The Allowable Value for the OPRM Upscale Period-Based Detection algorithm is specified in the COLR."
This note is applied to new APRM Function 2.f, as discussed in Section 4.4.3.7, below. Placing the OPRM Upscale Allowable Value in the COLR was approved by the NRC for Monticello (Reference 10).
4.4.3.2 Neutron Flux - High, Setdown (existing Function This existing function compares APRM flux to an adjustable trip with an Allowable Value set at < 20% RTP and activated in Mode 2 (bypassed in the other Modes). Three channels are required for operability. No change in the Allowable Value is required.
APRM Function 2.a has been retained but modified in TS Table 3.3.1.1-1 as follows :
a.
Apply new Note (c) to the "Required Channels per Trip System" value, as discussed in Section 4.4.3.1.a, above.
b.
Reflect the following changes to the list of applicable SRs :
i)
Delete SR 3.3.1.1.1 and add new SR 3.3.1.1.19 as discussed in Section 4.4.2.4, above.
ii)
Delete SR 3.3.1.1.3 and add new SR 3.3.1.1.20 as discussed in Section 4.4.2.5, above.
iii)
Delete the -requirement to perform LSFTs by deleting SR 3.3.1.1.13, as discussed in Section 4.4.2.6, above.
c.
Apply new Notes (d) and (e) to the channel calibration SR 3.3. 1. 1.10 listing, as discussed in Section 4.4.3.1.b, above.
4.4.3.3 Fixed Neutron Flux-High, (existing Function 2.b)
This existing function compares APRM neutron flux to a fixed trip setpoint with an Allowable Value of < 120% RTP. Function 2-b is required to be operable in Mode 1 with three channels required per trip system. No change to the Allowable Value is required. This function is standard for the BWR/6 design.
APRM Function 2.b has been retained but modified in TS Table 3.3.1 :1-1 as follows : to GNRO-2009-00054 Page 22 of 41 4.4.3.2 4.4.3.3 c.
In accordance with Section 8.4.6.1 of the NUMAC PRNM LTR, add new Note (f) to denote that the Allowable Value is contained in the Core Operating Limits Report (COLR). Note (f) states:
"The Allowable Value for the OPRM Upscale Period-Based Detection algorithm is specified in the COLR."
This note is applied to new APRM Function 2.f, as discussed in Section 4.4.3.7, below. Placing the OPRM Upscale Allowable Value in the COLR was approved by the NRC for Monticello (Reference 10).
Neutron Flux - High. Setdown (existing Function 2.a)
This existing function compares APRM flux to an adjustable trip with an Allowable Value set at ~ 200/0 RTP and activated in Mode 2 (bypassed in the other Modes). Three channels are required for operability. No change in the Allowable Value is required.
APRM Function 2.a has been retained but modified in TS Table 3.3.1.1-1 as follows:
a.
Apply new Note (c) to the "Required Channels per Trip System" value, as discussed in Section 4.4.3.1.a, above.
b.
Reflect the following changes to the list of applicable SRs:
i)
Delete SR 3.3.1.1.1 and add new SR 3.3.1.1.19 as discussed in Section 4.4.2.4, above.
ii)
Delete SR 3.3.1.1.3 and add new SR 3.3.1.1.20 as discussed in Section 4.4.2.5, above.
iii)
Delete the requirement to perform LSFTs by deleting SR 3.3.1.1.13, as discussed in Section 4.4.2.6, above.
c.
Apply new Notes (d) and (e) to the channel calibration SR 3.3.1.1.10 listing, as discussed in Section 4.4.3.1.b, above.
Fixed Neutron Flux - High. (existing Function 2.b)
This existing function compares APRM neutron flux to a fixed trip setpoint with an Allowable Value of ~ 120% RTP. Function 2.b is required to be operable in Mode 1 with three channels required per trip system. No change to the Allowable Value is required. This function is standard for the BWR/6 design.
APRM Function 2.b has been retained but modified in TS Table 3.3.1.1-1 as follows:
to GNRO-2009-00054 Page 23 of 41 b.
Apply new Note (c) to the "Required Channels per Trip System" value, as discussed in Section 4.4.3.1.a, above.
Reflect the following changes to the list of applicable SRs :
ii)
Delete SR 3.3.1.1.8 and add new SR 3.3.1.1.20 as discussed in Section 4.4.2.5. above.
4.4.3.4 Inop (existing Function 2.c Delete SR 3.3.1.1.1 and add new SR 3.3.1.1.19 as discussed in Section 4.4.2.4, above.
iii)
Delete the requirement to perform LSFTs by deleting SR 3.3.1.1.13, as discussed in Section 4.4.2.6, above.
iv)
Delete the requirement to perform response time testing by deleting SR 3.3.1.1.15, as discussed in Section 4.4.2.7, above.
Apply new Notes (d) and (e) to the channel calibration SR 3.3.1.1.10 listing, as discussed in Section 4.4.3.1.b, above.
This existing function ensures that a minimum number of APRMs are operable. Anytime an APRM mode switch is moved to any position other than "Operate," an APRM module is unplugged, the electronic operating voltage is low, or the APRM has too few LP inputs, an inoperative trip signal is sent to the RPS. Function 2.c is required to be operable in Modes 1 and 2 with three channels required per trip system. No Allowable Value is applicable to Function 2.c.
As discussed in Section 8.3.1 of the NUMAC PRNM LTR, the NUMAC PRNM System design has removed the LPRM detector count from the automatic Inop trip ; however, it is retained in the Inop alarm. SR 3.3.1.1.7, which requires calibrating the LPRM detectors, was used to ensure the minimum LPRM detector count was satisfied. With the removal of this parameter from Function 2.c, this SR is no longer required. This change is consistent with the TS marked-up pages contained in NUMAC PRNM LTR, Vol. 2 and Supplement 1.
APRM Function 2.c has been retained but modified in TS Table 3.3.1.1-1 as follows :
a.
Apply new Note (c) to the "Required Channels per Trip System" value, as discussed in Section 4.4.3.1.a, above.
Reflect the following changes to the list of applicable SRs : to GNRO-2009-00054 Page 23 of 41 4.4.3.4 a.
Apply new Note (c) to the "Required Channels per Trip System" value, as discussed in Section 4.4.3.1.a, above.
b.
Reflect the following changes to the list of applicable SRs:
i)
Delete SR 3.3.1.1.1 and add new SR 3.3.1.1.19 as discussed in Section 4.4.2.4, above.
ii)
Delete SR 3.3.1.1.8 and add new SR 3.3.1.1.20 as discussed in Section 4.4.2.5, above.
iii)
Delete the requirement to perform LSFTs by deleting SR 3.3.1.1.13, as discussed in Section 4.4.2.6, above.
iv)
Delete the requirement to perform response time testing by deleting SR 3.3.1.1.15, as discussed in Section 4.4.2.7, above.
c.
Apply new Notes (d) and (e) to the channel calibration SR 3.3.1.1.10 listing, as discussed in Section 4.4.3.1.b, above.
Inop (existing Function 2.c)
This existing function ensures that a minimum number of APRMs are operable. Anytime an APRM mode switch is moved to any position other than "Operate," an APRM module is unplugged, the electronic operating voltage is low, or the APRM has too few LPRM inputs, an inoperative trip ~ignal is sent to the RPS. Function 2.c is required to be operable in Modes 1 and 2 with three channels required per trip system. No Allowable Value is applicable to Function 2.c.
As discussed in Section 8.3.1 of the NUMAC PRNM LTR, the NUMAC PRNM System design has removed the LPRM detector count from the automatic Inop trip; however, it is retained in the Inop alarm. SR 3.3.1.1.7, which requires calibrating the LPRM detectors, was used to ensure the minimum LPRM detector count was satisfied. With the removal of this parameter from Function 2.c, this SR is no longer required. This change is consistent with the TS marked-up pages contained in NUMAC PRNM LTR, Vol. 2 and Supplement 1.
APRM Function 2.c has been retained but modified in TS Table 3.3.1.1-1 as follows:
a.
Apply new Note (c) to the "Required Channels per Trip System" value, as discussed in Section 4.4.3.1.a, above.
b.
Reflect the following changes to the list of applicable SRs:
to GNRO-2009-00054 Page 24 of 41 4.4.3.5 i)
Delete SR 3.3.1.1.7, as discussed above.
ii)
Delete SR 3.3.1.1.8 and add new SR 3.3.1.1.20 as discussed in Section 4.4.2.5, above.
iii)
Delete the requirement to perform LSFTs by deleting SR 3.3.1.1.13, as discussed in Section 4.4.2.6, above.
Flow Biased Simulated Thermal Power-Hi This existing function compares filtered flux (simulated thermal power) to a variable flow-biased trip point and also includes a clamp to assure that the variable trip does not exceed an Allowable Value, which is currently depicted in the GGNS COLR. Function 2.d is required to be operable in Mode 1 with three channels required per trip system. This function is standard for the BWR/6 design.
APRM Function 2.d has been retained but modified in TS Table 3.3.1.1-1 as follows :
a.
Currently, the Allowable Values for APRM Function 2.d are depicted in the GGNS COLR. With the change in core stability solution from Option E-I-A to Option III (see Section 3.3, above), these values will no longer be cycle-specific ; therefore, they are being identified in TS Table 3.3.1.1-1. This is accomplished by revising existing Note (b) to state :
"Two-Loop Operation : 0.65W + 62.9% RTP and clamped at 113% RTP "Single-Loop Operation : 0.65W + 42.3% RTP" (W is total recirculation drive flow in percent of rated flow.)
The Allowable Values have been confirmed in GEH Report 0000-0102-8815, Instrument Limits Calculation - Average Power Range Monitor-Power Range Neutron Monitoring System (NUMAC) - CLTP Operation (Reference 14).
In addition, Entergy proposes an editorial change to reposition the reference for Note (b) located the "ALLOWABLE VALUES" column of TS Table 3.3.1.1-1 to align with the first row of APRM Function 2.d information in the table.
b.
Apply new Note (c) to the "Required Channels per Trip System" value, as discussed in Section 4.4.3.1.a, above.
c.
Reflect the following changes to the list of applicable SRs : to GNRO-2009-00054 Page 24 of 41 i)
Delete SR 3.3.1.1.7, as discussed above.
ii)
Delete SR 3.3.1.1.8 and add new SR 3.3.1.1.20 as discussed in Section 4.4.2.5, above.
iii)
Delete the requirement to perform LSFTs by deleting SR 3.3.1.1.13, as discussed in Section 4.4.2.6, above.
4.4.3.5 Flow Biased Simulated Thermal Power - High (existing Function 2.d)
This existing function compares filtered flux (simulated thermal power) to a variable flow-biased trip point and also includes a clamp to assure that the variable trip does not exceed an Allowable Value, which is currently depicted in the GGNS COLR. Function 2.d is required to be operable in Mode 1 with three channels required per trip system. This function is standard for the BWRl6 design.
APRM Function 2.d has been retained but modified in TS Table 3.3.1.1-1 as follows:
a.
Currently, the Allowable Values for APRM Function 2.d are depicted in the GGNS COLR. With the change in core stability solution from Option E-I-A to Option III (see Section 3.3, above), these values will no longer be cycle-specific; therefore, they are being identified in TS Table 3.3.1.1-1. This is accomplished by revising existing Note (b) to state:
"Two-Loop Operation: O.65W + 62.9% RTP and clamped at 1130/0 RTP "Single-Loop Operation: 0.65W + 42.3%
RTP" (W is total recirculation drive flow in percent of rated flow.)
The Allowable Values have been confirmed in GEH Report 0000-0102-8815, Instrument Limits Calculation -Average Power Range Monitor - Power Range Neutron Monitoring System (NUMAC) - CLTP Operation (Reference 14).
In addition, Entergy proposes an editorial change to reposition the reference for Note (b) located the "ALLOWABLE VALUES" column of TS Table 3.3.1.1-1 to align with the first row of APRM Function 2.d information in the table.
b.
Apply new Note (c) to the "Required Channels per Trip System" value, as discussed in Section 4.4.3.1.a, above.
c.
Reflect the following changes to the list of applicable SRs:
to GNRO-2009-00054 Page 25 of 41 d
- a.
- b.
C.
V)
Delete SR 3.3.1.1.1 and add new SR 3.3.1.1.19 as discussed in Section 4.4.2.4, above.
Delete SR 3.3.1.1.8 and add new SR 3.3.1.1.20 as discussed in Section 4.4.2.5, above.
Delete the requirement to perform LSFTs by deleting SR 3.3.1.1.13, as discussed in Section 4.4-2.6, above.
Delete the requirement to perform response time testing by deleting SR 3.3.1.1.15, as discussed in Section 4.4.2.7, above.
Delete the requirement to verify the simulated thermal power constant by deleting SR 3.3.1.1.16, as discussed in Section 4.4.2.2, above.
Delete the requirement to adjust the FCTR by deleting SR 3.3.1.1.18, as discussed in Section 4.4.2.3, above.
Apply new Notes (d) and (e) to the channel calibration SR 3.3.1.1.10 listing, as discussed in Section 4.4.3.1.b, above.
4.4.3.6
.2-Out-Of-4 Voter (new. Function 2.e)
In accordance with Section 8.3.1.2 of the NUMAC PRNM LTR, this function facilitates minimum operable channel definition and associated actions. Unlike the other APRM functions, each 2-Out-Of-4 Voter does, not provide inputs to both RPS trip systems.
See Section 3.2, above, for additional information pertaining to the 2-Out-Of-4 Voter channel and its configuration.
APRM Function 2.e is added to TS Table 3.3.1.1-1 with the following denotations, which are consistent with the NUMAC PRNM LTR requirements :
Add Function 2.e, "2-Out-Of-4 Voter," to the "Function" column.
Specify the "Applicable MODES or Other Specified Conditions" to be 1, 2" to reflect the associated Modes specified for the APRM functions, which input into this function.
Specify the "Required Channels per Trip System" to be "2" in accordance with Section 8.3.2 of the NUMAC PRNM LTR.
- d.
Specify the "Conditions Referenced from Required Action D.1" to be "H." Current TS Condition H provides a conservative default condition when the lower tier conditions associated with combinations of channel / function / RPS trip capability cannot to GNRO-2009-00054 Page 25 of 41 i)
Delete SR 3.3.1.1.1 and add new SR 3.3.1.1.19 as discussed in Section 4.4.2.4, above.
ii)
Delete SR 3.3.1.1.8 and add new SR 3.3.1.1.20 as discussed in Section 4.4.2.5, above.
iii)
Delete the requirement to perform LSFTs by deleting SR 3.3.1.1.13, as discussed in Section 4.4.2.6, above.
iv)
Delete the requirement to perform response time testing by deleting SR 3.3.1.1.15, as discussed in Section 4.4.2.7, above.
v)
Delete the requirement to verify the simulated thermal power constant by deleting SR 3.3.1.1.16, as discussed in Section 4.4.2.2, above.
vi)
Delete the requirement to adjust the FCTR by deleting SR 3.3.1.1.18, as discussed in Section 4.4.2.3, above.
d.
Apply new Notes (d) and (e) to the channel calibration SR 3.3.1.1.10 listing, as discussed in Section 4.4.3.1.b, above.
4.4.3.6 2-0ut-Of-4 Voter (new Function 2.e)
In accordance with Section 8.3.1.2 of the NUMAC PRNM LTR, this new function facilitates minimum operable channel definition and associated actions. Unlike the other APRM functions, each 2-0ut-Of-4 Voter does not provide inputs to both RPS trip systems.
See Section 3.2, above, for additional information pertaining to the 2-0ut-Of-4 Voter channel and its configuration.
APRM Function 2.e is added to TS Table 3.3.1.1-1 with the following denotations, which are consistent with the NUMAC PRNM LTR requirements:
a.
Add Function 2.e, "2-0ut-Of-4 Voter," to the "Function" column.
b.
Specify the "Applicable MODES or Other Specified Conditions" to be "1, 2" to reflect the associated Modes specified for the APRM functions, which input into this function.
c.
Specify the "Required Channels per Trip System" to be "2" in accordance with Section 8.3.2 of the NUMAC PRNM LTR.
d.
Specify the "Conditions Referenced from Required Action D.1" to be "H." Current TS Condition H provides a conservative default condition when the lower tier conditions associated with combinations of channel/function / RPS trip capability cannot to GNRO-2009-00054 Page 26 of 41 be met. That is, it requires the plant to be placed in a mode in which the function is not required.
e.
Apply the following SRs in accordance with the noted sections of the NUMAC PRNM LTR :
i)
SR 3.3.1.1.19 - Channel Check (8.3.4.1) i)
SR 3.3.1.1.20 - Channel Functional Test (8.3.4.2, 8.4.4.2) iii)
SR 3.3.1.1.21-LEFT (8.3.5.2, 8.4.5.2) v) SR 3.3.1.1.22 - Response Time Testing (8.3.4.4) f.
Specify the "Allowable Value" to be "NA" ; no allowable value is applicable to the 2-Out-Of-4 Voter function.
4.4.3.7 QPRM Upscale (new Function 2.f)
As discussed in Sections 3.3.2 and 8.4 of the NUMAC PRNM LTR, this new function provides the capability to detect and suppress reactor thermal-hydraulic instabilities. This instability trip function is defined by the BWROG as Option III in NEDO-31960-A and Supplement 1 (Reference 6). NEDO-32465-A, BWR Owners' Group Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications, (Reference 15) defines the Option III implementation requirements for basic logic and algorithms, provides the licensing basis for specific requirements, and defines the process by which plants demonstrate safety limit protection.
The minimum number of 4PRM cells required for OPRM Upscale operability (30) is defined by GEH analyses performed in accordance with GEH LTR NEDO-32465-A based on selecting the OPRM cell assignments and a requirement for a minimum of two LPRMs per cell. The setpoint is established to conform to the licensing bases defined in NEDO-31960-A and NEDO-32465-A consistent with the guidance provided in the NUMAC PRNM LTR.
The OPRM Period-Based Detection algorithm Upscale trip setpoint is determined using the Option III reload licensing methodology described in NEDO-32465-A (Reference 15) with the exception that a plant/cycle-specific D IVOM3 curve slope is applied in place of the generic DIVOM curve slope. As described in the NRC staff Safety Evaluation for activating the OPRM trip for Peach Bottom (Reference 11), this change from the original LTR licensing basis was necessitated by the BWROG resolution of a 10 CFR Part 21 report filed by GEH (then General Electric).
DIVOM - Delta CPR over Initial MCPR versus the Oscillation Magnitude to GNRO-2009-00054 Page 26 of 41 be met. That is, it requires the plant to be placed in a mode in which the function is not required.
4.4.3.7 e.
Apply the following SRs in accordance with the noted sections of the NUMAC PRNM LTR:
i)
SR 3.3.1.1.19 - Channel Check (8.3.4.1) ii)
SR 3.3.1.1.20 - Channel Functional Test (8.3.4.2, 8.4.4.2) iii)
SR 3.3.1.1.21 - LSFT (8.3.5.2, 8.4.5.2) iv)
SR 3.3.1.1.22 - Response Time Testing (8.3.4.4) f.
Specify the "Allowable Value" to be "NA"; no allowable value is applicable to the 2-0ut-Of-4 Voter function.
OPRM Upscale (new Function 2.f)
As discussed in Sections 3.3.2 and 8.4 of the NUMAC PRNM LTR, this new function provides the capability to detect and suppress reactor thermal-hydraulic instabilities. This instability trip function is defined by the BWROG as Option III in NEDO-31960-A and Supplement 1 (Reference 6). NEDO-32465-A, BWR Owners' Group Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications, (Reference 15) defines the Option III implementation requirements for basic logic and algorithms, provides the licensing basis for specific requirements, and defines the process by which plants demonstrate safety limit protection.
The minimum number of OPRM cells required for OPRM Upscale operability (30) is defined by GEH analyses performed in accordance with GEH LTR NEDO-32465-A based on selecting the OPRM cell assignments and a requirement for a minimum of two LPRMs per cell. The setpoint is established to conform to the licensing bases defined in NEDO-31960-A and NEDO-32465-A consistent with the guidance provided in the NUMAC PRNM LTR.
The OPRM Period-Based Detection algorithm Upscale trip setpoint is determined using the Option III reload licensing methodology described in NEDO-32465-A (Reference 15) with the exception that a plant/cycle-specific DIVOM3 curve slope is applied in place of the generic DIVOM curve slope. As described in the NRC staff Safety Evaluation for activating the OPRM trip for Peach Bottom (Reference 11), this change from the original LTR licensing basis was necessitated by the BWROG resolution of a 10 CFR Part 21 report filed by GEH (then General Electric).
3 DIVOM - Qelta CPR over Initial MCPR yersus the Oscillation Magnitude to GNRO-2009-00054 Page 27 of 41 The Period-Based Detection algorithm includes several "tuning" parameters. These parameters, as has been the case for other licensees, will be established in accordance with GGNS procedures as part of the system setup and calibration, and will be defined in plant procedures.
The Period-Based Detection algorithm trip setpoint, which can change with each new fuel cycle, will be documented in the COLR.
Since the OPRM Upscale function trip setpoint is cycle-specific, it meets the requirements for inclusion in the COLR. Also, this approach provides the same information as previously approved for other licensees and is consistent with the ITS format for references to parameters provided in the COLR and with the NUMAC PRNM LTR requirements. The NRC approved placing the OPRIVI Upscale trip setpoint in the COLR for Monticello (Reference 10).
There are also setpoints for the defense-in-depth algorithms, i.e.,
the Amplitude-Based algorithm and the Growth-Rate algorithm, which are discussed in the OPRM Upscale function description within the draft TS Bases markup. These algorithms, together with the Period-Based Detection algorithm, are treated as nominal setpoints based on qualitative studies documented in Appendix A of NEDO-32465-A (Reference 15). Use of Appendix A of NEDO-32465-A as a basis for establishing these defense-in-depth settings is consistent with the approach used by other license (and approved by the NRC) for activating the OPRM Upscale function. The Amplitude-Based and Growth-Rate algorithms are not credited in the safety analysis, and their settings are documented only in GGNS procedures.
The TS-related setpoints for the auto-enable (not-bypassed) region are established as nominal setpoints only, as described in the draft TS Bases markup and designated in new SR 3.3.1.1.23 (see Section 4.4.2.8, above).
APRM Function 2.f is added to TS Table 3.3.1.1-1 with the following denotations, which are consistent with the NUMAC PRNM LTR requirements :
a.
Add Function 2.f, "OPRM Upscale," to the "Function" column in accordance with Section 8.4.1 of the NUMAC PRNM LTR.
b.
Specify the "Applicable Modes or Other Specified Conditions" to be "5 24% RTP" in accordance with Section 8.4.3 of the NUMAC PRNM LTR and reflecting the GGNS-specific value. to GNRO-2009-00054 Page 27 of 41 The Period-Based Detection algorithm includes several "tuning" parameters. These parameters, as has been the case for other licensees, will be established in accordance with GGNS procedures as part of the system setup and calibration, and will be defined in plant procedures.
The Period-Based Detection algorithm trip setpoint, which can change with each new fuel cycle, will be documented in the COLR.
Since the OPRM Upscale function trip setpoint is cycle-specific, it meets the requirements for inclusion in the COLR. Also, this approach provides the same information as previously approved for other licensees and is consistent with the ITS format for references to parameters provided in the COLR and with the NUMAC PRNM LTR requirements. The NRC approved placing the OPRM Upscale trip setpoint in the COLR for Monticello (Reference 10).
There are also setpoints for the defense-in-depth algorithms, i.e.,
the Amplitude-Based algorithm and the Growth-Rate algorithm, which are discussed in the OPRM Upscale function description within the draft TS Bases markup. These algorithms, together with the Period-Based Detection algorithm, are treated as nominal setpoints based on qualitative studies documented in Appendix A of NEDO-32465-A (Reference 15). Use of Appendix A of NEDO-32465-A as a basis for establishing these defense-in-depth settings is consistent with the approach used by other licensees (and approved by the NRC) for activating the OPRM Upscale function. The Amplitude-Based and Growth-Rate algorithms are not credited in the safety analysis, and their settings are documented only in GGNS procedures.
The TS-related setpoints for the auto-enable (not-bypassed) region are established as nominal setpoints only, as described in the draft TS Bases markup and designated in new SR 3.3.1.1.23 (see Section 4.4.2.8, above).
APRM Function 2.f is added to TS Table 3.3.1.1-1 with the following denotations, which are consistent with the NUMAC PRNM LTR requirements:
a.
Add Function 2.f, "OPRM Upscale," to the "Function" column in accordance with Section 8.4.1 of the NUMAC PRNM LTR.
b.
Specify the "Applicable Modes or Other Specified Conditions" to be "? 24% RTP" in accordance with Section 8.4.3 of the NUMAC PRNM LTR and reflecting the GGNS-specific value.
to GNRO-2009-00054 Page 28 of 41
- f.
- 9.
Specify the "Required Channels per Trip System" to be "Y in accordance with Section 8.4.2 of the NUMAC PRNM LTR and apply new Note (c) to the value, as discussed in Section 4.4.3.1.a, above.
Specify the "Condition Referenced from Required Action D.1" to be "J". New TS Condition J provides a conservative default condition when the lower tier conditions associated with combinations of OPRM channel/function/RPS trip capability cannot be met. This is discussed in more detail in Section 4.4.1.2, above.
Apply the following SRs in accordance with the noted sections of the NUMAC PRNM LTR:
}
SR 3.3.1.1.7 - LPRM Calibration (8.3.5 and 8.4.5) ii)
SR 3.3.1.1-10 -Channel Calibration (8.4.4.3) iii) SR 3.3.1.1 Channel Check (8.4.4.1) iv) SR 3.3.1.1.20 - Channel Functional Test (8.4.4.2) v) SR 3.3.1.1.23 - OPRM not Bypassed (8.4.4.2)
Apply new Notes (d) and (e) to the Channel Calibration SR 3.3.1.1.10 listing, as discussed in Section 4.4.3.1.b, above.
Apply new Note (f) to the Allowable Value reflecting that it is contained in the COLR, as discussed in Section 4.4.3.1.c, above.
4.5 ITS 3.3.1.3. Period Based Detection System (PBDSJ The current option E-I-A stability solution methodology (discussed in Sections 3.1 and 3.3, above) utilizes the Period-Based Detection algorithm to detect when conditions consistent with a significant degradation in the stability performance of the reactor core have occurred and the potential for imminent onset of neutron ic/thermal-hyd rau I ic instability may exist. The PRNM System upgrade encompasses this algorithm within new OPRM Upscale Function 2.f, as described in Sections 3.3 and 4.4.3.7, above. As such, TS 3.3.1.3 is duplicative to the proposed TS changes and is no longer needed ;
therefore, Entergy proposes to delete TS 3.3.1.3 in its entirety.
4.6 TS 3.10.8, Shutdown Maroin (SDM) Test - Refueling TS 3.10.8 permits SDM testing to be performed in Mode 5; i.e., the reactor pressure vessel head is either not in place or the head bolts are not fully tensioned. LCO 3.10.8 specifies conditions that must be met in order to perform SDM tests, one of these being the Mode 2 requirements for APRM Functions 2.a and 2.c. In addition, SR 3.10.8.1 requires Mode 2-applicable SRs for these functions be performed. to GNRO-2009-00054 Page 28 of 41 c.
Specify the "Required Channels per Trip System" to be "3" in accordance with Section 8.4.2 of the NUMAC PRNM LTR and apply new Note (c) to the value, as discussed in Section 4.4.3.1.a, above.
d.
Specify the "Condition Referenced from Required Action 0.1" to be "J". New TS Condition J provides a conservative default condition when the lower tier conditions associated with combinations of OPRM channel/function/RPS trip capability cannot be met. This is discussed in more detail in Section 4.4.1.2, above.
e.
Apply the following SRs in accordance with the noted sections of the NUMAC PRNM LTR:
i)
SR 3.3.1.1.7 - LPRM Calibration (8.3.5 and 8.4.5) ii)
SR 3.3.1.1.10 - Channel Calibration (8.4.4.3) iii)
SR 3.3.1.1.19 - Channel Check (8.4.4.1 )
iv)
SR 3.3.1.1.20 - Channel Functional Test (8.4.4.2) v)
SR 3.3.1.1.23 - OPRM not Bypassed (8.4.4.2) f.
Apply new Notes (d) and (e) to the Channel Calibration SR 3.3.1.1.10 listing, as discussed in Section 4.4.3.1.b, above.
g.
Apply new Note (f) to the Allowable Value reflecting that it is contained in the COLR, as discussed in Section 4.4.3.1.c, above.
4.5 TS 3.3.1.3. Period Based Detection System (PBDS)
The current Option E-I-A stability solution methodology (discussed in Sections 3.1 and 3.3, above) utilizes the Period-Based Detection algorithm to detect when conditions consistent with a significant degradation in the stability performance of the reactor core have occurred and the potential for imminent onset of neutronic/thermal-hydraulic instability may exist. The PRNM System upgrade encompasses this algorithm within new OPRM Upscale Function 2.f, as described in Sections 3.3 and 4.4.3.7, above. As such, TS 3.3.1.3 is duplicative to the proposed TS changes and is no longer needed; therefore, Entergy proposes to delete TS 3.3.1.3 in its entirety.
4.6 TS 3.10.8. Shutdown Margin (SDM) Test - Refueling TS 3.10.8 permits SDM testing to be performed in Mode 5; i.e., the reactor pressure vessel head is either not in place or the head bolts are not fully tensioned. LCO 3.10.8 specifies conditions that must be met in order to perform SDM tests, one of these being the Mode 2 requirements for APRM Functions 2.a and 2.c. In addition, SR 3.10.8.1 requires Mode 2-applicable SRs for these functions be performed.
to GNRO-2009-00054 Page 29 of 41 As discussed in Section 4.4.3.6, above, the NUMAC PRNM System adds APRM Function 2.e, which is also required to be operable in Mode 2. Therefore, Entergy proposes to add Function 2.e to LCO 3.10.8.a and SR 3.10.8.1 as follows (change noted in bold, italicized text) :
4.8 Conclusion LCO 3.10.8.a is changed to read :
"LCO 3.3.1.1, `Reactor Protection System (RPS} Instrumentation,' MODE 2 requirements for Function 2.a, 2.c, and 2.e of Table 3.3.1.1-1 ;"
- b.
SR 3.10.8.1 is changed to read :
"Perform the MODE 2 applicable SRs for LCO 3.3.1.1, Functions 2.a, 2.c, and 2.e of Table 3.3.1.1-1."
4.7 TS 5.6.5. Core Operating Limits Report (COLR)
TS 5.6.5 identifies the TS sections for which core operating limits are established and the analytical methods used to determine these limits. To implement the NUMAC PRNM System with Option 111, Entergy proposes the following changes to TS 5.6.5 :
Delete APRM Function 2.d, which is no longer included in the COLR (see Section 4.4.3.5, above), and add APRM Function 2.f to TS 5.6.5.a.5 as follows (changes noted in bold, italicized text):
"5)
LCO 3.3.1.1, RPS Instrumentation, Table 3.3.1.1-1 APRM Function 2X
- b.
Delete LCO 3.2.4 from TS 5.6.5.a.4 ; TS 3.2.4 is being deleted as discussed in Section 4.3. above.
Delete LCO 3.3.1.3 from TS 5.6.5.a.6 ; TS 3.3.1.3 is being deleted as discussed in Section 4.5, above.
- d.
Add the following references to TS 5.6-5 :
i)
NEDO-31960-A, BWR Owners' Group Long-Term Stability Solutions Licensing Methodology ii)
NEDO-32465-A, Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology and Reload Applications With the above changes, the GGNS OL and TS appropriately reflect the NUMAC PRNM LTR, as approved by the NRC, insuring design requirements and acceptance criteria are met. to GNRO-2009-00054 Page 29 of 41 As discussed in Section 4.4.3.6, above, the NUMAC PRNM System adds APRM Function 2.e, which is also required to be operable in Mode 2. Therefore, Entergy proposes to add Function 2.e to LCO 3.1 0.8.a and SR 3.10.8.1 as follows (change noted in bold, italicized text):
a.
LCO 3.10.8.a is changed to read:
"LCO 3.3.1.1, 'Reactor Protection System (RPS) Instrumentation,' MODE 2 requirements for Function 2.a, 2.c, and 2.e of Table 3.3.1.1-1;"
b.
SR 3.10.8.1 is changed to read:
"Perform the MODE 2 applicable SRs for LCO 3.3.1.1, Functions 2.a, 2.c, and 2.e of Table 3.3.1.1-1."
4.7 T5 5.6.5. Core Operating Limits Report (COLR)
TS 5.6.5 identifies the TS sections for which core operating limits are established and the analytical methods used to determine these limits. To implement the NUMAC PRNM System with Option III, Entergy proposes the following changes to TS 5.6.5:
a.
Delete APRM Function 2.d,which is no longer included in the COLR (see Section 4.4.3.5, above), and add APRM Function 2.f to TS 5.6.5.a.5 as follows (changes noted in bold, italicized text):
"5)
LCO 3.3.1.1, RPS Instrumentation, Table 3.3.1.1-1 APRM Function 2.f' b.
Delete LCO 3.2.4 from TS 5.6.5.a.4; TS 3.2.4 is being deleted as discussed in Section 4.3, above.
c.
Delete LCO 3.3.1.3 from TS 5.6.5.a.6; TS 3.3.1.3 is being deleted as discussed in Section 4.5, above.
d.
Add the following references to TS 5.6.5:
i)
NEDO-31960-A, BWR Owners' Group Long-Term Stability Solutions Licensing Methodology ii)
NEDO-32465-A, Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology and Reload Applications 4.8 Conclusion With the above changes, the GGNS OL and TS appropriately reflect the NUMAC PRNM LTR, as approved by the NRC, insuring design requirements and acceptance criteria are met.
to GNRO-2009-00054 Page 30 of 41
5.0 REGULATORY ANALYSIS
5.1 Applicable Regulatory Requ irements and Guidance 5.1.1 10 CFR Part 50 10 CFR 50.36, Technical Specifications, provides the regulatory requirements for the content required in the Technical Specifications (TS). As stated in 10 CFR 50.36, TS include Surveillance Requirements (SRs} to assure that the Limiting Conditions for Operation (LCO} are met. The proposed TS changes would revise SRs and the LCO actions and completion times, as applicable, for each change in APRM functions and related LCOs.
The GGNS Neutron Monitoring System was designed and licensed to the GDCs specified in 10 CFR 50 Appendix A. The applicable GDCs are discussed below.
Criterion 13 -- Instrumentation and control. Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.
Criterion 20 -- Protection system functions. The protection system shall be designed (1) to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences and (2) to sense accident conditions and to initiate the operation of systems and components important to safety.
Criterion 21 -- Protection system reliability and testability. The protection system shall be designed for high functional reliability and in-service testability commensurate with the safety functions to be performed.
Redundancy and independence designed into the protection system shall be sufficient to assure that (1) no single failure results in loss of the protection function and (2) removal from service of any component or channel does not result in loss of the required minimum redundancy unless the acceptable reliability of operation of the protection system can be otherwise demonstrated. The protection system shall be designed to permit periodic testing of its functioning when the reactor is in operation, including a capability to test channels independently to determine failures and losses of redundancy that may have occurred.
Criterion 22 -- Protection system independence. The protection system shall be designed to assure that the effects of natural phenomena, and of normal operating, maintenance, testing, and postulated accident conditions to GNRO-2009-00054 Page 30 of 41
5.0 REGULATORY ANALYSIS
5.1 Applicable Regulatory Requirements and Guidance 5.1.1 10 CFR Part 50 10 CFR 50.36, Technical Specifications, provides the regulatory requirements for the content required in the Technical Specifications (TS). As stated in 10 CFR 50.36, TS include Surveillance Requirements (SRs) to assure that the Limiting Conditions for Operation (LCO) are met. The proposed TS changes would revise SRs and the LCO actions and completion times, as applicable, for each change in APRM functions and related LCOs.
The GGNS Neutron Monitoring System was designed and licensed to the GOCs specified in 10 CFR 50 Appendix A. The applicable GOCs are discussed below.
Criterion 13 -- Instrumentation and control. Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.
Criterion 20 -- Protection system functions. The protection system shall be designed (1) to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences and (2) to sense accident conditions and to initiate the operation of systems and components important to safety.
Criterion 21 -- Protection system reliability and testability. The protection system shall be designed for high functional reliability and in-service testability commensurate with the safety functions to be performed.
Redundancy and independence designed into the protection system shall be sufficient to assure that (1) no single failure results in loss of the protection function and (2) removal from service of any component or channel does not result in loss of the required minimum redundancy unless the acceptable reliability of operation of the protection system can be otherwise demonstrated. The protection system shall be designed to permit periodic testing of its functioning when the reactor is in operation, including a capability to test channels independently to determine failures and losses of redundancy that may have occurred.
Criterion 22 -- Protection system independence. The protection system shall be designed to assure that the effects of natural phenomena, and of normal operating, maintenance, testing, and postulated accident conditions to GNRO-2009-00054 Page 31 of 41 on redundant channels do not result in loss of the protection function, or shall be demonstrated to be acceptable on some other defined basis.
Design techniques, such as functional diversity or diversity in component design and principles of operation, shall be used to the extent practical to prevent loss of the protection function.
Criterion 29 -- Protection against anticipated operational occurrences. The protection and reactivity control systems shall be designed to assure an extremely high probability of accomplishing their safety functions in the event of anticipated operational occurrences.
The BWROG long-term stability solution Option III approach consists of detecting and suppressing stability-related power oscillations by automatically inserting control rods (scramming) to terminate power oscillations, thereby complying with the requirements of GDCs 10 and 12 discussed below.
Criterion 10 -- Reactor design. The reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences.
Criterion 12 -- Suppression of reactor power oscillations. The reactor core and associated coolant, control, and protection systems shall be designed to assure that power oscillations which can result in conditions exceeding specified acceptable fuel design limits are not possible or can be reliably and readily detected and suppressed.
Entergy has evaluated the proposed changes against the applicable regulatory requirements and acceptance criteria and finds the design of the NUMAC PRNM System consistent with the applicable regulatory criteria described above. The technical analysis in Section 4.0, above, concludes that the proposed changes to install and implement the NUMAC PRNM System continue to assure that the design requirements and acceptance criteria of the RPS are met. Based on this, there is reasonable assurance the health and safety of the public, following approval of this change, remain unaffected.
5.1.2 NRC Safety Evaluation and NUMAC PRNM LTR Requirements To receive NRC approval of an NUMAC PRNM System retrofit installation (including the Option III OPRM Upscale function), a licensee must indicate how the requirements of the NUMAC PRNM LTR and the conditions of the NRC Safety Evaluations for the system are met, or provide an acceptable alternative (deviation) for NRC staff evaluation. The Safety Evaluations for the NUMAC PRNM System specify conditions to be demonstrated by each licensee applying to install the NUMAC PRNM System.
To demonstrate conformance, Entergy has evaluated the GGNS-specific PRNM System installation against the requirements of the NUMAC PRNM LTR and associated NRC Safety Evaluations. Attachment 2 provides a plant-specific to GNRO-2009-00054 Page 31 of 41 on redundant channels do not result in loss of the protection function, or shall be demonstrated to be acceptable on some other defined basis.
Design techniques, such as functional diversity or diversity in component design and principles of operation, shall be used to the extent practical to prevent loss of the protection function.
Criterion 29 -- Protection against anticipated operational occurrences. The protection and reactivity control systems shall be designed to assure an extremely high probability of accomplishing their safety functions in the event of anticipated operational occurrences.
The BWROG long-term stability solution Option III approach consists of detecting and suppressing stability-related power oscillations by automatically inserting control rods (scramming) to terminate power oscillations, thereby complying with the requirements of GDCs 10 and 12 discussed below.
Criterion 10 -- Reactor design. The reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences.
Criterion 12 -- Suppression of reactor power oscillations. The reactor core and associated coolant, control, and protection systems shall be designed to assure that power oscillations which can result in conditions exceeding specified acceptable fuel design limits are not possible or can be reliably and readt'ly detected and suppressed.
Entergy has evaluated the proposed changes against the applicable regulatory requirements and acceptance criteria and finds the design of the NUMAC PRNM System consistent with the applicable regulatory criteria described above. The technical analysis in Section 4.0, above, concludes that the proposed changes to install and implement the NUMAC PRNM System continue to assure that the design requirements and acceptance criteria of the RPS are met. Based on this, there is reasonable assurance the health and safety of the public, following approval of this change, remain unaffected.
5.1.2 NRC Safety Evaluation and NUMAC PRNM LTR Requirements To receive NRC approval of an NUMAC PRNM System retrofit installation (including the Option III OPRM Upscale function), a licensee must indicate how the requirements of the NUMAC PRNM LTR and the conditions of the NRC Safety Evaluations for the system are met, or provide an acceptable alternative (deviation) for NRC staff evaluation. The Safety Evaluations for the NUMAC PRNM System specify conditions to be demonstrated by each licensee applying to install the NUMAC PRNM System.
To demonstrate cO,nformance, Entergy has evaluated the GGNS-specific PRNM System installation against the requirements of the NUMAC PRNM LTR and associated NRC Safety Evaluations. Attachment 2 provides a plant-specific to GNRO-2009-00054 Page 32 of 41 comparison matrix entitled, Grand Gulf Nuclear Station Plant-Specific Responses Required by NUMAC PRNM Retrofit Plus Option /// Stability Trip Function Topical Report (NEaC-32410P-A). A response to each NRC staff requirement is provided below:
- 2.
- 3.
Confirm the applicability of the NUMAC PRNM LTR (NEDC-3241OP-A and its supplement), including clarifications and reconciled differences between the specific plant design and the topical report design descriptions.
RESPONSE
Entergy performed an evaluation of the proposed GGNS-specific PRNM System installation against the requirements of the NUMAC PRNM LTR and associated NRC Safety Evaluations ; the resulting document is provided in. Clarifications and reconciled differences between the plant-specific design and the NUMAC PRNM LTR design descriptions are identified in Section 5.1.3, below.
Confirm the applicability of the BWROG topical reports that address PRNMS and associated instability functions, setpoints, and margins
RESPONSE
The applicability of the various BWROG LTRs that address the NUMAC PRNM System, the Option III stability solution, the reload-related aspects, and the development of setpoints is discussed herein or through reference to the various reports.
Provide plant-specific revised TS for the NUMAC PRNMS functions consistent with NEDC-32410P-A, Appendix H, and Supplement 1.
RESPONSE
Entergy confirms the plant-specific TS changes to implement the NUMAC PRNM System (including the OPRM Option III stability solution), which are provided in Attachment 3, are consistent with the requirements of the NUMAC PRNM LTR.
Confirm the plant-specific environmental conditions are enveloped by the NUMAC PRNM System equipment environmental qualification values.
RESPONSE
The analysis of the plant-specific environmental conditions to the NUMAC PRNM System equipment qualification (EQ} values is discussed in GEH Report GE-NE-0000-0102-0888 (Reference 5), which is provided in. The results of this analysis confirm the plant-specific environmental conditions are enveloped by the NUMAC PRNM System EQ values. to GNRO-2009-00054 Page 32 of 41 comparison matrix entitled, Grand Gulf Nuclear Station Plant-Specific Responses Required by NUMAC PRNM Retrofit Plus Option III Stability Trip Function Topical Report (NEDC-32410P-A). A response to each NRC staff requirement is provided below:
1.
Confirm the applicability of the NUMAC PRNM LTR (NEDC-3241 OP-A and its supplement), including clarifications and reconciled differences between the specific plant design and the topical report design descriptions.
RESPONSE
Entergy performed an evaluation of the proposed GGNS-specific PRNM System installation against the requirements of the NUMAC PRNM LTR and associated NRC Safety Evaluations; the resulting document is provided in. Clarifications and reconciled differences between the plant-specific design and the NUMAC PRNM LTR design descriptions are identified in Section 5.1.3, below.
2.
Confirm the applicability of the BWROG topical reports that address PRNMS and associated instability functions, setpoints, and margins.
RESPONSE
The applicability of the various BWROG LTRs that address the NUMAC PRNM System, the Option III stability solution, the reload-related aspects, and the development of setpoints is discussed herein or through reference to the various reports.
3.
Provide plant-specific revised TS for the NUMAC PRNMS functions consistent with NEDC-32410P-A, Appendix H, and Supplement 1.
RESPONSE
Entergy confirms the plant-specific TS changes to implement the NUMAC PRNM System (including the OPRM Option III stability solution), which are provided in Attachment 3, are consistent with the requirements of the NUMAC PRNM LTR.
4.
Confirm the plant-specific environmental conditions are enveloped by the NUMAC PRNM System equipment environmental qualification values.
RESPONSE
The analysis of the plant-specific environmental conditions to the NUMAC PRNM System equipment qualification (EQ) values is discussed in GEH Report GE-NE-0000-01 02-0888 (Reference 5), which is provided in. The results of this analysis confirm the plant-specific environmental conditions are enveloped by the NUMAC PRNM System EQ values.
to GNRO-2009-00054 Page 33 of 41 5.1.3 5.1.4 5.
Confirm that administrative controls are provided for manually bypassing APRM / OPRM channels or protective functions, and for controlling access to the APRM / OPRM panel and channel bypass switch.
RESPONSE
In the NRC Safety Evaluation for the NUMAC PRNM LTR, the NRC staff found the NUMAC PRNM System design features that control access to setpoint adjustments, calibrations, and test points acceptable. Entergy is not proposing any changes to those features. In accordance with the requirements of the NUMAC PRNM LTR, administrative controls will be provided for manually bypassing the APRM / OPRM channels or protective functions, and for controlling access to the APRM / OPRM panel and channel bypass switch.
6.
Confirm that any changes to the plant operator's panel have received human factors reviews per plant-specific procedures.
RESPONSE
The site design change process requires performing a Human Factors Engineering {HFE} review of changes to the Control Room Operator's panels. Documenting the HFE review will be included in the final design package(s) for the PRNM System and available on-site for NRC inspection.
Based upon the above discussions, Entergy believes the requirements raised within the NRC staff Safety Evaluations have been adequately addressed.
GGNS PRNM System Deviations from the NUMAC PRNM LTR The NUMAC PRNM System in development for GGNS by GEH reflects three deviations from the NUMAC PRNM LTR. They are :
1.
APRM Upscale / OPRIVI Upscale / APRM Inop Function Logic 2.
OPRM Pre-Trip Alarms 3.
Recirculation Flow Processing Each deviation is discussed and justified in Appendix A of GEH Report 0000-0102-0888 (Reference 5), which is provided in Attachment 2.
GGNS Option 111 -Stability Solution Deviations from the BWROG Stability LTR The Option III stability solution developed for GGNS by GEH reflects two deviations from the BWROG Option III methodology (References 6 and 15)
They are :
1.
Base Period Definition for Period-Based Detection Algorithm {PBDA} to GNRO-2009-00054 Page 33 of 41 5.
Confirm that administrative controls are provided for manually bypassing APRM / OPRM channels or protective functions, and for controlling access to the APRM / OPRM panel and channel bypass switch.
RESPONSE
In the NRC Safety Evaluation for the NUMACPRNM LTR, the NRC staff found the NUMAC PRNM System design features that control access to setpoint adjustments, calibrations, and test points acceptable. Entergy is not proposing any changes to those features. In accordance with the requirements of the NUMAC PRNM LTR, administrative controls will be provided for manually bypassing the APRM / OPRM channels or protective functions, and for controlling access to the APRM / OPRM panel and channel bypass switch.
6.
Confirm that any changes to the plant operator's panel have received human factors reviews per plant-specific procedures.
RESPONSE
The site design change process requires performing a Human Factors Engineering (HFE) review of changes to the Control Room Operator's panels. Documenting the HFE review will be included in the final design package(s) for the PRNM System and available on-site for NRC inspection.
Based upon the above discussions, Entergy believes the requirements raised within the NRC staff Safety Evaluations have been adequately addressed.
5.1.3 GGNS PRNM System Deviations from the NUMAC PRNM LTR The NUMAC PRNM System in development for GGNS by GEH reflects three deviations from the NUMAC PRNM LTR. They are:
1.
APRM Upscale / OPRM Upscale / APRM Inop Function Logic 2.
OPRM Pre-Trip Alarms 3.
Recirculation Flow Processing Each deviation is discussed and justified in Appendix A of GEH Report 0000-0102-0888 (Reference 5), which is provided in Attachment 2.
5.1.4 GGNS Option III Stability Solution Deviations from the BWROG Stability LTR The Option III stability solution developed for GGNS by GEH reflects two deviations from the BWROG Option III methodology (References 6 and 15).
They are:
1.
Base Period Definition for Period-Based Detection Algorithm (PBDA) to GNRO-2009-00054 Page 34 of 41
- 2.
Period Tolerance Offset Each deviation is discussed and justified in GEH Report 0000-0107-7607-P, Grand Gulf Nuclear Station - Grand Gulf PRNM Upgrade Project Option ///
Stability Deviations (Reference 16), which is provided in Attachments 5 and 6 (proprietary and non-proprietary versions, respectively).
5.1.5 Setpoint Methodolo-q Description The instrument setpoint methodology currently implemented at GGNS is based on Instrument Society of America (ISA) Standard 67.04 Part 11, 1994, Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation (Reference 17), and the GEH Instrument Setpoint Methodology (ISM) specified in NEDC-31336P-A, General Electric Instrument Setpoint Methodology (Reference 18).
Setpoint calculations provide a conservative analysis of setpoints, taking into account the applicable instrument measurement errors.
The Nominal Trip Setpoint (NTSP} is more conservative than the Allowable Value (AV). Because it is impossible to set an instrument channel to an exact value, a calibration tolerance is established around the NTSP. The NTSP is, therefore, considered a nominal value and the instrument adjustment is considered successful if the "as-left" instrument setting is within the calibration tolerance established around the NTSP.
Entergy calculates the setpoints from the Analytical Limit (AL), establishing margins between the AL, the AV, and the NTSP based on calculated instrument errors. Random errors are combined using the square-root-of-the sum-of-the-squares method, and non-conservative bias errors are added algebraically. This approach provides sufficient margin between the AL and AV to ensure at least 95% probability that the AL is not exceeded if the setpoint drifts toward the AV.
Enterw's Tvpical Calibration Process At the start of each calibration, the instrument is declared inoperable (in the case of TS-controlled instruments) and removed from service. The Operations Shift Supervisor or Manager reviews the results of the surveillance and determines whether the results are acceptable based on TS operability requirements prior to returning the instrument to service.
If the as-found setpoint value exceeds its designated tolerance, the condition is documented for trending purposes and appropriate corrective actions are taken before the instrument is returned to service. Once actions have been taken to correct the condition, the instrument setpoint is reset to as close to the NTSP value as practicable and the instrument is returned to service. to GNRO-2009-00054 Page 34 of 41 2.
Period Tolerance Offset Each deviation is discussed and justified in GEH Report 0000-0107-7607-P, Grand Gulf Nuclear Station - Grand Gulf PRNM Upgrade Project Option III Stability Deviations (Reference 16), which is provided in Attachments 5 and 6 (proprietary and non-proprietary versions, respectively).
5.1.5 Setpoint Methodology Description The instrument setpoint methodology currently implemented at GGNS is based on Instrument Society of America (ISA) Standard 67.04 Part II, 1994, Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation (Reference 17), and the GEH Instrument Setpoint Methodology (ISM) specified in NEDC-31336P-A, General Electric Instrument Setpoint Methodology (Reference 18).
Setpoint calculations provide a conservative analysis of setpoints, taking into account the applicable instrument measurement errors.
The Nominal Trip Setpoint (NTSP) is more conservative than the Allowable Value (AV). Because it is impossible to set an instrument channel to an exact value, a calibration tolerance is established around the NTSP. The NTSP is, therefore, considered a nominal value and the instrument adjustment is considered successful if the "as-left" instrument setting is within the calibration tolerance established around the NTSP.
Entergy calculates the setpoints from the Analytical Limit (AL), establishing margins between the AL, the AV, and the NTSP based on calculated instrument errors. Random errors are combined using the square-root-of-the-sum-of-the-squares method, and non-conservative bias errors are added algebraically. This approach provides sufficient margin between the AL and AV to ensure at least 95% probability that the AL is not exceeded if the setpoint drifts toward the AV.
Entergy's Typical Calibration Process At the start of each calibration, the instrument is declared inoperable (in the case of TS-controlled instruments) and removed from service. The Operations Shift Supervisor or Manager reviews the results of the surveillance and determines whether the results are acceptable based on TS operability requirements prior to returning the instrument to service.
If the as-found setpoint value exceeds its designated tolerance, the condition is documented for trending purposes and appropriate corrective actions are taken before the instrument is returned to service. Once actions have been taken to correct the condition, the instrument setpoint is reset to as close to the NTSP value as practicable and the instrument is returned to service.
to GNRO-2009-00054 Page 35 of 41 For cases in which the as-found setpoint value is within its designated tolerance, it is common practice to reset the setpoint value to as close to the NTSP value as practicable.
This process is applied to both safety-related and non-safety-related setpoints.
NRC and Industry Guidance and Application Over the past several years, the NRC and the nuclear industry have participated in various forums to address the setpoint methodology issue. On September 7, 2005, the NRC transmitted a letter to the NEI Setpoint Methods Task Force (Reference 19) that described setpoint-related TS that are acceptable for instrument settings associated with Safety Limit-related setpoints. On August 24, 2006, the NRC issued Regulatory Issue Summary (RIS} 2006-17 (Reference 20) to provide guidance and information pertaining to the requirements of 10 CFR 50.36 with respect to limiting safety system settings (LSSSs} assessed during periodic instrument testing and calibration.
The NRC and industry have been working together on a Technical Specifications Task Force (TSTF) proposal, TSTF-493, Clarify Application of Setpoint Methodology for LSSS Functions, to address the setpoint methodology issue.
In a letter to the NRC dated February 23, 2009 (Reference 21), the TSTF documented a proposed course of action to be taken by the industry to address the NRC's questions and concerns with TSTF-493. The NRC responded in a letter dated March 9, 2009 (Reference 22) stating the TSTF letter "meets the agreed course of action...
for resolving the TSTF-493 setpoint issue". The NRC's comments have been incorporated into TSTF-493, Rev. 4, which was submitted to the staff on July 31, 2009 (Reference 13 In order to address the setpoint methodology issue, Entergy has applied the actions identified in TSTF-493 (Reference 13) to this LAR ; the results being that the two notes specified in the TSTF are applied to channel calibration SR 3.3. 1. 1.10 for the following APRM functions listed in TS Table 3.3.1.1-1 :
TS APRM Function TS APRIVI Function Name Designation Neutron Flux - High, Setdown 2.a Fixed Neutron Flux - High 2.b Flow Biased Simulated Thermal Power - High 2.d OPRM Upscale 2.f The new notes, Notes (d) and (e) of TS Table 3.3.1.1-1, are specified in Section 4.4.3.1.b, above.
15 APRM Function Name to GNRO-2009-00054 Page 35 of 41 For cases in which the as-found setpoint value is within its designated tolerance, it is common practice to reset the setpoint value to as close to the NTSP value as practicable.
This process is applied to both safety-related and non-safety-related setpoints.
NRC and Industry Guidance and Application Over the past several years, the NRC and the nuclear industry have participated in various forums to address the setpoint methodology issue. On September 7,2005, the NRC transmitted a letter to the NEI Setpoint Methods Task Force (Reference 19) that described setpoint-related TS that are acceptable for instrument settings associated with Safety Limit-related setpoints. On August 24, 2006, the NRC issued Regulatory Issue Summary (RIS) 2006-17 (Reference 20) to provide guidance and information pertaining to the requirements of 10 CFR 50.36 with respect to limiting safety system settings (LSSSs) assessed during periodic instrument testing and calibration.
The NRC and industry have been working together on a Technical Specifications Task Force (TSTF) proposal, TSTF-493, Clarify Application of Setpoint Methodology for LSSS Functions, to address the setpoint methodology issue. In a letter to the NRC dated February 23, 2009 (Reference 21), the TSTF documented a proposed course of action to be taken by the industry to address the NRC's questions and concerns with TSTF-493. The NRC responded in a letter dated March 9, 2009 (Reference 22) stating the TSTF letter "meets the agreed course of action...
for resolving the TSTF-493 setpoint issue". The NRC's comments have been incorporated into TSTF-493, Rev. 4, which was submitted to the staff on July 31, 2009 (Reference 13).
In order to address the setpoint methodology issue, Entergy has applied the actions identified in TSTF-493 (Reference 13) to this LAR; the results being that the two notes specified in the TSTF are applied to channel calibration SR 3.3.1.1.10 for the following APRM functions listed in TS Table 3.3.1.1-1:
15 APRM Function Designation Neutron Flux - High, Setdown Fixed Neutron Flux - High Flow Biased Simulated Thermal Power - High OPRM Upscale 2.a 2.b 2.d 2.f The new notes, Notes (d) and (e) ofTS Table 3.3.1.1-1, are specified in Section 4.4.3.1.b, above.
to GNRO-2009-00054 Page 36 of 41 The TRM will be revised to reflect the NTSP and methodologies used to determine the as-found and as-left tolerances prior to startup from the 2012 refueling outage.
New Notes (d) and (e) are not applicable to Inop Function 2.c and 2-Out-Of-4 Voter Function 2.e since they meet the third criterion for exemption provided in the TSTF letter, as follows :
"3.
Instrument functions that derive input from contacts which have no associated sensor or adjustable device, e.g., limit switches, breaker position switches, etc. Many permissives or interlocks are excluded under this criterion. Other permissives and interlocks rely on the input from a sensor or adjustable device (e.g., a pressure transmitter). If the permissive or interlock derives input from a sensor or adjustable device that is tested as part of another TS function, then the permissive or interlock is excluded from the footnotes (emphasis added). Otherwise, the footnotes are added to the permissive or interlock to ensure that it is functioning as expected."
The Bases for TS 3.3.1.1 describe the application of the notes to SR 3.3. 1. 1.10 as applied to APRM Functions 2.a, 2.b, 2.d, and 2.f. Draft marked-up pages of the affected TS Bases are provided in Attachment 4, for information only. In addition, GGNS calibration procedures for these APRM functions will be revised to reflect the instructions given in the above notes.
5.2 No Significant Hazards Determination RESPONSE: No In accordance. with the requirements of 10 CFR 50.90, Entergy Operations, Inc.
(Entergy} requests an amendment to facility Operating License NPF-29, for the Grand Gulf Nuclear Station (GGNS}. This license amendment request proposes to revise the GGNS Technical Specifications (TS) to reflect installation of the Nuclear Measurement Analysis and Control (NUMAC} Power Range Neutron Monitoring (PRNM} System.
Entergy has evaluated the proposed license amendment request in accordance with 10 CFR 50.91 against the standards in 10 CFR 50.92 and has determined that the operation of GGNS in accordance with the proposed amendment presents no significant hazards. Entergy's evaluation against each of the criteria in 10 CFR 50.92 follows.
Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
The probability (frequency of occurrence) of design basis accidents (DBAs) occurring is not affected by the NUMAC PRNM System, since the system does not interact with equipment whose failure could cause an accident. Compliance with the regulatory criteria established for plant equipment are maintained with to GNRO-2009-00054 Page 36 of 41 The TRM will be revised to reflect the NTSP and methodologies used to determine the as-found and as-left tolerances prior to startup from the 2012 refueling outage.
New Notes (d) and (e) are not applicable to Inop Function 2.c and 2-0ut-Of-4 Voter Function 2.e since they meet the third criterion for exemption provided in the TSTF letter, as follows:
"3.
Instrument functions that derive input from contacts which have no associated sensor or adjustable device, e.g., limit switches, breaker position switches, etc. Many permissives or interlocks are excluded under this criterion. Other permissives and interlocks rely on the input from a sensor or adjustable device (e.g., a pressure transmitter). If the permissive or interlock derives input from a sensor or adjustable device that is tested as part ofanother T5 function, then the permissive or interlock is excluded from the footnotes (emphasis added). Otherwise, the footnotes are added to the permissive or interlock to ensure that it is functioning as expected."
The Bases for TS 3.3.1.1 describe the application of the notes to SR 3.3.1.1.10 as applied to APRM Functions 2.a, 2.b, 2.d, and 2.f. Draft marked-up pages of the affected TS Bases are provided in Attachment 4, for information only. In addition, GGNS calibration procedures for these APRM functions will be revised to reflect the instructions given in the above notes.
5.2 No Significant Hazards Determination In accordanc~. with the requirements of 10 CFR 50.90, Entergy Operations, Inc.
(Entergy) requests an amendment to facility Operating License NPF-29, for the Grand Gulf Nuclear Station (GGNS). This license amendment request proposes to revise the GGNS Technical Specifications (TS) to reflect installation of the Nuclear Measurement Analysis and Control (NUMAC) Power Range Neutron Monitoring (PRNM) System.
Entergy has evaluated the proposed license amendment request in accordance with 10 CFR 50.91 against the standards in 10 CFR 50.92 and has determined that the operation of GGNS in accordance with the proposed amendment presents no significant hazards. Entergy's evaluation against each of the criteria in 10 CFR 50.92 follows.
1.
Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
RESPONSE: No.
The probability (frequency of occurrence) of design basis accidents (DBAs) occurring is not affected by the NUMAC PRNM System, since the system does not interact with equipment whose failure could cause an accident. Compliance with the regulatory criteria established for plant equipment are maintained with to GNRO-2009-00054 Page 37 of 41 the installation of the upgraded NUMAC PRNM System. Scram setpoints in the NUMAC PRNM System are established such that the analytical limits are met.
The unavailability of the new NUMAC PRNM System is equal to or less than the existing system and, as a result, the scram reliability is equal to or better than the existing analog power range monitoring system. No new challenges to safety-related equipment result from the NUMAC PRNM System modification.
Therefore, the proposed change does not involve a significant increase in the ability of an accident previously evaluated.
kind of accident RESPONSE: No The proposed change replaces the current Option E-I-A stability solution with an NRC-approved Option III long-term stability solution. The NUMAC PRNM hardware incorporates the Oscillation Power Range Monitor (OPRM) Option III detect-and-suppress solution, which has been previously reviewed and approved by the NRC. The OPRM meets General Design Criterion (GDC) 10, Reactor Design, and GDC 12, Suppression of Reactor Power Oscillations, requirements by automatically detecting and suppressing design basis thermal-hydraulic oscillations prior to exceeding the fuel Minimum Critical Power Ratio (MCPR)
Safety Limit.
Based on the above, installation of the new NUMAC PRNIVI System with the OPRIVI Option III stability solution integrated into the NUMAC PRNM equipment does not increase the probability or consequences of an accident previously evaluated.
Does the proposed amendment create the possibility of a new or different om any accident previously evaluated?
The components of the NUMAC PRNM System are equivalent or of better design and qualification criteria than those currently installed and utilized in the plant. No new operating mode, safety-related equipment lineup, accident scenario, or system interaction mode not reviewed and approved as part of the design and licensing of the NUMAC PRNM System has been identified.
Therefore, the NUMAC PRNM System retrofit does not adversely affect plant equipment.
The new NUMAC PRNM System uses digital equipment that has software-controlled digital processing compared to the existing power range system that uses mostly analog and discrete component processing. Specific failures of hardware and potential software common-cause failures are different from the existing system. The effects of potential software common-cause failure are mitigated by specific hardware design and system architecture as discussed in Section 6.0 of NEDC-32410P-A. Failure(s) of the system have the same overall effect as the present design. No new or different kinds of accidents are introduced. Therefore, the NUMAC PRNM System does not adversely effect plant equipment. to GNRO-2009-00054 Page 37 of 41 the installation of the upgraded NUMAC PRNM System. Scram setpoints in the NUMAC PRNM System are established such that the analytical limits are met.
The unavailability of the new NUMAC PRNM System is equal to or less than the existing system and, as a result, the scram reliability is equal to or better than the existing analog power range monitoring system. No new challenges to safety-related equipment result from the NUMAC PRNM System modification.
Therefore, the proposed change does not involve a significant increase in the probability of an accident previously evaluated.
The proposed change replaces the current Option E-I-A stability solution with an NRC-approved Option III long-term stability solution. The NUMAC PRNM hardware incorporates the Oscillation Power Range Monitor (OPRM) Option III detect-and-suppress solution, which has been previously reviewed and approved by the NRC. The OPRM meets General Design Criterion (GDC) 10, Reactor Design, and GDC 12, Suppression of Reactor Power Oscillations, requirements by automatically detecting and suppressing design basis thermal-hydraulic oscillations prior to exceeding the fuel Minimum Critical Power Ratio (MCPR)
Safety Limit.
Based on the above, installation of the new NUMAC PRNM System with the OPRM Option III stability solution integrated into the NUMAC PRNM equipment does not increase the probability or consequences of an accident previously evaluated.
2.
Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
RESPONSE: No.
The components of the NUMAC PRNM System are equivalent or of better design and qualification criteria than those currently installed and utilized in the plant. No new operating mode, safety-related equipment lineup, accident scenario, or system interaction mode not reviewed and approved as part of the design and licensing of the NUMAC PRNM System has been identified.
Therefore, the NUMAC PRNM System retrofit does not adversely affect plant equipment.
The new NUMAC PRNM System uses digital equipment that has software-controlled digital processing compared to the existing power range system that uses mostly analog and discrete component processing. Specific failures of hardware and potential software common-cause failures are different from the existing system. The effects of potential software common-cause failure are mitigated by specific hardware design and system architecture as discussed in Section 6.0 of NEDC-3241 OP-A. Failure(s) of the system have the same overall effect as the present design. No new or different kinds of accidents are introduced. Therefore, the NUMAC PRNM System does not adversely effect plant equipment.
to GNRO-2009-00054 Page 38 of 41
- 3.
The currently installed Average Power Range Monitoring (APRM} system is replaced with a NUMAC PRNM System that performs the existing power range monitoring functions and adds an OPRIVI to react automatically to potential reactor thermal-hydraulic instabilities. Based on the above, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Does the proposed amendment involve a significant reduction in a margin of safety?
RESPONSE: No The proposed TS changes associated with the NUMAC PRNM System retrofit implement the constraints of the NUMAC PRNM System design and related stability analyses. The NUMAC PRNM System change does not impact reactor operating parameters or the functional requirements of the APRM system. The replacement equipment continues to provide information, enforce control rod blocks, and initiate reactor scrams under appropriate specified conditions. The proposed change does not reduce safety margins. The replacement APRM equipment has improved channel trip accuracy compared to the current analog system, and meets or exceeds system requirements previously assumed in setpoint analysis. Thus, the ability of the new equipment to enforce compliance with margins of safety equals or exceeds the ability of the equipment which it replaces.
Therefore, the proposed changes do not involve a reduction in a margin of safety.
Based on the above, Entergy has determined that operation of the facility in accordance with the proposed change does not involve a significant hazards consideration as defined in 10 CFR 50.92(c), in that it :
(1) Does not involve a significant increase in the probability or consequences of an accident previously evaluated ; or (2) Does not create the possibility of a new or different kind of accident from any accident previously evaluated ; or (3)
Does not involve a significant reduction in a margin of safety.
5.3 Environmental Consideration Entergy has determined that the proposed amendment would not change a requirement with respect to installation or use of a facility or component located within the restricted area, as defined in 10 CFR 20, nor would it change an inspection or surveillance requirement. The proposed amendment:
(i}
Does not involve a significant hazards consideration; or to GNRO-2009-00054 Page 38 of 41 The currently installed Average Power Range Monitoring (APRM) system is replaced with a NUMAC PRNM System that performs the existing power range monitoring functions and adds an OPRM to react automatically to potential reactor thermal-hydraulic instabilities. Based on the above, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
Does the proposed amendment involve a significant reduction in a margin of safety?
RESPONSE: No.
The proposed TS changes associated with the NUMAC PRNM System retrofit implement the constraints of the NUMAC PRNM System design and related stability analyses. The NUMAC PRNM System change does not impact reactor operating parameters or the functional requirements of the APRM system. The replacement equipment continues to provide information, enforce control rod blocks, and initiate reactor scrams under appropriate specified conditions. The proposed change does not reduce safety margins. The replacement APRM equipment has improved channel trip accuracy compared to the current analog system, and meets or exceeds system requirements previously assumed in setpoint analysis. Thus, the ability of the new equipment to enforce compliance with margins of safety equals or exceeds the ability of the equipment which it replaces.
Therefore, the proposed changes do not involve a reduction in a margin of safety.
Based on the above, Entergy has determined that operation of the facility in accordance with the proposed change does not involve a significant hazards consideration as defined in 10 CFR 50.92(c), in that it:
(1)
Does not involve a significant increase in the probability or consequences of an accident previously evaluated; or (2)
Does not create the possibility of a new or different kind of accident from any accident previously evaluated; or (3)
Does not involve a significant reduction in a margin of safety.
5.3 Environmental Consideration Entergy has determined that the proposed amendment would not change a requirement with respect to installation or use of a facility or component located within the restricted area, as defined in 10 CFR 20, nor would it change an inspection or surveillance requirement. The proposed amendment:
(i)
Does not involve a significant hazards consideration; or to GNRO-2009-00054 Page 39 of 41 (ii)
Does not authorize a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite; or Accordingly, the proposed amendment meets the eligibility criterion for a categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b),
Entergy concludes no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
6.0 PRECEDENCE
7.0 REFERENCES
Does not result in a significant increase in individual or cumulative occupational radiation exposure.
License amendments for installing the NUMAC PRNM System with Option III have been approved for many plants, among them : Susquehanna Units 1 and 2 ; Nine Mile Point Unit 2 ;
Browns Ferry Units 1, 2, and 3 ; Hatch Units 1 and 2 ; Fermi Unit 2 ; Limerick Units 1 and 2 ;
Peach Bottom Units 2 and 3; Brunswick Units 1 and 2 ; and Monticello.
GE Nuclear Energy Licensing Topical Report (LTR} NEDC-3241 OP-A Volume 1 and NEDC-3241 OP-A Volume 2 -- Appendices, Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAG PRNM) Retrofit Plus Option ///
Stability Trip Function, dated October 1995 (ADAMS Ascension No. ML9605290009 includes NRC SE) 2.
GE Nuclear Energy LTR NEDC-3241 OP-A Supplement 1, Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAG PRNM) Retrofit Plus Option /// Stability Trip Function, dated November 1997 (ADAMS Ascension No.
ML9806120242 includes NRC SE) 3.
NRC letter to GE Nuclear Energy, Acceptance of Licensing Topical Report NED C-324 I OP, Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC-PRNM) Retrofit Plus Option /// Stability Trip Function, (TAG No.
M90616) dated September 5, 1995 4.
NRC letter to GE Nuclear Energy, Acceptance of Licensing Topical Report NEDC-324 I OP, Supplement 1, Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAG-PRNM) Retrofit Plus Option /// Stability Trip Function, dated August 15, 1997
- 5.
GE Hitachi Nuclear Energy Report 0000-0102-0888, Grand Gulf Nuclear Station -
Plant-Specific Responses Required by NUMAC PRNM Retrofit Plus Option /// Stability Trip Function Topical Report (NEDG-3241QP-A)
GE Hitachi Nuclear Energy LTR NEDO-31960-A, BWR Owners' Group Long-Term Stability Solutions Licensing Methodology, and associated Supplement 1 to GNRO-2009-00054 Page 39 of 41 (ii)
Does not authorize a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite; or (iii)
Does not result in a significant increase in individual or cumulative occupational radiation exposure.
Accordingly, the proposed amendment meets the eligibility criterion for a categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b),
Entergy concludes no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
6.0 PRECEDENCE License amendments for installing the NUMAC PRNM System with Option III have been approved for many plants, among them: Susquehanna Units 1 and 2; Nine Mile Point Unit 2; Browns Ferry Units 1, 2, and 3; Hatch Units 1 and 2; Fermi Unit 2; Limerick Units 1 and 2; Peach Bottom Units 2 and 3; Brunswick Units 1 and 2; and Monticello.
7.0 REFERENCES
1.
GE Nuclear Energy Licensing Topical Report (LTR) NEDC-3241 OP-A Volume 1 and NEDC-32410P-A Volume 2 -- Appendices, Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function, dated October 1995 (ADAMS Ascension No. ML9605290009 includes NRC SE) 2.
GE Nuclear Energy LTR NEDC-3241 OP-A Supplement 1, Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function, dated November 1997 (ADAMS Ascension No.
ML9806120242 includes NRC SE) 3.
NRC letter to GE Nuclear Energy, Acceptance of Licensing Topical Report NEDC-32410P, Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC-PRNM) Retrofit Plus Option III Stability Trip Function, (TAC No.
M90616) dated September 5, 1995 4.
NRC letter to GE Nuclear Energy, Acceptance of Licensing Topical Report NEDC-32410P, Supplement 1, Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC-PRNM) Retrofit Plus Option III Stability Trip Function, dated August 15, 1997 5.
GE Hitachi Nuclear Energy Report 0000-0102-0888, Grand Gulf Nuclear Station -
Plant-Specific Responses Required by NUMAC PRNM Retrofit Plus Option III Stability Trip Function Topical Report (NEDC-32410P-A) 6.
GE Hitachi Nuclear Energy LTR NEDO-31960-A, BWR Owners' Group Long-Term Stability Solutions Licensing Methodology, and associated Supplement 1 to GNRO-2009-00054 Page 40 of 41
- 7.
NRC letter to Entergy Operations, Inc., Grand Gulf Nuclear Station, Unit I - Issuance of Amendment Re : Reactor Core Stability Enhanced Option I -A (TAC NO. MA3406),
January 19, 2000
- 8.
NRC Generic Letter 94-02, Long-Term Solutions and Upgrade of Interim Operating Recommendations for Thermal Hydraulic Instabilities in Boiling Water Reactors
- 9.
BWR Owners' Group Document OG-02-0119-260, GE to BWROG Detect and Suppress // Committee, "Backup Stability Protection (BSP) for Inoperable Option /I/
Soluti
- 10.
NRC letter to Northern States Power Company, Monticello Nuclear Generating Plant (MNGP) - Issuance of Amendment Regarding the Power Range Neutron Monitoring System (TAC No. MD8064), dated January 30, 2009 (ADAMS Ascension No.
M L083440681) 11.
NRC letter to Exelon Nuclear, Peach Bottom Atomic Power Station, Units 2 and 3 -
Issuance of Amendment Re : Activation of Oscillation Power Range Monitor Trip (TAC Nos. MC2219 and MC2220), dated March 21, 2005 (page 4 of SE) (ADAMS Accession No. ML05270020)
- 12.
NRC letter to the Carolina Power and Light Company, Brunswick Steam Electric Plant, Units I and 2 - Issuance of Amendment to Incorporate the General Electric Digital Power Range Neutron Monitoring System (TAC Nos.
M82321 and MB2322), dated March 8, 2002
- 13.
Technical Specifications Task Force letter to the NRC, Transmittal of TSTF-493, Rev. 4, "Clarify Application of Setpoint Methodology for LSSS Functions, " dated July 31, 2009 {ADAMSAccession Number ML092150990) 14.
GE Hitachi Nuclear Energy Report 0000-0102-8815, Instrument Limits Calculation -
Average Power Range Neutron Monitor - Power Range Neutron Monitoring System (NUMAC) - CL TP Operation
- 15.
GE Nuclear Energy LTR NEDO-32465-A, BWR Owners' Group Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications
- 16.
GE Hitachi Nuclear Energy Report 0000-0107-7607-P, Grand Gulf Nuclear Station -
Grand Gulf PRNM Upgrade Project Option /// Stability Deviations 17.
Instrument Society of America standard 67.04, Part 11, 1994, Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation 18.
GE Nuclear Energy LTR NEDC-31336P-A, General Electric Instrument Selpoint Methodology 19.
NRC letter to the NEI Setpoints Methods Task Force, Technical Specification for Addressing Issues Related to Setpoint Allowable Values, dated September 7, 2005 (ADAMS Accession Number ML052500004) to GNRO-2009-00054 Page 40 of 41 7.
NRC letter to Entergy Operations, Inc., Grand Gulf Nuclear Station, Unit 1-Issuance ofAmendment Re: Reactor Gore Stability Enhanced Option I-A (TAG NO. MA3406),
January 19, 2000 8.
NRC Generic Letter 94-02, Long-Term Solutions and Upgrade of Interim Operating Recommendations for Thermal Hydraulic Instabilities in Boiling Water Reactors 9.
BWR Owners' Group Document OG-02-0119-260, GE to BWROG Detect and Suppress II Committee, "Backup Stability Protection (BSP) for Inoperable Option III Solution" 10.
NRC letter to Northern States Power Company, Monticello Nuclear Generating Plant (MNGP) - Issuance ofAmendment Regarding the Power Range Neutron Monitoring System (TAG No. MDB064), dated January 30,2009 (ADAMS Ascension No.
11.
NRC letter to Exelon Nuclear, Peach Bottom Atomic Power Station, Units 2 and 3 -
Issuance ofAmendment Re: Activation of Oscillation Power Range Monitor Trip (TAC Nos. MC2219 and MC2220), dated March 21,2005 (page 4 of SE) (ADAMS Accession No. ML05270020) 12.
NRC letter to the Carolina Power and Light Company, Brunswick Steam Electric Plant, Units 1 and 2 - Issuance ofAmendment to Incorporate the General Electric Digital Power Range Neutron Monitoring System (TAC Nos. MB2321 and MB2322), dated March 8, 2002 13.
Technical Specifications Task Force letter to the NRC, Transmittal of TSTF-493, Rev. 4, "Clarify Application of Setpoint Methodology for LSSS Functions," dated July 31,2009 (ADAMS Accession Number ML092150990) 14.
GE Hitachi Nuclear Energy Report 0000-0102-8815, Instrument Limits Calculation-Average Power Range Neutron Monitor - Power Range Neutron Monitoring System (NUMAC) - CLTP Operation 15.
GE Nuclear Energy LTR NEDO-32465-A, BWR Owners' Group Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications 16.
GE Hitachi Nuclear Energy Report 0000-0107-7607-P, Grand Gulf Nuclear Station-Grand Gulf PRNM Upgrade Project Option III Stability Deviations 17.
Instrument Society of America standard 67.04, Part II, 1994, Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation 18.
GE Nuclear Energy LTR NEDC-31336P-A, General Electric Instrument Setpoint Methodology 19.
NRC letter to the NEI Setpoints Methods Task Force, Technical Specification for Addressing Issues Related to Setpoint Allowable Values, dated September 7,2005 (ADAMS Accession Number ML052500004) to GNRO-2009-00054 Page 4 1 of 41 20.
NRC Regulatory Issue Summary (RIS) 2006-17, NRC Staff Position on the Requirements of 10 CFR 50.36, "Technical Specifications," Regarding Limiting Safety System Settings During Periodic Testing and Calibration of Instrument Channels 21.
Technical Specifications Task Force letter to the NRC, Industry Plan to Resolve TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions, " dated February 23, 2009 (ADAMS Accession Number MI-090540849)
- 22.
NRC letter to the Technical Specifications Task Force, Reply to Industry Plan to Resolve TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions, dated March 9, 2009 (ADAMS Accession Number MI-0905460592) to GNRO-2009-00054 Page 41 of 41 20.
NRC Regulatory Issue Summary (RIS) 2006-17, NRC Staff Position on the Requirements of 10 CFR 50.36, "Technical Specifications," Regarding Limiting Safety System Settings During Periodic Testing and Calibration of Instrument Channels 21.
Technical Specifications Task Force letter to the NRC, Industry Plan to Resolve TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions," dated February 23,2009 (ADAMS Accession Number ML090540849) 22.
NRC letter to the Technical Specifications Task Force, Reply to Industry Plan to Resolve TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions,"
dated March 9,2009 (ADAMS Accession Number ML0905460592)
NU F NUC ITA HI NUCLEAR ENERGY REPORT 000-0102-0888 ATTACH RO-20
.EAR STATION - PLANT-SPECIFIC RESPONSES RE TROFIT PLUS OPTION III STABILITY TRIP FUNCTION TOPICAL REPORT (NEDC-3241OP-ENT 2 ATTACHMENT 2 GNRO-2009-Q0054 GE HITACHI NUCLEAR ENERGY REPORT 0000-0102-0888-RO GRAND GULF NUCLEAR STATION - PLANT-SPECIFIC RESPONSES REQUIRED BY NUMAC PRNM RETROFIT PLUS OPTION III STABiliTY TRIP FUNCTION TOPICAL REPORT (NEDC-32410P-A)
0000-0 1 02-0888-RO GEH DRF 0000-0098-4327 Class III October 2009 Grand Gulf Nuclear Station Plant-Specific Responses Required By NUMAC PRNM Retrofit Plus Option III Stability Trip Function Topical Report (NEDC-32410P-A)
Prepared by:
S. Rudy Verified by:
R. Hayes Approved by: E. Schrull HITACHI GE Hitachi NUclear Energy 0000-0102-0888-RO GEH DRF 0000-0098-4327 Class III October 2009 Grand GulfNuclear Station Plant-Specific Responses Required By NUMAC PRNM Retrofit Plus Option III Stability Trip Function Topical Report (NEDC-32410P-A)
Prepared by:
S. Rudy Verified by:
R. Hayes Approved by: E. Schroll
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRN Table of Content Grand Gulf Specific Responses Required by NUMAC PRNM Pages 1-19 trofit Topical Report Appendix A ulf Nuclear Station NUMAC PRNM L' Retrofit Topical Report eviations Pages Al-A7 0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Table of Contents Grand Gulf Specific Responses Required by NUMAC PRNM Pages 1-19 Retrofit Topical Report Appendix A, Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Pages AI-A7
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PAM Retrofit Topical Report The section numbers and Utility Actions Required listed below are from the NUMAC PAM Retrofit Plus Option III Stability Trip Function Topical Report NEDC-3 24 1 OP-A including Supplement 1.
Section Utility Action Required 2.3.2 2.3.4 3.4 Option III Stability Implementation of a required specific LTR response Confirm that the actual plant Option III configuration is included in the variations covered in the Power Range Neutron Monitor (PAM) Licensing Topical Report (LTR)
[NEDC-32410P-A, Volumes I & 2 and Supplement 1].
lout Unique or Plant-Specific Aspects Confirm that the actual plant configuration is included in the variations covered in the Power Range Neutron Monitor (PAM) Licensing opical Report (LTR) [NEDC-32410P-A, Volumes I & 2 and Supplement 1], and the configuration alternative(s) being applied for the replacement PRNM are covered by the PRNM LTR. Document in the plant-specific licensing submittal for the PRNM project the actual, current plant configuration of the replacement PRNM, and document confirmation that those are covered by the PRNM LTR. For any changes to the plant operator's panel, document in the submittal the human factors review actions that were taken to confirm compatibility with existing plant commitments and procedures.
System Functions As part of the plant-specific licensing submittal, the utility should document the following :
The pre-modification flow channel configuration, and any changes planned (normally changes will be either adding two channels to reach four or no change planned)
NOTE : If transmitters are added, the requirements on the added transmitters should be :
0 Non-safety related, but qualified espouse The GGNS Option III implementation is in accordance with the LTR Requirements of section 2.3.2 with the exception of 2 deviations from the BWROG Option III Topical Report.,
Justification for these deviations is provided separately (GEH document 0000-0107-7607-P-RO, September 2009).
The actual, current plant configuration and the proposed replacement PAM are included in the PRNM LTR as follows : (Applicable LTR sections are listed.)
Human Factors Engineering review will be performed as part of the normal design process.
The actual PRNMS System to be installed at GGNS contains 3 deviations from the system design as described in the LTR. Justification for these deviations is provided as Appendix A.
The current flow channel configuration consists of four flow channels, eight transmitters. Thus, the current configuration meets the requirements described in LTR Section 3.2.3.2.2, therefore no changes will be made.
I of 19 Current Proposed APRM 2.3.3.1.1.3 2.3.3.1.2.2 M
2.3.3.2.1.2 2.3.3.2.2.2 Flow Unit 2.3.3.3.1.3 2.3.3.3.2.2 Rod Control 2.3.3.4.1.3 2.3.3.4.2.3 ARTS 2.3.3.5.1.5 2.3.3.5.2.3 Panel Interface 2.3.3.6.1.2 2.3.3.6.2.1 0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report The section numbers and Utility Actions Required listed below are from the NUMAC PRNM Retrofit Plus Option III Stability Trip Function Topical Report NEDC-3241OP-A including Supplement 1.
Section No.
2.3.2 Utility Action Required Option III Stability Implementation Not a required specific LTR response Confirm that the actual plant Option III configuration is included in the variations covered in the Power Range Neutron Monitor (PRNM) Licensing Topical Report (LTR)
[NEDC-32410P-A, Volumes 1 & 2 and Supplement 1].
Response
The GGNS Option III implementation is in accordance with the LTR Requirements of section 2.3.2 with the exception of 2 deviations from the BWROG Option III Topical Report.
Justification for these deviations is provided separately (GEH document 0000-0107-7607-P-RO, September 2009).
Human Factors Engineering review will be performed as part of the normal design process.
The actual, current plant configuration and the proposed replacement PRNM are included in the PRNM LTR as follows: (Applicable LTR sections are listed.)
The actual PRNMS System to be installed at GGNS contains 3 deviations from the system design as described in the LTR. Justification for these deviations is provided as Appendix A.
2.3.4 3.4 Plant Unique or Plant-Specific Aspects Confirm that the actual plant configuration is included in the variations covered in the Power Range Neutron Monitor (PRNM) Licensing Topical Report (LTR) [NEDC-32410P-A, Volumes 1 & 2 and Supplement 1], and the configuration altemative(s) being applied for the replacement PRNM are covered by the PRNM LTR. Document in the plant-specific licensing submittal for the PRNM project the actual, current plant configuration of the replacement PRNM, and document confirmation that those are covered by the PRNM LTR. For any changes to the plant operator's panel, document in the submittal the human factors review actions that were taken to confirm compatibility with existing plant commitments and procedures.
System Functions As part ofthe plant-specific licensing submittal, the utility should document the following:
APRM RBM Flow Unit Rod Control ARTS Panel Interface Current 2.3.3.1.1.3 2.3.3.2.1.2 2.3.3.3.1.3 2.3.3.4.1.3 2.3.3.5.1.5 2.3.3.6.1.2 Proposed 2.3.3.1.2.2 2.3.3.2.2.2 2.3.3.3.2.2 2.3.3.4.2.3 2.3.3.5.2.3 2.3.3.6.2.1 1)
The pre-modification flow channel configuration, and any changes planned (normally changes will be either adding two channels to reach four or no change planned)
NOTE: If transmitters are added, the requirements on the added transmitters should be:
Non-safety related, but qualified 1 of 19 1)
The current flow channel configuration consists of four flow channels, eight transmitters. Thus, the current configuration meets the requirements described in LTR Section 3.2.3.2.2, therefore no changes will be made.
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PAM Retrofit Topical Report 2 of 19 Section No.
Action I Utility Required
Response
environmentally and seismically to operate in the application environment.
Mounted with structures equivalent or better than those for the currently installed channels.
Cabling routed to achieve separation to the extent feasible using existing cableways and routes.
- 2) Document the APB trips currently applied
- 2) The new and existing APRM trip functions at the plant. If different from those documented are listed below. The "post-modification" in the PRNM LTR, document plans to change to trips will be the same as those identified in those in the LTR.
the LTR.
The Neutron Flux - High, Setdown function {APB Function 2.a) has been retained as described in LTR paragraphs 3.2.4 and 8.3.1.4.
The Fixed Neutron Flux-High function
{APB Function 2.b) has been retained as described in LTR paragraph 3.2.5).
The Inop function (APB Function 2.c) has been retained as described in LTR paragraph 3.2.10.
The Flow Biased Simulated Thermal Power - High function (APB Function 2.d) has been retained as described in LTR paragraph 3.2.5.
The 2-Out-of-4 Voter function {APB Function 2.e) has been added as described in as described in LTR paragraphs 3.2.2 and 8.3.2.4.
The OPT Upscale function (APB Function 2J) has been added as described in LTR paragraph 8.4.1.2.
- 3)
Document the current status related to
- 3) ARTS is not applicable to GGNS because ARTS and the planned post modification status Grand Gulf is a BWR6.
as :
0 ARTS currently implemented, and retained in the PAM 0
ARTS will be implemented concurrently with the PRNM (reference ARTS submittal) 0 ARTS not implemented and will not be implemented with the PRNM 0
ARTS not applicable 4.4.1.11 Re gulatoly Requirements of the Replacement A review of the GGNS requirements confirms System - System D that the regulatory requirements addressed in the LTR encompass the related GGNS 0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
Utility Action Required
Response
environmentally and seismically to operate in the application environment.
Mounted with structures equivalent or better than those for the currently installed channels.
Cabling routed to achieve separation to the extent feasible using existing cableways and routes.
2)
Document the APRM trips currently applied 2)
The new and existing APRM trip functions at the plant. If different from those documented are listed below. The "post-modification" in the PRNM LTR, document plans to change to trips will be the same as those identified in those in the LTR.
the LTR.
The Neutron Flux - High, Setdown function (APRM Function 2.a) has been retained as described in LTR paragraphs 3.2.4 and 8.3.1.4.
The Fixed Neutron Flux-High function (APRM Function 2.b) has been retained as described in LTR paragraph 3.2.5).
The Inop function (APRM Function 2.c) has been retained as described in LTR paragraph 3.2.10.
The Flow Biased Simulated Thermal Power High function (APRM Function 2.d) has been retained as described in LTR paragraph 3.2.5.
The 2-0ut-of-4 Voter function (APRM Function 2.e) has been added as described in as described in LTR paragraphs 3.2.2 and 8.3.2.4.
The OPRM Upscale function (APRM Function 2.f) has been added as described in LTR paragraph 8.4.1.2.
3)
Document the current status related to 3)
ARTS is not applicable to GGNS because ARTS and the planned post modification status Grand Gulf is a BWR6.
as:
ARTS currently implemented, and retained in the PRNM ARTS will be implemented concurrently with the PRNM (reference ARTS submittal)
ARTS not implemented and will not be implemented with the PRNM ARTS not applicable 4.4.1.11 Regulatory Requirements ofthe Replacement A review of the GGNS requirements confirms System - System Design that the regulatory requirements addressed in the LTR encompass the related GGNS 2 of 19
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PAM Retrofit Topical Report 3 of 19 Section No.
Utility Action Required
Response
This section identifies requirements that are requirements. Part of the normal design process expected to encompass most specific plant confirms that the detailed PAM design meets commitments relative to the PRNM replacement the applicable detailed GGNS technical and project, but may not be complete and some may licensing requirements, not apply to all plants. Therefore, the utility must confirm that the requirements identified here address all of those identified in the plant commitments. The plant-specific licensing submittal should identify the specific requirements applicable for the plant, confirm that any clarifications included here apply to the plant, and document the specific requirements that the replacement PRNM is intended to meet for the plant.
4.4.2.2.1.4 Re gulatoly Requirements for the Replacement The PRNM control room electronics are System -Equipment i$,Iualification - Temperature qualified for continuous operation under the and Humidity following temperature conditions : 5 to 50 'C [41 to 122 'F].
The GGNS normal control room Plant-specific action will confirm that the temperature is : 72'F. The design process maximum control room temperatures plus includes actions to confirm that the PAM mounting panel temperature rise, allowing for equipment, as installed in the plant, is qualified heat load of the PRNM equipment, does not for the environmental limits, including exceed the temperatures presented in the PRNM temperature rise measurements.
LTR, and that control room humidity is maintained within the limits stated in the PRNM The PRNM control room electronics are LTR. This evaluation will normally be qualified for continuous operation under the accomplished by determining the operating following relative humidity conditions : 10 to temperature of the current equipment which will 90% (non-condensing). The GGNS relative be used as a bounding value because the heat humidity requirement for control room load of the replacement system is less than the equipment is 20-50%, which is within the range current system while the panel structure, and for which the PRNM equipment is qualified.
thus cooling, remains essentially the same.
The qualification results will be documented in Documentation of the above action, including a plant unique "Qualification Summary".
the specific method used for the required confirmation should be included in plant-specific licensing submittals.
4.4.2.2.2.4 Re aulatoly Requirements for the Replacement The PRNM control room electronics are Systern -Equipment Qualification - Pressure qualified for continuous operation under the Plant-specific action will confirm that the following pressure conditions : 13 -16 psia. The maximum control room pressure does not GGNS normal control room pressure is ambient exceed the limits presented in the PRNM LTR, atmospheric pressure +1/4 in. - 0 in w.g. This Any pressure differential from inside to outside range is within these limits. The qualification the mounting panel assumed to be negligible results will be documented in a plant unique since the panels are not sealed and there is no "Qualification Summary.
forced cooling or ventilation. Documentation of this action and the required confirmation should be included in plant-specific licensing submittals.
4.4.2.2.3.4 Regulatoly Requirements for the Replacement The PRNM control room electronics are System -Equipment Qualification -Radiation qualified for continuous operation under the 0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
Utility Action Required
Response
This section identifies requirements that are requirements. Part of the normal design process expected to encompass most specific plant confirms that the detailed PRNM design meets commitments relative to the PRNM replacement the applicable detailed GGNS technical and project, but may not be complete and some may licensing requirements.
not apply to all plants. Therefore, the utility must confirm that the requirements identified here address all of those identified in the plant commitments. The plant-specific licensing submittal should identify the specific requirements applicable for the plant, confirm that any clarifications included here apply to the plant, and document the specific requirements that the replacement PRNM is intended to meet for the plant.
4.4.2.2.1.4 Regulatory Requirements for the Replacement The PRNM control room electronics are System -Equipment Qualification - Temperature qualified for continuous operation under the and Humidity following temperature conditions: 5 to 50°C [41 to 122 OF].
The GGNS normal control room Plant-specific action will confirm that the temperature is: 72°F. The design process maximum control room temperatures plus includes actions to confirm that the PRNM mounting panel temperature rise, allowing for equipment, as installed in the plant, is qualified heat load of the PRNM equipment, does not for the environmental limits, including exceed the temperatures presented in the PRNM temperature rise measurements.
LTR, and that control room humidity is maintained within the limits stated in the PRNM The PRNM control room electronics are LTR. This evaluation will normally be qualified for continuous operation under the accomplished by determining the operating following relative humidity conditions: 10 to temperature of the current equipment which will 90% (non-condensing). The GGNS relative be used as a bounding value because the heat humidity requirement for control room load of the replacement system is less than the equipment is 20-50%, which is within the range current system while the panel structure, and for which the PRNM equipment is qualified.
thus cooling, remains essentially the same.
The qualification results will be documented in Documentation of the above action, including a plant unique "Qualification Summary".
the specific method used for the required confirmation should be included in plant-specific licensing submittals.
4.4.2.2.2.4 Regulatory Requirements for the Replacement The PRNM control room electronics are System -Equipment Qualification - Pressure qualified for continuous operation under the Plant-specific action will confirm that the following pressure conditions: 13 - 16 psia. The maximum control room pressure does not GGNS normal control room pressure is ambient exceed the limits presented in the PRNM LTR.
atmospheric pressure +1/4 in. - 0 in w.g. This Any pressure differential from inside to outside range is within these limits. The qualification the mounting panel assumed to be negligible results will be documented in a plant unique since the panels are not sealed and there is no "Qualification Summary.
forced cooling or ventilation. Documentation of this action and the required confirmation should be included in plant-specific licensing submittals.
4.4.2.2.3.4 Regulatory Requirements for the Replacement The PRNM control room electronics are System -Equipment Qualification -Radiation qualified for continuous operation under the 30f19
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PAM Retrofit Topical Report Section No.
I Utility Action Required Plant-specific action will confirm that the maximum control room radiation levels do not exceed the limits presented in the PRNM LTR.
Documentation of this action and the required confirmation should be included in plant-specific licensing submittals.
4.4.2.3.4 gulatoly Requirements for the Replacement System -Seismic Qualification Plant-specific action or analysis will confirm that the maximum seismic accelerations at the mounting locations of the equipment (control room floor acceleration plus panel amplification) for both OBE and SSE spectrums do not exceed the limits stated in the PRNM LTR. Documentation of this action and the required confirmation should be included in plant-specific licensing submittals.
4.4.2.4.4 Re gulatoly Requirements for the Replacement System -EMI Qualification The utility should establish or document practices to control emission sources, maintain good grounding practices and maintain equipment and cable separation.
Controlling Emissions a) Portable Transceivers (walkie-talkies) :
Establish practices to prevent operation of portable transceivers in close proximity of equipment sensitive to such emissions.
(NOTE : The qualification levels used for the NUMAC PRNM exceed those expected to result from portable transceivers, even if such transceivers are operated immediately adjacent to the NUMAC equipment.)
b) ARC Welding :
Establish practices to assure that ARC welding activities do not occur in the vicinity of equipment sensitive to such emissions, particularly during times when the potentially sensitive equipment is required to be operational for plant safety.
(NOTE : The qualification levels used for NUMAC PRNM minimize the likelihood of detrimental effects due to ARC welding as long as reasonable ARC welding control and shielding practices are used.)
Response
following conditions : Dose Rate < 0.001 Rads (carbon)/hr and Total Integrated Dose (TID) <
1000 Rads (carbon). The GGNS control room (Zone A) dose rates are 0.2 and 0.5 mrem/hr and TID are within the qualified limits. The qualification results will be documented in a plant unique "Qualification Summary.
Evaluations to confirm that the maximum seismic accelerations at the mounting locations of the equipment do not exceed qualification limits of the equipment is completed as part of the normal design change process. The seismic qualification results will be documented in "Qualification Summary".
- 1) Controlling Emissions a)
The qualification levels used for the NUMAC PRNM system exceed those expected to result from portable transceivers, even if such transceivers are operated immediately adjacent to NUMAC equipment. GGNS generally prohibits operation of portable transceivers near sensitive equipment, and if warranted, requires positioning of warning signs at critical locations throughout the plant.
Placement of warning signs is evaluated as part of the modification process.
b) The qualification levels used for the NUMAC PRNM system minimize the likelihood of detrimental effects due to ARC welding as long as reasonable ARC welding control and shielding practices are used.
ARC welding is only performed at GGNS with specific work orders and directions, and is known to have the potential to affect operation of I&C equipment at a number of locations in the plant. Therefore, ARC welding activity is only performed when any potential effect on I&C equipment is tolerable relative to plant operation.
4 of 19 0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
Utility Action Required
Response
Plant-specific action will confirm that the following conditions: Dose Rate.:s 0.001 Rads maximum control room radiation levels do not (carbon)/hr and Total Integrated Dose (TID).:s exceed the limits presented in the PRNM LTR.
1000 Rads (carbon). The GGNS control room Documentation of this action and the required (Zone A) dose rates are 0.2 and 0.5 mrem/hr and confirmation should be included in plant-TID are within the qualified limits. The specific licensing submittals.
qualification results will be documented in a plant unique "Qualification Summary~
4.4.2.3.4 Regulatory Requirements for the Replacement Evaluations to confirm that the maximum System -Seismic Qualification seismic accelerations at the mounting locations Plant-specific action or analysis will confirm of the equipment do not exceed qualification that the maximum seismic accelerations at the limits of the equipment is completed as part of mounting locations of the equipment (control the normal design change process. The seismic room floor acceleration plus panel qualification results will be documented in amplification) for both aBE and SSE spectrums "Qualification Summary".
do not exceed the limits stated in the PRNM LTR. Documentation ofthis action and the required confirmation should be included in plant-spec(fic licensing submittals.
4.4.2.4.4 Regulatory Requirements for the Replacement System -EMI Qualification The utility should establish or document practices to control emission sources, maintain good grounding practices and maintain equipment and cable separation.
1)
Controlling Emissions
- 1) Controlling Emissions a) Portable Transceivers (walkie-talkies):
a)
The qualification levels used for the Establish practices to prevent operation of NUMAC PRNM system exceed those portable transceivers in close proximity of expected to result from portable equipment sensitive to such emissions.
transceivers, even if such transceivers are (NOTE: The qualification levels used for operated immediately adjacent to NUMAC the NUMAC PRNM exceed those equipment. GGNS generally prohibits expected to result from portable operation of portable transceivers near transceivers, even ifsuch transceivers are sensitive equipment, and if warranted, operated immediately adjacent to the requires positioning of warning signs at NUMAC equipment.)
critical locations throughout the plant.
Placement ofwarning signs is evaluated as part of the modification process.
b) ARC Welding:
b)
The qualification levels used for the Establish practices to assure that ARC NUMAC PRNM system minimize the welding activities do not occur in the likelihood ofdetrimental effects due to ARC vicinity of equipment sensitive to such welding as long as reasonable ARC welding emissions, particularly during times when control and shielding practices are used.
the potentially sensitive equipment is ARC welding is only performed at GGNS required to be operational for plant safety.
with specific work orders and directions, (NOTE: The qualification levels used for and is known to have the potential to affect NUMAC PRNM minimize the likelihood operation ofI&C equipment at a number of of detrimental effects due to ARC welding locations in the plant. Therefore, ARC as long as reasonable ARC welding control welding activity is only performed when any and shielding practices are used.)
potential effect on I&C equipment is tolerable relative to plant operation.
40f19
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PAM Retrofit Topical Report Section No. -J Utility Action Required c) Limit Emissions from New Equipment :
Establish practices for new equipment and plant modifications to assure that they either do not produce unacceptable levels of emissions, or installation shielding, filters, grounding or other methods prevent such emissions from reaching other potentially sensitive equipment. These practices should address both radiated emissions and conducted emissions, particularly conducted emissions on power lines and power distribution systems.
Related to power distribution, both the effects of new equipment injecting noise on the power system and the power system conducting noise to the connected equipment should be addressed. (NOTE :
For the qualification of the PRNM equipment includes emissions testing.)
- 2) Grounding Practices Existing Grounding System: The specific details and effectiveness of the original grounding system in BWRs varied significantly.
As part of the modification process, identify any known or likely problem areas based on previous experience and include in the modification program either an evaluation step to determine if problems actually exist, or include corrective action as part of the modification. (NOTE : The PRNM equipment is being installed in place of existing PRM electronics which is generally more sensitive to EMI than the NUMAC equipment. As long as the plant has experienced no significant problems with the PRM, no problems are anticipated with the PRNM provided grounding is done in a comparable manner.)
Grounding Practices for New Modifications :
New plant modifications process should include a specific evaluation of grounding methods to be used to assure both that the new equipment is installed in a way equivalent to the conditions used in the qualification. (NOTE : NUMAC RNM equipment qualification is performed in a panel assembly comparable to that used in the plant.)
Response
c) EMI emissions from new equipment installed at GGNS are evaluated as part of the normal design modification process described in GGNS procedures.
- 2)
Grounding Practices The PRNM system equipment is being installed in place of existing Power Range Monitor (PRM) system electronics.
, The replacement system interfaces with the same cables and wiring at the panel interfaces as the current system, including ground bus connections. No problems have been identified with the current PRM system related to grounding or grounding practices. The original installation included specific grounding practices designed to minimize performance problems. The replacement PRNM system is less sensitive to grounding issues than is the current system and includes specific actions in the wiring inside the panel to maximize shielding and grounding effectiveness.
5 of 19 0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
Utility Action Required c) Limit Emissions from New Equipment:
Establish practices for new equipment and plant modifications to assure that they either do not produce unacceptablelevels of emissions, or installation shielding, filters, grounding or other methods prevent such emissions from reaching other potentially sensitive equipment. These practices should address both radiated emissions and conducted emissions, particularly conducted emissions on power lines and power distribution systems.
Related to power distribution, both the effects of new equipment injecting noise on the power system and the power system conducting noise to the connected equipment should be addressed. (NOTE:
For the qualification of the PRNM equipment includes emissions testing.)
- 2) Grounding Practices Existing Grounding System: The specific details and effectiveness of the original grounding system in BWRs varied significantly.
As part of the modification process, identify any known or likely problem areas based on previous experience and include in the modification program either an evaluation step to determine ifproblems actually exist, or include corrective action as part ofthe modification. (NOTE: The PRNM equipment is being installed in place of existing PRM electronics which is generally more sensitive to EMI than the NUMAC equipment. As long as the plant has experienced no significant problems with the PRM, no problems are anticipated with the PRNM provided grounding is done in a comparable manner.)
Grounding Practices for New Modifications:
New plant modifications process should include a specific evaluation of grounding methods to be used to assure both that the new equipment is installed in a way equivalent to the conditions used in the qualification. (NOTE: NUMAC PRNM equipment qualification is performed in a panel assembly comparable to that used in the plant.)
5 of 19
Response
c)
EMI emissions from new equipment installed at GGNS are evaluated as part of the normal design modification process described in GGNS procedures.
2)
Grounding Practices The PRNM system equipment is being installed in place of existing Power Range Monitor (PRM) system electronics. The replacement system interfaces with the same cables and wiring at the panel interfaces as the current system, including ground bus connections. No problems have been identified with the current PRM system related to grounding or grounding practices. The original installation included specific grounding practices designed to minimize performance problems. The replacement PRNM system is less sensitive to grounding issues than is the current system and includes specific actions in the wiring inside the panel to maximize shielding and grounding effectiveness.
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
6.6 Utility Action Required espouse
- 3) Equipment and Cable Separation Cabling : Establish cabling practices to assure that signal cables with the potential to be "receivers" are kept separate from cables that are sources of noise. (NOTE : The original PRM cable installation requirements met this objective. The replacement PRNM es the same cable routes and pa unless some specific problem has been identified in the current system, no special action should be necessary for the PAM modification.)
quipment : Establish equipment separation and shielding practices for the installation of new equipment to simulate that equipment's qualification condition, both relative to susceptibility and emissions. (NOTE : The original PRM cabinet design met this objective.
The replacement PAM uses the same mounting cabinet, and used an equivalent mounting assembly for qualification. No special action should be necessary for the PRNM modification.)
The plant-specific licensing submittals should identify the practices that are in place or will be applied for the PRNM modification to address each of the above items.
System Failure Analysis The utility must confirm applicability of the failure analysis conclusions contained in the PRNM LTR by the following actions :
1.
Confirm that the events defined in EPRI Report No. NP-2230 or in Appendices F and G of Reference I I of the PRNM LTR, encompass the events that are analyzed for the plant ;
- 3)
Equipment and Cable Separation The original PRM system cable installation requirements met this objective. The replacement PRNM system uses the same cable routes and paths at comparable energy levels where feasible. Because no specific problem has been identified in the current system, no special action is necessary for the PRNM modification The existing system cabling complies with applicable GGNS cable routing and separation requirements.
Additionally, the modification process is performed in accordance with the existing separation criteria.
1.
The GGNS Technical Specification Surveillance Requirements for the Reactor Protection System (RPS) are based on Reference I I of the PAM LTR as discussed in the GGNS Technical Specification Bases (Section 3.3.1.1, Reactor Protection System Instrumentation, Reference 9 in GGNS TS Bases). Therefore, the Reference I I failure analysis is applicable to GGNS. The overall redundancy and diversity of sensors available to provide trip signals in the RPS meets NRC-approved licensing basis requirements.
6 of 19 0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
Utility Action Required
Response
3)
Equipment and Cable Separation 3)
Equipment and Cable Separation Cabling: Establish cabling practices to The original PRM system cable installation assure that signal cables with the requirements met this objective. The potential to be "receivers" are kept replacement PRNM system uses the same separate from cables that are sources of cable routes and paths at comparable energy noise. (NOTE: The original PRM cable levels where feasible. Because no specific installation requirements met this problem has been identified in the current objective. The replacement PRNM system, no special action is necessary for the uses the same cable routes and paths, so PRNM modification. The existing system unless some specific problem has been cabling complies with applicable GGNS identified in the current system, no cable routing and separation requirements.
special action should be necessary for Additionally, the modification process is the PRNM modification.)
performed in accordance with the existing Equipment: Establish equipment separation criteria.
separation and shielding practices for the installation of new equipment to simulate that equipment's qualification condition, both relative to susceptibility and emissions. (NOTE: The original PRM cabinet design met this objective.
The replacement PRNM uses the same mounting cabinet, and used an equivalent mounting assembly for qualification. No special action should be necessary for the PRNM modification.)
The plant-specific licensing submittals should identify the practices that are in place or will be applied for the PRNM modification to address each ofthe above items.
6.6 System Failure Analysis The utility must confirm applicability of the failure analysis conclusions contained in the PRNM LTR by the following actions:
1.
Confirm that the events defined in EPRI 1.
The GGNS Technical Specification Report No. NP-2230 or in Appendices F and G Surveillance Requirements for the Reactor ofReference 11 of the PRNM LTR, encompass Protection System (RPS) are based on Reference the events that are analyzed for the plant; 11 of the PRNM LTR as discussed in the GGNS Technical Specification Bases (Section 3.3.1.1, Reactor Protection System Instrumentation, Reference 9 in GGNS TS Bases). Therefore, the Reference 11 failure analysis is applicable to GGNS. The overall redundancy and diversity of sensors available to provide trip signals in the RPS meets NRC-approved licensing basis requirements.
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0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report 7 of 19 Section No.
Action Utility Required
Response
2.
Confirm that the configuration implemented 2.
The proposed PRNM configuration is by the plant is within the limits described in the included among the configurations described in LTR; and the PRNM LTR, as itemized under Section 2.3.4 above. The proposed configuration is being designed by GEH and is within the limits described in the LTR.
3.
Prepare a plant-specific IOCFR50.59 3.
The requirements of IOCFR50.59 applies to evaluation of the modification per the applicable the PRNMS modification in accordance with plant procedures.
applicable plant procedures.
These confirmations and conclusions should be documented in the plant-specific licensing submittals for the PRNM modification.
[Reference I I of the LTR is NEDC-3085 IP-A, "Technical Specification Improvement Analysis for BWR Reactor Protection System", Licensing Topical Report, GE Nuclear Energy, Class III (proprietary), dated March 1988.
7.6 Impact on UFSAR Applicable sections of the FSAR are reviewed The plant-specific action required for FSAR and appropriate revisions of those sections are updates will vary between plants. In all cases, prepared and approved as part of the normal however, existing FSAR documents should be design process. Following implementation of reviewed to identify areas that have descriptions the design modification, and closure of the specific to the current PAM using the general design package, the FSAR revisions are guidance of Sections 7.2 through 7.5 of the i ncluded in the updated FSAR as part of the PRNM LTR to identify potential areas impacted.
periodic 10 CFR 50.71(e} FSAR update The utility should include in the plant-specific submittal.
licensing submittal a statement of the plans for updating the plant FSAR for the PRNM project.
8.3.1.4 APB-Related RPS Trip Functions - Functions Covered by Tech Specs 1.
Delete the APB Downscale function, if I.
GGNS does not have an "APB currently used, from the RPS Instrumentation Downscale" RPS Trip Function Tech Spec.
"function" table, the related surveillance requirements, and, if applicable, the related setpoint, and related descriptions in the bases sections.
2.
Delete the APRM Flow-biased Neutron 2.
APB Flow Biased Simulated Thermal Flux Upscale function, if currently used, from Power - High and the APB Fixed Neutron the RPS Instrumentation "function" table, the Flux - High functions have been retained.
related surveillance requirements, and, if applicable, the related setpoint, and related descriptions in the bases sections. Replace these with the corresponding entries for the APB Simulated Thermal Power - High and the APB Neutron Flux - High functions. Perform analysis necessary to establish setpoints for 0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
7.6 8.3.1.4 Utility Action Required 2.
Confirm that the configuration implemented by the plant is within the limits described in the LTR; and 3.
Prepare a plant-specific 10CFR50.59 evaluation of the modification per the applicable plant procedures.
These confirmations and conclusions should be documented in the plant-specific licensing submittals for the PRNM modification.
[Reference 11 of the LTR is NEDC-30851P-A, "Technical Specification Improvement Analysis for BWR Reactor Protection System", Licensing Topical Report, GE Nuclear Energy, Class III (proprietary), dated March 1988.
Impact on UFSAR The plant-specific action required for FSAR updates will vary between plants. In all cases, however, existing FSAR documents should be reviewed to identify areas that have descriptions specific to the current PRNM using the general guidance of Sections 7.2 through 7.5 of the PRNM LTR to identify potential areas impacted.
The utility should include in the plant-specific licensing submittal a statement of the plans for updating the plant FSAR for the PRNM project.
APRM-Related RPS Trip Functions - Functions Covered by Tech Specs 1.
Delete the APRM Downscale function, if currently used, from the RPS Instrumentation "function" table, the related surveillance requirements, and, if applicable, the related setpoint, and related descriptions in the bases sections.
2.
Delete the APRM Flow-biased Neutron Flux Upscale function, if currently used, from the RPS Instrumentation "function" table, the related surveillance requirements, and, if applicable, the related setpoint, and related descriptions in the bases sections. Replace these with the corresponding entries for the APRM Simulated Thermal Power - High and the APRM Neutron Flux - High functions. Perform analysis necessary to establish setpoints for 7 of 19
Response
2.
The proposed PRNM configuration is included among the configurations described in the PRNM LTR, as itemized under Section 2.3.4 above. The proposed configuration is being designed by GEH and is within the limits described in the LTR.
3.
The requirements of 10CFR50.59 applies to the PRNMS modification in accordance with applicable plant procedures.
Applicable sections of the FSAR are reviewed and appropriate revisions of those sections are prepared and approved as part of the normal design process. Following implementation of the design modification, and closure of the design package, the FSAR revisions are included in the updated FSAR as part of the periodic 10 CFR 50.71(e) FSAR update submittal.
1.
GGNS does not have an "APRM Downscale" RPS Trip Function Tech Spec.
2.
APRM Flow Biased Simulated Thermal Power - High and the APRM Fixed Neutron Flux - High functions have been retained.
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. - 1 Utili Action Required added trips.
3.
Add the APB Neutron Flux - High (Setdown) function, if not currently used, to the RPS Instrumentation "function" table, add the related surveillance requirements, and, if applicable, the related setpoints, and related descriptions in the bases, sections.
Perform analysis necessary to establish setpoints for added trips.
8.3.2.4 APB-Related RPS Trip Functions - Minim Number of Operable APB Channels I.
For the 4-APRM channel replacement configuration, revise the RPS Instrumentation "function" table to show 3 APB channels, shared by both trip systems for each APRM function shown (after any additions or deletions per PRNM LTR Paragraph 8.3.1.4). Add a out-of-4 Voter" function with two channels under the "minimum operable channels". For plants with Tech Specs that include a footnote calling for removing shorting links, remove the references to the footnote related to APRM (retain references for SRM and Imo) and delete any references to APB channels in the footnote. For smaller core plants, delete the notes for and references to special conditions related to loss of all LPRMs from the "other" APRM.
2.
Review action statements to see if changes are required. If the improvements documented in Reference I I have not been implemented, then changes will likely be required to implement the 12-hour and 6-hour operation times discussed above for fewer than the minimum required channels. If Improved Tech Specs are applied to the plant, action statements remain unchanged.
3.
Revise the Bases section as needed to replace the descriptions of the current 6-or 8-PRM channel systems and bypass capability with a corresponding description of the 4-APRM system, 2-out-of-4 Voter channels (2 per RPS system), and allowed one APB bypass total.
Response
3.
The current APB Neutron Flux - High Setdown function has been retained.
I.
The PRNM modification and the proposed Tech Spec and Bases change implement the changes as described in the PAM LTR for a BWR6 plant. GGNS Tech Specs do not include notes related to APRMs that call for removal of shorting links or references to special conditions related to loss of all LPs from the "other" RM. Therefore, no related note changes are required.
A "2-out-of-4 Voter" function with two channels under the "minimum operable channels" have been added as Function 2.e.
2.
Action statement changes in the proposed Tech Spec change are consistent with the PRNM LTR described changes for plants with Improved Tech Specs. GGNS has previously switched to the ISTS format.
3.
The proposed Tech Spec Bases changes include revisions to the descriptions of the architecture, consistent with the PRNM LTR-8.3.3.4 APRM-Related RPS Trip Functions -
Applicable Modes of Operation 8 of 19 0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
Utility Action Required
Response
added trips.
3.
Add the APRM Neutron Flux - High 3.
The current APRM Neutron Flux - High, (Setdown) function, if not currently used, to Setdown function has been retained.
the RPS Instrumentation "function" table, add the related surveillance requirements, and, if applicable, the related setpoints, and related descriptions in the bases.sections.
Perform analysis necessary to establish setpoints for added trips.
8.3.2.4 APRM-Related RPS Trip Functions - Minimum Number of Operable APRM Channels 1.
For the 4-APRM channel replacement 1.
The PRNM modification and the proposed configuration, revise the RPS Instrumentation Tech Spec and Bases change implement the "function" table to show 3 APRM channels, changes as described in the PRNM LTR for a shared by both trip systems for each APRM BWR6 plant. GGNS Tech Specs do not include function shown (after any additions or deletions notes related to APRMs that call for removal of per PRNM LTR Paragraph 8.3.1.4). Add a "2-shorting links or references to special conditions out-of-4 Voter" function with two channels related to loss of all LPRMs from the "other" under the "minimum operable channels". For APRM. Therefore, no related note changes are plants with Tech Specs that include a footnote required.
calling for removing shorting links, remove the A "2-out-of-4 Voter" function with two channels references to the footnote related to APRM (retain references for SRM and IRM) and delete under the "minimum operable channels" have any references to APRM channels in the been added as Function 2.e.
footnote. For smaller core plants, delete the notes for and references to special conditions related to loss of all LPRMs from the "other" APRM.
2.
Review action statements to see if changes 2.
Action statement changes in the proposed are required. If the improvements documented Tech Spec change are consistent with the PRNM in Reference 11 have not been implemented, LTR described changes for plants with then changes will likely be required to Improved Tech Specs. GGNS has previously implement the 12-hour and 6-hour operation switched to the ISTS format.
times discussed above for fewer than the minimum required channels. If Improved Tech Specs are applied to the plant, action statements remain unchanged.
3.
Revise the Bases section as needed to 3.
The proposed Tech Spec Bases changes replace the descriptions of the current 6-or 8-include revisions to the descriptions of the APRM channel systems and bypass capability architecture, consistent with the PRNM LTR.
with a corresponding description ofthe 4-APRM system, 2-out-of-4 Voter channels (2 per RPS system), and allowed one APRM bypass total.
8.3.3.4 APRM-Related RPS Trip Functions-Applicable Modes of Operation 80f19
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PAM Retrofit Topical Report Section No.
Utility Action Required Respons
- 1) APB Neutron Flux - Hit h (Setdown)
- 1)
Tech Spec and Bases changes are Change Tech Spec "applicable modes" entry, if consistent with the PRNM LTR.
required, to be Mode 2 (startup). Delete references to actions and surveillance requirements associated with other modes.
Delete any references to notes associated with "non-coincidence" mode and correct notes as required. Revise Bases descriptions as required.
- 2) APRM Simulated Thermal Power - High
- 2)
The APRM Flow Biased Simulated Retain as is unless this function is being added Thermal Power - High function has been to replace the APRM Flow-biased Neutron Flux retained and is consistent with the PRNM LTR.
Trip. In that case, add requirement for operation in Mode 1 (RUN) and add or modify Bases descriptions as required.
- 3) APB Neutron Flux - High
- 3)
The APRM Fixed Neutron Flux - High Retain as is unless this function is being added function has been retained and is consistent with to replace the APB Flow-biased Neutron Flux the PRNM LTR.
Trip. In that case, add requirement for operation in Mode 1 (RUN) and add or modify Bases descriptions as required.
- 4) APB Inon Trip
- 4)
The current GGNS TS require this function Delete any requirements for operation in modes only in Modes I and 2.
other than Mode I and Mode 2 (RUN and STARTUP). Revise the Bases descriptions as needed.
8.3.4.1.4 APB-Related RPS Trip Functions - Channel Checks/ Instrument Checks a) For plants without Channel Check a)
The GGNS Technical 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 once per currently include a once-per-shift Channel day Channel Check or Instrument Check Check requirement for the APB Functions requirement for the three APRM flux based (except for Inop). The APRM Function Channel functions. No Channel Check requirements are Check requirement has been changed from once added for APB Inop function. Plants with per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to once per day (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />). The once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or once per shift requirements new Channel Check SR 3.3.1.1.19 with a may change them to once per day.
frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been added to TS 3.3.1.1 and applies to Functions 2.a, 2.b, 2.d, 2.e, and 2.f.
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
Utility Action Required
Response
1)
APRM Neutron Flux - High (Setdown) 1)
Tech Spec and Bases changes are Change Tech Spec "applicable modes" entry, if consistent with the PRNM LTR.
required, to be Mode 2 (startup). Delete references to actions and surveillance requirements associated with other modes.
Delete any references to notes associated with "non-coincidence" mode and correct notes as required. Revise Bases descriptions as required.
2)
APRM Simulated Thermal Power - High 2)
The APRM Flow Biased Simulated Retain as is unless this function is being added Thermal Power - High function has been to replace the APRM Flow-biased Neutron Flux retained and is consistent with the PRNM LTR.
Trip. In that case, add requirement for operation in Mode 1 (RUN) and add or modify Bases descriptions as required.
3)
APRM Neutron Flux - High 3)
The APRM Fixed Neutron Flux - High Retain as is unless this function is being added function has been retained and is consistent with to replace the APRM Flow-biased Neutron Flux the PRNM LTR.
Trip. In that case, add requirement for operation in Mode 1 (RUN) and add or modify Bases descriptions as required.
4)
APRM Inop Trip 4)
The current GGNS TS require this function Delete any requirements for operation in modes only in Modes 1 and 2.
other than Mode 1 and Mode 2 (RUN and STARTUP). Revise the Bases descriptions as needed.
8.3.4.1.4 APRM-Related RPS Trip Functions - Channel Checks/ Instrument Checks a)
For plants without Channel Check a)
The GGNS Technical 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 once per currently include a once-per-shift Channel day Channel Check or Instrument Check Check requirement for the APRM Functions requirement for the three APRM flux based (except for Inop). The APRM Function Channel functions. No Channel Check requirements are Check requirement has been changed from once added for APRM Inop function. Plants with per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to once per day (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />). The once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or once per shift requirements new Channel Check SR 3.3.1.1.19 with a may change them to once per day.
frequency of24 hours has been added to TS 3.3.1.1 and applies to Functions 2.a, 2.b, 2.d, 2.e, and 2.f.
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8.3.4.2.4 tility Action Required b) For plants with 4 full recirculation flow channels and with Tech Specs that call for daily or other channel check requirements for flow comparisons under APB Flow Biased Simulated Thermal Power Trip, delete those requirements. Move any note reference related to verification of flow signals to Channel Functional Test entry.
APRM-Related RPS Trip Functions - Channel Functional Tests a) Delete existing channel functional test requirements and replace with a requirement for a Channel Functional Test frequency of each 184 days (6 months) [delete any specific requirement related to startup or shutdown except for the APRM Neutron Flux - High (Setdown) function as noted in Paragraph 8.3.4.2.2(l) of the PAM LTR. Add a notation that both the APB channels and the 2-out-of-4 Voter channels are to be included in the Channel Functional Test.
b) Add a notation for the APRM Simulated Thermal Power - High function that the test shall include the recirculation flow input processing, excluding the flow transmitters.
CAUTION : Plants that have not implemented the APB surveillance improvements of eference I I of the PRNM LTR, or those that have continued to use a weekly surveillance of.
scram contactors, may need to implement or modify surveillance actions to continue to provide a once per week functional test of scram contactors. (Prior to changes defined in Reference 11, the weekly APRM functional test also provides a weekly test of all automatic scram contactors.)
Response
b)
GGNS currently uses 8 recirculation flow transmitters. Associated surveillances have been included in those for the APRM Flow Biased Simulated Thermal Power - High and the OPT Upscale functions (the latter because of the OPT trip enable function). The proposed Technical Specification and Bases changes for the recirculation flow related SRs are consistent with the PRNM LTR but with some expansion to clarify that the recirculation flow functions also support the OPT Upscale function trip enable.
a)
The proposed Technical Specification and Bases changes related to Channel Functional Tests are consistent with the PRNM LTR.
b)
The proposed Technical Specification and ases changes to Channel Functional Test for the APB functions include a notation, applicable to the Flow Biased Simulated Thermal Power - High (Function 2.d) and the OPRM Upscale (Function 2J), consistent with the PRNM LTR requirements, that the SR includes the recirculation flow input processing, excluding the flow transmitters. However, the PRNM LTR includes this notation only in the Bases. For the GGNS Technical Specification, the Channel Functional Test has been added as SR 3.3.1.1.20, and has been expanded to also apply to the OPT Upscale function (to cover OPT Upscale trip enable).
The functional test procedure will be established to test all of the hardware required to produce the trip functions, but not to directly re-test software-only (firmware-only} logic. The APRM automatic self-test function monitors the integrity of the EPROMs storing all of the firmware so that if a hardware fault results in a "change" to the firmware (software), that fault will be detected by the self test logic. The continued operation of the self-test procedures is 1 0 of 19 0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
8.3.4.2.4 Utility Action Required b)
For plants with 4 full recirculation flow channels and with Tech Specs that call for daily or other channel check requirements for flow comparisons under APRM Flow Biased Simulated Thermal Power Trip, delete those requirements. Move any note reference related to verification of flow signals to Channel Functional Test entry.
APRM-Related RPS Trip Functions - Channel Functional Tests a)
Delete existing channel functional test requirements and replace with a requirement for a Channel Functional Test frequency of each 184 days (6 months) [delete any specific requirement related to startup or shutdown except for the APRM Neutron Flux - High (Setdown) function as noted in Paragraph 8.3.4.2.2(1) ofthe PRNM LTR. Add a notation that both the APRM channels and the 2-out-of-4 Voter channels are to be included in the Channel Functional Test.
b)
Add a notation for the APRM Simulated Thermal Power - High function that the test shall include the recirculation flow input processing, excluding the flow transmitters.
CAUTION: Plants that have not implemented the APRM surveillance improvements of Reference 11 of the PRNM LTR, or those that have continued to use a weekly surveillance of scram contactors, may need to implement or modify surveillance actions to continue to provide a once per week functional test of scram contactors. (Prior to changes defined in Reference 11, the weekly APRM functional test also provides a weekly test of all automatic scram contactors.)
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Response
b)
GGNS currently uses 8 recirculation flow transmitters. Associated surveillances have been included in those for the APRM Flow Biased Simulated Thermal Power - High and the OPRM Upscale functions (the latter because ofthe OPRM trip enable function). The proposed Technical Specification and Bases changes for the recirculation flow related SRs are consistent with the PRNM LTR but with some expansion to clarify that the recirculation flow functions also support the OPRM Upscale function trip enable.
a)
The proposed Technical Specification and Bases changes related to Channel Functional Tests are consistent with the PRNM LTR.
b)
The proposed Technical Specification and Bases changes to Channel Functional Test for the APRM functions include a notation, applicable to the Flow Biased Simulated Thermal Power - High (Function 2.d) and the OPRM Upscale (Function 2.f), consistent with the PRNM LTR requirements, that the SR includes the recirculation flow input processing, excluding the flow transmitters. However, the PRNM LTR includes this notation only in the Bases. For the GGNS Technical Specification, the Channel Functional Test has been added as SR 3.3.1.1.20, and has been expanded to also apply to the OPRM Upscale function (to cover OPRM Upscale trip enable).
The functional test procedure will be established to test all of the hardware required to produce the trip functions, but not to directly re-test software-only (firmware-only) logic. The APRM automatic self-test function monitors the integrity of the EPROMs storing all of the firmware so that if a hardware fault results in a "change" to the firmware (software), that fault will be detected by the self-test logic. The continued operation ofthe self-test procedures is
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
I Utility Action Required
.3.4.3.4 8.3.4.4.4 APB-Related RPS Trip,, Functions - Channel Calibrations a) Replace current calibration interval with either 18 or 24 months except for APB Inop.
Retain Inop requirement as is (i.e., no requirement for calibration),
b) Delete any requirements for flow calibration and calibration of the 6 second time constant separate from overall calibration of the APB Simulated Thermal Power - High function.
c) Replace every 3 day frequency for calibration of APRM power against thermal power with a 7 day frequency if applicable.
d) Revise Bases text as required.
APB-Related RPS Trip Functions - Response Testing elete response time testing requirement from Tech Specs_ or plant procedures, -as applicable, espouse monitored by the built-in "watch-dog timer" function, so if for some unforeseen reason the self-test function (lowest priority in the instrument logic) stops running, that failure also will be detected automatically. To provide further assurance that the self test function continues to operate, a step will be included in the APRM Channel Check surveillance to confirm that self test is still running.
a) The proposed Technical Specification and ases changes related to Channel Calibration has been changed to 24-month interval, with no calibration required for the Inop Function, consistent with the PRNM LTR.
b) Consistent with the PAM LTR requirements, the proposed Technical Specification and Bases changes add a notation applicable to the Channel Calibration for the APB Flow Biased Simulated Thermal Power -
High function to exclude requirements to calibrate the recirculation flow transmitters.
However, the PRNM LTR includes this notation only in the Bases. For the GGNS Technical Specification, the notation has been included in Channel Calibration SR 3.3.1.1.10. In addition, current SRs 3.3.1.1.16, which verifies the simulated thermal power time constant, and 3.3.1.1.18, which adjusts the flow control reference card, have been deleted.
c)
The current GGNS Technical Specifications include a "weekly" frequency for the verification of APB power versus calculated plant thermal power so no change in that frequency is required to be consistent with the PRNM LTR.
d)
The proposed Technical Specification Bases changes related to Channel Calibrations are consistent with the PRNM LTR.
The proposed Technical Specification and Bases changes related to Response Time Testing (new SR 3.3.1.1.22 and Table 3.3.1.1-1) are consistent with the justification in the PRNM LTR Supplement 1. _
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8.3.4.3.4 8.3.4.4.4 Utility Action Required APRM-Related RPS Trip Functions - Channel Calibrations a)
Replace current calibration interval with either 18 or 24 months except for APRM Inop.
Retain Inop requirement as is (i.e., no requirement for calibration).
b)
Delete any requirements for flow calibration and calibration of the 6 second time constant separate from overall calibration of the APRM Simulated Thermal Power - High function.
c)
Replace every 3 day frequency for calibration ofAPRM power against thermal power with a 7 day frequency if applicable.
d)
Revise Bases text as required.
APRM-Related RPS Trip Functions - Response Time Testing Delete response time testing requirement from Tech Specs or plant procedures, as applicable, 11 of 19
Response
monitored by the built-in "watch-dog timer" function, so if for some unforeseen reason the self-test function (lowest priority in the instrument logic) stops running, that failure also will be detected automatically. To provide further assurance that the self-test function continues to operate, a step will be included in the APRM Channel Check surveillance to confirm that self-test is still running.
a)
The proposed Technical Specification and Bases changes related to Channel Calibration has been changed to 24-month interval, with no calibration required for the Inop Function, consistent with the PRNM LTR.
b)
Consistent with the PRNM LTR requirements, the proposed Technical Specification and Bases changes add a notation applicable to the Channel Calibration for the APRM Flow Biased Simulated Thermal Power -
High function to exclude requirements to calibrate the recirculation flow transmitters.
However, the PRNM LTR includes this notation only in the Bases. For the GGNS Technical Specification, the notation has been included in Channel Calibration SR 3.3.1.1.10. In addition, current SRs 3.3.1.1.16, which verifies the simulated thermal power time constant, and 3.3.1.1.18, which adjusts the flow control reference card, have been deleted.
c)
The current GGNS Technical Specifications include a "weekly" frequency for the verification ofAPRM power versus calculated plant thermal power so no change in that frequency is required to be consistent with the PRNM LTR.
d)
The proposed Technical Specification Bases changes related to Channel Calibrations are consistent with the PRNM LTR.
The proposed Technical Specification and Bases changes related to Response Time Testing (new SR 3.3.1.1.22 and Table 3.3.1.1-1) are consistent with the justification in the PRNM LTR Supplement 1.
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
8.3.5.4 8.3.6.1 Utility Action Required for the APRM functions. Replace it with a response time testing requirement for the 2-out-of-4 Voter "pseudo" function, to include the output solid-state relays of the voter channel through the final RPS trip channel contactors.
Frequency of response time testing shall be determined using four 2-out-of-4 Voter channels, but tests may alternate use of 2-out-of-4 Voter outputs provided each APRM/RPS interfacing relay is tested at least once per eight refueling cycles (based on a maximum 24 month cycle), and each RPS scram contactor is tested at least once per four refueling cycles. Each 2-out-of-4 Voter output shall be tested at no less than half the frequency of the tests of the APRM/RPS interface relays. Tests shall alternate such that one logic train for each RPS trip system is tested every two cycles.
APRM-Related RPS Trip Functions - Logic System Functional Testiniz (LSFT) vise Tech Specs to change the interval for LSFT from 18 months to 24 months unless the utility elects to retain the 18-month interval for plant scheduling purposes. Delete any LSFT requirements associated with the APRM channels and move it to the 2-out-of-4 Voter channel. Include testing of the 2-out-of-4 voting logic and any existing LSFTs covering RPS relays.
APRM-Related RPS Trip Functions - Setpoints Add to or delete from the appropriate document any changed RPS setpoint information. If ARTS is being implemented concurrently with the PRNM modification, either include the related Tech Spec submittal information with the PRNM information in the plant-specific submittal, or reference the ARTS submittal in the PRNM submittal. In the plant-specific licensing submittal, identify what changes, if
Response
Consistent with the PRNM LTRs, the only APRM Function to which the SR applies is Function 2.e (voter). However, while the PRNM LTRs justified reduced response time testing frequency for Function 2.e, no TS markups were included to implement an "n" greater than 4 (the total number of voter channels). Therefore, a note has been added to the GGNS SR Table 3.3.1.1-1 to define that "n=8" for Function 2.e.
The PRNM LTR Supplement 1 justified response time testing at a rate that tested one RPS Interface relay every plant operating cycle, with tests using the APRM output for one cycle and the OPRM output for the next cycle. This yields a testing rate once per 8 operating cycles for each RPS interface relay and once per eve 16 operating cycles for the APRM or OPRM output.
The APRM trip and redundant OPRM trip outputs from each 2-Out-Of-4 Voter channel. One of the OPRM outputs and one of the APRM outputs are connected in series to the coil of one RPS interface relay. The second OPRM output and the second APRM output from the 2-Out-Of-4 Voter channel are connected in series with the coil to a second RPS interface relay. There are 8 total RPS interface relays.
modification includes redundant The GGNS Technical Specifications have been changed to delete the LSFT requirement from the existing APRM Functions 2.a, 2.b, 2.c, and 2.d. New SR 3.3.1.1.21 with a 24-month interval, has been added to TS 3.3.1.1 and applied to the new 2-Out-of-4 Voter function, APRM Function 2.e.
ARTS is not applicable at GGNS. PRNM setpoints and Allowable Values are re-calculated or confirmed using approved setpoint methodology. The Allowable Values for the APRM RPS Functions are included in the Technical Specifications or the COLR, comparable to what is currently in the GGNS Technical Specifications and consistent with the M LTR.
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Vtility Action Required
Response
for the APRM functions. Replace it with a Consistent with the PRNM LTRs, the only response time testing requirement for the 2-out-APRM Function to which the SR applies is of-4 Voter "pseudo" function, to include the Function 2.e (voter). However, while the output solid-state relays of the voter channel PRNM LTRs justified reduced response time through the final RPS trip channel contactors.
testing frequency for Function 2.e, no TS markups were included to implement an "n" Frequency ofresponse time testing shall be greater than 4 (the total number of voter determined using four 2-out-of-4 Voter channels). Therefore, a note has been added to channels, but tests may alternate use of 2-out-of-the GGNS SR Table 3.3.1.1-1 to define that 4 Voter outputs provided each APRM/RPS "n=8" for Function 2.e.
interfacing relay is tested at least once per eight refueling cycles (based on a maximum 24 month The PRNM LTR Supplement 1justified cycle), and each RPS scram contactor is tested at response time testing at a rate that tested one least once per four refueling cycles. Each 2-out-RPS Interface relay every plant operating cycle, of-4 Voter output shall be tested at no less than with tests using the APRM output for one cycle half the frequency of the tests of the APRMlRPS and the OPRM output for the next cycle. This interface relays. Tests shall alternate such that yields a testing rate once per 8 operating cycles one logic train for each RPS trip system is tested for each RPS interface relay and once per every every two cycles.
16 operating cycles for the APRM or OPRM output.
The PRNM modification includes redundant APRM trip and redundant OPRM trip outputs from each 2-0ut-Of-4 Voter channel. One of the OPRM outputs and one of the APRM outputs are connected in series to the coil ofone RPS interface relay. The second OPRM output and the second APRM output from the 2-0ut-Of-4 Voter channel are connected in series with the coil to a second RPS interface relay. There are 8 total RPS interface relays.
8.3.5.4 APRM-Related RPS Trip Functions - Logic System Functional Testing (LSFT)
The GGNS Technical Specifications have been Revise Tech Specs to change the interval for changed to delete the LSFT requirement from LSFT from 18 months to 24 months unless the the existing APRM Functions 2.a, 2.b, 2.c, and utility elects to retain the 18-month interval for 2.d. New SR 3.3.1.1.21 with a 24-month plant scheduling purposes. Delete any LSFT interval, has been added to TS 3.3.1.1 and requirements associated with the APRM applied to the new 2-0ut-of-4 Voter function, channels and move it to the 2-out-of-4 Voter APRM Function 2.e..
channel. Include testing ofthe 2-out-of-4 voting logic and any existing LSFTs covering RPS relays.
8.3.6.1 APRM-Related RPS Trip Functions - Setpoints Add to or delete from the appropriate document ARTS is not applicable at GGNS. PRNM any changed RPS setpoint information. If setpoints and Allowable Values are re-calculated ARTS is being implemented concurrently with or confirmed using approved setpoint the PRNM modification, either include the methodology. The Allowable Values for the related Tech Spec submittal information with APRM RPS Functions are included in the the PRNM information in the plant-specific Technical Specifications or the COLR, submittal, or reference the ARTS submittal in comparable to what is currently in the GGNS the PRNM submittal. In the plant-specific Technical Specifications and consistent with the licensin~ submittal, identify what changes, if PRNMLTR.
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8.4.1.4 8.4.2.4 Utility Action Required any, are being implemented and identify the basis or method used for the calculation of setpoints and where the setpoint information or changes will be recorded.
OPT-Related RPS Trip Functions - Functions Covered by Tech Specs Add the OPRM Upscale function as an "APRM function" in the RPS Instrumentation "function" table. Also add the related surveillance requirements and, if applicable, the related setpoint, and the related descriptions in the bases sections. Perform analysis necessary to establish setpoints for the OPT Upscale trip.
Add discussions related to the OPT function in the Bases for the APB Inop and 2-out-of-4 Voter functions.
NOTE : The markups in Appendix H of Supplement I to the PRNM LTR show the OPT Upscale as an APB sub-function.
However, individual plants may determine that for their particular situation, addition of the OPRM to the RPS Instrumentation table separate from the APB, or as a separate Tech Spec, better meets their needs. In those cases, the basis elements of the Tech Spec as shown in this Supplement would remain, but the specific implementation would be different.
OPRM-Related RPS Trip Functions - Minimum Number of Operable OPT Channels For the OPT functions added (Section 8.4.1),
include in the OPT Tech Spec a "minimum operable channels" requirement for three OPT channels, shared by both trip system Add the same action statements as for th APB Neutron Flux - High function for OPT Upscale function. In addition, add a new action statement for OPT Upscale function unavailable per Paragraph 8.4.2.2 of the PRNM LTR.
Revise the Bases section as needed to add descriptions of the 4-OPT system with 2-out-of-4 output Voter channels (2 per RPS Trip System), and allowed one OPRM bypass total.
Response
An OPRM Upscale Function has been added to the GGNS Technical Specification as an "APB Function" (Function 2J) consistent with PRNM LTR Supplement 1, Appendix Additions to the Technical Specification for Function 2.f have also been incorporated consistent with the PAM LTR.
s The PRNM LTR Supplement I included some additional wording for Function 2.e (voter) to address independent voting of the OPT and APB signals.
A minimum operable channels requirement of three, shared by both trip systems has been included in the Technical Specification for the OPRM Upscale Function (Function 2J). This addition, as well as addition of Required Actio, statements and Bases descriptions, is consistent ith the PRNM LTR and LTR Supplement 1.
ever, to make the Required Action statements more consistent with the intent of the LTR, a note has been added to Required Action J.2 stating that LCO 3.0.4(c) is applicable. LCO 3.0.4 was revised in GGNS Technical Specifications Amendment 175 to reflect NRC-approved changes regarding Mode change limitations via BWROG TSTF-359, "Increased Flexibility in Mode Restraints."
Although applying LCO 3.0.4(c) is not included in the NUMAC PAM LTR Supplement 1, it is consistent with the intent of Required Action
.2. Inclusion of Action J.2 is intended to allow 13 of 19 0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
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Response
any, are being implemented and identify the basis or method used for the calculation of setpoints and where the setpoint information or changes will be recorded.
8.4.1.4 OPRM-Related RPS Trip Functions - Functions An OPRM Upscale Function has been added to Covered by Tech Specs the GGNS Technical Specification as an "APRM Function" (Function 2.f) consistent with Add the OPRM Upscale function as an "APRM PRNM LTR Supplement 1, Appendix H.
function" in the RPS Instrumentation "function" Additions to the Technical Specification Bases table. Also add the related surveillance for Function 2.fhave also been incorporated requirements and, if applicable, the related consistent with the PRNM LTR.
setpoint, and the related descriptions in the bases The PRNM LTR Supplement 1 included some sections. Perform analysis necessary to additional wording for Function 2.e (voter) to establish setpoints for the OPRM Upscale trip.
address independent voting of the OPRM and Add discussions related to the OPRM function in the Bases for the APRM Inop and 2-out-of-4 APRM signals.
Voter functions.
NOTE: The markups in Appendix H of Supplement 1 to the PRNM LTR show the OPRM Upscale as an APRM sub-function.
However, individual plants may determine that for their particular situation, addition of the OPRM to the RPS Instrumentation table separate from the APRM, or as a separate Tech Spec, better meets their needs. In those cases, the basis elements of the Tech Spec as shown in this Supplement would remain, but the specific implementation would be different.
8.4.2.4 OPRM-Related RPS Trip Functions - Minimum A minimum operable channels requirement of Number ofOperable OPRM Channels three, shared by both trip systems has been For the OPRM functions added (Section 8.4.1),
included in the Technical Specification for the include in the OPRM Tech Spec a "minimum OPRM Upscale Function (Function 2.f). This operable channels" requirement for three OPRM addition, as well as addition of Required Action statements and Bases descriptions, is consistent channels, shared by both trip systems.
with the PRNM LTR and LTR Supplement 1.
Add the same action statements as for the However, to make the Required Action APRM Neutron Flux - High function for OPRM statements more consistent with the intent of the Upscale function. In addition, add a new action LTR, a note has been added to Required Action statement for OPRM Upscale function J.2 stating that LCO 3.0.4(c) is applicable. LCO unavailable per Paragraph 8.4.2.2 ofthe PRNM 3.0.4 was revised in GGNS Technical LTR.
Specifications Amendment 175 to reflect NRC-approved changes regarding Mode change Revise the Bases section as needed to add limitations via BWROG TSTF-359, "Increased descriptions of the 4-0PRM system with 2-out-Flexibility in Mode Restraints."
of-4 output Voter channels (2 per RPS Trip System), and allowed one OPRM bypass total.
Although applying LCO 3.0.4(c) is not included in the NUMAC PRNM LTR Supplement 1, it is consistent with the intent ofRequired Action J.2. Inclusion ofAction J.2 is intended to allow 13 of 19
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Response
orderly identification and Implementation of a resolution plan for an unanticipated design problem with the OPT system without undue impact on normal plant operation. The LCO 3.0.4(c) application does not eliminate the requirement to restore the OPRM Upscale function to OPERABLE status within a 120-day period. Applying LCO 3.0.4(c) does, however, allow the plant to start up with the alternate detect and suppress provision of Action J.2 in effect during the 120-day period.
8.4.3.4 OPRM-Related RPS Trip Functions -
A GGNS-specific Modes of Operation Applicable Modes of Operation requirement of > 24% RTP, consistent with the PRNM LTR Supplement I has been included in Add the requirement for operation of the OPRM the Technical Specification along with Upscale function in Mode 1 (RUN) when associated Bases descriptions.
Thermal Power is > 25% RTP, and add Bases descriptions as required.
8.4.4.1.4 OPT-Related RPS Trip Functions - Channel Check A new Channel Check requirement of once per Add once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or once per day Channel day (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />), SR 3.3.1.1.19, has been added. It Check or Instrument Check requirements for the is applied to the OPT Upscale function, OPRM Upscale function.
consistent with the PRNM LTR.
8.4.4.2.4 OPT-Related RPS Trip Functions - Channel Functional Test Add Channel Functional Test requirements with a requirement for a test frequency of every 184 A new Channel Functional Test requirement days (6 months), including the 2-out-of-4 Voter w
with a test frequency of every 184 days (Table function..
3 has been added to TS 3.3. 1. 1 as SR 3.3.1.1.20 for the OPT Upscale and 2-Out-Of 4 Voter Functions consistent with the PAM LTR, Supplement 1. The third note to SR 3.3.1.1.20 (not included in the PRNM LTR) clarifies that the SR also applies to the flow input function, except the flow transmitters.
Add a "confirm auto-enable region" surveillance on a once per outage basis up to 24 month New "confirm auto-enable region" surveillance intervals.
requirement, SR 3.3.1.1.23, has been added to TS 3.3.1.1 to require confirmation that the OPRM Upscale trip output auto-enable (not bypassed) setpoints remain correct. The SR Bases wording is consistent with the LTR.
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
Vtility Action Required
Response
orderly identification and Implementation of a resolution plan for an unanticipated design problem with the OPRM system without undue impact on normal plant operation. The LCO 3.0.4(c) application does not eliminate the requirement to restore the OPRM Upscale function to OPERABLE status within a 120-day period. Applying LCO 3.0.4(c) does, however, allow the plant to start up with the alternate detect and suppress provision of Action J.2 in effect during the 120-day period.
8.4.3.4 OPRM-Related RPS Trip Functions -
A GGNS-specific Modes of Operation Applicable Modes of Operation requirement of~ 24% RTP, consistent with the PRNM LTR Supplement 1 has been included in Add the requirement for operation of the OPRM the Technical Specification along with Upscale function in Mode 1 (RUN) when associated Bases descriptions.
Thermal Power is ~ 25% RTP, and add Bases descriptions as required.
8.4.4.1.4 OPRM-Related RPS Trip Functions - Channel Check A new Channel Check requirement of once per Add once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or once per day Channel day (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />), SR 3.3.1.1.19, has been added. It Check or Instrument Check requirements for the is applied to the OPRM Upscale function, OPRM Upscale function.
consistent with the PRNM LTR.
8.4.4.2.4 OPRM-Related RPS Trip Functions - Channel Functional Test Add Channel Functional Test requirements with A new Channel Functional Test requirement a requirement for a test frequency of every 184 days (6 months), including the 2-out-of-4 Voter with a test frequency of every 184 days (Table function.
3.3.1.1-1) has been added to TS 3.3.1.1 as SR 3.3.1.1.20 for the OPRM Upscale and 2-0ut-Of 4 Voter Functions consistent with the PRNM LTR, Supplement 1. The third note to SR 3.3.1.1.20 (not included in the PRNM LTR) clarifies that the SR also applies to the flow input function, except the flow transmitters.
Add a "confirm auto-enable region" surveillance New "confirm auto-enable region" surveillance on a once per outage basis up to 24 month intervals.
requirement, SR 3.3.1.1.23, has been added to TS 3.3.1.1 to require confirmation that the OPRM Upscale trip output auto-enable (not bypassed) setpoints remain correct. The SR Bases wording is consistent with the LTR.
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Response
8.4.4.3.4 OPRM-Related RPS Trip Functions - Channel Calibration Add calibration interval requirement of every 24 Channel Calibration SR 3
.3
.1,1
.10 has been months for the OPT Upscale function.
applied to the OPRM Upscale function to be consistent with the PRNM LTR Supplement 1.
Revise Bases text as required.
The frequency of SR 3
.3,1
.1
.10 has been changed from 184 days to 24 months, consistent with the LTR.
8.4.4.4.4 OPT-Related RPS Trip Functions - Response Time Testing Modify as necessary the response time testing See response to 8.3.4.4.4. That response also procedure for the 2-out-of-4 Voter function to addresses OPT.
include the Voter OPT output solid-state relays as part of the response time tests, alternating testing of the Voter OPT output with the Voter APRM output.
8.4.5.4 OPT-Related RPS Trip Functions - Logic The LSFT surveillance (new SR 3.3.1.1.21} for System Functional Testin-eg (LSFTJ the OPT Upscale Function is a test of the 2-Out-Of-4 Voter only, consistent with the PRNM Add requirement for LSFT every refueling LTR. Consistent with the PRNM LTR cycle, 18 or 24 months at the utility's option Supplement 1, revision of the related plant based on which best fits plant scheduling.
procedures to include testing of the OPT Upscale trip outputs from the 2-Out-Of-4 Voter is required. The procedure changes are made as part of the normal modification process.
8.4.6.1 OPT-Related RPS Trip Functions - Setpoints There are four "sets" of OPT related setpoints and adjustable parameters : a) OPT trip auto-Add setpoint information to the appropriate enable (not bypassed) setpoints for STP and document and identify in the plant-specific drive flow ; b) period based detection algorithm submittal the basis or method used for the (PBDA) confirmation count and amplitude calculation and where the setpoint information setpoints ; c) PBDA tuning parameters ; and d) will be recorded.
growth rate algorithm (ORA) and amplitude based algorithm (ABA) setpoints.
The first set, the setpoints for the "auto-enable" region for OPRM, as discussed in the Bases for Function 21, will be treated as nominal setpoints with no additional margins added. The deadband for these setpoints is established so that it increases the enabled region once the enabled region is entered. The settings are defined plant procedures.
The second set, the PBDA trip setpoints, will be established in accordance with the BWROG LTR 32465-A methodology, previously reviewed and approved by the NRC, and will be documented in the COLR.
The third set, the PBDA "tuning" parameter 0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
Utility Action Required
Response
8.4.4.3.4 OPRM-Related RPS Trip Functions - Channel Calibration Add calibration interval requirement of every 24 Channel Calibration SR 3.3.1.1.10 has been months for the OPRM Upscale function.
applied to the OPRM Upscale function to be consistent with the PRNM LTR Supplement 1.
Revise Bases text as required.
The frequency ofSR 3.3.1.1.10 has been changed from 184 days to 24 months, consistent with the LTR.
8.4.4.4.4 OPRM-Related RPS Trip Functions - Response Time Testing Modify as necessary the response time testing See response to 8.3.4.4.4. That response also procedure for the 2-out-of-4 Voter function to addresses OPRM.
include the Voter OPRM output solid-state relays as part ofthe response time tests, alternating testing of the Voter OPRM output with the Voter APRM output.
8.4.5.4 OPRM-Related RPS Trip Functions - Logic The LSFT surveillance (new SR 3.3.1.1.21) for System Functional Testing (LSFT) the OPRM Upscale Function is a test ofthe 2-Out-Of-4 Voter only, consistent with the PRNM Add requirement for LSFT every refueling LTR. Consistent with the PRNM LTR cycle, 18 or 24 months at the utility's option Supplement 1, revision of the related plant based on which best fits plant scheduling.
procedures to include testing of the OPRM Upscale trip outputs from the 2-0ut-Of-4 Voter is required. The procedure changes are made as part of the normal modification process.
8.4.6.1 OPRM-Related RPS Trip Functions - Setpoints There are four "sets" of OPRM related setpoints and adjustable parameters: a) OPRM trip auto-Add setpoint information to the appropriate enable (not bypassed) setpoints for STP and document and identify in the plant-specific drive flow; b) period based detection algorithm submittal the basis or method used for the (PBDA) confirmation count and amplitude calculation and where the setpoint information setpoints; c) PBDA tuning parameters; and d) will be recorded.
growth rate algorithm (GRA) and amplitude based algorithm (ABA) setpoints.
The first set, the setpoints for the "auto-enable" region for OPRM, as discussed in the Bases for Function 2.f, will be treated as nominal setpoints with no additional margins added. The deadband for these setpoints is established so that it increases the enabled region once the enabled region is entered. The settings are defined plant procedures.
The second set, the PBDA trip setpoints, will be established in accordance with the BWROG LTR 32465-A methodology, previously reviewed and approved by the NRC, and will be documented in the COLR.
The third set, the PBDA "tuning" parameter 15 of 19
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report 16 of 19 Section No.
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values, will be established in accordance with and controlled by GGNS procedures, within the limits established in the BWROG LTRs, or as documented in this submittal, and documented in the GGNS Core Operating Limits Report.
The fourth set, the GRA and ABA setpoints, consistent with the BWROG submittals, will be established as nominal values only, and controlled by GGNS procedures.
8.5.1.4 APRM-Related Control Rod Block Functions -
ARTS is not applicable at GGNS.
Functions Covered by Tech Specs If ARTS will be implemented concurrently with GGNS Technical Specifications currently do not the PRNM modification, include or reference contain any APB rod block functions.
those changes in the plant-specific PRNM submittal. Implement the applicable portion of the above described changes via modifications to the Tech Specs and related procedures and documents. In the plant-specific submittal, identify functions currently in the plant Tech Specs and which, if any, changes are being implemented. For any functions deleted from Tech Specs, identify where setpoint and surveillance requirements will be documented.
NOTE : A utility may choose not to delete some or all of the items identified in the PRNM LTR from the plant Tech Specs.
8.5.2.4 APRM-Related Control Rod Block Functions -
See 8.5.1.4 above. No additional confirmation Minimum Number of Operable Control Rod of action required relative to minimum operable Block Channels channels as shown in the Technical Change the minimum number of APRM Specifications beyond that required by 8.5.1.4 channels to three, if APRM functions are above.
retained in Tech Specs. No additional action is required relative to minimum operable channels beyond that required by Paragraph 8.5.1.4 of the PRNM LTR.
8.5.3.4 APRM-Related Control Rod Block Functions -
See 8.5.1.4 above. No additional confirmation Ax*licable Modes of Operation of action required relative to applicable modes No action required relative to modes during of operation as shown in the Technical which the function must be available beyond Specifications beyond that required by 8.5.1.4 that required by Paragraph 8.5.1.4 of the PRNM above.
LTR unless APRM functions are retained in Tech Specs and include operability requirements for Mode 5. In that case, delete such requirements.
8.5.4.1.4 APB-Related Control Rod Block Functions -
GGNS Technical Specifications currently do not Required Surveillances and Calibration contain any APB rod block functions, or any Channel Check Channel Check requirements for the RBM rod 0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
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values, will be established in accordance with and controlled by GGNS procedures, within the limits established in the BWROG LTRs, or as documented in this submittal, and documented in the GGNS Core Operating Limits Report.
The fourth set, the GRA and ABA setpoints, consistent with the BWROG submittals, will be established as nominal values only, and controlled by GGNS procedures.
8.5.1.4 APRM-Related Control Rod Block Functions-ARTS is not applicable at GGNS.
Functions Covered by Tech Specs If ARTS will be implemented concurrently with GGNS Technical Specifications currently do not the PRNM modification, include or reference contain any APRM rod block functions.
those changes in the plant-specific PRNM submittal. Implement the applicable portion of the above described changes via modifications to the Tech Specs and related procedures and documents. In the plant-specific submittal, identify functions currently in the plant Tech Specs and which, if any, changes are being implemented. For any functions deleted from Tech Specs, identify where setpoint and surveillance requirements will be documented.
NOTE: A utility may choose not to delete some or all of the items identified in the PRNM LTR from the plant Tech Specs.
8.5.2.4 APRM-Related Control Rod Block Functions -
See 8.5.1.4 above. No additional confirmation Minimum Number of Operable Control Rod of action required relative to minimum operable Block Channels channels as shown in the Technical Change the minimum number ofAPRM Specifications beyond that required by 8.5.1.4 channels to three, ifAPRM functions are above.
retained in Tech Specs. No additional action is required relative to minimum operable channels beyond that required by Paragraph 8.5.1.4 of the PRNMLTR.
8.5.3.4 APRM-Related Control Rod Block Functions -
See 8.5.1.4 above. No additional confirmation Applicable Modes of Operation of action required relative to applicable modes No action required relative to modes during of operation as shown in the Technical which the function must be available beyond Specifications beyond that required by 8.5.1.4 that required by Paragraph 8.5.1.4 of the PRNM above.
LTR unless APRM functions are retained in Tech Specs and include operability requirements for Mode 5. In that case, delete such requirements.
8.5.4.1.4 APRM-Related Control Rod Block Functions -
GGNS Technical Specifications currently do not Required Surveillances and Calibration -
contain any APRM rod block functions, or any Channel Check Channel Check requirements for the RBM rod 16 of 19
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUNUC PAM Retrofit Topical Report 1 7 of 19 Section No.
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Delete any requirements for instrument or block functions. Therefore, no change to GGNS channel checks related to PBM and, where Technical Specifications is required to applicable, recirculation flow rod block implement the PRNM LTR requirements. The functions (non-ARTS plants), and APRM RBM is not applicable to GGNS.
functions. Identify in the plant-specific PRNM submittals if any checks are currently included in Tech Specs, and confirm that they are being deleted.
8.5.4.2.4 APB-Related Control Rod Block Functions -
GGNS Technical Specifications currently do not Required Surveillances and Calibration -
contain any APB rod block functions.
Channel Functional Test Change Channel Functional Test requirements to identify a frequency of every 184-days (6 months).
In the plant-specific licensing submittal, identify current Tech Spec test frequencies that will be changed to 184 days (6 months).
8.5.4.3.4 APB-Related Control Rod Block Functions -
GGNS Technical Specifications currently do not Required Surveillances and Calibration -
contain any APRM rod block functions Channel Calibrations Change channel calibration requirements to identify a frequency of every 24 months. In the plant-specific licensing submittal, identify current Tech Spec test frequencies that will be changed to 24 months.
8.5.4.4.4 APRM-Related Control Rod Block Functions -
GGNS Technical Specifications currently do not Required Surveillances and Calibration -
contain any APB rod block functions.
Response Time Testing None.
8.5.5.4 APRM-Related Control Rod Block Functions -
GGNS Technical Specifications currently do not Required Surveillances and Calibration -
contain any APB rod block functions.
System Functional Testing (LSFTj None.
8.5.6.1 APB-Related Control Rod Block Functions -
ARTS is not applicable to GGNS.
Required Surveillances and Calibration -
Set-points Add to or delete from the appropriate document any changed control rod block setpoint information. If ARTS is being implemented concurrently with the PRNM modification, either include the related Tech Spec submittal information with the PAM information in the plant-specific submittal, or reference the ARTS submittal in the PAM submittal. In the plant-specific submittal, identify what changes, if any, are being implemented and identi the basis or 0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
Utility Action Required
Response
Delete any requirements for instrument or block functions. Therefore, no change to GGNS channel checks related to RBM and, where Technical Specifications is required to applicable, recirculation flow rod block implement the PRNM LTR requirements. The functions (non-ARTS plants), and APRM RBM is not applicable to GGNS.
functions. Identify in the plant-specific PRNM submittals if any checks are currently included in Tech Specs, and confirm that they are being deleted.
8.5.4.2.4 APRM-Related Control Rod Block Functions -
GGNS Technical Specifications currently do not Required Surveillances and Calibration -
contain any APRM rod block functions.
Channel Functional Test Change Channel Functional Test requirements to identify a frequency of every 184-days (6 months).
In the plant-specific licensing submittal, identify current Tech Spec test frequencies that will be changed to 184 days (6 months).
8.5.4.3.4 APRM-Related Control Rod Block Functions-GGNS Technical Specifications currently do not Required Surveillances and Calibration -
contain any APRM rod block functions Channel Calibrations Change channel calibration requirements to identify a frequency of every 24 months. In the plant-specific licensing submittal, identify current Tech Spec test frequencies that will be changed to 24 months.
8.5.4.4.4 APRM-Related Control Rod Block Functions -
GGNS Technical Specifications currently do not Required Surveillances and Calibration -
contain any APRM rod block functions.
Response Time Testing None.
8.5.5.4 APRM-Related Control Rod Block Functions -
GGNS Technical Specifications currently do not Required Surveillances and Calibration - Logic contain any APRM rod block functions.
System Functional Testing (LSFT)
None.
8.5.6.1 APRM-Related Control Rod Block Functions-ARTS is not applicable to GGNS.
Required Surveillances and Calibration -
Setpoints Add to or delete from the appropriate document any changed control rod block setpoint information. If ARTS is being implemented concurrently with the PRNM modification, either include the related Tech Spec submittal information with the PRNM information in the plant-specific submittal, or reference the ARTS submittal in the PRNM submittal. In the plant-specific submittal, identify what changes, ifany, are being implemented and identify the basis or 17 of 19
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PAM Retrofit Topical Report 1 8 of 19 Section No.
Utility Action Required Respons method used for calculation of setpoints and where the setpoint information or changes will be recorded.
8.6.2 Shutdown Margin Testing - Refaelinj!4 Technical Specification and Technical As applicable, revise the Shutdown Margin Specification Bases changes to Specification Testing - Refueling (or equivalent Tech Spec) 3.10.8, Shutdown Margin (SDM) Test -
LCO(s), action statements, surveillance Refueling have been made by adding APRM requirements and Bases as required to be Function 2.e to LCO 3.10.8 and SR 3.10.8.1..
consistent with the APRM Tech Spec changes implemented for PRNM.
None' Slir-04ftwil nm Changes are included in the proposed Tech Spec O
-Perating Bases for LCO 3.4.1. Deleted statements related No action identified in the PRNM LTR.
to Fraction of Core Boiling Boundary and PBDS and Reference 4 (NEDO 32339-A).
These changes, although not directly addressed in the PRNM LTR, are consistent with the remainder of the PRNM modification and implementation of the option III Stability Solution.
None Core Operating Limits Report Specification 5.6.5 has been modified to require the setpoints for APB Function 2.f (OPRM Reporting requirements Section 5.6.5 does not Upscale) to be included in the COLR.
currently address the OPT.
9.1.3 Utility Quality Assurance Program Quality assurance requirements for work performed at GGNS are defined and described As part of the plant-specific licensing submittal, in GGNS Quality Assurance Program Manual.
the utility should document the established program that is applicable to the project For the PRNM modification, GGNS has modification. The submittal should also contracted with GEH to include the following document for the project what scope is being PRNM scope: 1) design, 2) hardware/ software, performed by the utility and what scope is being
- 3) licensing support, 4) training, 5) O&M supplied by others. For scope supplied by manuals and design documentation, 6) EMIR FI others, document the utility actions taken or qualification of equipment, and 7) PRNMS planned to define or establish requirements for setpoint calculations.
the project, to assure those requirements are compatible with the plant-specific configuration.
On-site engineering work to incorporate the Actions taken or planned by the utility to assure GEH provided design information into an compatibility of the GEH quality program with Engineering Change (EC) or to provide any the utility program should also be documented.
supporting, interface design changes will be performed per requirements of applicable GGNS Utility planned level of participation in the procedures. Modification work to implement overall V&V process for the project should be the design change will be performed per GGNS documented, along with utility plans for procedures or GGNS-approved contractor software configuration management and procedures. GGNS participates in appropriate provision to support any required changes after reviews of GEH's design and V&V program for delivery should be documented.
the PRNM modification.
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
Utility Action Required
Response
method used for calculation of setpoints and where the setpoint information or changes will be recorded.
8.6.2 Shutdown Margin Testing - Refueling Technical Specification and Technical As applicable, revise the Shutdown Margin Specification Bases changes to Specification Testing - Refueling (or equivalent Tech Spec) 3.10.8, Shutdown Margin (SDM) Test-LCO(s), action statements, surveillance Refueling have been made by adding APRM requirements and Bases as required to be Function 2.e to LCO 3.10.8 and SR 3.10.8.1..
consistent with the APRM Tech Spec changes implemented for PRNM.
None Specification 3.4.1, Recirculation Loops Changes are included in the proposed Tech Spec Operating Bases for LCO 3.4.1. Deleted statements related No action identified in the PRNM LTR.
to Fraction of Core Boiling Boundary and PBDS and Reference 4 (NEDO 32339-A).
These changes, although not directly addressed in the PRNM LTR, are consistent with the remainder of the PRNM modification and implementation of the Option III Stability Solution.
None Core Operating Limits Report Specification 5.6.5 has been modified to require the setpoints for APRM Function 2.f(OPRM Reporting requirements Section 5.6.5 does not Upscale) to be included in the COLR.
currently address the OPRM.
9.1.3 Utility Quality Assurance Program Quality assurance requirements for work performed at GGNS are defined and described As part of the plant-specific licensing submittal, in GGNS Quality Assurance Program Manual.
the utility should document the established program that is applicable to the project For the PRNM modification, GGNS has modification. The submittal should also contracted with GEH to include the following document for the project what scope is being PRNM scope: 1) design, 2) hardware/ software, performed by the utility and what scope is being
- 3) licensing support, 4) training, 5) O&M supplied by others. For scope supplied by manuals and design documentation, 6) EMI/RFI others, document the utility actions taken or qualification of equipment, and 7) PRNMS planned to define or establish requirements for setpoint calculations.
the project, to assure those requirements are compatible with the plant-specific configuration.
On-site engineering work to incorporate the Actions taken or planned by the utility to assure GEH provided design information into an compatibility of the GEH quality program with Engineering Change (EC) or to provide any the utility program should also be documented.
supporting, interface design changes will be performed per requirements of applicable GGNS Utility planned level ofparticipation in the procedures. Modification work to implement overall V&V process for the project should be the design change will be performed per GGNS documented, along with utility plans for procedures or GGNS-approved contractor software configuration management and procedures. GGNS participates in appropriate provision to support any required changes after reviews of GEH's design and V&V program for delivery should be documented.
the PRNM modification.
18 of 19
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
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For software delivered in the form of hardware (EPROMs), GGNS intends to have GEH maintain post delivery configuration control of the actual source code and handle any changes.
GGNS handles any changes in the EPROMs as hardware changes under its applicable hardware modification procedures.
0000-0102-0888-RO Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No.
Utility Action Required
Response
For software delivered in the form ofhardware (EPROMs), GGNS intends to have GEH maintain post delivery configuration control of the actual source code and handle any changes.
GGNS handles any changes in the EPROMs as hardware changes under its applicable hardware modification procedures.
19 of 19
Appendix A Grand Gulf Nuclear Station Nuclear NUMAC PRNM LTR Deviations GE Hitachi Nuclear Energy I
0000-0103-7166-RO
Title:
Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator : F.G. Novak Verified T-QEH External Date : 9/4/09 I Sheet I of 7 GE Hitachi Nuclear Energy I 0OOO-0103-7166-RO
Title:
Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator: F.G. Novak Verified I
I GEH External Date: 9/4/09 ISheet 1 of7 Appendix A Grand Gulf Nuclear Station NUMAC' PRNM LTR Deviations A-I
Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Grand Gulf Nuclear Station (GGNS) will be submitting a license application for the implementation of Power Range Neutron Monitor (PRNM). The bases for the license application are the referenced documents in the relevant licensing topical reports (Reference 1-3).
The PRNM developed for GGNS has three deviations from the referenced documents. These are summarized in Table I and discussed in detail below. The licensing topical reports explicitly allow for plant-to-plant variation of some features. These are not addressed herein.
Table 1. GGNS NUMAC PRN M LTR Deviations a.
- b.
C.
PRM Upscale OPT Upscale /
Inop Function Logic OPT Pre-Trip Alarm Recirculation Flow Processing OPT Upscale function voted separately from the Inop function OPT Upscale function voted with the APB Inop function Improved operating flexibility Alarm if any instability algorithm exceeds defined alarm setpoints.
The PCI uses 2 Total Flow signals for the Flow Comparison.
Alarm if the period based algorithm exceeds defined alarm setpoints.
The PCI uses 4 Total Flow signals for the Flow Comparison.
Delete function that does not afford timely operator action.
Safety functions are not affected ; design was reviewed and approved for all plants in original report.
0000-0103-7166-RO Title :
Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator : F.G. Novak Verified I
I GEH External Date : 9/4/09 Sheet 2 of 7 GE Hitachi Nuclear EnerfVJ I 0OOO-0103-7166-RO
Title:
Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator: F.G. Novak Verified I
I GEH External Date: 9/4/09 ISheet 2 of7 Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Grand GulfNuclear Station (GGNS) will be submitting a license application for the implementation of Power Range Neutron Monitor (PRNM). The bases for the license application are the referenced documents in the relevant licensing topical reports (Reference 1-3).
The PRNM developed for GGNS has three deviations from the referenced documents. These are summarized in Table 1 and discussed in detail below. The licensing topical reports explicitly allow for plant-to-plant variation of some features. These are not addressed herein.
Table 1. GGNS NUMAC PRNM LTR Deviations a.
APRM Upscale /
OPRM Upscale function OPRM Upscale Improved operating OPRMUpscale /
voted separately from the function voted with flexibility APRM Inop Function APRM Inop function the APRM Inop Lo ic function b.
OPRM Pre-Trip Alarm if any instability Alarm if the period Delete function that Alarm algorithm exceeds defined based algorithm does not afford timely alarm setpoints.
exceeds defined operator action.
alarm set oints.
c.
Recirculation Flow The PCI uses 2 Total The PCI uses 4 Total Safety functions are not Processing Flow signals for the Flow Flow signals for the affected; design was Comparison.
Flow Comparison.
reviewed and approved for all plants in original re ort.
A-2
Technical Justifications
- a. APRM Upscale / OPRM Upscale / APRM Inop Function Logic Licensing Topical Report NEDC-324 I OP-A Supplement 1 (Reference 3) Section 8.4.1.3 describes the logic wherein the OPT Upscale function is voted separately from the APB Inop function. That is, an APB Inop in one APB channel and an OPT Upscale in another will result in two half trips in each of the 2-out-of-4 voter channels, but no RPS trips.
Designed this way, when an APB chassis keylock switch is placed in the "INOP" position, the APB upscale trip signal sent to the 2-out-of-4 voter channels is set to trip. However, the OPT trip output from that chassis continues to be processed normally. Typically this logic is of no consequence because if an APB chassis (affecting both the APB and OPT channels) is declared inoperable, the APB bypass can be used to bypass both the APB and OPT trips from that channel, which in turn modifies the logic in the 2-out-of-4 voter to be a 2-out-of-3 vote of both the APB and OPT trips from the remaining 3 channels. However, if the need to declare a second APB/OPT channel inoperable arises when another APRM/OPRM channel is already bypassed (and cannot be returned to service within the allowed out of service time), it is necessary to place the APB and OPT outputs from the second channel in the tripped condition to satisfy Technical Specification requirements. If the APB channel is still sufficiently functional to process trip outputs, placing the keylock switch in the INOP position will force a trip for the APB channel, but not for the OPT channel. Other action, such as disconnecting a fiber-optic cable to the 2-out-of-4 voters or removing power from the APB chassis, is necessary to satisfy the requirement to place the OPT channel in the tripped condition.
The automatic APB Inop trip is intended to provide a trip when the APB channel is known to be incapable of providing a trip based on normal functions. This trip occurs immediately even though the Technical Specification requirements allow a period of time for action. The automatic trip is provided to assure that conditions that may disable the APB trip function do not go undetected. Since the OPT trip function is implemented in the same equipment as the APB trip function, conditions that could disable the APB trip function would likely disable the OPT trip function as well.
For the Grand Gulf PRNM, the OPT Upscale function is combined with the APB Inop function as the OPT channel input to be voted. That is, an APB Inop in one APB channel and an OPT Upscale in another will result in RPS trip outputs from all four 2-out-of-4 voter channels. Again this logic is typically of no consequence because if an APB chassis (affecting both the APB and OPT channels) is declared inoperable, the APB bypass can be used to bypass both the APB and OPT trips from that channel, which in turn modifies the logic in the 2-out-of-4 voter to be a 2-out-of-3 vote of both the APB and OPT trips from the GE Hitachi Nuclear Energy I
0000-0103-7166-RO Title :
Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator : F.G. Novak Verified
,"- GEH External Date : 9/4/09 1 Sheet 3 of 7 GE Hitachi Nuclear Energy I 0OOO-0103-7166-RO
Title:
Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator: F.G. Novak Verified I
1 GEH External Date: 9/4/09 ISheet 3 of7 Technical Justifications
- a. APRM Upscale / OPRM Upscale / APRM Inop Function Logic Licensing Topical Report NEDC-32410P-A Supplement 1 (Reference 3) Section 8.4.1.3 describes the logic wherein the OPRM Upscale function is voted separately from the APRM lnop function. That is, an APRM lnop in one APRM channel and an OPRM Upscale in another will result in two half-trips in each ofthe 2-out-of-4 voter channels, but no RPS trips.
Designed this way, when an APRM chassis keylock switch is placed in the "lNOP" position, the APRM upscale trip signal sent to the 2-out-of-4 voter channels is set to trip. However, the OPRM trip output from that chassis continues to be processed normally. Typically this logic is of no consequence because if an APRM chassis (affecting both the APRM and OPRM channels) is declared inoperable, the APRM bypass can be used to bypass both the APRM and OPRM trips from that channel, which in tum modifies the logic in the 2-out-of-4 voter to be a 2-out-of-3 vote ofboth the APRM and OPRM trips from the remaining 3 channels. However, if the need to declare a second APRM/OPRM channel inoperable arises when another APRM/OPRM channel is already bypassed (and cannot be returned to service within the allowed out of service time), it is necessary to place the APRM and OPRM outputs from the second channel in the tripped condition to satisfy Technical Specification requirements. Ifthe APRM channel is still sufficiently functional to process trip outputs, placing the keylock switch in the INOP position will force a trip for the APRM channel, but not for the OPRM channel. Other action, such as disconnecting a fiber-optic cable to the 2-out-of-4 voters or removing power from the APRM chassis, is necessary to satisfy the requirement to place the OPRM channel in the tripped condition.
The automatic APRM lnop trip is intended to provide a trip when the APRM channel is known to be incapable ofproviding a trip based on normal functions. This trip occurs immediately even though the Technical Specification requirements allow a period of time for action. The automatic trip is provided to assure that conditions that may disable the APRM trip function do not go undetected. Since the OPRM trip function is implemented in the same equipment as the APRM trip function, conditions that could disable the APRM trip function would likely disable the OPRM trip function as well.
For the Grand GulfPRNM, the OPRM Upscale function is combined with the APRM lnop function as the OPRM channel input to be voted. That is, an APRM lnop in one APRM channel and an OPRM Upscale in another will result in RPS trip outputs from all four 2-out-of-4 voter channels. Again this logic is typically ofno consequence because if an APRM chassis (affecting both the APRM and OPRM channels) is declared inoperable, the APRM bypass can be used to bypass both the APRM and OPRM trips from that channel, which in tum modifies the logic in the 2-out-of-4 voter to be a 2-out-of-3 vote ofboth the APRM and OPRM trips from the A-3
remaining 3 channels. This design allows using the APRM chassis keylock switch to place APRM and OPRM outputs from a second channel in the tripped condition when another APRM/OPRM channel is already bypassed (and cannot be returned to service within the allowed out of service time) without having to resort to other actions such as disconnecting a fiber-optic cable to the 2-out-of-4 voters or removing power from the APRM chassis.
For the GGNS PRNM, the Supplement 1 (Reference 3) Bases are changed as follows.
1. Page H-12 : change the second paragraph as shown below The APRM System is divided into four APRM channels and four 2-out-of-4 voter channels.
Each APRM channel provides inputs to each of the four voter channels.
The four voter channels are divided into two groups of two each, with each group of two providing inputs to one RPS trip system.
The system is designed to allow one APRM channel, but no voter channels, to be bypassed.
A trip from any one unbypassed APRM will result in a "half-trip" in all four of the voter channels, but no trip inputs to either RPS trip system.
A
^ '
r n Ineb_4 ~0
~ 7^l 1 Y'1 I~.+4 N ~ A ~ '~ ~
Ih I1 ~ ~
T /'\\ ~
~+a M W ~
r1 M M I\\ ~ M
. T.41 1 H ~ 7 Three of the f our APRM channels and all four of the voter channels are required to be OPERABLE to ensure that no single failure will preclude a scram on a valid signal.
In addition, to provide adequate coverage of the entire core, consistent with the design bases for the APRM Functions 2.a, 2.b, and 2.d, at least [20] LPRM nputs, with at least [three] LPRM inputs from each of the four axial levels at which the LPRMs are located, must be operable for each APRM channel.
For the OPRM Upscale, Function 2.f, LPRMs are assigned to "cells" of [4] detectors.
A minimum of
[later] cells, each with a minimum of [2] LPRMs, must be OPERABLE for the OPRM Upscale Function 2.f to be OPERABLE.
Replaced deleted text with the following:
Since APRM trip Functions 2.a, 2.b, 2.d and 2.f are implemented in the same hardware, these trip Functions are combined with APRM Inop trip Function 2.c.
Any Function 2.a, 2.b, 2.c or 2.d trip from any two unbypassed APRM channels will result in a full trip in each of the four voter channels, which in turn results in two trip inputs into each RPS trip system logic channel (Al, A2, B1, and B2)
Similarly, any Function 2.c or 2.f trip from any two unbypassed APRM channels will result in a full trip from each of the four voter channels GE Hitachi Nuclear Energy 0000-0103-7166-RO Title :
Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator : F.G
. Novak Verified GEH External Date: 9/4/09 Sheet 4 of 7 GE Hitachi Nuclear Energy I 0OOO-0103-7166-RO
Title:
Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator: F.G. Novak Verified I
1 GEH External Date: 9/4/09 lSheet 4 of7 remaining 3 channels. This design allows using the APRM chassis keylock switch to place APRM and OPRM outputs from a second channel in the tripped condition when another APRM/OPRM channel is already bypassed (and cannot be returned to service within the allowed out of service time) without having to resort to other actions such as disconnecting a fiber-optic cable to the 2-out-of-4 voters or removing power from the APRM chassis.
For the GGNS PRNM, the Supplement 1 (Reference 3) Bases are changed as follows.
1.
Page H-12: change the second paragraph as shown below.
The APRM System is divided into four APRM channels and four 2-out-of-4 voter channels.
Each APRM channel provides inputs to each of the four voter channels.
The four voter channels are divided into two groups of two each, with each group of two providing inputs to one RPS trip system.
The system is designed to allow one APRM channel, but no voter channels, to be bypassed.
A trip from anyone unbypassed APRM will result in a "half-trip" in all four of the voter channels, but no trip inputs to either RPS trip system.
APRP1 t::ri~
Fl:lRCt::ioRS 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
- El:lIl t::ri~ iR eacH O:E 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 of the four APRM channels and all four of the voter channels are required to be OPERABLE to ensure that no single failure will preclude a scram on a valid signal.
In addition, to provide adequate coverage of the entire core, consistent with the design bases for the APRM Functions 2.a, 2.b, and 2.d, at least
[20]
LPRM inputs, with at least
[three]
LPRM inputs from each of the four axial levels at which the LPRMs are located, must be operable for each APRM channel.
For the OPRM Upscale, Function 2.f, LPRMs are assigned to "cells" of
[4]
detectors.
A minimum of
[later] cells, each with a minimum of
[2]
Replaced deleted text with the following:
Since APRM trip Functions 2.a, 2.b, 2.d and 2.f are implemented in the same hardware, these trip Functions are combined with APRM Inop trip Function 2.c.
Any Function 2.a, 2.b, 2.c or 2.d trip from any two unbypassed APRM channels will result in a full trip in each of the four voter channels, which in turn results in two trip inputs into each RPS trip system logic channel (Al, A2, Bl, and B2).
Similarly, any Function 2.c or 2.f trip from any two unbypassed APRM channels will result in a full trip from each of the four voter channels.
A-4
- 2. Page H-13 : For Function 2.e, change the I st sentence of the 3rd paragraph to the following. "The 2-Out-Of-4 Voter Function votes APB Functions 2.a, 2.b, and 2.d independently of Function If."
4,111 OPRM 11I Pre-Trip Alarms Licensing Topical Report NEDC-324 I OP-A (Reference 1) paragraph 3.3.3.1.2 states that the OPT provides an oscillation pre-trip alarm when one of the instability algorithms (period based, amplitude based, or growth based) for an operable OP setpoints. The GGNS PAM design will provide the OPT pre-trip alarm when the Period Based Algorithm for an operable OPRM cell has exceeded user defined setpoints.
cell has exceeded user defined The pre-trip Alarms are intended to alert the operator of a developing instability event so that manual actions to avoid a reactor scram can be attempted. The OPRM Licensing Topical Reports (References 4-6) do not require. pre-trip alarms.
For Option 111, the OPRM cell signals are analyzed by the Period Based Algorithm (PBA), the Amplitude Based Algorithm (ABA), and the Growth Rate Algorithm (GRA). Automatic protection is actuated if any one of the three algorithms meets its trip conditions. However, only the PBA is required to provide protection of the Safety Limit Minimum Critical Power Ratio (SLMCPR) for anticipated reactor instabilities. The other two algorithms (ABA and GRA) are included as defense-in-depth.
The PBA amplitude trip setpoint is the relative power level, or peak over average (PIA), at which the OPRM cell generates a trip signal, provided the required number of Successive Confirmation Counts (SCCs) has been reached. The following two conditions must both be met for at least one cell in an OPT channel to result in a PBA-based channel trip.
1. The Successive Confirmation Count (SCC) reaches or exceeds the SCC trip setpoint.
2. The cell relative power level, or peak over average (P/A), signal reaches or exceeds the amplitude trip setpoint.
The GRA and ABA are designed to detect large, fast growing oscillations. Unlike the PBA, the ABA and GRA trips do not require a minimum number of SCCs to generate a trip signal.
During fast growing oscillation events, the trips will occur very early in the event with little time for effective operator action. Consequently, GRA and ABA pre-trip alarms are not provided in the GGNS PAM design.
0000-0103-7166-RO Title :
Grand Gulf Nuclear Station NUMAC PAM LTR Deviations Originator : F.G. Novak Verified I
I GEH External '_ Date : 9/4/09 1 Sheet 5 of 7 GE Hitachi Nuclear EnerfDJ I 0OOO-0103-7166-RO
Title:
Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator: F.G. Novak Verified I
I GEH External Date: 9/4/09 ISheet 5 of7 2.
Page H-13: For Function 2.e, change the 1st sentence ofthe 3rd paragraph to the following. "The 2-0ut-Of-4 Voter Function votes APRM Functions 2.a, 2.b, and 2.d independently ofFunction 2.f."
- b. OPRM Pre-Trip Alarms Licensing Topical Report NEDC-32410P-A (Reference 1) paragraph 3.3.3.1.2 states that the OPRM provides an oscillation pre-trip alarm when one ofthe instability algorithms (period based, amplitude based, or growth based) for an operable OPRM cell has exceeded user defined setpoints. The GGNS PRNM design will provide the OPRM pre-trip alarm when the Period Based Algorithm for an operable OPRM cell has exceeded user defined setpoints.
The pre-trip Alarms are intended to alert the operator of a developing instability event so that manual actions to avoid a reactor scram can be attempted. The OPRM Licensing Topical Reports (References 4-6) do not require.pre-trip alarms.
For Option III, the OPRM cell signals are analyzed by the Period Based Algorithm (PBA), the Amplitude Based Algorithm (ABA), and the Growth Rate Algorithm (GRA). Automatic protection is actuated if anyone of the three algorithms meets its trip conditions. However, only the PBA is required to provide protection of the Safety Limit Minimum Critical Power Ratio (SLMCPR) for anticipated reactor instabilities. The other two algorithms (ABA and GRA) are included as defense-in-depth.
The PBA amplitude trip setpoint is the relative power level, or peak over average (PIA), at which the OPRM cell generates a trip signal, provided the required number of Successive Confirmation Counts (SCCs) has been reached. The following two conditions must both be met for at least one cell in an OPRM channel to result in a PBA-based channel trip.
1.
The Successive Confirmation Count (SCC) reaches or exceeds the SCC trip setpoint.
2.
The cell relative power level, or peak over average (PIA), signal reaches or exceeds the amplitude trip setpoint.
The GRA and ABA are designed to detect large, fast growing oscillations. Unlike the PBA, the ABA and GRA trips do not require a minimum number of SCCs to generate a trip signal.
During fast growing oscillation events, the trips will occur very early in the event with little time for effective operator action. Consequently, GRA and ABA pre-trip alarms are not provided in the GGNS PRNM design.
A-5
- c. Recirculation Flow Process Licensing Topical Report NEDC-32410P-A Volume I (Reference 1) and Supplement I (Reference 3) Section 3.2.3.2.2 provide a Description of (flow processing) Logic in the PRNM System for plants with 4 Flow Channels and 8 Transmitters. Statement (c) explains that each APRM sends its total flow signal to two PRNM Communication Interface (PCI) chassis for the BWR6. Statement (d) explains that the PCI chassis compares two total flows, one from each of two APRMs, and that alarms are issued if the flow differs by more than a user-entered value.
In the replacement system at GGNS, each PCI will compare all four total flows. One total flow signal is from the APB chassis in the same channel and one is from the LPG in the other channel belonging to the same RPS trip system. The other two flow signals are provided by the other PCI chassis men the PCI determines that the flow differs by more than the user-entered value, it will transmit this status to its associated APB, which will issue the alarm as described In order to make all four total flow signals available at each PCI chassis, fiber optic communication between all four PCI chassis will be established. Licensing Topical Report NEDC-324 I OP-A Supplement 1 (Reference 3) Figure E.1.7 (BWR 6, Larger Core), which illustrates the APRM/PCI configuration block diagram, is amended to include a dotted line (fiber-optic) network between the PCI chassis. Additionally, Figure E.1.7 is also amended to show that each APB chassis communicates with the PCI in the same channel, and each LPG chassis communicates with the PCI belonging to the other channel in the same RPS trip system.
There is no. effect on any APB hardware.
By using all four total flow signals, the logic is the same as that described in Reference I for all plants with a similar configuration (4 Flow Channels and 8 Transmitters), and in Reference 3 for non-BWR6 plants with a similar configuration. The communication network between the PCI chassis agrees conceptually with Figure E.3.6 of Reference 3. Additionally, by providing all four flow signals for comparison, the logic satisfies what is discussed in Licensing Topical Report NEDC-32410P-A (Reference 1) Section 8.3.4.1.2, where it is explained that any requirement for a daily flow comparison check is deleted from surveillances and replaced by the automatic comparison of all four total recirculation flow values. It is noted that the justification (Section 8.3.4.1.3) explicitly calls out comparison logic that includes all four channels.
Incorporating this logic has no affect on any safety functions.
GE Hitachi Nuclear Energy F 0000-0103-7166-RO
Title:
Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations _Originator: F.G. Novak Verified w"~
7GEH External Date : 9/4/09 1 Sheet 6 of 7 GE Hitachi Nuclear Energy I 0OOO-0103-7166-RO
Title:
Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator: F.G. Novak Verified I
I GEH External Date: 9/4/09 ISheet 6 of7
- c. Recirculation Flow Processing Licensing Topical Report NEDC-3241OP-A Volume 1 (Reference 1) and Supplement 1 (Reference 3) Section 3.2.3.2.2 provide a Description of (flow processing) Logic in the PRNM System for plants with 4 Flow Channels and 8 Transmitters. Statement (c) explains that each APRM sends its total flow signal to two PRNM Communication Interface (PCI) chassis for the BWR6. Statement (d) explains that the PCI chassis compares two total flows, one from each of two APRMs, and that alarms are issued ifthe flow differs by more than a user-entered value.
In the replacement system at GGNS, each PCI will compare all four total flows. One total flow signal is from the APRM chassis in the same channel and one is from the LPRM in the other channel belonging to the same RPS trip system. The other two flow signals are provided by the other PCI chassis When the PCI determines that the flow differs by more than the user-entered value, it will transmit this status to its associated APRM, which will issue the alarm as described.
In order to make all four total flow signals available at each PCI chassis, fiber optic communication between all four PCI chassis will be established. Licensing Topical Report NEDC-32410P-A Supplement 1 (Reference 3) Figure E.1.7 (BWR 6, Larger Core), which illustrates the APRM/PCI configuration block diagram, is amended to include a dotted line (fiber-optic) network between the PCI chassis. Additionally, Figure E.1.7 is also amended to show that each APRM chassis communicates with the PCI in the same channel, and each LPRM chassis communicates with the PCI belonging to the other channel in the same RPS trip system.
There is no effect on any APRM hardware.
By using all four total flow signals, the logic is the same as that described in Reference 1 for all plants with a similar configuration (4 Flow Channels and 8 Transmitters), and in Reference 3 for non-BWR6 plants with a similar configuration. The communication network between the PCI chassis agrees conceptually with Figure E.3.6 of Reference 3. Additionally, by providing all four flow signals for comparison, the logic satisfies what is discussed in Licensing Topical Report NEDC-32410P-A (Reference 1) Section 8.3.4.1.2, where it is explained that any requirement for a daily flow comparison check is deleted from surveillances and replaced by the automatic comparison of all four total recirculation flow values. It is noted that the justification (Section 8.3.4.1.3) explicitly calls out comparison logic that includes all four channels.
Incorporating this logic has no affect on any safety functions.
A-6
References 1. NEDC-3241 OP-A Volume 1, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PAM) Retrofit Plus Option III Stability Trip Function,"
October, 1995.
2. NEDC-32410P-A Volume 2 --Appendices, "Nuclear Measurement Analysis and Control over Range Neutron Monitor (NUMAC PAM) Retrofit Plus Option III Stability Trip unction," October, 1995.
3. NEDC-32410P-A Supplement 1, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PAM) Retrofit Plus Option III Stability Trip Function,"
November, 1997.
GE Hitachi Nuclear Energy 0000-0103-7166-RO Title :
Grand Gulf Nuclear Station NUMAC PAM LTR Deviations riginator : F.G. Novak Verified I
I GEH External Date : 9/4/09 1 Sheet 7 of 7 GE Hitachi Nuclear Energy I 0OOO-0103-7166-RO
Title:
Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator: F.G. Novak Verified I
I GEH External Date: 9/4/09 ISheet 7 of7 References 1.
NEDC-32410P-A Volume 1, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMACPRNM) Retrofit Plus Option III Stability Trip Function,"
October, 1995.
2.
NEDC-32410P-A Volume 2 -- Appendices, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," October, 1995.
3.
NEDC-32410P-A Supplement 1, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function,"
November, 1997.
A-7
ATTACHMENT 3 GNRO-2009-00054 MARKED-UP OPERATING LICENSE A TECHNICAL SPECIFICATION PAGES D
ATTACHMENT 3 GNRO-2009-Q0054 MARKED-UP OPERATING LICENSE AND TECHNICAL SPECIFICATION PAGES
GGNS OPERATING LICENSE (b)
SERI is required to notify the NRC in writing prior to any change in (i) the terms or conditions of any new or existing sale or lease agreements executed as part of the above authorized GGNS Unit 1 operating agreement, (iii) the existing property insurance coverage for GGNS Unit 1 that would materially alter the representations and conditions set forth in the Staff's Safety Evaluation Report dated December 19, 1988 attached to Amendment No. 54.
In addition, SERI is required to notify the NRC of any action by a lessor or other successor in interest to SERI that may have an effect on the operation of the facility.
C.
The license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect ; and is subject to the additional conditions specified or incorporated below :
(1)
Maximum Power Level Entergy Operations, Inc. i s authorized to operate the facility at reactor core power levels not in excess of 3898 megawatts thermal (100 percent power) in accordance with the conditions specified herein.
S (2)
Technical _peCif 4-1-ca -'-- ions The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 182 are hereby incorporated into this license.
Entergy Operations, Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
a4;Ei !~steel belew, aie net j~e ut'ifed te
-- r-tf--forme e!ff Pffftendment No.
+/--6-9t SR 3.8.1.14 anei transactions.
j-1 1
).the (SR5~ ftf Bie5ei-to GNRO-2009-00054 Page 1 of 20 (b)
GGNS OPERATING LICENSE SERI is required to notify the NRC in writing prior to any change in (i) the terms or conditions of any new or existing sale or lease agreements exe~uted as part of the above authorizeC :.; uf..nl,-,.~o.=-
transact_Lons.~
\\iii* the GGNS Unit 1 operating agreement, (iii) the existing property insurance coverage for GGNS Unit 1 that would materially alter the representations and conditions set forth in the Staff's Safety Evaluation Report dated December 19, 1988 attached to Amendment No.
54.
In addition, SERI is required to notify the NRC of any action by a lessor or other successor in interest to SERI that may have an effect on the operation of the facility.
C.
The license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)
Maximum Power Level Entergy Operations, Inc. is authorized to operate the facility at reactor core power levels not in excess of 3898 megawatts thermal (100 percent power) in accordance with the conditions specified herein.
(2)
Technical Specifica~ions The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No.
182 are hereby incorporated into this license.
Entergy Operations, Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
The eurveillance Requireffients
(~ for Die:'5el Generator 12 contained in the Technic~l Specifications and listed belovJ, are not required to be perforItted iffiRlediately upon implcr-nentation of ArfteI1eb:rt~nt No.
169.
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&&
SR 3.9.1.14 4
Amendment No. ~ __
to GNRO-2009-00054 Page 2 of 20 During Cycle 19, GGNS may conduct monitoring of the Oscillation Power Range Monitor (OPRM). During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) may be disabled and operated in an "indicate only" mode at which time technical specification requirements would not apply. During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations. to GNRO-2009-00054 Page 2 of 20 INSERT A - Exception During Cycle 19, GGNS may conduct monitoring of the Oscillation Power Range Monitor (OPRM). During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) may be disabled and operated in an "indicate only" mode at which time technical specification requirements would not apply. During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations.
to Definitions GNRO-2009-00054 Page 3 of 20 1.1 Definitions DOSE EQUIVALENT 1-131 be those listed in Federal Guidance Report (FGR) 11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion," X989.
(continued EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE The ECCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.).
Times shall include diesel generator starting and sequence loading delays, where applicable.
The response time may be measured by means of any series of sequential,.
overlapping, or total steps so that the entire response time is measured.
END OF CYCLE The EOC-RPT SYSTEM RESPONSE TIME shall be that RECIRCULATION PUMP TRIP time interval from initial movement of the (EOC-RPT) SYSTEM RESPONSE associated turbine stop valve or the turbine TIME control valve to complete suppression of the electric arc between the fully open contacts of recirculation pump circuit breaker.
The response time may be measured by means of any serf es of sequenti al, overt appi hg, or total steps so that the entire response time is measured, except for the breaker arc suppression time, whi is not measured but is validated to conform to the manufacturer's design value.
a :~
of th P W F 9 e n e ra a t e
- 4.
- E actjv-e re
-j-re 4 to pro-due-,
A4 0 0 ~
t 1-1
\\.1 GRAND GULF 1.0-3
~SdLur-, CJLL'U UUf I I fly Ul fit! UUU I d IL, t~flutr - illy LIlt:-.
6ai34i9 g op W 15 IA. I 1A U I i.: I,Q.e be 45 ffl ef the aC-tiH,Ae ri-eaetep Geple ;
ISOLATION SYSTEM The ISOLATION SYSTEM RESPONSE TIME shall be that RESPONSE TIME time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions.
The response time Amendment No
. to GNRO-2009-00054 Page 3 of 20 1.1 Definitions DOSE EQUIVALENT 1-131 (continued)
EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME END OF CYCLE RECIRCULATION PUMP TRIP CEOC-RPT) SYSTEM RESPONSE TIME FRACTION OF CORE BOILIN6 BOUNDARY (FCBB)
ISOLATION SYSTEM RESPONSE TIME Definitions 1.1 be those listed in Federal Guidance Report (FGR) 11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion," 1989.
The EeCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values~ etc.).
Times shall include diesel generator starting and sequence loading delays, where applicable.
The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.
The EOC-RPT SYSTEM RESPONSE TIME shall be that time interval from initial movement of the associated turbine stop valve or the turbine control valve to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker.
The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured, except for the breaker arc suppression time, which is not measured but is validated to conform to the manufacturer's design value.
fA@; FC88 SMall be tAe rat; a of tAc pOlh'er generated in the lo'der 4 fQQt gf thQ active
\\ eacten eOt @ to tM@
~ow@r,@qu; \\ @d to
~rocluee bul k saturated boiling of tile cooldtiL ellter illy tilE Fuel ehaRRels.
T~e core
~oiliAg beuftclary is the axial e1 e'lati on of core average bul k saturati 019 above tAe bottoffi of t~e active reactor coro.
The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions.
The response time (continued)
GRAND GULF 1.0-3 Amendment No. +4+, 145 to G N RO-2009-00054 Page 4 of 20 3.2 POWER DISTRIBUTION LIMITS ACTIONS Appl Tf ARTI TTV 4 r raacng &
- he-than -an I'm Y Q C1r+ t n
]acs of :Eaddwatn r CONDITION t W" B-..
R.
wi -p ?.d--A~-til p
'F Gt1ra
- 43, i PlIg F{nilYtfl,V~t/
t I:C. C an n
ii i n # h e rQ1 0 D GULF 3. 2-4 Amendment No. to GNRO-2009-00054 Page 4 of 20 3.2 POWER DISTRIBUTION LIMITS 3.2.4 Fraction of Cors Boiling Boyndary (FC88j ThQ FCBB
~hall as
< 1.0.
APPLICABILITY*
i A t t1eRe 5t ric ted R~ 9i 0 I' a 5 Thermal POl,t/sr :
~igh, Allo\\lable
~~sGified in the COLR.
ACTIONS CQbfDITION REQUIRED ACTION COMPLeTION HM-E A...
FeBS ngt \\-lithin liFAit U
for rea~ons other than an unexpected lO~a of feedwater heating gr
~nexpected reductign in Gore
~
Restore FCBB to
'.Ji th i n 1i mi t.
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> B-gequired Action and
~
associitQd Completion Ti~e of Condition A not I+lQt.
Region.
lFAFAediately IFRFAediately foll oln'i ng ~
of Restricted Region Q-f-el~~~~~d
- ~
Value to
" ~~~Io-oH" 'v'al ue.
(continued)
GRAND GULF 3.2-4 Amendment No.
to GNRO-2009-00054 Page 5 of 20 r-a- d-w a-t -Q n i A- =e N
comp I1 l i r i
1 oo-f f.a.gr e a-t i n g Op-'~',T°~'~'
° v
r s
i v
a.-
d to GNRO-2009-00054 Page 5 of 20 ACTIONS CQblDITION 8-(cent i nlsted)
- - - - - - ---+'r~'+-HOTI-fll.E---
geq'lirQd Action B.l and geqlsti rQQ Act; on 8 2 shall bQ co~pleted if thi~
Condition i~ QntirQd due to an unQxpQctQd loss of feed\\elatQr heating er unQxpQctQd red'lction in cor~
llOJ.Ah FeES not within lil+lit d'lQ to an 'lnQxpQctQd loss of fQQdwatQr heating or unQxpQctQd reduction in cor~
llOJ.Ah REQUIRED ACTION COMPL£TION HM-f GRAND GlIlF to GNRO-2009-00054 Page 6 of 20 Ver4 ;Fy
Nuir ----------------
441:
F entp-in a th RestP4 4 4 0 P;~ p
~ A I ; :z : 1: H
.1 --
-11.1 Ile pe
~-ed t e a ig t" "9 P1 Yt
~-. 0.
I I",
FQF-Qllr-hlr-y
., "4,j '.,, to GNRO-2009-00054 Page 6 of 20 SURVEILLANCE REQUIREMENTS 5URVElL LA ~~CE FREQUE~~CY
~
3.2.4.1
.*.. ---------------NOTE--------------------
Net re~uirecl to be perforffied until 15 ffiiAutes after cAtry into the Restricted Regien if eAtry was the result of an u~expected traRsient.
24 ROUfS Orlee w'i tltii fl 15 ffliAutes followirlg uflexJ'eeted traflsieflt GRANO GULF to G N RO-2009-00054 Page 7 of 20 3.3 INSTRUMENTATION 3.3.1.1 Reactor Protection System (RPS) Instrumentation Separate Condition entry is allowed GRAND GULF
-N E-each channel.
RPS Instrumentation 3.3.1.1
- ----------------------------y-------- - ----------------------
3.3-1 (continued) ndment No.
CONDITION REQUIRED CTION COMPLETION TIME A.
One or more required A.1 Place ch nnel in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> channels inoperable.
trip.
OR A-2 Place associated trip 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> system in trip.
B.
One or more Functions B.1 Place channel i n one fi hours with one or more trip system in trip.
required channels inoperable in both OR trip systems.
B.2 P1 ace one trip system 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> in trip.
C.
One or more Functions C.1 Restore RPS trip 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> with RPS trip capability.
capability not maintained.
NCO 3.3.1.1 The RPS instrumentation for each shall be OPERABLE.
NOTE----- "-------------
Not applicable for Functions 2.a, 2.b, 2.c, 2.d, or 2.f.
APPLICABILITY :
According to Table 3.3.1 1-ACTIONS to GNRO-2009-00054 Page 7 of 20 RPS Instrumentation 3.3.1.1 3.3 INSTRUMENTATION 3.3.1.1 Reactor Protection System (RPS) Instrumentation COMPLETION TIME 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in
~()lrE:-------------------
~ot applicable for Functions 2.a, 2.b, 2.c, 2.d, or 2.f.
A.2 Place associated trip 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> system in trip.
According to Table 3.3.1.1-1 The RPS instrumentation for each--..--~-L.--""""''''''~'~.~~,~............................ ~--...
shall be OPERABLE.
A.
One or more required channels inoperable.
CONDITION LCO 3.3.1.1 APPLICABILITY:
ACTIONS
~----------------------N Separate Condition entry is allowed f B.
One or more Functions B.1 with one or more reqUired channels inoperable in both OR trip systems.
Place channel in one 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> trip system in trip.
B.2 Place one trip system 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> in trip.
c.
One or more Functions e.l with RPS trip capability not maintained.
Restore RPS trip capability.
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (continued)
GRAND GULF 3.3-1 Amendment No. -tre- -
to GNRO-2009-00054 Page 8 of 20 ACTIONS continued)
F RPS Instrumentation 3,3.I.1 INSERT B - New Conditions J and K with Required Actions GRAND GULF 3.3-2 Amendment No.
CONDITION REQUIRED ACTION COMPLETION TIME D.
Required Action and D.1 Enter the Condition Immediately associated Completion referenced in Time of Condition A, Table 3.3.1.1-1 for B, or C not met, the channel.
E.
As required by E-1 Reduce THERMAL POWER 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Required Action D.1 to < 40% RTP.
and referenced in Table 3.3.1.1-1.
F.
As required by F.1 Reduce THERMAL POWER 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Required Action D.1 to < 25% RTP.
and referenced in Table 3.3.1.1-1.
G.
As required by G.1 Be in MODE 2.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Required Action D.1 and referenced in Table 3.3.1.1-1.
H.
As required by H.1 Be in MODE 3.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Required Action 0.1 and referenced in Table 3.3.1.1-1.
I.
As required by I.1 Initiate action to Immediately Required Action D.1 fully insert all and referenced in insertable control Table 3.3.1.1-1.
rods in -, care cells containing one or more fuel assemblies. to GNRO-2009-00054 Page 8 of 20 RPS Instrumentation 3.3.1.1 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME D.
ReqUired Action and 0.1 Enter the Condition Immediately associated Completion referenced in Time of Condition A, Table 3.3.1.1-1 for B, or C not met.
the channel.
E.
As required by E.1 Reduce THERMAL POWER 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> ReqUired Action 0.1 to < 40% RTP.
and referenced in Table 3.3.1.1-1.
F.
As required by F.l Reduce THERMAL POWER 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Required Action 0.1 to < 25% RTP.
and referenced 1n Table 3.3.1.1-1.
G.
As required by G.I Be in MODE 2.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> ReqUired Action 0.1 and referenced in Table 3.3.1.1-1.
H.
As required by H.1 Be in MODE 3.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Required Action 0.1 and referenced in Table 3.3.1.1-1.
I.
As required by 1.1 Initiate action to Immediately Required Action 0.1 fully insert all and referenced in insertablp control Table 3.3.1.1-1.
rods in: core Jcell s containing one or more fuel assemblies.
~-------.Y.-INSERT B - New Conditions J and K with Required Actions GRAND GULF 3.3-2 Amendment No.~---
to GNRO-2009-00054 Page 9 of 20 INSERT B - New Conditions J and K with Required Actions J.
K As required by Required Action J.1 Initiate alternate method to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> D.1 and referenced in detect and suppress thermal Table 3.3.1.1-1.
hydraulic instability oscillations.
AND J.2
-________NOTE_._._.__
LCO 3.0.4.b is not applicable.
Restore required channels to 120 days OPERABLE.
Required Action and associated K.1 Reduce THERMAL POWER 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time of Condition J to < 24% RTP.
not met. to GNRO-2009-00054 Page 9 of 20 INSERT B - New Conditions J and K with Required Actions J.
As required by Required Action J.1 Initiate alternate method to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 0.1 and referenced in detect and suppress thermal Table 3.3.1.1-1.
hydraulic instability oscillations.
AND J.2
NOTE--------
LCO 3.0.4.b is not applicable.
Restore required channels to 120 days OPERABLE.
K~
Required Action and associated K.1 Reduce THERMAL POWER 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time of Condition J to <24% RTP.
not met.
to GNRO-2009-00054 Page 10 of 20 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE SR 3.3.1.1.10
NOTES ---------------
Neutron detectors are excluded For Function 2.a, not required to be performed when entering MODE 2 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 2.
Function 2.d, APRM recirculation flow transmitters are excluded.
Perform C L CALIBRATION RPS Instrumentation 3.3.1.1 FREQUENCY ND GULF 3.3-4a Amendment (continued) to GNRO-2009-00054 Page 10 of 20 SURVEILLANCE REQUIREMENTS (continued)
RPS Instrumentation 3.3.1.1 SURVEILLANCE SR 3.3.1.1.10
NOTES------------------
1.
Neutron detectors are excluded.
2.
For Function 2.a, not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> a r entering MODE 2.
3.
For Function 2.d, APRM recirculation flow transmitters are excluded.
~
For function 2.d, tAe digital components of the flew eont,ol t, ip reference cards are exelud~d.
Perform CHANNEL CALIBRATION.
FREQUENCY (continued)
GRAND GULF 3.3-4a Amendment No. -+4+-----l to GNRO-2009-00054 Page 11 of 20 SURVEILLANCE RE UIREMENTS (continued)
RPS Instrumentation 3.3.1.1 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 3.3-5a Amendment No SURVEILLANCE FREQUENCY SR 3.3.1.1.15
NOTES ------------------
1.
Neutron detectors are excluded.
2.
For Functions 3, 4, and 5 in Table 3.3.1.1-1, the channel sensors may be excluded.
3.
For Function 6, "n" equals 4 channels for the purpose of determining the STAGGERED TEST BASIS Frequency.
Verify the RPS RESPONSE TIME is within 18 months on a
- limits, STAGGERED TEST Deleted BASIS SR 3.3.1.1.16 V r 4
.4,
-Y m,
FPO ffle jq ::~ 6 S SR 3.3.1.1.17 Perform APRM recirculation flow 18 months transmitter calibration SR 3.3.1.1.18 d Sib t e w e (5 mi:r 1.
e me M
W 4 I
- 1
- 6 4 if I :7 e a rd, a
Mfo to Peaet i, flow.
A ays aft, r r a e h4ftg qtJ 4 14 16 r i tim e am.,.
444:4 " s Deleted I
. I I -,I Ull 04-ft 9 refut 1 4.-ftg to GNRO-2009-00054 Page 11 of 20 SURVEILLANCE REQUIREMENTS (continued)
RPS Instrumentation 3.3.1.1 SURVEILLANCE SR 3.3.1.1.15
NOTES------------------
1.
Neutron detectors are excluded.
2.
For Functions 3,4, and 5 in Table 3.3.1.1-1, the channel sensors may be excluded.
3.
For Function 6, un" equals 4 channels for the purpose of determining the STAGGERED TEST BASIS Frequency.
Verify the RPS RESPONSE TIME is within 1imits.
SR 3.3.1.1.16 SR 3.3.1.1.17 Perform APRM recirculation flow transmitter calibration.
~ GULF 3.3-5a FREQUENCY 18 months on a STAGGERED TEST BASIS 18 mOfltl'is 18 months Oflee 'vv'itl9ifl 7 da)'5 after reaer-Ii ft9 eC1uilibrium eOflditioflS foll ('jOW'; "9 refueliFig outage Amendment No. ~
to GNRO-2009-00054 Page 12 of 20 INSERT C - New SRs 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 SR 3.3.1.1.19 Perform CHANNEL CHECK.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> SR 3.3.1.1.20
NOTE ------------------------
1.
For Function 2.a, not required to be performed when entering MODE 2 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 2.
- 2.
For Functions 2.a, 2.b, and 2.c, the APRM/OPRM channels and the 2-Out-Of-4 Voter channels are included in the CHANNEL FUNCTIONAL TEST.
- 3.
For Functions 2.d and 2.f, the APRM/OPRM channels and the 2-Out-Of-4 Voter channels plus the flow input function, excluding the flow transmitters, are included in the CHANNEL FUNCTIONAL TEST.
Perform CHANNEL FUNCTIONAL TEST.
184 days SR 3.3.1.1.21 Perform LOGIC SYSTEM FUNCTIONAL TEST.
24 months SR 3.3.1.1.22
--._.______._._______NOTE__._______.___.__.._._._
For Function 2.e, "n" equals 8 channels for the purpose of determining the STAGGERED TEST BASIS Frequency. Testing APRM and OPRM outputs shall alternate.
Verify the RPS RESPONSE TIME is within limits.
24 months on a STAGGERED TEST BASIS SR 3.3.1.1.23 Verify OPRM is not bypassed when APRM Simulated Thermal 24 months Power is greater than or equal to 29% RTP and recirculation drive flow is less than 60% of rated recirculation drive flow. to GNRO-2009-00054 Page 12 of 20 INSERT C - New SRs 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 SR 3.3.1.1.19 Perform CHANNEL CHECK.
SR 3.3.1.1.20
- - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - -
1.
For Function 2.a, not required to be performed when entering MODE 2from MODE 1until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 2.
2.
For Functions 2.a, 2.b, and 2.c, the APRM/OPRM channels and the 2-0ut-Of-4 Voter channels are included in the CHANNEL FUNCTIONAL TEST.
3.
For Functions 2.d and 2.f, the APRM/OPRM channels and the 2-0ut-Of-4 Voter channels plus the flow input function, excluding the flow transmitters, are included in the CHANNEL FUNCTIONAL TEST.
Perform CHANNEL FUNCTIONAL TEST.
SR 3.3.1.1.21 Perform LOGIC SYSTEM FUNCTIONAL TEST.
SR 3.3.1.1.22
- - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - -
For Function 2.e, "n" equals 8 channels for the purpose of determining the STAGGERED TEST BASIS Frequency. Testing APRM and OPRM outputs shall alternate.
Verify the RPS RESPONSE TIME is within limits.
SR 3.3.1.1.23 Verify OPRM is not bypassed when APRM Simulated Thermal Power is greater than or equal to 29% RTP and recirculation drive flow is less than 60% of rated recirculation drive flow.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 184 days 24 months 24 months on a STAGGERED TEST BASIS 24 months
( a )
(b) to GNRO-2009-00054 Page 13 of 20 SR 3.3.1.1.1
< 122/125 SR 3.3.1.1.3 divisions of SR, 3.3.1.1.12 full scale SR 3.3.1.1.13 SR 3.3.1.1.1 1221125 SR 3.3.1.1.4 divisions of SR 3.3.1.1.12 full scale SR 3.3.1.1.13 SR 3.3.1-1.3 NA SR 3.3.1.1.13 SR 3.3.1.1.4 NA SR 3.3.1.1.13 th
!leviable Val Table 3.3.1.1-1 (page 1 of 3)
Reactor Protection System Instrumentation Flow Biased Simulated Thermal Power - High SURVEILLANCE ALLOWABLE REQUIREMENTS VALUE INSERT D - New APRIVI Functions 2.e and 2J Feduetiens eedwatep, tempepatHpe fflay be delayed ;6,F INSERT E - New Table Notes (c), (d), (e), and (f) 12 heHps.
SR ~
. ~. i. i_.
GR ;
iI SR 3.3.1.1.7 SR, 3.3.1.1.10 SR ;. ;. I. I. I SR 3,3.1.1.2 SR 3.3.1.1.7 SR
- . ;. i. ~~
SR 9.3.1 SR --3-,9. 1. 1. i SR 3.3.1.1.2 SR 3.3.1.1.7 SR 9. ;. i. 1-4 SR, 3.3.1.1.1 C n 0
Ij 11 SR 3.3.1.1.17 SR W
. ;. i
. i. I any control rod withdrawn from a core cell containing one or more fuel assemblies.
eified in the GG6R.
Allewable Va!He FnedifieatieH Feeuir-ed by the GG~R ue Two-Loop operation : 0.65W + 62.9% RTP and < 113% RTP Single-Loop Operation : 0.65W + 42.3% RTP RPS Instrumentation 3.3.1.1 (continued)
GRAND GULF 3.3-6 Amendment No. ~, 4-6-9 APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFI D PER TRIP REQUIRED FUNCTION CONDITIONS SYSTEM ACTION D.1 Intermediate Range Monitors a.
Neutron Flux-High 2
3 H
5(a) 3 1 to GNRO-2009-00054 Page 13 of 20 RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 (page 1 of 3)
Reactor Protection System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER TRIP SYSTEM CONDITIONS REFERENCED FROM REQUIRED ACTION 0.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE SR 3.3.1.1.1
~ 122/125 SR 3.3.1.1.3 divisions of SR 3.3.1.1.12 full scale SR 3.3.1.1.13 SR 3.3.1.1.1
~ 122/125 SR 3.3.1.1.4 divisions of SR 3.3.1.1.12 full scale SR 3.3.1.1.13 SR 3.3.1.1.3 NA SR 3.3..1.1.13 SR 3.3.1.1.4 NA SR 3.3.1.1.13 SR SR SR SR SR SR SR 3.3.1.1.1 SR 3.3.1.1.2 SR 3.3.1.1.7 SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.13 SR 3.3.1.1.16 SR 3.3.1.1.16 SR 3.3.1.1.17 SR 3.3.1.1.18 G
H 3
3 1,2 sea) 3 2
b.
Fixed Neutron Flux-High c.
I nop d.
Flow Biased Simulated Thermal Power
- High b.
Inop 2
3 H
sea) 2.
Average Power Range Monitors a.
Neutron Flux-High, 2
Setdown 1.
Intermediate Range Monitors a.
Neutron Flux-High (continued)
(a)
With any control rod withdrawn from a core cell containing one or more fuel assemblies.
(b)
All o\\~'aBl e Val ues spec; fi ed i 19 tRe GOLR.
All o'..'abl e Val ue FRedi fi cati OR f'eql:1i red By tAe GOLR Eiue to f'cdl:1ctioAS 119 feedwater teFflperat~re may be delayed for
~p to 12
~ours.
GRAND GULF 3.3-6 Amendment No. +4+, ~
to GNRO-2009-00054 Page 14 of 20 INSERT D - New APRM Functions 2.e and 2.f 2-Out-Of-4 Voter
- f.
OPRM Upscale 1,2 2
H SR 3.3.1.1.19 NA SR 3.3.1.1.20 S R 3.3.1.1.21 SR 3.3.1.1.22
> 24% RTP 3(c)
S R 3.3.1.1.7 (f)
S R 3.3. 1. 1.10 SR 3.3.1.1.19 SR 3.3.1.1.20 SR 3.3.1.1.23 INSERT E - New Table Notes (c), (d), (e), and (f)
(c)
(d)
(e) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP} at the completion of the surveillance ; otherwise, the channel shall be declared inoperable. Setpoints more conservative that the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures to confirm channel performance. The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in the Technical Requirements Manual.
Each channel provides inputs to both trip systems.
If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.
The Allowable Value for the OPRM Upscale Period-Based Detection algorithm is specified in the COLR. to GNRO-2009-00054 Page 14 of 20 INSERT D - New APRM Functions 2.e and 2.f e.
2-0ut-Of-4 Voter 1,2 2
H SR3.3.1.1.19 NA SR 3.3.1.1.20 SR3.3.1.1.21 SR 3.3.1.1.22 f.
OPRM Upscale
~ 24%
RTP 3(C)
J SR 3.3.1.1.7 (f)
SR 3.3.1.1.10 (d), (e)
SR 3.3.1.1.19 SR 3.3.1.1.20 SR 3.3.1.1.23 INSERT E - New Table Notes (cl, (dl, (el, and (f)
Each channel provides inputs to both trip systems.
(d)
If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.
(e)
The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative that the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures to confirm channel performance. The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in the Technical Requirements Manual.
(f)
The Allowable Value for the OPRM Upscale Period-Based Detection algorithm is specified in the COLR.
3.3 S
U O
Attachment 3 to GNRO-2009-00054 Page 5 o 0
3.31 3
ln-r~r r-l
-r;rlrcsrrr~-
n,~-n-n-~-~ w0--cn-- I -
ro-c~
AND a
" l L_tI'S t
J1 H
1 -
TI
~
4,
~
'^I A 1 a
Y'li 1Y1
-T9 ld 4
+4 R a
'TfT1'.
T l'~L-P191 "All C D a m d r.,., r
.G' 1
64 w TR F
,- Rl mll A".
t9 d
~. r ".~
D GU 3.3-13a Amendment o
One cRenAel of PBDS instrumeAtation sRall be OPERABLE.
Each OPERABLE chaAnel of PBDS in~truffientatioA shall not
- nd; cate Iii Iii DR a1 arm.
flB-&S 3.3.1.3 (Coflt;flueel)
CO~1PLETION T+M£ Iffifficdiately Immediately Place the reactor mode switch in the shutdown position.
REQUIRED ACTION TfIER~~AL PO~~ER aAd core flow i A t1ge Rcstri cted Regi on specified in the COLR, THERMAL POWER and core flow in the Monitored Region specified in the COLR. to GNRO-2009-00054 Page 15 of 20 CONDITION 8.
Requi red PBOS channel B-:4 inoperable while in the Restricted Region.
- \\.
AFlY OPERABLE p.e.g.£ ehaFlFlel iFldieating Hi Hi OR Alarm
/\\(T I O~! S bf8 3.3.1.3 APPLICABILITY:
3.3.1.3 Period Based DeteetioA System (PBDS) 3.3 INSTRUMENTATION GRAND GULF 3.3-13a Amendment No. ~
I to GNRO-2009-00054 Page 16 of 20 rn N 11 ~N E-QWRI-9 N MnIn s to GNRO-2009-00054 Page 16 of 20 ACTIONS
~
3.3.1,3 CONDITION REQUIRED ACTION COMPLETION ~
B. (conti nued ~
B-:4 Place the reactor I I+lRH~)di ~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
&R 3.3.1.3.2
&R 3.3.1.3.3 Perforffi GHANN~L G~~GK.
12 h061rs 12 h06lPS 24 R:lonths GRA~~D GULF 3.3 13b Amendment ~ ~
to GNRO-2009-00054 Page 17 of 20 3.10 SPECIAL OPERATIONS 3.10.8 Shutdown Margin (SDM) Test-Refueling LCO 3.10.8 The reactor mode switch position specified in Table 1.1-1 for MODE 5 may be changed to include the startup/hot standby position, and operation considered not to be in MODE 2, to allow SDM testing, provided the following requirements are met :
LCO 3.3.1-1, "Reactor Protection System (RPS)
Instrumentation," MODE 2 requirements for Function 2 2.q -of Table 3.3-1.1-1 ;
OR 3.3.2.1, "Control Rod Block Instrumentation,"
MODE 2 requirements for Function 1.b of Table 3.3.2.1-1.
2.
Conformance to the approved control rod sequence fo the SDM test is verified by a second licensed operator or other qualified member of the technical staff; Each withdrawn control rod shall be coupled to the associated CRD ;
CRD charging water header >_ 1520 prig.
SDM Test-Refueling 3.10.8 All control rod withdrawals during out of sequence control rod moves shall be made in single notch wi thdrawal mode ;
No other CORE ALTERATIONS are in progress ; and APPLICABILITY :
MODE 5 with the reactor mode switch in startup/hot standby position.
GRAND GULF 3.10-19 Amendment No. to GNRO-2009-00054 Page 17 of 20 3.10 SPECIAL OPERATIONS 3.10.8 Shutdown Margin (SOH) Test--Refueling SDM Test---Refueling 3.10.8 LCO 3.10.8 The reactor mode switch position specified in Table 1.1-1 for MODE 5 may be changed to include the startup/hot standby position, and operation considered not to be in MODE 2, to allow SOH testing, provided the following requirements are met:
a.
LCO 3.3.1.1, "Reactor Protection System {RPS}
Instrumentation," MODE 2 requirements for Function 2.a
~2.c of Table 3.3.1.1-1; b.
CO 3.3.2.1, "Control Rod Block Instrumentation,"
~~-~~
MODE 2 requirements for Function l.b of Table 3.3.2.1-1, 2.
Conformance to the approved control rod sequence for the SOH test is verified by a second licensed operator or other qualified member of the technical staff; c.
Each withdrawn control rod shall be coupled to the associated CRD; d.
All control rod withdrawals during out of sequence control rod moves shall be made in single notch withdrawal mode; e.
No other CORE ALTERATIONS are in progress; and f.
CRD charging water header ~ 1520 psig.
APPLICABILITY:
MODE 5 with the reactor mode switch in startup/hot standby position.
GRAND GULF 3.10-19 Amendment No. ~ ____
to GNRO-2009-00054 Page 18 of 20 ACTIONS CONDITION
_____NOTE______..___
Separate Condition entry is allowed for each control rod.
A.
One control rod not coupled to its associated CRD.
B.
One or more of the I B above requirements not met for reasons other I
than Condition A.
SURVEILLANCE RE
NOTE ------------
Inoperable control rods may be bypassed in RAGS in accordance with SR 3.3.2.1.9, if required, to allow rtion of inoperable control rod and continued operation.
A.1 Fully insert inoperable control rod.
AND A.2 Disarm the associated CRD.
REQUIRED ACTION Place the reactor mode switch in the shutdown or refuel position.
SR 3.10.8.1 Perform the MODE 2 applicable SRs for LCO 3.3.1.1, Functions 2.a 2.c,of Table 3.3-1.1-1.
SDM Test-Refueling 3.10.8 COMPLETION TIME 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 4 hours I mmed i atel y According to the applicable SRs GRAND GULF 3.10- 20 Amendment No. to GNRO-2009-00054 Page 18 of 20 SOM Test--Refueling 3.10.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
*-----NOTE-----------
Separate Condition entry is allowed for each control rod.
A.
One control rod not coupled to its associated eRD.
NOTE------------
Inoperable control rods may be bypassed in RACS in accordance with SR 3.3.2.1.9, if required, to allow insertion of inoperable control rod and continued operation.
A.1 Fully insert inoperable control rod.
3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> A.2 Disarm the associated 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> CRD.
B.
One or more of the B.1 above requirements not met for reasons other than Condition A.
Place the reactor mode switch in the shutdown or refuel position.
Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY (continued)
According to the applicable SRs SR 3.10.8.1 Perform the MODE 2 applicable SRs for leO 3.3.1.1, Functions 2. a-and-2.c of Table 3.3.1.1-1.
GRANO GULF 3.10-20 Amendment No. -t21r _
to G N RO-2009-00054 Reporting Requirements Page 19 of 20 5.6 Reporting Requi resents 5.6.2 5.6.3 G RA ~D GULF 5.6.4 Deleted
- 6) 3.
Lin results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results.
The missing data shall be submitted in a supplementary report as soon as possible.
The Radioactive Effluent Release Report covering the operation of the unit during the previous calendar year shall be submitted by May 1 of each year.
The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit.
The material provided shall be consistent with the objectives outlined in the ODCM and process control program and in conformance with 10 CFR 50.36a and 10 CFR Appendix I,Section IV.B.1 5.6.5 Core Operating Limits Report tCOLR)
Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following :
- 1)
LCO 3.2.1, Average Planar Linea (APLHGR),
- 2)
LCO 3.2.2, Minimum Critical Power Ratio (MCPR),
- 3)
- 4)
- 5)
f 1 i 19. tc i H
Pe i ~ ij~t (con at Generation Rate a r Heat Generation Rate ( LHGR),
IQ, i m od a ity
( F G 81 LQI )
1.1, RPS Instrumentation, Table 3.3.1.1-1 A
~ n R 1~ sz 1
.1 "1 need)
(continue 5.0-18 Amendment No. 15 ;,
5.6 to GNRO-2009-00054 Page 19 of 20 5.6 Reporting Requirements Reporting Requirements 5.6 5.6.2 Annual Radiological Environmental Operating Report (continued) results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results.
The missing data shall be submitted in a supplementary report as soon as possible.
5.6.3 5.6.4 5.6.5 Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the unit during the previous calendar year shall be submitted by May 1 of each year.
The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit.
The material provided shall be consistent with the objectives outlined in the aDCM and process control program and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I,Section IV.B.l.
Deleted Core Operating Limits Report (COLR) a.
Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:
1)
LCO 3.2.1, Average Planar Linear Heat Generation Rate (APLHGR),
2)
LCO 3.2.2, Minimum Critical Power Ratio (MCPR),
3)
LCO 3.2.3, Linear Heat Generation Rate (LHGR),
4)
LeO 3.2.4, Fraction of Core BoiliR9 BouAdary (FGBB),
5)
LCO 3.3.1.1, RPS Instrumentation, Table 3.3.1.1-1 fUAction 2.d, aAd 6)
GRAND GULF 5.0-18 Amendment No.
+§..7., -+/-:6:t:::. __
to GNRO-2009-00054 age 20 of 20 5.6 Reporting Requirement LF Opera.t.inq Limits Report (COLRY (continued) 21 NEDE-33383-P, "GEXL97 Correlation Applicable to ATRIUM-Global Nuclear Fuel.
0 Fuel "
22.
EMF-CC-074(P)(A), Vol Assessment of STAIF with Input from M1 Siemens Power Corporation, Richland EMF-2292(P)(A), "ATRIUM-10 Appendix K Spray Heat Transfer Coefficients, Siemens Power Corporat Richland. WA.
Reporting Requ 24.
NEDE-24011 -P-A, General Electric Standard Application for Reactor Fuel (GESTAR-11)
The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, car thermal hydraulic limits, emergency Core Cool (ECCS) limits, nuclear limits such as SDM, transi limits, and accident analysis limits) of the safety analysis e me ROBURN-B2,
25. NEDO-31 Licensi 26. NE tic n 11BWR Owners' Group Long-Term Stability Solutions Methodology" 0-32465-A, "Reactor Stability Detect and Suppress Solutions ing Basis Methodology and Reload Applications" d.
The COLR, including any midcycle revisions or sup shall be provided upon issuance for each reload c eat to 5.0-21 Amendment No. ~,
eats 5.6 Attachment.3 to GNRO-2009-00054 Page 20 of 20 Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 Core Operating Limits Report (COLR) (continued) 21.
NEDE-33383-P, "GEXL97 Correlation Applicable to ATRIUM-10 Fuel," Global Nuclear Fuel.
22.
EMF-CC 074(P)(A),
Volume 4.
"BWR Stability Analysis Assessment of STAIF with Input from MICROBURN-B2",
Siemens Power Corporation, Richland, WA.
23.
EMF-2292(P)(A>, "ATRIUM-10 Appendix K Spray Heat Transfer Coefficients", Siemens Power Corporation,
- Richland, WA.
24.
NEOE-24011 -P-A, General Electric Standard Application for Reactor Fue 1 (GESTAR ~ II).
c.
The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.
d.
The COLR, including any midcycle reV1S1ons or supplements, shall be provided upon issuance for each reload cycle to the NRC.
NEDO-31960-A, "BWR Owners' Group Long-Term Stability Solutions Licensing Methodology" NEDO-32465-A, "Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology and Reload Applications" GRAND GULF 5.0 21 Amendment No.
.p.J. J -::::tt:9::- __
ATTACHMENT 4 G N RO-2009-00054 DRAFT MARKED-UP TECHNICAL SPECIFICATION BASES PAGES (FOR INFORMATION ONLY)
ATTACHMENT 4 GNRO-2009-00054 DRAFT MARKED-UP TECHNICAL SPECIFICATION BASES PAGES (FOR INFORMATION ONLY)
B 3.2 POWER DISTRIBUTION LIMNS B 3.2.4 to G N RO-2009-00054 Page 1 of 49 pr
'a
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GRAND GULF B 3.2 - 12 a
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w LDC 98037 to GNRO-2009-00054 Page 1 of 49 B 3.2 POWER DISTRIBUTION LIMITS B 3.2.4 Fraetiefl of Cor@ Boi1i"9 Doutida,y (FEBD)
BACKGROUND GeAeral DesigA Criterion 12 re~uire5
~rotection of fuel 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 U1d res u1t i fl exceed; M9 the
~1CPR Sa f etje Limi t (S L).
++te HCrR SL eA5ures that at least 99.9% of the fuel rods avoid
~
- 1*
t
- t*
d
~
01 1ngran51 lonurlMg normal operation and duriMg aM anticipated operatio"al OCCUII @llce (ADO)
(ref@1 to tl,@ Bases for SL 2.1.1.2).
(cofttiflu@d)
GRAND GULF B 3.2-12 LDC 98037 to GNRO-2009-00054 Page 2 of 49 Q A C. F_ ~
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&A5f5 (continued)
F&BB B 3.2.4 APPLICABLE SAFETY ANALYSES T~e analytical method! and a!!umptions u!@d in @!tabli!hing t~e boiling boundary limit are presented in Section 9 of 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 t~at operation within the R@st, ieted R@gion will not, @sult i MMeutroMi cltl.er mal -I,ydl aul i c i,,~tabi 1i ty due to ei th@r' steady state ope' ation 0\\
as the result of an AGO which iMitiat@s and terminates entirely within the R@strict@d Region.
Analysis also confirms that AGOs initiated f-r-o-m outside t~e Restricted Region (i.e., without an initia~
restri eti on 0"
FCOO) whi el, tel mi "ate i I' tll@ R@!t, i et@d Reg i e fI are "0t expected to, @5 U1t i " i "stabi 1i ty.
TI.e ty p@ S of transients sp@cifically evaluated are 1055 of flow and coolant temperature decrease which are limiting fOl the ORset of instability (R@f. 1).
GRAND GULF B 3.2 13 NRC Policy Statement.
- II (continued)
LOG 98037 to GNRO-2009-00054 Page 3 of 49 BAS'E-S k'e-m
- b41mtitd)
APPI 11. G 14, D-.11, ~v RANO GUI-F a -t e p
v Mt r
f a r t 16, M s e t a.4 i M 5t. a b i 1 i4by Q-4 4 pp A" 4 meA 4 m r-O' 111~j 1A I
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, u, R-.
pewei-eted Pi eted R, s ; t i. - 4. 1-t -ad eted 1 i C 44C*-.L..-
99 Region 1\\,:: !3 lull 'Boundary 0
I Qr-QQO::Z :7 ILI, "I'v" to GNRO-2009-00054 Page 3 of 49 BA&E5 (ceMtiliu@d)
F-BB B 3.2.4 l\\PPLICAB I LITY GRAND GULF Tlge FESS limit is u~~d to l'Ievel,t cOle cOI,ditions I,ecessaly for ttete Oflset of i I'lstabi 1i ty ar,d tl,el eb) pi @el ude 1geutreFli c/tn@fmal -I,)d, aul i c i "stab; 1; ty wi,; 1e opel at; ng i-n the Restricted Regiol'l defined in t~e COLR.
(c6t'ltil9ued)
LOG 98037 to GNRO-2009-00054 Page 4 of 49 Ctl I t'11RT1 TT r
r r
sHse 't'.4164e
,14 ;, ;.y f a.
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r to GNRO-2009-00054 Page 4 of 49 F&B-B B 3.2.4 APPLIC/\\BI LITY (continued)
ACTIONS Operation outside tMe Restricted Re§io~ is
~ot susceptible to fl@utroflic/tRelffial Ryd, aulic ili3tability ~
app1i cab1e the r ffialp 0'04er dist fib uti en 1i ffti t:s 3 Ueh f1 ~
t1CPR are Fflet.
~~"""""~A--'lF-tGHill---+l\\o~~~""'d Re g:; 0 "
6 1 e to @I'ltry was cO~5i st@"t w4-H1 fer e"t,) wag,eeog,,:; fed
~
~~~~~~~~~~d a~d k~OWM to Mot AetioRS to exit the
~~r-R--~Iiiil--jiiPR-Ri~~~e 'yiR e~ FeBB CBrl Mot b@
(coAtinl-AQd)
GRAND GULF 8 3.2 15 LDG 98037 to GNRO-2009-00054 Page 5 of 49 A r-:~ I G*S a19 -4 Q
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41 '1: th e IR @ 5t i-i e ttd I~imiulail;, d Th.
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k I.-Ul I k, I I I U to GNRO-2009-00054 Page 5 of 49 F&B-B B 3.2.4 ACTION5 (cofltiftuee)
GRAND GULF B.1 aAd B.2 B 3.2 16 (COllti Hued)
LOG 98037 to GNRO-2009-00054 Page 6 of 49 AG:~ i -O4S I"1 Vh fS l^ t
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Exit of the Restricted RegioM caM be accoffiplish@d by contro~
rod insertion aAd/or recirculation flow iMcreas@3.
ActioAS to restart an idle recirculation loop, withdraw cOMtrol rods 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.
~
3.2.4.1 5 af ety a19 a1:)' 5 is.
~~~~oR-R---R-FH+R~~~-fR+~~~~~~~dto ens ure t hat
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operation.
(eolititiued)
GRAND GULF B 3.2 17 LOG 98037 to G N RO-2009-00054 e 7 of 49 A5 2-:A-:1
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)P 99P to GNRO-2009-00054 Page 7 of 49 F-&8 B 3.2.4 SURV[ ILL/\\NCE RtQUIRE;M[NTS REFERENCES
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3.2.4.1 (coAtiAued) h
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B 3.2 18 LOG 9g0~7 to GNRO-2009-00054 Page 8 of 49 BASES INSERT A - APRM Subsystem Description RAND GULF (continued)
Setdown 1.b.
Intermediate Range Monitor-In Monitor (IRM) Neutron Flu RPS Instrumentation B 3.3-1.1 APPLICABLE 1.a.
Intermediate SAFETY ANALYSES, LCO, and APPLICABILITY unexpected reactivity excursions.
In MODE 1, the APRM System, the rod withdrawal limiter (RWL), and the RPC provide protection against control rod withdrawal error events and the IRMs are not required.
This trip signal provides assurance that a minimum number of IRMs are OPERABLE.
Anytime an IRM mode switch is moved to any position other than "Operate," the detector voltage drops below a preset level, or a module i s not plugged in, an inoperative trip signal will be received by the RPS unless the IRM is bypassed.
Since only one IRM in each trip system may be bypassed, only one IRM in each RPS trip system may be inoperable without resulting in an RPS trip signal -
This Function was not specifically credited in the accident analysis, but it is retained for the RPS as required by the NRC approved licensing basis.
channels of Intermediate Range Monitor-Inop with three channels in each trip system are required to be OPERABLE to ensure that no single instrument failure will preclude a scram from this Function on a valid signal.
Since this Function is not assumed in the safety analysis, there is no Allowable Value for this Function.
This Function is required to be OPERABLE wh Intermediate Range Monitor Neutron Flux-Hig required.
n the Funct i on i s, 2.a.
Average Power Range Monitor Neutron Fl ux- H=
( continuedl 8 3.3-6 Revision No. 0 to GNRO-2009-00054 Page 8 of 49 BASES APPLICABLE SAFETY ANALYSES, LeO, and APPLICABILITY RPS Instrumentation B 3.3.1.1 l.a.
Intermediate Range Monitor fIRM) Neutron Flux--High (continued) unexpected reactivity excursions.
In MODE 1, the APRM System, the rod withdrawal limiter (RWl), and the RPC provide protection against control rod withdrawal error events and the IRMs are not required.
I.b.
Intermediate Range Monitor--Inop This trip signal provides assurance that a minimum number of IRMs are OPERABLE.
Anytime an IRM mode switch is moved to any position other than "Operate," the detector voltage drops below a preset level, or a module is not plugged in, an inoperative trip signal will be received by the RPS unless the IRM 1s bypassed.
Since only one IRM in each trip system may be bypassed, only one IRM in each RPS trip system may be inoperable without resulting in an RPS trip signal.
This Function was not specifically credited in the accident analysis, but it is retained for the RPS as required by the NRC approved licensing basis.
Six channels of Intermediate Range Monitor--Inop with three channels in each trip system are required to be OPERABLE to ensure that no single instrument failure will preclude a scram from this Function on a valid signal.
Since this Function 1s not assumed 1n the safety analysis, there is no Allowable Value for this Function.
This Function 1s required to be OPERABLE when the Intermediate Range Monitor Neutron Flux--High Function is required.
2.a.
Average Power Range Monitor Neutron Flux-High, 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 continued GRAND GULF B 3.3-6 Revision No. 0 to GNRO-2009-00054 Page 9 of 49 INSERT A - APRM Subsystem Description e Power Range Monitor The APRM subsystem provides the primary indication of neutron flux within the core and responds almost instantaneously to neutron flux increases. The APRMs receive input signals from the local power range monitors {LPRMs} within the reactor core to provide an indication of the power distribution and local power changes. The channels average these LPRM signals to provide a continuous indication of average reactor power from a few percent t greater than RTP. Each APRM also includes an Oscillation Power Range Monitor {OPRM}
Upscale Function which monitors small groups of LPRM signals to detect thermal-hydraulic instabilities.
The APRM subsystem is divided into four APRM/OPRM channels and four 2-Out-Of-4 Voter channels. Each APRM/OPRM channel provides inputs to each of the four voter channels.
The four voter channels are divided into two groups of two each, with each group of two providing inputs to one RPS trip system. The system is designed to allow one APRM/OPRM channel, but no voter channels, to be bypassed. A trip from any one un-bypassed APRM/OPRM channel will result in a "half-trip" in all four of the voter channels, but no trip inputs to either RPS trip system. Since APRM Functions 2.a, 2.b, 2.d, and 2.f are mplemented in the same hardware, these functions are combined with APRM Inop Function 2.c. Any Function 2.a, 2.b, 2.c, or 2.d trip from any two unbypassed APRM/OPRM channels will result in a full trip in each of the four 2-Out-Of-4 Voter channels, which in turn results in two trip inputs to each RPS trip system logic channel (Al, A2, B1, and 132). Similarly, any Function 2.d or 2.f trip from any two unbypassed APRM/OPRM channels will result in a full trip from each Voter channel. Three of the four APRM/OPRM channels and all four of the voter channels are required to be OPERABLE to ensure that no single failure will preclude a scram on a valid signal. In addition, to provide adequate coverage of the entire core, consistent with the design bases for APRM Functions 2.a, 2.b, and 2.d, at least 20 LPRM inputs, with at least three LPRM inputs from each of the four axial levels at which the LPRMs are located, must be operable for each APRM/OPRM channel. For the OPRM Upscale, Function 2.f, LPRMs are assigned to "cells" of four detectors. A minimum of 30 cells, each with a minimum of two LPRMs, must be OPERABLE for the OPRM Upscale Function 2.f to be OPERABLE. to GNRO-2009-00054 Page 9 of 49 INSERT A - APRM Subsystem Description Average Power Range Monitor (APRMl The APRM subsystem provides the primary indication of neutron flux within the core and responds almost instantaneously to neutron flux increases. The APRMs receive input signals from the local power range monitors (LPRMs) within the reactor core to provide an indication of the power distribution and local power changes. The channels average these LPRM signals to provide a continuous indication of average reactor power from a few percent to greater than RTP. Each APRM also includes an Oscillation Power Range Monitor (OPRM)
Upscale Function which monitors small groups of LPRM signals to detect thermal-hydraulic instabilities.
The APRM subsystem is divided into four APRM/OPRM channels and four 2-0ut-Of-4 Voter channels. Each APRM/OPRM channel provides inputs to each of the four voter channels.
The four voter channels are divided into two groups of two each, with each group of two providing inputs to one RPS trip system. The system is designed to allow one APRM/OPRM channel, but no voter channels, to be bypassed. A trip from anyone un-bypassed APRM/OPRM channel will result in a "half-trip" in all four of the voter channels, but no trip inputs to either RPS trip system. Since APRM Functions 2.a, 2.b, 2.d, and 2.f are implemented in the same hardware, these functions are combined with APRM Inop Function 2.c. Any Function 2.a, 2.b, 2.c, or 2.d trip from any two unbypassed APRM/OPRM channels will result in a full trip in each of the four 2-0ut-Of-4 Voter channels, which in turn results in two trip inputs to each RPS trip system logic channel (A1, A2, B1, and B2). Similarly, any Function 2.d or 2.f trip from any two unbypassed APRM/OPRM channels will result in a full trip from each Voter channel. Three of the four APRM/OPRM channels and all four of the voter channels are required to be OPERABLE to ensure that no single failure will preclude a scram on a valid signal. In addition, to provide adequate coverage of the entire core, consistent with the design bases for APRM Functions 2.a, 2.b, and 2.d, at least 20 LPRM inputs, with at least three LPRM inputs from each of the four axial levels at which the LPRMs are located, must be operable for each APRM/OPRM channel. For the OPRM Upscale, Function 2.f, LPRMs are assigned to "cells" of four detectors. A minimum of 30 cells, each with a minimum of two LPRMs, must be OPERABLE for the OPRM Upscale Function 2.f to be OPERABLE.
to GNR4-2009-00054 Page 10 of 49 BASES RPS Instrumentation B 3,3.1.1 APPLICABLE 2.a.
Average Power Range Monitor Neutron Flux-SAFETY ANALYSES, Setdown (continued)
LCO, and APPLICABILITY For operation at low power (i.e., MODE 2), the Average Power Range Monitor Neutron Flux-High, Setdown Function is capable of generating a trip signal that prevents fuel damage resulting from abnormal operating transients in this power range.
For most operation at low power levels, the Average Power Range Monitor Neutron Flux-High, Setdown Function will provide a secondary scram to the Intermediate Range Monitor Neutron Flux-High Function because of the relative setpoints.
With the IRMs at Range 9 or 10, it is possible that the Average Power Range Monitor Neutron Flux-High, Setdown Function will provide the primary trip signal for a corewide increase in power.
No specific safety analyses take direct credit for the Average Power Range Monitor Neutron Flux-High, Setdown Function.
However, this Function indirectly ensures that, before the reactor mode switch is placed in the run position, reactor power does not exceed 25% RTP (SL 2.1.1-1) when operating at low reactor pressure and low core flow.
Therefore, it indirectly prevents fuel damage during significant reactivity increases with THERMAL POWER
< 25% RTP.
I DOMS 9.1
.. - lee& ted.
The Allowable Value is based on preventing signifi increases in power when THERMAL POWER is < 25% RTP-ant GRAND GULF B 3.3-7 Revision No. 0 to GNRO-2009-00054 Page 10 of 49 BASES RPS Instrumentation B 3.3.1.1 APPLICABLE 2.a.
Average Power Range Monitor Neutron Flux--High.
SAFETY ANALYSES, Setdown (continued)
LCD, and APPLICABILITY from a few percent to greater than RTP.
For operation at low power (1.e., MODE 2), the Average Power Range Monitor Neutron Flux--High, Setdown Function is capable of generating a trip signal that prevents fuel damage resulting from abnormal operating transients in this power range.
For most operation at low power levels, the Average Power Range Monitor Neutron Flux--High, Setdown Function will provide a secondary scram to the Intermediate Range Monitor Neutron Flux--High Function because of the relative setpoints.
With the IRMs at Range 9 or 10, it is possible that the Average Power Range Monitor Neutron Flux--High, Setdown Function will provide the primary trip signal for a corewide increase in power.
No specific safety analyses take direct credit for the Average Power Range Monltor Neutron Flux--High, Setdown Function.
However, this Function indirectly ensures that, before the reactor mode switch is placed in the run position, reactor power does not exceed 25% RTP (SL 2.1.1.1) when operating at low reactor pressure and low core flow.
Therefore, it indirectly prevents fuel damage during significant reactivity increases with THERMAL POWER
< 25% 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 LPRMs are leeated.
The Allowable Value is based on preventing significant increases in power when THERMAL POWER is < 25% RTP.
(continued)
GRAND GULF B 3.3-7 Revision No. 0 to GNRO-2009-00054 Page 11 of 49 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY 2.a.
Average Power Range Monitor Neutron Flux-High, Setdown (continued)
The Average Power Range Monitor Neutron Flux-High, Setdown Function must be OPERABLE during MODE 2 when control rods may be withdrawn since the potential for criticality exits.
In MODE 1, the Average Power Range Monitor Neutron Flux-High Function provides protection against reactivity transients and the RWL and RPC protect against control rod withdrawal error events.
RPS Instrumentation 3.3. 1.1 The Average Power Range Monitor Fixed Neutron Flux-High Function is capable of generating a trip signal to prevent fuel damage or excessive RCS pressure.
For the overpressurization protection analysis of Reference 2, the Average Power Range Monitor Fixed Neutron Flux--High Function i s assumed to terminate the main steam isolation valve (MSIV) closure event and, along with the safety/relief valves (S/RVs), limits the peak reactor pressure vessel (RPV) pressure to less than the ASME Code limits.
The control rod drop accident (CRDA) analysis (Ref. 7) takes credit for the Average Power Range Monitor Fixed Neutron Flux-High Function to terminate the CROA.
The Allowable Value is based on the Analytical Limit assumed n the CRDA analyses.
GRAND GULF 8 3.3-8 Revision No. 0 to GNRO-2009-00054 Page 11 of 49 BASES RPS Instrumentation B 3.3.1.1 APPLICABLE 2.a.
Average Power Range Monitor Neutron Flux--High, SAFETY ANALYSES, Setdown (continued)
LCO, and APPLICABILITY The Average Power Range Monitor Neutron Flux--High, Setdown Function must be OPERABLE during MODE 2 when control rods may be withdrawn since the potential for criticality exits.
In MODE 1, the Average Power Range Monitor Neutron Flux--High Function provides protection against reactivity transients and the RWl and RPC protect against control rod withdrawal error 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 Power Range Monitor Fixed Neutron Flux--High Function is capable of generating a trip signal to prevent fuel damage or excessive ReS pressure.
For the overpressurization protection analysis of Reference 2t the Average Power Range Monitor Fixed Neutron Flux--H1gh Function 1s assumed to terminate the main steam isolation valve (MSIY) closure event and t along with the safety/relief valves (S/RVs), limits the peak reactor pressure vessel (RPV) pressure to less than the ASHE Code limits.
The control rod drop accident (eRDA) analysis (Ref. 7) takes credit for the Average Power Range Monitor Fixed Neutron Flux--H1gh Function to tenminate 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
- np~ts frOM 8ath af the feur axial levels at w~1ch the LPRMs are leeated.
The Allowable Value is based on the Analytical Limit assumed in the eRDA analyses.
(continued)
GRAND GULF B 3.3-8 Revision No. 0 to GNRO-2009-00054 Page 12 of 49 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY The Average Power Range Monitor Fixed Neutron Flux-High Function is required to be OPERABLE in MODE 1 where the potential consequences of the analyzed transients could result i n the SLs (e.g., MCPR and RCS pressure) being exceeded.
Although the Average Power Range Monitor Fixed Neutron Flux-Nigh Function i s assumed i n the CRDA analysis that i s applicable i n MODE 2, the Average Power Range Monitor Neutron Flux-Nigh, Setdown Function conservatively bounds the assumed trip and, together with the assumed I trips, provides adequate protection.
Therefore, the Averag Power Monitor Fixed Neutron Flux-High Function i s not required i n MODE Z.
RPS Instrumentation B 3.3. 1.1 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.
There i s no Allowable Value for this Function.
This Function i s required to be OPERABLE i n the MODES where the APRM Functions are required.
GRAND GULF 8 3.3-9 Revision No. 0 to GNRO-2009-00054 Page 12 of 49 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY RPS Instrumentation B 3.3.1.1 2.b.
Average Power Range Monitor Fixed Neutron Flux--High (continued)
The Average Power Range Monitor Fixed Neutron Flux--High Function is required to be OPERABLE in MODE 1 where the potential consequences of the analyzed transients could result 1n the SLs (e.g., MCPR and ReS pressure) being exceeded.
Although the Average Power Range Monitor Fixed Neutron Flux--H1gh Function 1s assumed in the eRDA analysis that 1s applicable in MODE 2, the Average Power Range Monitor Neutron Flux--H1gh, Setdown Function conservatively bounds the assumed trip and, together with the assumed IRM trips, provides adequate protection.
Therefore, the Average Power Monitor Fixed Neutron Flux--High Function is not required in MODE 2.
2.e.
Average Power Range Monitor--Inop 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 no Allowable Value for this Function.
This Function 1s required to be OPERABLE in the MODES where the APRM Functions are required.
(continued)
GRAND GULF B 3.3-9 Revision No. 0 to GNRO-2009-00054 Page 13 of 49 INSERT B Three of the four APRM/OPRM channels are required to be OPERABLE for each of the APRM Functions. This Function (Inop) provides assurance that the minimum number of channels is OPERABLE.
t For any APRM/OPRM channel, any time its mode switch is in any position other than "Operate," a module is unplugged, or the automatic self test system detects a critical fault with APRM/OPRM channel, an Inop trip is sent to all four voter channels. Inop trips fr more unbypassed APRM/OPRM channels result in a trip output from all four voter channels to their associated trip system. to GNRO-2009-00054 Page 13 of 49 INSERT B Three of the four APRM/OPRM channels are required to be OPERABLE for each of the APRM Functions. This Function (Inop) provides assurance that the minimum number of channels is OPERABLE.
For any APRM/OPRM channel, any time its mode switch is in any position other than "Operate," a module is unplugged, or the automatic self-test system detects a critical fault with the APRM/OPRM channel, an Inop trip is sent to all four voter channels. Inop trips from two or more unbypassed APRM/OPRM channels result in a trip output from all four voter channels to their associated trip system.
BASES to GNRO-2009-00054 Page 14 of 49 APPLICABLE 2.d.
Average Power Range Monitor Flow Biased Simul SAFETY ANALYSES, Thermal Power - Hi LCO, and APPLICABILITY The Average Power Range Monitor Flow Bias d Simulate (continued)
Thermal Power - High Function monitors netitron flux to approximate the THERMAL POWER being trans
. erred to the reactor coolant.
The APRM neutron flux i electronically filtered with a time constant representat ve of the fuel heat transfer dynamics to generate a sign I proportional to the THERMAL POWER in the reactor.
The tr level is varied ction of recirculation drive flow i s cl amped at an upper limit that is always lower than the Average Power Range Monitor Fixed Neutron Flux - High Function Allowable Val ue.
Th FFflal Pewer -
iilfflil ing saf y ys :~, effl F e a et-m--
eeuld r-sult in e)l eeedif+g GRAND GULF B 3.3-9a RPS Instrumentation B 3.3.1.1 1 i FR4 esta-bli,sh d t1h 14 emse perat 4 A
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LDC 98037 to GNRO-2009-00054 Page 14 of 49 BASES RPS Instrumentation B 3.3.1.1 APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) 2.d.
Avera e Power Ran e Monitor Flow Biased Simula Thermal Power - High The Average Power Range Monitor Flow Bias d Simulate Thermal Power - High Function monitors ne tron flux to approximate the THERMAL POWER being trans erred to the reactor coolant.
The APRM neutron flux i electronically filtered with a time constant representat ve of the fuel heat transfer dynamics to generate a sign 1 proportional to the THERMAL POWER in the reactor.
The tr level is varied as a function of recirculation drive flow ~ is clamped at an upper limit that is always lower than the Average Power Range Monitor Fixed Neutron Flux - High Function Allowable Val ue.
The Aver age Po\\1erRat9 9e
~4a t9ito r Flo'i' Bi a5ed Simu1ated Thermal Po 'n'er - Iii 9A Fut'l Ct i 0 t'l fo' r 0 vi clega 9eflera1 definition of the liceRsed core power/core flow ope, ating domaifl.
The l\\vera 9e Po 'n'erRat9 9e
~4 0 fl ito r Flo" Bi asecl Si mu1ated The rmal Po'Iiera H; 9A Fu19 Ct i 0 fl i S fl 0 t ass 0 ciated witM a limiting safety systcffi settiflg.
Operatiflg limits established for the licel9sed operatifl9 domaifl are used to devel 0 p the A" era 9e Po'tverRa19 9e
~4 0 19ito r Flo"f Bi agcd Si ffi U1ated The rmal Po',fer *,~i 9h Fut'l Ct i af1 All a',tae1e Val ue ~ to provide preemptive reactor serafR at'ld prevel9t gross violation 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 ana1:)' 5is.
0perat ion
~.,i t hi A the 1icensed 0 perat i f19 dofflai n a1sa ens ures c0 fAP1i at9ce 'ft'i tAGet'lera1 0esi 9n CFiterion 3::-2-;-
GeAeral DesigA Criterion 12 requires protection of fuel therffial safety limits frofR eot'lditions caused by neutroAie/therfRal Aydraulic if1staeility.
Neutronic/thermal-hydraulic instabilities result ifl pO'ffer oscillations w+t+eh could result iA e)(ceeding the MCPR SL.
The area of the core power afldflow operatifl9 domain susceptible to neutrot'lic/therma1 hydraulic instability ~
be affected by reactor parafficters such as reactor inlet feed\\~ater temperature (Ref. 12).
T'tt'O compl ete at'ld (continued)
GRAND GULF B 3.3-9a LDC 98037 to GNRO-2009-00054 Page 1 5 of 49 INSERT 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 The APRM Flow Biased Simulated Thermal Power - High function provides protection against transients where THERMAL POWER increases slowly such as the loss of feedwater heating event) and protects the fuel cladding integrity by ensuring that the MCPR SL is not exceeded. During these events, the THERMAL POWER increase does not significantly lag the neutron flux response and, because of a lower trip setpoint, will initiate a scram before the high neutron flux scram. For rapid neutron flux increase events, the THERMAL POWER lags the neutron flux and the APRM Neutron Flux - High function will provide a scram signal before the APRM Flow Biased Simulated Thermal Power - High function setpoint is exceeded. to GNRO-2009-00054 Page 15 of 49 INSERT C INSERT D The APRM Flow Biased Simulated Thermal Power - High function provides protection against transients where THERMAL POWER increases slowly (such as the loss of feedwater heating event) and protects the fuel cladding integrity by ensuring that the MCPR SL is not exceeded. During these events, the THERMAL POWER increase does not significantly lag the neutron flux response and, because of a lower trip setpoint, will initiate a scram before the high neutron flux scram. For rapid neutron flux increase events, the THERMAL POWER lags the neutron flux and the APRM Neutron Flux - High function will provide a scram signal before the APRM Flow Biased Simulated Thermal Power - High function setpoint is exceeded.
SASE to GNR(J-2009-00054 Page 16 of 49 P P 1 16 -A IQ, E A
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I e to GNRO-2009-00054 Page 16 of 49 BASES RPS Instrumentation B 3.3.1.1 APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY
~
Average PO'iter Raflge
~1oflitor Flo'"
Biased Simulated Thermal Power - H+/-gh (continued) i fldef)endent 3et3 of AverB9c POW@1 Ran9c
~iOI,i tor Flow Bi aged Si mu1ated Tner mB1 P{}we,
- IIi 911 FU"ct i 0 "
,At1low ab1e VB 1Ue!; may be sf)ecified in the COLR.
Set 1 (Normal Trif) Refereflce Set) provides protection agaiRgt n@utronic/th@fmal hyd\\ aulic instability during @xp@ct@d }@BctO}
opelating condition!.
Set 2 (Alternate Tfi~ Refelence Set) provides ptotection against neutronie/thermal hydraulic instability dUI ing reactor operating conditions requiring added stability protection and ig con3ervat;ve with l@~p@ct to Set 1.
Feedwater temperature values requiring tl an3ition between flow control trip teference cald gets are specified in tne COLR, when necessary.
In the eveAt of a feedwater 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 Reference Set) as 5f'eci fi @d i " tile COLR i!; }@~ui,ed to preserve the mar~iR associated ffith the
~oteMtial for the Oflset of fleutraMi cltne, mel =hydt aul i c ; },~tabi 1i ty wh+eh existed prior to the feeclwat@r t@m~@rature reductioM.
~
Allo\\table Value modification r@~uired b; the COLR ma) be del a:teeJ up to 12 haur s to a11 0 w t ; me to adj u~tea" deneek t I*e adjustmeftt of cacR flo'" control trip refe, eMce ~
At tRe 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 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 ~
on the low probability of a flcutroMic/tRerma1 hydraulic iflstability CVCMt Bnd the continued plotection plovided by the flow cOfltrol trip refelence cald.
1ft addition, when the feed\\tater temf3erature reducti on re3ul t5 in ol'@rati on +n ei tner tMc Restr; cted Reg; at! at the r~{}\\ii tat cd Re9i 01', tile requirements for the Period Based Detection System (LCO 3.3Gl.3, Period Based Detection SY3t@m (PODS)) plovide added f)rotccti on a~ai fl3t Meutl ani e/thel mal I.ydt eaul i c ; J,~teab; 1i ty 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.
The area of the core power and flow ope) ating domain suseef3ti bl e to flcutre}l'l; c/tnel mal =I'l,draul i c ; li5tabi 1i ty h affected b)' tMe value of Fraetiol, of Cote 80;li119 BouildalY
( LCO 3. 2*4, FeBB) (Ref.
12).
" SetUf3" aft d ne, mal
("n 0 n Setuf3") Aver age ra'vcN! r Ra nge
~1on i to r Flow Bi a ~@d 5i mul Bt@d Thermal Power - IfigM FunctioM Allowable Valu@~ al e $p@cifi@d
- 19 the COLR.
(continued)
GRAND GULF B 3.3-9b LDC 9S037
BASES to GNRO-2009-00054 Page 17 of 49 T
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{continued}
GRAND GULF B 3.3-9c LDC 98037 to GNRO-2009-00054 Page 17 of 49 BASES RPS Instrumentation B 3.3.1.1 APPLICABLE SAFETY ANALYSES, LCO, and
/\\PPLIGABILITY 2-:-6-:
Av0 rag 0 P0'n'0 r Rafl 9e
~40flito r Flo ',0' Bi as 0 cl Si mu1ated The rfflalP 0 \\ver
.. H4-§fl (c0 fl t i fl Ucd)
The florffial
("190fl Setup") 'fal ue provi cles protecti on a~a; flst neutroflic/therffial Aydraulic iNstability by provefltiflg operation ifl tMe susceptible area of tAe o~erati~g domain
'h'heN operati flg outsi cle tRe Restr; cted Regi Ofl spec; f; ed ffi tt:le GOLR 'n'; tt:l tAe rGBB 1i fRi t flat reCfui roa to be fRet.
Wfrefl the "Setup" ';a1 ue ; s sel ected, ffieeti ftg the FCBB 1imi t provides protection agaiftst iftstability.
"Set" a"
S t" 1
up afl RaRe up va ues are selected by operator maNipulation of a Setup buttOfl 019 eaCM flo" cOfltrol trip refereftce cara.
Selectioft of the "Setup" value is iflteflcled only for planned operation ift the Restricted Regiofl as s~ecifiocl ifl the COLR.
Operation ifl tho Rostricted Region wlth the Average Power Raflge MOflitor Flow Biased Simulated The rffialP a'fter IIi 9M Fufl Ct i 0 fl "Sotup" reet uires t fI e FCBB limit to be mot and is flOt geflerally cOflsistel9t with 190rmal po',ier 0 perati aA
- The Average Power Raflge MOflitor Flow Biased Simulated Tho rfflalP0'ft' 0 r IIi 9h FUACti 0fl us 0satrip 1eve 1 9Cfl Cratcd ~
tho floio' cOfltrol trip refereftcc card based OM,ecirculation loop drive flow.
Proper trip level gefleration as a fUAction of dri ve flo 'h' reCfUire s cl ri ve flo 'v~ ali gflme19t.
This ; s 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 fUNctioNal relatioAship may vary over the core flow operatiflg raN~e.
These cRaNges caA result from botA graaual chal9ges iM recirculation system aRa core compONeNts over t~e reactor life time as well as s~ecific ffiaiRteflaNce performed on these components (e.g., jet pump cleal9ing).
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 designed to allow OAe chaAlgel il9 each trip system to be bypassecl.
AI9Y Ofle APRM chaflflel in a trip system eaft cause the associated
~rip system to trip.
Six cRaftnelsof Average Po 'n'erRaAge
~~ 0 191 tor Flo'h' Bi a5ccl Si mu1ated T19er ffialPowe r High with tMree chaftAels ift each trip system arranged in a (continued)
GRAND GULF B 3.3-9c LDC 98037
BASES to GNRO-2009-00054 Page 18 of 49 ARP 1 A9 E AF T4 AWAI-42-E& l APR CA --I
!T-Y E)i;e eut f
hr-e generating excessive THERMAL POWER and potentially exceeding
~PkMs ape 19eat Each APRM channel one total drive flow signal representative of total core flow.
1 W uni.
S n 1 P dFily,
-1Hew signal are generat d
\\VThe THERMAL POWER time constant transfer dynamics and provides THERMAL POWE The Average Power Range Monitor Flow Biased Si mul Thermal Power - High Function is required to be OPERABLE i MODE 1 when there is the possibility hYdr-au! 4c ilms abil lilty.
The petent4-al applicable to high pressure and core SL)
During MODES 2 and 5, OTHER IRM and APR protection for fuel cladding integrity.
GRAND GULF B 3.3-9d e :t a j w
RPS Instrumentation B 3.3.1.1 based on the fuel heat signal proportional to the n
INSERT G - New APRM Functions 2.e and 2J y eam unctions provide (conti need )
LDC 98037 to GNRO-2009-00054 Page 18 of 49 RPS Instrumentation B 3.3.1.1 BASES The THERMAL POWER time constant transfer dynamics and provides THERMAL POWER.
~
Average PO'hler RaFlge Monitor Flo'h' Biased Simulated Therffial POHer
- H-bth (conti nued)
LPRMs are located.
Each APRM channel drive flow signal representative of total recirculation loop drive flow signals are generated flo 'tJ units.
0ne flo 'h' Uflit fromeaeAreeireu1ation provided to each APRM chanFlel.
Total 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.
The Average Power Range Monitor Flow Biased Simulated Thermal Power - High Function is required to be OPERABLE in MODE 1 when there is the possibility of neutroftie/t~@rmal-hydraulic instability.
The potcfltial the SL applicable to high pressure and core fl w conditions CMCPR SL),
- y protect; 0,
~~~-+-+--FH~~TH-~~I-foIi+tTt-t--ftoIlHi-f''''~~~~'f't'"t-t-H" Y eaFI (5 eeU1
- and 5, OTHER IRM and APR Functions provide fuel cladding integrity.
APPLICABLE SAFETY A~I!\\LYSES,
~
i+l4 l\\PPlIG,A,E3 I lITY (continued)
GRAND GULF B 3.3-9d LDC 98037 to 0 NRO-2009-00054 Page 19 of 49 INSERT E The total drive flow signal is generated by the flow processing logic, part of the APRM/OPRM channel, but summing up the flow calculated from two flow transmitter signal inputs, one from each of the two recirculation loop flows. The flow processing logic OPERABILITY is part of the APRM/OPRM channel OPERABILITY requirements for this Function.
INSERT 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 G - New APRM Functions 2.e and 2J 2.e 2-Out-Of-4 Voter The 2-Out-Of-4 Voter Function provides the interface between the APRM Functions, including the OPRM Upscale Function, and the final RPS trip system logic. As such, it is required to be OPERABLE in the MODES where the APRM Functions are required and is necessary to support the safety analysis applicable to each of those Functions. Therefore, the 2-Out-Of-4 Voter Function must be OPERABLE in MODES 1 and 2.
All four voter channels are required to be OPERABLE. Each voter channel includes self-diagnostic functions.
If any voter channel detects a critical fault in its own processing, a trip is issued from that voter channel to the associated trip system.
The 2-Out-Of-4 Voter Function votes APRM Functions 2.a, 2.b, and 2.d independently of Function 2.f. The voter also includes separate outputs to RPS for the two independently voted sets of functions, each of which is redundant (four total outputs). The voter Function 2.e must be declared inoperable if any of its functionality is inoperable. However, due to the independent voting of APRM trips, and the redundancy of outputs, there may be conditions where the voter Function 2.e is inoperable, but trip capability for one or more of the other APRM Functions through that voter is still maintained. This may be considered when determining the condition of other APRM Functions resulting from partial inoperability of the Voter Function 2.e redundant (four total outputs). The voter Function 2.e must be declared inoperable if any of its functionality is inoperable. However, due to the independent voting of APRM trips, and the redundancy of outputs, there may be conditions where the voter Function 2.e is inoperable, but trip capability for one or more of the other APRM Functions through that voter is still maintained. This may be considered when determining the condition of other APRM Functions resulting from partial inoperability of the Voter Function 2.e.
There is no Allowable Value for this Function. to GNRO-2009-00054 Page 19 of 49 INSERT E The total drive flow signal is generated by the flow processing logic, part of the APRM/OPRM channel, but summing up the flow calculated from two flow transmitter signal inputs, one from each of the two recirculation loop flows.
The flow processing logic OPERABILITY is part of the APRM/OPRM channel OPERABILITY requirements for this Function.
INSERT F INSERT G - New APRM Functions 2.e and 2.f 2.e 2-0ut-Of-4 Voter The 2-0ut-Of-4 Voter Function provides the interface between the APRM Functions, including the OPRM Upscale Function, and the final RPS trip system logic. As such, it is required to be OPERABLE in the MODES where the APRM Functions are required and is necessary to support the safety analysis applicable to each of those Functions. Therefore, the 2-0ut-Of-4 Voter Function must be OPERABLE in MODES 1 and 2.
All four voter channels are required to be OPERABLE. Each voter channel includes self-diagnostic functions. If any voter channel detects a critical fault in its own processing, a trip is issued from that voter channel to the associated trip system.
The 2-0ut-Of-4 Voter Function votes APRM Functions 2.a, 2.b, and 2.d independently of Function 2.f. The voter also includes separate outputs to RPS for the two independently voted sets of functions, each of which is redundant (four total outputs). The voter Function 2.e must be declared inoperable if any of its functionality is inoperable. However, due to the independent voting of APRM trips, and the redundancy of outputs, there may be conditions where the voter Function 2.e is inoperable, but trip capability for one or more of the other APRM Functions through that voter is still maintained. This may be considered when determining the condition of other APRM Functions resulting from partial inoperability of the Voter Function 2.e redundant (four total outputs). The voter Function 2.e must be declared inoperable if any of its functionality is inoperable. However, due to the independent voting of APRM trips, and the redundancy of outputs, there may be conditions where the voter Function 2.e is inoperable, but trip capability for one or more of the other APRM Functions through that voter is still maintained. This may be considered when determining the condition of other APRM Functions resulting from partial inoperability of the Voter Function 2.e.
There is no Allowable Value for this Function.
to GNRO-2009-00054 Page 20 of 49 2.f.
Oscillation Power Range Monitor (OPRM) Upscale The OPRM Upscale Function provides compliance with GDC 10 and GDC 12, thereby providing protection from exceeding the fuel MCPR safety limit (SL) due to anticipated thermal-hydraulic power oscillations.
References 13 and 14 describe three algorithms for detecting thermal-hydraulic instability related neutron flux oscillations : (1) the Period-Based Detection algorithm ; (2) the Amplitude-Based algorithm ; and (3) the Growth-Rate algorithm. All three are implemented in the OPRM Upscale Function, but the safety analysis takes credit only for the Period-Based Detection algorithm. The remaining algorithms provide defense-in-depth and additional protection against unanticipated oscillations. OPRM Upscale Function OPERABILITY for Technical Specification purposes is based only on the Period-Based Detection algorithm. The Allowable Value for the OPRM Upscale Period-Based Detection algorithm is specified in the COLR.
The OPRM Upscale Function receives input signals from the local power range monitors (LPRMs}, which are combined into "cells" for evaluation by the OPRM algorithms.
The OPRM Upscale Function is required to be OPERABLE when the plant is at > 24% RTP, the region of power-flow operation where anticipated events could lead to thermal-hydraulic instability and related neutron flux oscillations. Within this region, the automatic trip is enabled when THERMAL POWER, as indicated by the APRM Simulated Thermal Power, is
> 29% RTP and reactor core flow, as indicated by recirculation drive flow, is < 60% of rated flow, the operating region where actual thermal-hydraulic oscillations may occur. The lower bound, 24% RTP, is chosen to provide margin in the unlikely event of loss of feedwater heating while the plant is operating below the 29% automatic OPRM Upscale trip enable point. Loss of feedwater heating is the only identified event that could cause reactor power to increase into the region of concern without operator action.
An OPRM Upscale trip is issued from an APRM/OPRM channel when the Period-Based Detection algorithm in that channel detects oscillatory changes in the neutron flux, indicated by the combined signals of the LPRM detectors in a cell, with period confirmations and relative cell amplitude exceeding specified setpoints. One or more cells in a channel exceeding the trip conditions will result in a channel trip. An OPRM Upscale trip is also issued from the channel if either the Growth-Rate or Amplitude-Based algorithms detect growing oscillatory changes in the neutron flux for one or more cells in that channel.
Three of the four channels are required to be OPERABLE. Each channel is capable of detecting thermal-hydraulic instabilities, by detecting the related neutron flux oscillations, and issuing a trip signal before the MCPR SL is exceeded.
There is no Allowable Value for this function. to GNRO-2009-00054 Page 20 of 49 2.f.
Oscillation Power Range Monitor (OPRM) Upscale The OPRM Upscale Function provides compliance with GDC 10 and GDC 12, thereby providing protection from exceeding the fuel MCPR safety limit (SL) due to anticipated thermal-hydraulic power oscillations.
References 13 and 14 describe three algorithms for detecting thermal-hydraulic instability related neutron flux oscillations: (1) the Period-Based Detection algorithm; (2) the Amplitude-Based algorithm; and (3) the Growth-Rate algorithm. All three are implemented in the OPRM Upscale Function, but the safety analysis takes credit only for the Period-Based Detection algorithm. The remaining algorithms provide defense-in-depth and additional protection against unanticipated oscillations. OPRM Upscale Function OPERABILITY for Technical Specification purposes is based only on the Period-Based Detection algorithm. The Allowable Value for the OPRM Upscale Period-Based Detection algorithm is specified in the COLR.
The OPRM Upscale Function receives input signals from the local power range monitors (LPRMs), which are combined into "cells" for evaluation by the OPRM algorithms.
The OPRM Upscale Function is required to be OPERABLE when the plant is at ~ 240/0 RTP, the region of power-flow operation where anticipated events could lead to thermal-hydraulic instability and related neutron flux oscillations. Within this region, the automatic trip is enabled when THERMAL POWER, as indicated by the APRM Simulated Thermal Power, is
~ 290/0 RTP and reactor core flow, as indicated by recirculation drive flow, is < 60%
of rated flow, the operating region where actual thermal-hydraulic oscillations may occur. The lower bound, 240/0 RTP, is chosen to provide margin in the unlikely event of loss of feedwater heating while the plant is operating below the 290/0 automatic OPRM Upscale trip enable point. Loss of feedwater heating is the only identified event that could cause reactor power to increase into the region of concern without operator action.
An OPRM Upscale trip is issued from an APRM/OPRM channel when the Period-Based Detection algorithm in that channel detects oscillatory changes in the neutron flux, indicated by the combined signals of the LPRM detectors in a cell, with period confirmations and relative cell amplitude exceeding specified setpoints. One or more cells in a channel exceeding the trip conditions will result in a channel trip. An OPRM Upscale trip is also issued from the channel if either the Growth-Rate or Amplitude-Based algorithms detect growing oscillatory changes in the neutron flux for one or more cells in that channel.
Three of the four channels are required to be OPERABLE. Each channel is capable of detecting thermal-hydraulic instabilities, by detecting the related neutron flux oscillations, and issuing a trip signal before the MCPR SL is exceeded.
There is no Allowable Value for this function.
to G N RC)-2009-00054 Page 21 of 49 BASES A.1 and A.2 B.1 and B.2 GRAND GULF 8 3.3-19 RPS Instrumentation B3.3-1-1 ACTIONS Times, specifies that once a Condition has been entered, (continued) subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result i n separate entry into the Condition.
Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Time entry into the Condition.
However, the Required Actions for inoperable RPS instrumentation channels provide appropriate compensatory measures for separate, inoperable channels.
As such, a Note has been provided that allows separate Condition entry for each inoperable RPS instrumentation channel.
Because of the di versi t of sensors available to provide trip signals and the r dundancy of the RPS design, an allowable out of serv e time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> has been shown to be acceptable {Ref. 9 to permit restoration of any inoperable channel to OPERABLE status.
However, this out of service time i s only acceptable provided the associated Function's inoperable channel i s i n one trip system and the Function still maintains RPS trip capability (refer to Required Actions B.1, B.2, and C.1 Bases.)
If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel or the associated trip system must be placed i n the tripped condition per Required Actions A.1 and A.2.
Placing the inoperable channel i n trip (or the associated trip system " i n trip) would conservatively compensate for the inoperability restore capability to accommodate a single failure, and allow operation to continue.
Alternately, if it is not desired to place the channel (or trip system in trip (e.g.,
as i n the case where placing the inoperable channel i n trip would result i n a full scram), Condition D must be entered and its Required Action taken.
Condition B exists when, for any one or more Functions, least one required channel i s inoperable i n each trip system.
In this condition, provided at least one channel Rev i s (continued) at on No. 0 to GNRO-2009-00054 Page 21 of 49 BASES ACTIONS (continued)
RPS Instrumentation B 3.3.1.1 Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition.
Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition.
However, the Required Actions for inoperable RPS instrumentation channels provide appropriate compensatory measures for separate, inoperable channels.
As such, a Note has been provided that allows separate Condition entry for each inoperable RPS instrumentation channel.
A.I and A.2 Because of the diversit a
sensors available to provide trip signals and the r ijundancy of the RPS design, an allowable out of serv e time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> has been shown to be acceptable (Ref. 9 to permit restoration of any inoperable channel to OPERABLE status.
However, this out of service time is only acceptable provided the associated Function's inoperable channel is in one trip system and the Function still maintains RPS trip capability (refer to Required Actions B.l, B.2, and e.l Bases.)
If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel or the associated trip system must be placed in the tripped condition per Required Actions A.l and A.2.
Placing the inoperable channel in trip (or the associated trip system';n trip) would conservatively compensate for the ;noperab1lity, restore capability to accommodate a single failure, and allow operation to continue.
Alternately, if it is not desired to place the channel (or trip system) in trip (e.g.,
as in the case where placing the inoperable channel in trip would result in a full scram), Condition 0 must be entered and its ReqUired Action taken.
B.1 and B.2 Condition B exists when, for anyone or more Functions, at least one required channel is inoperable in each trip system.
In this condition, provided at least one channel (continued)
GRAND GULF B 3.3-19 Revision No. 0 to GNRO-2009-00054 Page 22 of 49 INSERT H - Note Description As noted, Action A.2 is not applicable to APRM Functions 2.a, 2.b, 2.c, 2.d, or 2.f.
Inoperability of one required APRM/OPRM channel affects both trip systems. For that condition, Required Action A.1 must be satisfied, and is the only action (other than restoring OPERABILITY) that will restore capability to accommodate a single failure. Inoperability of more than one required APRM/OPRM channel of the same trip function results in loss of trip capability and entry into Condition C, as well as entry into Condition A for each channel. to GNRO-2009-00054 Page 22 of 49 INSERT H - Note Description As noted, Action A.2 is not applicable to APRM Functions 2.a, 2.b, 2.c, 2.d, or 2.f.
Inoperability of one required APRM/OPRM channel affects both trip systems. For that condition, Required Action A.1 must be satisfied, and is the only action (other than restoring OPERABILITY) that will restore capability to accommodate a single failure. Inoperabilityof more than one required APRM/OPRM channel of the same trip function results in loss of trip capability and entry into Condition C, as well as entry into Condition A for each channel.
to G N RO-2009-00054 Page 23 of 49 BASES ACTIONS per trip system is OPERABLE, the RPS still maintains trap capability for that Function, but cannot accommodate single failure i n either trip system.
equired Actions B.1 and 8.2 limit the time the RP sd logic for any Function would not accommodate singe failure i n both trip systems (e.g., one-out-of-one a one-out-of-one arrangement for a typical four annel Function)
The reduced reliability of this a i c arrangement was not evaluated in Reference 9 *for the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time.
Within the G hour allowance, the associated Function will have all required channels ei the OPERABLE or in trA-~in any combination) in one trip system 1 and 8.2 (continued)
RPS Instrumentation B3.3.1.1 Completing on of-5'ese Requ i red Actions restores RPS to equivalent liability level as that evaluated in Reference 9, which justified a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowable ou service time as presented in Condition A*
The trip system i n the more degraded state should be placed i n trip or, alternatively, all the inoperable channels i n that trip system should be placed i n trip (e.g., a trip system with two inoperable channels could be i n a more degraded state than a trip system with four inoperable channels, i f the two inoperable channels are i n the same Function while the four inoperable channels are all i n different Functions).
The decision as to which trip system is in the more degraded state should be based on prudent judgment and current plant conditions (i.e., what MODE the plant is in).
If this action would result i n a scram or rec i rcul ati on pump trip, i t i s permissible to place the other trip system or its inoperable channels i n trip.
The 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Completion Time is judged acceptable based on the remaining capability to trip, the diversity of the sensors available to provide the trip signals, the low probability of extensive numbers of i noperabi l i t i es affecting all diverse Functions, and the low probability of an event requiring the initiation of a scram.
Alternately, if it is not desired to place the inoperable channels (or one trip system) i n trip (e.g., as i n the case where placing the inoperable channel or associated trip GRAND GULF B 3.3-20 Revision No. 0 to GNRO-2009-00054 Page 23 of 49 RPS Instrumentation B 3.3.1.1 BASES B.1 and B.2 (continued) per trip system is OPERABLE, the RPS still maintains trip capability for that Function, but cannot accommodate
~~~~.~
slng1e failure in either trip system.
Required Actions B.1 and B.Z limit the time the RP sc logic for any Function would not accommodate sing e failure in both trip systems (e.g., one-out-of-one and one-out-of-one arrangement for a typical four annel Function).
The reduced reliability of this gic arrangement was not evaluated in Reference 9 or the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time.
Within the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowance, the associated Function will have all required channels either OPERABLE or in*
in any combination) in one trip system.
Completing on 0
nese Required Actions restores RPS to an equivalent liability level as that evaluated in Reference 9, which justified a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowable out of service time as presented in Condition A.
The trip system 1n the more degraded state should be placed 1n trip or, alternatively, all the inoperable channels in that trip system should be placed 1n trip (e.g., a trip system with two inoperable channels could be in a more degraded state than a trip system with four inoperable channels, if the two inoperable channels are in the same Function while the four inoperable channels are all in different Functions).
The decision as to which trip system is in the more degraded state should be based on prudent judgment and current plant conditions (1.e., what MODE the plant 1s in).
If this action would result in a scram or recirculation pump trip, it is permissible to place the other trip system or its inoperable channels 1n trip.
The 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Completion Time 1s judged acceptable based on the remaining capability to trip, the diversity of the sensors available to provide the trip s1gnals, the low probability of extensive numbers of inoperabilities affecting all diverse Functions, and the low probability of an event requiring the initiation of a scram.
Alternately, if it 1s not desired to place the inoperable channels (or one trip system) in trip (e.g., as 1n the case where placing the inoperable channel or associated trip ACTIONS (continued)
GRAND GULF B 3.3-20 Revision No. 0 to GNRO-2009-00054 Page 24 of 49 BASES ACTIONS 8.1 and B.2,
(continued) system in trip would result in a scram or RPT), -Condition D must be entered and its Required Action taken.
ed Action C.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, onus Aped channels within the same trip system for the same Function result in the Function not maintaining RPS trip capability.
A Function is considered to be maintaining RPS trip capability when sufficient channels are OPERABLE or in trip (or the associated trip system is in trip), such that both trip systems will generate a trip signal from the given Function on a valid signal.
Forthe typical Function with one-out-of-two taken twice logic and the IRM and APRM Functions, this would require both trip systems to have one channel OPERABLE or in trip (or the associated trip system in trip).
For Function 6 (Main Steam Isolation Valve-Closure), this would require both trip systems to have each channel associated with the MSIVs in three MSLs (not necessarily the same MSLs for both trip systems),
OPERABLE or in trip (or the associated trip system in trip).
For Function 9 (Turbine Stop Valve Closure, Trip Oil Pressure-Low), this would require both trip systems to have three channels, each OPERABLE or in trip (or the associated trip system in trip).
RPS Instrumentation B 3.3. 1.1 The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabi 1 i ties.
The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.
Required Action D.1 directs entry into the appropriate Condition referenced in Table 3.3.1.1-1.
The applicable Condition specified in the table is Function and MODE or other specified condition dependent and may change as th Required Action of a previous Conditiob is completed.
Each time an inoperable channel has not met any Required Action GRAND GULF B 3.3-21 Revision No. 0 to GNRO-2009-00054 Page 24 of 49 BASES ACTIONS RPS Instrumentation B 3.3.1.1 B.1 and B.2' (continued)
'Condition 0 Required Action e.l is intended to ensure that appropriate actions are taken if.ultiple, inoperable, untripped channels within the same trip system for the same Function result in the Function not maintaining RPS trip capability.
'A Function is considered to be maintaining RPS trip capability when sufficient channels are OPERABLE or in trip (or the associated trip system is in trip), such that both trip systems will g~nerate a trip s1gna1 from the given
- Function on a valid s1gna1.
For*the typical Function with one-out-of-two taken twice logic and the IRM and APRM Functions, this would require both trip systems to have one channel OPERABLE or in trip (or the associated trip system in trip).
For Function 6 (Main Steam Isolation Valve--Closure), this would require both trip systems to have each channel associated with the MSIVs in three MSLs (not necessarily the same MSLs for both trip systems),
OPERABLE or 1n trip (or the associated trip system in trip).
For Function 9 (Turbine Stop Valve Closure, Trip Oil Pressure--Low), this would require both trip systems to have three channels, each OPERABLE or in trip (or the associated trip system in trip).
The Completion Time 1s intended to allow the operator time to evaluate and repair any discovered inoperabilities.
The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.
D.l Required Action 0.1 directs entry into the appropriate Condition referenced in Table 3.3.1.1-1.
The applicable Condition specified in the table is Function and MODE or other specified condition dependent and may change as the Required Action of a previous Condition is completed.
Each time an inoperable channel has not met any Required Action (continued)
GRAND GULF B 3.3-21 Revision No. 0 to GNRO-2009-00054 Page 25 of 49 INSERT I - Note Description As noted, Condition B is not applicable to APRM Functions 2.a, 2.b, 2.c, 2.d, or 2.f.
Inoperability of one required APRM/OPRM channel affects both trip systems and is not associated with a specific trip system, as are the APRM 2-Out-Of-4 Voter and other non-APRM/OPRM channels for which Condition B applies. For an inoperable APRM/OPRM channel, Required Action A.1 must be satisfied, and is the only action (other than restoring OPERABILITY) that will restore capability to accommodate a single failure. Inoperability of more than one required APRM/OPRM channel of the same trip function results in loss of trip capability and entry into Condition C, as well as entry into Condition A for each channel.
Because Conditions A and C provide Required Actions that are appropriate for the inoperability of APRM Functions 2.a, 2.b, 2.c, 2.d, and 2.f, and these functions are not associated with specific trip systems as are the APRM 2-Out-Of-4 Voter and other non-APRM channels, Condition B does not apply. to GNRO-2009-00054 Page 25 of 49 INSERT I - Note Description As noted, Condition B is not applicable to APRM Functions 2.a, 2.b, 2.c, 2.d, or 2.f.
Inoperability of one required APRM/OPRM channel affects both trip systems and is not associated with a specific trip system, as are the APRM 2-0ut-Of-4 Voter and other non-APRM/OPRM channels for which Condition B applies. For an inoperable APRM/OPRM channel, Required Action A.1 must be satisfied, and is the only action (other than restoring OPERABILITY) that will restore capability to accommodate a single failure. Inoperabilityof more than one required APRM/OPRM channel of the same trip function results in loss of trip capability and entry into Condition C, as well as entry into Condition A for each channel.
Because Conditions A and C provide Required Actions that are appropriate for the inoperability of APRM Functions 2.a, 2.b, 2.c, 2.d, and 2.f, and these functions are not associated with specific trip systems as are the APRM 2-0ut-Of-4 Voter and other non-APRM channels, Condition B does not apply.
to GNR4-2009-00054 Page 26 of 49 BASES ACTIONS D.1 (continued)
INSERT J - New Required Actions J.1 and J.2 EQUIREMENTS of Condition A, B, or C, and the associated Completion Time has expired, Condition D will be entered for that channel and provides for transfer to the appropriate subsequent Condition.
If the channel (s) is not restored to OPERABLE 'status or placed in trip (or the associated trip system placed in trip) - within the allowed Completion Time, the plant must be placed in a MODE or other specified condition in which the LCO does not apply.
The Completion Times are reasonable based on operating experience, to reach the specified condition from full power conditions in an orderly manner and without challenging plant systems.
In addition, the Completion of Required en E.1 J S consistent with
'41.1%191
/ih LCO 3.2-.'2 "MINIMUM CRITICAL the Completio, Time provided POWER RATIO ( CPR)."
If the channel(s) is not restored to OPERABLE status placed in trip (or the associated trip system placed in trip) within the allowed Compl-etion Time, the plant must be placed in a MODE or other specified condition in which the LCO does not apply.
This is done by immediately initiating action to fully insert all insertable control rods in core cells containing one or more fuel assemblies.
Control rods in core cells containing no fuel assemblies do not affect the reactivity of the core and are, therefore, not required to be inserted.
Action must continue until all inoperable control rods in core cells containing one or more fuel a ssemblies are fully inserted.
Subsequently, if the manual scram channels are inoperable, the reactor mode switch is locked in the shutdown position to prevent inadvertent control rod withdrawal SURVEILLANCE As noted at the.begs nning of the S instrumentation Function are located Table 3.3.1.1-1.
GRAND GULF 8 3.3-22 RPS Instrumentation B 3.3.1.1 Revision SRs for each RPS the SRs column of (continued) to GNRO-2009-00054 Page 26 of 49 BASES RPS Instrumentation B 3.3.1.1 E.l, F.l, G.l, aRG H.l If the channel(s) is not restored to OPERABLE 'status or placed in trip (or the associated trip system placed in trip)' within the allowed Completion Time, the plant must be placed in a MODE or other specified condition in which the LeO does not apply.
The Completion Times are reasonable, based on operating experience, to reach the specified condition from full power conditions 1n an orderly manner and without challenging plant systems.
In addition, the Completion of Required' E.1 ts consistent with the Completio Time prOVided LeO 3.
"MINIMUM CRITICAL POWER RATIO ( CPR).-
1.1 If the channel(s) is not restored to OPERABLE status or placed in trip (or the associated trip system placed in trip) within the allowed Completion Time, the plant must be placed in a MODE or other specified condition in which the LCO does not apply.
This 1s done by immediately initiating action to fully insert all lnsertable control rods in core cells containing one or more fuel assemblies.
Control rods 1n core cells containing no fuel assemblies do not affect the reactivity of the core and are, therefore, not required to be inserted.
Action must continue until all insertable control rods in core cells containing one or more fuel assemblies are fully inserted.
Subsequently, if the manual scram channels are inoperable, the reactor mode switch is locked in the shutdown position to prevent ;nadvertent control rod withdrawals.
- 0.1 (continued) of Condition A, B, or C, and the associated Completion Time has expired, Condition Dwill be entered for that channel and provides for transfer to the appropriate subsequent Condition.
ACTIONS SURVEILLANCE REQUIREMENTS As noted at the beginning of the SRs, the SRs for each RPS instrulDentation Function 'are located in the SRs column of Tab1e 3.3*1*1-1..
(cont;nued)
GRAND GULF B 3.3-22 Revision No. 1 to GNRO-2009-00054 Page 27 of 49 INSERT J --New Reauired Actions J.1 and J.2 If OPRM Upscale trip capability is not maintained, Condition J exists. Reference 15 justified use of alternate methods to detect and suppress oscillations for a limited period of time. The alternate methods are procedurally established consistent with the guidelines identified in Reference 16 requiring manual operator action to scram the plant if certain predefined events r. The 12-hour allowed action time is based on engineering judgment to allow orderly transition to the alternate methods while limiting the period of time during which no automatic or alternate detect and suppress trip capability is formally in place. Based on the small probability of an instability event occurring at all, the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is judged to be reasonable.
J.2 The alternate method to detect and suppress oscillations implemented in accordance with J.1 was evaluated (Reference 15) based on use up to 120 days only. The evaluation, based on engineering judgment, concluded that the likelihood of an instability event that could not be adequately handled by the alternate methods during this 120-day period was negligibly small.
The 120-day period is intended to be an outside limit to allow for the case where design changes or extensive analysis might be required to understand or correct some unanticipated characteristic of the instability detection algorithms or equipment. This action is not intended and was not evaluated as a routine alternative to returning failed or inoperable equipment to OPERABLE status. Correction of routine equipment failure or inoperability is expected to normally be accomplished within the completion times allowed for Actions for Conditions A and B.
LCO 3.0.4.b is not applicable to J.2 to allow uni 120-day completion time.
re tart in the event of a shutdown during the to GNRO-2009-00054 Page 27 of 49 INSERT J - New Required Actions J.1 and J.2 If OPRM Upscale trip capability is not maintained, Condition J exists. Reference 15 justified use of alternate methods to detect and suppress oscillations for a limited period of time. The alternate methods are procedurally established consistent with the guidelines identified in Reference 16 requiring manual operator action to scram the plant if certain predefined events occur. The 12-hoUr allowed action time is based on engineering judgment to allow orderly transition to the alternate methods while limiting the period of time during which no automatic or alternate detect and suppress trip capability is formally in place. Based on the small probability of an instability event occurring at all, the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is judged to be reasonable.
The alternate method to detect and suppress oscillations implemented in accordance with J.1 was evaluated (Reference 15) based on use up to 120 days only. The evaluation, based on engineering judgment, concluded that the likelihood of an instability event that could not be adequately handled by the alternate methods during this 120-day period was negligibly small.
The 120-day period is intended to be an outside limit to allow for the case where design changes or extensive analysis might be required to understand or correct some unanticipated characteristic of the instability detection algorithms or equipment. This action is not intended and was not evaluated as a routine alternative to returning failed or inoperable equipment to OPERABLE status. Correction of routine equipment failure or inoperability is expected to normally be accomplished within the completion times allowed for Actions for Conditions A and B.
LCO 3.0.4.b is not applicable to J.2 to allow unit restart in the event of a shutdown during the 120-day completion time.
BASES to GNRO-2009-00054 Page 28 of 49 SURVEILLANCE REQUIREMENTS (continued)
The Surveillances are modified by a Note to indicate that, a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, provided the associated Function maintains trip capability.
Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowance, the channel must be LE status or the applicable Condition entered and Required Actions taken.
This Note is based on the RPS reliability analysis (Ref.
- 9) assumption of the average time required to perform channel surveillance.
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 not significantly reduce the probability that the RPS will trip when necessary RPS Instrumentation B 3.3. 1.1 Performance of the CHANNEL CHECK eAee evepy 12 houps ensures that a gross failure of instrumentation has not occurred.
CHANNEL CHECK is normally a comparison of the parameter icated on one channel to a similar parameter on other channels It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value.
Significant deviations between the instrument channels could be an indication of excessive instrument drift on one of the channels or something even more serious.
A CHANNEL CHECK will detect gross channel failure ; thus, it is key to verifying the strumentation continues to operate properly between each CHANNEL CALIBRATION Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability.
If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit.
The agreement criteria include an expectation of overlap when transitioning between neutron flux instrumentation.
The overlap between SRMs and IRMs must be demonstrated p to withdrawing SRMs from the fully inserted position since indication is being transitioned from SRMs to the IRMs This will ensure that reactor power will not be increased into a neutron flux region without adequate indication The (continued)
A GRAND GULF B 3.3-23 LDC 06007 to GNRO-2009-00054 Page 28 of 49 BASES SURVEILLANCE REQUIREMENTS (continued)
RPS Instrumentation B 3.3.1.1 The Surveillances are modified by a Note to indicate that, when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, provided the associated Function maintains trip capability.
Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken.
This Note is based on the RPS reliability analysis (Ref. 9) assumption of the average time required to perform channel surveillance.
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 does not significantly reduce the probability that the RPS will trip when necessary.~
~~
SR 3.3.1.1.1 Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ensures that a gross failure of instrumentation has not occurred.
A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels.
It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value.
Significant deviations between the instrument channels could be an indication of excessive instrument drift on one of the channels or something even more serious.
A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.
Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability.
If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit.
The agreement criteria include an expectation of overlap when transitioning between neutron flux instrumentation.
The overlap between SRMs and IRMs must be demonstrated prior to withdrawing SRMs from the fully inserted position since indication is being transitioned from SRMs to the IRMs.
This will ensure that reactor power will not be increased into a neutron flux region without adequate indication.
The (continued)
GRAND GULF B 3.3-23 LDC 06007 to GNRO-2009-00054 Page 29 of 49 SURVEILLANCE REQUIREMENTS overlap between IRMs and APRMs is of concern when reducing power into the IRM range.
On power increases, the system design will prevent further increases (by initiating a rod block) if adequate overlap is not.maintained.
IRMs and APR and APRMs concurrently have on-scale readings such that the transition between MODE I and MODE 2 can be made without either APRM downscale rod block, or IRM upscale rod block.
Overlap between SRMs and IRMs similarly exists when, prior to withdrawing the SR.Ms from the fully inserted position, IRMs are above 2140 on range 1 before SRMs have reached the upscale rod block.
If overlap for a group of channels is not demonstrated IRM/APRM overlap), the reason for the failure of the illance should be determined and the appropriate s) that are required in the current MODE or haul d be declared inoperable.
The Frequency is based upon operating experience that demonstrates channel failure is rare.
The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO.
E RPS Instrumentation B 3.3.1.1 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 GRAND GULF B 3.3-23a LDC 06007 1 to GNRO-2009-00054 Page 29 of 49 BASES SURVEILLANCE REQUIREMENTS RPS Instrumentation B 3.3.1.1 SR 3.3.1.1.1 overlap between IRMs and APRMs is of concern when reducing power into the IRM range.
On power increases, the system design will prevent further increases (by initiating a rod block) if adequate overlap is not.maintained.
Overlap between IRMs and APRMs exists when sufficient IRMs and APRMs concurrently have on-scale readings such that the transition between MODE 1 and MODE 2 can be made without either APRM downscale rod block, or IRM upscale rod block.
Overlap between SRMs and IRMs similarly exists when, prior to withdrawing the SRMs from the fully inserted position, IRMs are above 2/40 on range 1 before SRMs have reached the upscale rod block.
If overlap for a group of channels is not demonstrated (e.g.,
IRM/APRM overlap), the reason for the failure of the veillance should be determined and the appropriate chan l(s) that are required in the current MODE or conditl should be declared inoperable.
The Frequen is based upon operating experience that demonstrates channel failure is rare.
The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO.
(continued)
GRAND GULF B 3.3-23a LDC 06007,
to GNRO-2009-00054 Page 30 of 49 BASES SURVEILLANCE SR 3.3.1.1.10, SR 3.3.1.1.12 and SR 3.3.1.1.17 REQUIREMENTS (continued)
INSERT K -
Note Description for S R 3.3. 1. 1.10 INSERT L - Frequency of SR 3.3.1.1.10 Note 3 to SR 3.3.1.1.10 states that the APRM recirculation flow transmitters are excluded from CHANNEL CALIBRATION of Function 2.d, Average Power Range Monitor Flow Biased Simulated Thermal Power - High.
Calibration of the flow transmitters is performed on an 18-month frequency (SR 1
4: e -d 45 SIR 3 31 - 1 31 IQ, 5
~,. a t e s t, h a t, th le d
41 gi, t1a efflp neHts ef the f 1 ew eent Pei tp
,, -, --Pferrenee e RPS Instrumentation B 3.3.1.1 1141gh.
analog autput patent.i.-Affl-eteps A' the eanti, al tpip P f r nee eapd, ape net eamtl, al trip Peferemee eap.,"
an
. au'Eefflatie self t.
s-t-t"Me Ir"i'44la! a!
t-itQ 1
.1 1
- ~j -,
a m e n t--s Ex It s 1
lan of ti-s~imital eefflp W eentpe! tripv P feeeigee e Pd f Feffl cHANINE4--
.11 1
11.1 6-1 -A IL - I B R
-A T I e f F i m e 41: J.
m 122. di i s
~1:14 s
'd e
ig t1h, e e e i9d i t, i
-1 The Frequency of SR 3.3.1.1.12 and SR 3.3.1.1.17 is base upon the assumption of the magnitude of equipment drift in thd setpoint analysis.
s :~ a u 5 a s
e a ffl p a m e n t s m t 1:4 e I n g 44 e :t e
- t a s~
Cconti n-u-ed )
GRAND GULF B 3.3-27a LDC 98037 1 to GNRO-2009-00054 Page 30 of 49 BASES RPS Instrumentation B 3.3.1.1 SURVEILLANCE REQUIREMENTS SR 3.3.1.1.10, SR 3.3.1.1.12 and SR 3.3.1.1.17 (continued)
Note 3 to SR 3.3.1.1.10 sta,tes that the APRM recirculation flow transmitters are excluded from CHANNEL CALIBRATION of Function 2.d, Average Power Range Monitor Flow Biased Simulated Thermal Power - High.
Calibration of the flow transmitters is performed on an IS-month frequency (SR 3.3.1.1.17).
Note 4 to SR 3.3.1,1.10 states that the dig; tal coffIpoAeAts 0 f the flo~; coAt r 0 1 t rip referenee card are excluded froffl CIIAN~~EL CALIBRATION of Function 2.d, Average Power Range MOAitor Flow Biased Sifflulated Therfflal POiier IIi gh.
The aAalog output potent; offleters of the flo',,'
control trip refereAce card are AOt excluded.
The flow control trip refereAce card has aA 'autofflatic self test feature
'vv'h; ch peri ad i cally t ests the hardtv;are tv;hieh performs the digital algorithm.
ExclusioA of the digital cOfflpoAeAts of the flow cOAtrol trip reference card from CHANNEL CALIBRATION of FUAction 2.d is based on the conditions required to perforffl tMe test aAd the likelihood of a chaAge in the status of these components not being detected.
The Frequency of
, SR 3.3.1.1.12 and SR 3.3.1.1.17 is based u on the assumption of the magnitude of equipment drift in th setpoint analysis.
(continued)
GRAND GULF B 3.3-27a LDC 98037 to GNRO-2009-00054 Page 31 of 49 INSERT K - Note Description for SR 3.3.1.1.10 SR 3.3. 1. 1.10 for the designated function is modified by two Notes as identified in Table 3.3.1.1-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. The performance of these channels will be evaluated under the station's Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition to establish a reasonable expectation for continued OPERABILITY.
The second Note requires that the as-left setting for the channel be within the as-left tolerance of the Nominal Trip Setpoint (NTSP}. Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures, the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained.
If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable. The second Note also requires that NTSP and the methodologies for calculating the as-left and the as-found tolerances be in the Technical Requirements Manual.
INSERT L - Frec luency f SR 3.3.1.1.10 The Frequency of 24 months for SR 3.3. 1. 1.10 is based upon the justification provided in Reference 15. The only analog components involved with main signal processing are input isolation amplifiers (one per LPRM and one per flow input), a sample-and-hold circuit, and an analog-to-digital (AID} converter. These analog components are highly reliable and very stable with virtually no drift. In addition, the sample-and-hold circuit and AID converters are tested as part of the automatic self test.
The processing hardware for the APRM Functions is digital and has no drift. One of the most sensitive signals, the flow processing, is automatically compared between channels. Any digital failures will be identified by the automatic self-test, CHANNEL CHECK, or in very rare cases by the CHANNEL FUNCTIONAL TEST.
The automatic self-test includes steps that check the performance and accuracy of the sample and hold circuits and the AID converters, and the related processing. Self-test logic also periodically tests the input amplifiers and processing for accuracy. In addition, CHANNEL FUNCTIONAL TESTS include an automated "cal check" which will check the performance of all of the analog amplifiers and the entire processing loop.
The combined improvement justifies the factor-of-four increase in calibration interval, particularly in that the calibration will actually be checked at the CHANNEL FUNCTIONAL TEST and self-test frequencies. to GNRO-2009-00054 Page 31 of 49 INSERT K - Note Description for SR 3.3.1.1.10 SR 3.3.1.1.10 for the designated function is modified by two Notes as identified in Table 3.3.1.1-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. The performance of these channels will be evaluated under the station's Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition to establish a reasonable expectation for continued OPERABILITY.
The second Note requires that the as-left setting for the channel be within the as-left tolerance of the Nominal Trip Setpoint (NTSP). Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures, the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable. The second Note also requires that NTSP and the methodologies for calculating the as-left and the as-found tolerances be in the Technical Requirements Manual.
INSERT L - Frequency of SR 3.3.1.1.10 The Frequency of 24 months for SR 3.3.1.1.10 is based upon the justification provided in Reference 15. The only analog components involved with main signal processing are input isolation amplifiers (one per LPRM and one per flow input), a sample-and-hold circuit, and an analog-to-digital (AID) converter. These analog components are highly reliable and very stable with virtually no drift. In addition, the sample-and-hold circuit and AID converters are tested as part of the automatic self-test.
The processing hardware for the APRM Functions is digital and has no drift. One of the most sensitive signals, the flow processing, is automatically compared between channels. Any digital failures will be identified by the automatic self-test, CHANNEL CHECK, or in very rare cases by the CHANNEL FUNCTIONAL TEST.
The automatic self-test includes steps that check the performance and accuracy of the sample and hold circuits and the AID converters, and the related processing. Self-test logic also periodically tests the input amplifiers and processing for accuracy. In addition, CHANNEL FUNCTIONAL TESTS include an automated "cal check" which will check the performance of all of the analog amplifiers and the entire processing loop.
The combined improvement justifies the factor-of-four increase in calibration interval, particularly in that the calibration will actually be checked at the CHANNEL FUNCTIONAL TEST and self-test frequencies.
BASES to GNRO-2009-00054 Page 32 of 49 ILLANCE SR 3.3.1.1.15 (continued)
EQUIREMENTS ONSE TIME tests are conducted on an 18 month D TEST BASIS.
Note 3 requires STAGGERED TEST BASIS Frequency to be determined based on 4 channels per tri system, in lieu of the 8 channels specified in Table 3.3.1.1-1 for the MSIV Closure Function.
This Frequency is based on the logic interrelationship channels required to produce an RPS scram signal Therefore, staggered testing results in response time verification of these devices every 18 months.
This Frequency is consistent with the typical industry ref u cycle and is based upon plant operating experience, hat random failures of instrumentation components causing serious time degradation, but not channel fai are infrequent.
4 r-t 4-t generate TW I
R I
4-44 1 t -r G4 Peu,
11 +6 FAW 6 th e s 4 P d p a F a t F.
t r-4 9 i9et4 i9eutp
-r Fe,erenee aee 9
RPS Instrumentation B 3.3.1.1 am 1 eetraf4c 4~4 11 41:11--
1 n
si em a 4-.
ZI -
s 1
e t-k d I IV 5
19 W
I-P I-e, s e nt " 4 Y e F 1 a-t, 4 e n
~n 4 p I e ': w M e d trtfl aeetir y
(continued)
GRAND GULF B 3.3-29a LDC 98037 to GNRO-2009-00054 Page 32 of 49 BASES RPS Instrumentation B 3.3.1.1 SURVEILLANCE REQUIREMENTS SR 3.3.1.1.15 (continued)
RPS RESPONSE TIME tests are conducted on an 18 month STAGGERED TEST BASIS.
Note 3 requires STAGGERED TEST BASIS Frequency to be determined based on 4 channels per trip system, in lieu of the 8 channels specified in Table 3.3.1.1-1 for the MSIV Closure Function.
This Frequency is based on the logic interrelationships of the various channels required to produce an RPS scram signal.
Therefore, staggered testing results in response time verification of these devices every 18 months.
This Frequency is consistent with the typical industry refueling cycle and is based upon plant operating experience, which shows that random failures of instrumentation components causing serious time degradation, but not channel failure, 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 uses aA electroAic filter circuit to generate a signa~ proportional to tAc core THERMAL ~ froffi the APRM neutron ~ s;gAa1.
~
filter circuit is reprqsentative of the fuel heat tran~fer dynaFR; as that produce the rel ati oAshi p bet'yt'een the neutron
~ and the core T~ERMAL POWER.
The filter time COM5taMt
~ be verified to ensure tMat the chaAAcl is accurately reflecting the desired 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 the flo'., control tri preference card based or; tMe reci raul ati on 1cop dri'le =R-ew-.
The dri ve flo'h' i 5 adj usted by a digital algorithm according to selected ~ f+ew ali gnFAent dip 5in'i t ch 5et tin 95 *
+R4-s SR 5et 5 t t1e flo ~,
(continued)
GRAND GULF B 3.3-29a LDC 98037
BASES SURVEILLANCE REQUIREMENTS to GNRO-2009-00054 Page 33 of 49 EFERE CES GgHtrnp! tr-iiq i-ef i-eigee ear,~ to j 1 4 4-low pr-a--ba IV 444 t8bi.14Y eyen-t-.
ie PF queney ef enee kllawing
( e e 19 tv i 19 a 4)
INSERT M - New SRS 3.3.1.1.20, 3.3.1.1.21 3.3.1.1.22, and 3.3.1.1.23 UFSAR, Sec UFSAR, Section 6.3.3.
UFSAR, Section 15.4.1 Section 15.4.9.
GRAND GULF B 3.3-29b ensufle RPS Instrumentation B
.3.1. 1 I
23842, "Continuous Control Rod Withdrawal in the Startup Range," April 18, 1978.
(conti nued)
LDC 98037 to GNRO-2009-00054 Page 33 of 49 BASES RPS Instrumentation B 3.3.1.1 SURVEILLANCE REQUIREMENTS
~
3.3.1.1.18 (continued) control trip reference card to ensure tRe drive flow alignment used results in tAe appropriate trip level being generated froffi the digital cOffiponents of tRe card.
The Frequency of once followiR9 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\\,,' probabi 1i ty of a neutron; e/tRermal hydl aul i c instability event.
REFERENCES 1.
- UFSAR, Fi g 2.
UFSAR, Sec 3.
UFSAR, Section 6.3.3.
4.
UFSAR, Chapter 15.
5.
UFSAR, Section 15.4.1.
6.
NEDO-23842, "Continuous Control Rod Withdrawal in the Startup Range," April 18, 1978.
7.
UFSAR, Section 15.4.9.
(continued)
GRAND GULF B 3.3-29b LDC 98037 to GNRO-2009-00054 Page 34 of 49 INSERT M - New SRs 3.3.1.1.20, 3.3.1.1.21, 3.3.1.1.22, and 3.3.1.1.23 SR 3.3.1.1.20 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.
For the APRM Functions, this test supplements the automatic self-test functions that operate continuously in the APRM/OPRM and voter channels. The CHANNEL FUNCTIONAL TEST covers the APRM/OPRM channels (including recirculation flow processing -- applicable to Function 2.b only), the 2-Out-Of-4 Voter channels, and the interface connections into the RPS trip systems from the voter channels. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.
The 184 day Frequency of SR 3.3.1.1.20 is on the reliability analysis of Reference 15.
(NOTE : Actual voting logic of the 2-Out-Of-4 Voter Function is as part of SR 3.3.1.1.21.)
Note 1 is provided for APRM Function 2.a that requires this SR to be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of entering MODE 2 from MODE 1. Testing of the MODE 2 APRM Function cannot be performed in MODE 1 without utilizing jumpers or lifted leads. This Note allows entry into MODE 2 from MODE 1 if the associated Frequency is not met per SR 3.0.2.
Note 2 is provided for APRM Functions 2.a, 2.b, and 2.c to clarify that the APRM/OPRM channels and 2-Out-Of-4 Voter channels are included in the CHANNEL FUNCTIONAL TEST.
Note 3 is provided for APRM Functions 2.d and 2.f to clarify that the APRM/OPRM channels and the 2-Out-Of-4 Voter channels plus the flow input function, excluding the flow transmitters, are included in the CHANNEL FUNCTIONAL TEST.
SR 3.3.1.1.21 The LOGIC SYSTEM FUNCTIONAL TEST for APRM Function 2.e simulates APRM and OPRM trip conditions at the 2-Out-Of-4 Voter channel inputs to check all combinations of two tripped inputs to the 2-out-of-4 logic in the voter channels and APRM-related redundant RIPS relays. The test is only required to include the voting logic of the 2-Out-Of-4 Voter channels and RPS-relays not tested as part of the CHANNEL FUNCTIONAL TEST.
SR 3.3.1.1.22 The 24-month Frequency is based on the justification that virtually all of the equipment is tested by the CHANNEL FUNCTIONAL TESTS. The periodic LPRM calibrations (every 2000 full power hours) provide an indirect test of LPRM interfaces including detectors. The design of the equipment allows virtually all testing and routine adjustments to be performed with no changes to the configuration (e.g., no disconnecting wires), so the risk of problems caused by the normal operation of the system is greatly reduced.
This SR ensures that the individual channel response times for Function 2.e are less than or equal to the maximum values assumed in the accident analysis. This test may be performed in one measurement or in overlapping segments, with verification that all associated components are tested. The RPS RESPONSE TIME acceptance criteria are included in the applicable plant procedures. to GNRO-2009-00054 Page 34 of 49 INSERT M - New SRs 3.3.1.1.20,3.3.1.1.21,3.3.1.1.22, and 3.3.1.1.23 SR 3.3.1.1.20 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.
For the APRM Functions, this test supplements the automatic self-test functions that operate continuously in the APRM/OPRM and voter channels. The CHANNEL FUNCTIONAL TEST covers the APRM/OPRM channels (including recirculation flow processing -- applicable to Function 2.b only), the 2-0ut-Of-4 Voter channels, and the interface connections into the RPS trip systems from the voter channels. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.
The 184 day Frequency of SR 3.3.1.1.20 is on the reliability analysis of Reference 15.
(NOTE: Actual voting logic of the 2-0ut-Of-4 Voter Function is as part of SR 3.3.1.1.21.)
Note 1 is provided for APRM Function 2.a that requires this SR to be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of entering MODE 2 from MODE 1. Testing of the MODE 2 APRM Function cannot be performed in MODE 1 without utilizing jumpers or lifted leads. This Note allows entry into MODE 2 from MODE 1 if the associated Frequency is not met per SR 3.0.2.
Note 2 is provided for APRM Functions 2.a, 2.b, and 2.c to clarify that the APRM/OPRM channels and 2-0ut-Of-4 Voter channels are included in the CHANNEL FUNCTIONAL TEST.
Note 3 is provided for APRM Functions 2.d and 2.f to clarify that the APRM/OPRM channels and the 2-0ut-Of-4 Voter channels plus the flow input function, excluding the flow transmitters, are included in the CHANNEL FUNCTIONAL TEST.
SR 3.3.1.1.21 The LOGIC SYSTEM FUNCTIONAL TEST for APRM Function 2.e simulates APRM and OPRM trip conditions at the 2-0ut-Of-4 Voter channel inputs to check all combinations of two tripped inputs to the 2-out-of-4 logic in the voter channels and APRM-related redundant RPS relays. The test is only required to include the voting logic of the 2-0ut-Of-4 Voter channels and RPS' relays not tested as part of the CHANNEL FUNCTIONAL TEST.
The 24-month Frequency is based on the justification that virtually all of the equipment is tested by the CHANNEL FUNCTIONAL TESTS. The periodic LPRM calibrations (every 2000 full power hours) provide an indirect test of LPRM interfaces including detectors. The design of the equipment allows virtually all testing and routine adjustments to be performed with no changes to the configuration (e.g., no disconnecting wires), so the risk of problems caused by the normal operation of the system is greatly reduced.
SR 3.3.1.1.22 This SR ensures that the individual channel response times for Function 2.e are less than or equal to the maximum values assumed in the accident analysis. This test may be performed in one measurement or in overlapping segments, with verification that all associated components are tested. The RPS RESPONSE TIME acceptance criteria are included in the applicable plant procedures.
to GNRO-2009-00054 Page 35 of 49 RPS RESPONSE TIME for the APRM 2-Out-Of-4 Voter Function 2.e includes the output relays of the voter and the associated RPS relays and contactors. (The digital portion of the APRM and 2-Out-Of-4 Voter channels are excluded from RPS RESPONSE TIME testing because self-testing and calibration checks the time base of the digital electronics.
Confirmation of the time base is adequate to assure required response times are met.
Neutron detectors are excluded from RPS RESPONSE TIME testing because the principles of detector operation virtually ensure an instantaneous response time.)
APRM and OPRM RESPONSE TIME tests are conducted on a 24 month STAGGERED TEST BASIS. The Note requires the STAGGERED TEST BASIS to be determined based on 4 channels of APRM outputs and 4 channels of OPRM outputs, (total "n" = 8) being tested on an alternating basis. This allows the STAGGERED TEST BASIS Frequency for Function 2.e to be determined based on 8 channels rather than the 4 actual 2-Out-Of-4 Voter channels.
The redundant outputs from the 2-Out-Of-4 Voter channel (2 for APRM trips and 2 for OPRM trips) are considered part of the same channel, but the OPRM and APRM outputs are considered to be separate channels for application of SR 3.3.1.1.22, so "n" = 8. The note further requires that testing of OPRM and APRM outputs from a 2-Out-Of-4 Voter be alternated. In addition to these commitments, Reference 15 require that the testing of inputs to each RPS Trip System alternat SR 3.3.1.1.23 a.
Tests each RPS trip system interface every other cycle, Alternates between divisions at least every other test cycle.
Combining these frequency requirements, an acceptable test sequence is one that :
b.
Alternates testing APRM and OPRM outputs from any specific 2-Out-Of-4 Voter channel, and Each test of an APRM or OPRM output tests each of the redundant outputs from the 2-Out-Of-4 Voter channel for that Function and each of the corresponding relays in the RPS.
Consequently, each of the RPS relays is tested every fourth cycle. The RPS relay testing frequency is twice the frequency justified by Reference 15.
This SR ensures that scrams initiated from OPRM Upscale Function 2.f will not be inadvertently bypassed when THERMAL POWER, as indicated by the APRM Simulated Thermal Power is greater than or equal to 29% RTP and core flow as indicated by recirculation drive flow is less than 60% rated flow. This normally involves confirming the bypass setpoints. Adequate margins for the instrument setpoint methodologies are incorporated into the actual setpoint. The actual surveillance ensures that the OPRM Upscale Function is enabled (not bypassed) for the correct values of APRM Simulated Thermal Power and recirculation drive flow. Other surveillances ensure that the APRM Simulated Thermal Power and recirculation flow properly correlate with THERMAL POWER and core flow, respectively.
If any bypass setpoint is non-conservative (i.e., the OPRM Upscale function is bypassed when APRM Simulated Thermal Power is greater than or equal 29% RTP and recirculation drive flow is less than 60% of rated flow), then the affected channel is considered inoperable for the OPRM Upscale function. Alternatively, the bypass setpoint may be adjusted to place to GNRO-2009-00054 Page 35 of 49 RPS RESPONSE TIME for the APRM 2-0ut-Of-4 Voter Function 2.e includes the output relays of the voter and the associated RPS relays and contactors. (The digital portion of the APRM and 2-0ut-Of-4 Voter channels are excluded from RPS RESPONSE TIME testing because self-testing and calibration checks the time base of the digital electronics.
Confirmation of the time base is adequate to assure required response times are met.
Neutron detectors are excluded from RPS RESPONSE TIME testing because the principles of detector operation virtually ensure an instantaneous response time.)
APRM and OPRM RESPONSE TIME tests are conducted on a 24 month STAGGERED TEST BASIS. The Note requires the STAGGERED TEST BASIS to be determined based on 4 channels of APRM outputs and 4 channels of OPRM outputs, (total "n" = 8) being tested on an alternating basis. This allows the STAGGERED TEST BASIS Frequency for Function 2.e to be determined based on 8 channels rather than the 4 actual 2-0ut-Of-4 Voter channels.
The redundant outputs from the 2-0ut-Of-4 Voter channel (2 for APRM trips and 2 for OPRM trips) are considered part of the same channel, but the OPRM and APRM outputs are considered to be separate channels for application of SR 3.3.1.1.22, so "n" = 8. The note further requires that testing of OPRM and APRM outputs from a 2-0ut-Of-4 Voter be alternated. In addition to these commitments, Reference 15 require that the testing of inputs to each RPS Trip System alternate.
Combining these frequency requirements, an acceptable test sequence is one that:
a.
Tests each RPS trip system interface every other cycle, b.
Alternates testing APRM and OPRM outputs from any specific 2-0ut-Of-4 Voter channel, and c.
Alternates between divisions at least every other test cycle.
Each test of an APRM or OPRM output tests each of the redundant outputs from the 2-0ut-Of-4 Voter channel for that Function and each of the corresponding relays in the RPS.
Consequently, each of the RPS relays is tested every fourth cycle. The RPS relay testing frequency is twice the frequency justified by Reference 15.
SR 3.3.1.1.23 This SR ensures that scrams initiated from OPRM Upscale Function 2.f will not be inadvertently bypassed when THERMAL POWER, as indicated by the APRM Simulated Thermal Power is greater than or equal to 29% RTP and core flow as indicated by recirculation drive flow is less than 600k rated flow. This normally involves confirming the bypass setpoints. Adequate margins for the instrument setpoint methodologies are incorporated into the actual setpoint. The actual surveillance ensures that the OPRM Upscale Function is enabled (not bypassed) for the correct values of APRM Simulated Thermal Power and recirculation drive flow. Other surveillances ensure that the APRM Simulated Thermal Power and recirculation flow properly correlate with THERMAL POWER and core flow, respectively.
If any bypass setpoint is non-conservative (Le., the OPRM Upscale function is bypassed when APRM Simulated Thermal Power is greater than or equal 29%
RTP and recirculation drive flow is less than 600/0 of rated flow), then the affected channel is considered inoperable for the OPRM Upscale function. Alternatively, the bypass setpoint may be adjusted to place to GNRO-2009-00054 Page 36 of 49 the channel in a conservative condition (non-bypassed). If placed in "non-bypassed," this SR is met and the channel is considered OPERABLE.
The Frequency of once every 24 months is based on engineering judgment recognizing that the actual values are stored digitally, so there is no drift, and that any hardware failures that ffect these setpoints will most likely be detected by the automatic self-test function. to GNRO-2009-00054 Page 36 of 49 the channel in a conservative condition (non-bypassed). If placed in "non-bypassed," this SR is met and the channel is considered OPERABLE.
The Frequency of once every 24 months is based on engineering judgment recognizing that the actual values are stored digitally, so there is no drift, and that any hardware failures that affect these setpoints will most likely be detected by the automatic self-test function.
BASES to GNRO-2009-00054 Page 37 of 49 REFERENCES Letter, P. Check (NRC) to G. Lamas (NRC), "
(continued)
Scram Discharge System Safety Evaluation,"
December 1, 1980, as attached to NRC Generic Letter dated December 9, 1980.
11.
GNRI-97/00181, Amendment 133 to the Operating RPS Instrumentation B 3.3.1.1 NEDO-30851-P-A, "Technical Specification Improvement Analyses for BWR Reactor Protection System,"
Mar 10.
NEDO-32291-A, System Analyses for Elimination of Selected Response Time Testing Requirements," October 1995.
12.
NEDO-32339-A, "Long Term Stability Solution Enhanced Option I-A GRAND GULF B 3.3-30 LDC 98031 13. NEDO-31960-P-A, "BWR Owners' Group Long-Term Stability Solution Licensing Methodology," and Supplement 1.
14. NEDO-32465-P-A, "BWR Owners' Group Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications" 15. NEDC-3241 O-P-A, "Nuclear Measurement Analysis and Control -
Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," Vols 1 and 2, and Supplement 1 16. BWR Owners' Group Letter, L. A. England to the NRC, M. J. Virgilio, "BWR Owners' Group Guidelines for Stability Interim Corrective Action,"
June 6, 1994
- 17. TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions" to GNRO-2009-00054 Page 37 of 49 BASES RPS Instrumentation B 3.3.
1.1 REFERENCES
(continued) 8.
Letter, P. Check (NRC) to G. Lainas (NRC),
"BWR Scram Discharge System Safety Evaluation,"
December 1, 1980, as attached to NRC Generic Letter dated December 9, 1980.
9.
NEDO-30851-P-A, "Technical Specification Improvement Analyses for BWR Reactor Protection System,"
March 1988.
10.
NEDO-32291-A, "System Analyses for Elimination of Selected Response Time Testing Requirements," October 1995.
11.
GNRI-97/00181, Amendment 133 to the Operating License.
12.
NEDO-32339-A, "Long Term Stability Solution: Enhanced Option I-A."
- 13. NEDO-31960-P-A, "BWR Owners' Group Long-Term Stability Solution Licensing Methodology," and Supplement 1.
- 14. NEDO-32465-P-A, "BWR Owners' Group Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications"
- 15. NEDC-32410-P-A, "Nuclear Measurement Analysis and Control -
Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," Vols 1and 2, and Supplement 1
- 16. BWR Owners' Group Letter, L. A. England to the NRC, M. J. Virgilio, "BWR Owners' Group Guidelines for Stability Interim Corrective Action,"
June 6, 1994 TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions" GRAND GULF B 3.3-30 LDC 98037 to GNRO-2009-00054 Page 38 of 49 B 3.3 INSTRUMENTATION B 3.3. 1
. 3
-8 A rl-W., G R '9 lvl ~D GRAND GULF 4' 4.
I ty p
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1 A e. I r ads 0 Bases for 2.3
.3
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1 ic 4msta,614 14 try.
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- - - 4. 1- - - -
.. 4. - -
1~1
-C "I U7, i C 4-t t f-eatui TH s if-test to GNRO-2009-00054 Page 38 of 49 B 3.3 INSTRUMENTATION B 3.3.1.3 P@rio6 Based D@tection System (PODS) i A:5t r Uffiet9tation 1Aoo+f......tF-fh;w;e............~~~-f¥I-Ao~F-A-f~
of ttriO CRBFlFH!l g"
~Eaiiit-fc-"h~~~lii?r---+'~"""'-~~~
GRAND GULF B 3.3-39a LOG 98037 to G N RO-2009-00054 Page 39 of 49 BACK
__PQ_ I-IND GRAN t 1 -e s R
ee.
rn nr t
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4, ed to GNRO-2009-00054 Page 39 of 49
~
B 3.3.1.3 8ACl<GgOUND (continblQQ) fblncti ons are executed duri ng tft.e4-r allocated port; on of tfle QXQcbltive lGGp sequence.
Any self test failure iAdieati~g lo~~ of critical function results in a eontro1 rOOffl alarm.
ThQ inopQrable condition is also displayed by an iAdicati~g light on the card front panel.
A manually initiated intQrnil tQ£t 6equence can be actuated via a recessed ~
b'tttQn.
~ internal test consists 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 Regi 0 i9
- Peri 0die
~~~~~~~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.
Actuation of the the Restricted Region aAd the the prese~ee of a source core and are not iAdicatioAs ef
~~~~~~~~~~~licinstability.
APPlICAalE SAFETY ANALYSES contrQ~
appl i ed
+-I.~~i...-fII.~~~~
3 2.4, "Fraction Q~tibli~hQd to prevent inatability d~ring OpQrstion
~.~~~~~~
inatability ~
~ analyzed
.. ~~~;w;;u.;:.
spQcificilly evaluated tQmpQratYre decrease inatability.
(continued)
LOG 98037
ADDl I
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Q r-Q Q Q ::Z :7 "j", Illv" to GNRO-2009-00054 Page 40 of 49 P-&&5 B 3.3.1.3 BASES APPLICABLE SAFETY ANALYSES (continu@d)
TAe i~itial co~ditiot9s a53um@d i~ tRe analysis ~
reasonably conservative a~d tRe immediate post eveAt reactor cOt9ditions are sigAificantly stable.
Ilowever, ~ assuffied iAitial conditions do not bound @acR individual paraffieter
~ impacts stability performance (Ref. 1.).
TAe PBDS iAstrumet9tation provides t~e operator ~ aft iAdieation tRat conditions consistent ~ a
~;gnificant degradation
+ft tAe stability performance of the reactor ~ Ras occurred aAd tRe potential for imffiinent ~ of tgeutrot9ic/tRermal-Rydraulic instability ffiay exist.
SUCR cORditioAS are only postulated to result from events it9itiated ~ iAitia1 cOAditiot9s beyot9d the eot9ditions assumed in tRe safety aAalysis (refer to Section 4, Ref. 1).
f+:te PODS Iii Iii ~
setpoint of 2 ffiot9itored LPRMs with 11 or more successive confirmation counts is 3elected to provide adequate indication of degraded stability p@rformat9ce (refer ~
Section 5, Ref. 1).
LOG 98037 (eoJ9tiMued)
~~~~~~~~~~~~~*~n cAaRnels
~
operation iM either ~
~~~~~~~d Region 3peeified it9 tRe A-R-t1iil~F-"+-A-n ~ the PODS tli Iii DR Al arm e-f
~~~~I'I++Ff~~F-="l-f'\\n eM6Mt,el
-;:s not allo'Qiied i-n One PODS chantgel
~~~~~~
reactor tgeutton requires reactor is not actuated TRe PODS Ras no at9d is not a3suffied
~
fUAction during
~
accide~t or traR5ie~t a~ a1y 5 is.
II 0 'vfetv er, i"-A-t1il--footr++~"'H'I+'H+-+-Ft-fiil-S the 0191 Y i ~di cation erf the i mmi ~ ent ~
Ao=F---I=HilH+=F'-t'I-A~~r:-FHi~t-P\\-f-~lrf'-R-lI~1i c i~stability during n in regions of the operating domain potentially to instability.
TRerefore, the PODS is included
- 1 Speeificatio~s.
APPLICABILITY to GNRO-2009-00054 Page 41 of 49 p L -I C A -B -I L I-T Y R@ tpiGt d Rea' i n p d R p Q a o4p,&
l e r
.1 y (r-fp-r t t4+e 94 R e4.
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tr-irt d R alQ, ARRM FIQW eia d
a-MQ-tQ th P Q a_ G W-Y T kQ M iqit r-d 1 ~4 + ;@ I ly ono 4ps FiAR4 pt n ehann RRf1C Up n ehann i--, t her n in th Se ~~~~-,
4 n-Hewe yep that ape Ret 4
Up ea nt.pel t t n t e r 4 r b e a n dT-H-y f
4te eentp@14ed ap on t h s t s a r-e 4-k
~~ ~9!
tei-iiis ef th efflal, d
pei-ati, ein e
~y Mffl-a Red 6y e bi t "-n de~ t fflem i4lered 15-Y a+ to GNRO-2009-00054 Page 41 of 49 APPLICABILITY (cQntinuid) thQ gQatrictQd Region or the
~onitored Region.
Operation
~
~ rQgions i~
~Ysceptible to instability (refer to the Bases for lCO 3,2.4 and Section 4 of Ref. 1).
OP[RABILITY of it lQa~t one PBDS instru~entation channe~
and operation hi; th no i ndi cati on of a PBDS f:fi f:fi DR /\\1 aPAl froFA aAy QPtRA8lE P~QS instrYmentation channe~ is therefore required during operition in these regions.
this LeO is f.TO'We'f' and,core
~Jeutron ~ - Upscal e COFitrol fte.ej
~~~~~" the applicable setpoints used to to the interior bouFldary of the con t ra11ed ope ration \\,'itA i n tfl.e the setpoi nt s are "Setup" tfl.e
~~~y remains defined by the norffia~
~ - Upscale Control Rod Block When thQ APRM Block
~etpoints genQrite RQ~triGted Ro,tricted Re~tricted Region
~ Flo\\t' Bi iGed setpointg..
PiraR-leters the reactor controls, confirR-lition rQsaonably The Monitored Region
~*~~~~~~~~
analytically established
~
However, unlike MonitorQd Region boundar
~ instrYmentation B 3.3 39d LOG 98037 to GNRO-2009-00054 Page 42 of 49 M
4: V., A.
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r a ~ -.6. y d 1, - A l.
- I, i C t e*
lic I'MM itabi llity at a r f-5tilt 0-f FM u 5 15--e
.4 N to GNRO-2009-00054 Page 42 of 49 P-&&S B 3.3.1.3 APPLICABILITY (cofltiflu@a)
ACTIONS re~ ion efltry.
Tt=Iere f 0 Ie, t t=I@ ~1 0 fl itored Region b0 Ufl clary t-s-clefi fled i fl terms of tt=lermB~ ~ ilrlG cere fl O*ut.
+fl-e
~~ofli tored Region bounclal Y for tlt=li 5 LCO AJ:)~l i cabi 1i ty +-s-specified ift tMe COLR.
Operation outgide the Restricted Region afld the
~10flitored Region is flot susce~tible to fleutroflic/tM@fmal Ryclraulic instability @ven und@r extreme postulated eOflditiofls.
to tRc 8.1 Bfld B.2 Flow Siaged Simulated TM@rmBl P-o-we-r to LCO 3.3.1.1, ~ 3.3.1.1 1,
~~~~~~~~.~ tRe gtability cOrltrol applied (r@f@r to LCO 3.2.4) to b@ met.
~~~~~n ~ tRc stability cOfltlo1 met reactor tRermal Ayclraulic
~~~*~n iM tt=le R@stlieted Regiofl.
~
~~~~~~
ifloperabl@, tRc ability to mOflitor 1F-f'Hii---F\\'~~;;...;;r.-ftol for i mmi I., ertt
(; fl set of fHiI-t+F-f~~+-'fi-tI'TfiPtl~-+--~~rH1i c i fI Stab i 1i t y agare3 u1t of TRerefore, action ~ &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)
B 3.3 3ge LOG 9S837 to GNRO-2009-00054 Page 43 of 49 reaete-r e fl i:AI to 0 f5 t a-rt s
I I IdA s am ae at, p I a m A VS /S a etor e a M trtr~
eemsi 5temt
+9-f to e
54-fl d
efts u M st e
a eampiy te d e Rl e fit 4 ete i eted r-4mul a :~ d T6 rffla-1 Pow Ij I I - 1 1 MI'14, eatel umeamtr ed eem 1 5 :41 mt M. e-M:': r d "ti-s wlq 4, ty d
a I +d
~~~'t ~~-
a e a e+tw a vidl a w -) a r 4:6e Q S:~p4pi:-
ixe g ivig. to GNRO-2009-00054 Page 43 of 49 P-B-8-5 8 3.3.1.3 ACTIO~~S B+eek setpoil9ts are "Setup," operation il9 the Restricted RegioM may be cOMfirmed by use of plaMt parameters such as reactor ~ aNG core fl e(,,4 a'Ite; 1ebl e at the reactor col'ttrols.
Region caR be accomplished by c019trol
- n flow i19creases.
Actiol'ts
~~~--f'I-j~~+H-~.~n 100p, iti t 19 cl raw eo 19 t r 01 r-e-eJ-s may result il9 uRstable reactor to be used to 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++e b-a-s-e-J 0 fI the +ew
~ roba19i 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 S1 mul at@d Tlgermal flo-we-r Iii SI9 FUMcti on.
Operati on ; r; the Restri eted RegioR without Flow Biased Simulated Thermal flo-we-r Iii 919 FUflcti on "
, i Mdi cates uflcofltroll ed ~ i-ft-t:.e trte Restri cted Re§i Ofl..
U"corltroll ed efl-t-f-:y i 5 COM!; stent vi; tR tf:le occurreMce d traMS; erlts, WRi eM, ffi combil9ation of stability col'ttrols ~ met may result degradation of stability performal'tce.
~~I, @M t fle APR~1 Flux Up !5eale Cont t 01 Rod 810ck setpoi I,ts
~il---A~~~~" uflcontroll ed efl-t-f-:y ~
the Restricted R@gion d by reeei~t of a valid
~
Iffiffiediate n ~ RREA is valid ~
iRdicates afl actual iMto the Re3trieted R@gion ma) be performed ffitrtout Immecliate eOflfirmation cOMstitutes observation that
~lal'tt
~arameters iffifflediately available
~
t~@ r@aetor eontrols
.., r@actor ~ and eore flow~ ~
reasoRa19ly cOflsistel'tt efl-t-f-:y iflto t~e Restricted Region.
B 3.3 39f LOG 98037 to GNR4-2009-00054 Page 44 of 49 9
T-I Q4LS'z ilm-Ffl-iate that plant papaffletl-ers ape rapi,dly 4
1, 4-4 4- -
4 - N
-A, 4 Peasenably Fesu H t i 19 H
.,4 est and I
4 in h
Meni.teppd indi,eatien th Men; -mod Hyar-auii I
to fflpni :~
-p 4 q! aiqlq e r-e a s c:-,-
r-u 1 t 19til e e n id ilt. -*. -
I s s
"-d 14, e 'E. il e ft.
e h ee-~
p -A '.: ent. 4 a 1 I i c i. m s :
I
. a b 4 14. '.-- y 4
-5 r
u i F e o d A t il e n 2 F e q u i i--~
Ffl ffl e reaeter sepa-ffl-.
-D IQ,
-A 1 -a-m e r a v il dl st a 11-1 4-4 a M fs et d+
Rl e n -t y e p 9 9--a e
n Moverab:H I-fil-d me to GNRO-2009-00054 Page 44 of 49 P-BB£ 8 3.3.1.3 ACTIONS B.1 and B.2 (continued)
~ iffifficdiate confirmation may also constitute recognition that plant paraffieters are rapidly changing during fr transient (e.g., a recirculation pump trip~ ~ ~
reasonably result in entry into the Restricted Region.
~or uncontrolled ~ into the Restricted Region w+tfl tft required PBDS instrumentation channei inoperable, tft abilit~ to ffionitor conditions indicating the potential
~
iffiffiinent ~ of neutronic/thermal hydraulic instability ~
lost and continued operation is not justified.
Therefore, Required Action B.2 requires immediate reactor scram.
In the Monitored Region Hi Hi DR Alarm provides indication of degraded performance.
Operation
~
the Moni tored Regi on
~.~M::t'5'ee-~t-t:rte to neutrot9i c/tt1ermal-hydraulic instability postulated conditions exceeding t-h-e-s-e previ 0 Usly the saf ety ana1:)'sis.
W+-tfl tft required PBDS channel
, the ability to monitor conditions indicating
- 1 for imminent ~ 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 conditions and are not allowed to be used to comply Required Action.
Exit of the Monitored Region
~*~~~~~~d by eOt9trol rod iMsertion and/ 0 r rccireu1ation H0,,,e'0'er, acti 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 ffi;nutcs) verified Recent verification of FC8B
~
ATe.:&-; provi des e that Hi th the PBDS i floperabl e, pl anned decreases *
- n ~ f+e.w shoul d tTe-t result in significant
- n of core stability perforffiance.
(coAtinu@d)
B 3.3 399 LOG 98037
4A4-E-S to GNRO-2009-00054 Page 45 of 49 I
Ximp A4 3F. miAllte-,
s f 4-e-d G ell, m v 1. -et.
n Ili,-- I-Y E) F) e r-a et g' en
-a :tl Peaet md4i,eigs assuffl i, fq t 1Q.
safetly wiped te exi,t, tlq," IMOA.H4, Ped i s - X, 4 e -d-,
Pp babi y
lit 1
1 pe f P an e eeeup inap r 6-1-e.
Bur-4igg patien z' Tt PQQ~U4 U4 19 di ti I
v I eigs eeigsisteig 19 i
PE)iqi.e4i: hepffl a gpe i i9di, eat-i-en uffient a-i, e n e a 1919, 1 S afl 44 G 1: -
H C-K will! d-eiEl-e e !,,A,,,, -1 9
el-S t
5t, a t.
i i s (14 t I r 1 M g r 4.
e at. 4, a n m
e a n to GNRO-2009-00054 Page 45 of 49 fl&8.5 8 3.3.1.3 ACTIONS SUR'IE I LLI'JJCE REQU I R~J4ENTS G.l (continued)
The specified Completion riffle of IS ffliMutes eM~ur@s timely ope rato r aeti on to e)(i t the reg; on COl9Si stel9t '09'; tM tMe 1ow probability that reactor c019clitions exceed the
- "iti6~
conditions assumed in the safety analysis.
The time requi red to e><; t the
~4ofli tared Regi 019 'vi; 11 clel'efld etn Provided efforts are begun
\\,,1i t hi n 15 ffi; nutes aAd co At i 19 Ued Utitil t 19e ti 0 19ito red Region i 5 e)(i ted, 0 perat ion i 5 aceeptab1e base eI 019 t 19e 10 'vi probability of a transient wft+efl de~rades stability performance oceurritig simultafleously w4-t+l tRc reefuired PB-Et5 channe~
~
3.3.1.3.1 Ouri ng operati on
~.~~ioo-of+I~~~-Ao Region the PBDS Hi Hi conditions COflsistent neutronie/thermal hydraul*c 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> provides e
alarm during operation
~.~~~~~~~
Monitored RegioR.
forffial; but morc frequcflt operation.
SR 3.3.1.3.2 8 3.3 39h LOG 98037 to G N RO-2009-00054 Page 46 of 49
'- 6 n n1n+1 W1rtA 1
F -l-, a-e-ee-d A
1 IA A
- 11 IaS l
..l 4Y1 A 1A t
+4 t ` A
/
L ~~-L TE -.
- FA-~~-t 5~ ff 6~
e~r~- -~~-ice n e*
t u t, a 4. wil: te-s.
- i. m 1 a c1 i-n~a ;~. -erg d
ri n mom Strait A /R e m t s
-f a,
11i 41:1 E~ r +Itg r al opera--.
M s I"1 n IIR 'S ~R ri tH A M 4Y it1 A
,~ r r v
---G H A*N-F~ F G -H dA L P
°fram e e a11 ~
y-e- =F=ps or - effl~t s t a A
h 'kA' IA a A h I'V 1 1 A Ih A A 19 6-e 11-aM~ e=rg t~~t 4 Is e
d W1 151-SH44
~~-A t
"hRe-a ear '~
~y S e l-t t
a End 8 e
ra A 1
-1A.
'~
' ° A n to GNRO-2009-00054 Page 46 of 49 P-BB-5 B 3.3.1.3 SURVEILLANCE REQU I RE~i ENTS
&R 3.3.1.3.2 (coMtiMued) verifyiMg the iM5tl umentation continues to operate properly between each CIIA~~NEL FUNCTIONAL =Ff:-&f-.
A9reement cri teri a are determined by the
~lant ~ ~ on a combination e4 t~e c~annel instrument unc@rtainti@s, including indication and readability.
TRe 12
~our FreetueMcy ;5 based on o~erating eXJgerieflce t-ITa-t d@ffloflstrat@s chanMel failure is rare.
Tfte CIIANNEL 6++E--K sUJ9pl@ments less formal, but more freetuent, e~eeks frt chann@ls cluring norma~ oJgerational use of the displays associ ated ~
t~e channel s reCfui red b)' the LCO.
&R 3.3.1.
3.3 REFERENCES
A CHANNEL FUNCTIONAL 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 test seetuence &ft6 verification of approJ9riate and inop conditions ~
reported.
Perform8flce of 8 CIIANNEL
~H-+-+++t'tH*L T-E-£1 at a Fr@queflcy ef 24 months verifies ~~~~~~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 system or component statu5$
The alarm circuit is designed to operate
~ sufficient accuracy 8fl signal amplitude
~an~d~~~..
considering environment, initiai calibration y ~ (Ref. 2).
~
NEOO 32339 A,
~,,~~~~~~. ~Q~y LOR9 T@rmSolutioR:
EnRanced Option
~
NEOC 32339P A, f-e-Ffn Solution:
B 3.3 39; LOC 98037
BASES LC O to GNRO-2009-00054 Page 47 of 49 APPLICABLE margins during abnormal operational transients (Ref. 2),
SAFETY ANALYSES (continued) which are analyzed in Chapter 15 of the UFSAR A plant specific LOCA analysis has been performed assuming only one operating recirculation loop.
This analysis has demonstrated that, in the event of a LOCA caused by a pipe break in the operating recirculation loop, the Emergency ling System response will provide adequate provided the APLHGR requirements are modified accordingly (Ref. 3).
abnormal at ono Recirculation Loops Operating B 3.4.1 The transient analyses of Chapter 15 of the UFSAR have also been performed for single recirculation loop operation (Ref. 3) and demonstrate sufficient flow coastdown characteristics to maintain fuel thermal margins during the Tents analyzed provided the MCPR requirements are modified.
The APLHGR and MCPR limits for single loop operation are specified in the COLR.
Recirculation loops operating satisfies Criterion 2 of the NRC Policy Statement.
Two recirculation loops are normally required to b operation with their flows matched within the limits specified in SR 3.4.1.1 to ensure that during a LOCA caused by a break of the piping of one recirculation loop the ons of the LOCA analysis are satisfied.
I Alternatively, with only one recirculation loop in on, modifications to the required APLHGR limits
AVERAGE PLANAR LINEAR HEAT GENERATION RATE MCPR limits RCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)", and W ;
k A
W A 1
17 U_-L]
undaFY 99 (K~, LCO 3.3.1.1, "RPS Instrumentation" ;
I f, a :2
- Z 3
- ~
11 w e,-4 0.4 Q, p - -4 Q - t -
_* - r.
A QQRQ 4-L-1,V I
I I
U DOZ-=u LJI=
t=t~
lull J y _111h!111 krDul))) must be applied to allow continued opera assumptions of References. 3 cons stmt with n
The LCO is modified by a Note which allows up to 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> before having to put in effect the required modifications to red limits after a change in the reactor operating conditions from two recirculation loops operating to single recirculation loop operation.
If the required limits are (continued)
GRAND GULF B 3.4-3 LDC 98031 to GNRO-2009-00054 Page 47 of 49 BASES Recirculation Loops Operating B 3.4.1 APPLICABLE SAFETY ANALYSES (continued)
LCO margins during abnormal operational transients (Ref. 2),
which are analyzed in Chapter 15 of the UFSAR.
A plant specific LOCA analysis has been performed assuming only one operating recirculation loop.
This analysis has demonstrated that, in the event of a LOCA caused by a pipe break in the operating recirculation loop, the Emergency Core Cooling System response will provide adequate core cooling, provided the APLHGR requirements are modified accordingly (Refo 3).
The transient analyses of Chapter 15 of the UFSAR have also been performed for single recirculation loop operation (Ref. 3) and demonstrate sufficient flow coastdown characteristics to maintain fuel thermal margins during the abnormal operational transients analyzed provided the MCPR requirements are modified.
The APLHGR and MCPR limits for single loop operation are specified in the COLR.
Recirculation loops operating satisfies Criterion 2 of the NRC Policy Statement.
Two recirculation loops are normally required to be in operation with their flows matched within the limits specified in SR 3.4.1.1 to ensure that during a LOCA caused by a break of the piping of one recirculation loop the assumptions of the LOCA analysis are satisfied.
Alternatively, with only one recirculation loop in operation, modifications to the required APLHGR limits (LCO 3.2.1, "AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)"),
MCPR limits (LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)", and APR~4 Flo'"
8; ased 5; fflul ated TMermal Powe,-
High, ALLOWABLE Value (LCD 3.2.4, "Fraction of Core 80iling Boundary" Cl=CBB),
LCO 3.3.1.1, "RPS Instrumentation", and LCO 3.3.1.3, "P@tiod Based Detection System" (PBDS)) must be applied to allow continued operation consistent with the assumptions of Reference~ 3 ~.
The LCO is modified by a Note which allows up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> before having to put in effect the required modifications to required limits after a change in the reactor operating conditions from two recirculation loops operating to single recirculation loop operation.
If the required limits are (continued)
GRAND GULF B 3.4-3 LDC 98037
BASE to GNRO-2009-00054 Page 48 of 49 REFERENCES (continued)
UFSAR, Section 6.3.3.7.
UFSAR, Section 5.4.1.1 UFSAR, Chapter 15, Appendix 15C.
Deleted 11 C' 4-
"Reaete Ij I'luo I v
Recirculation Loops Operating B 3.4.1 1 emg Term S. 1, ut, 41 1-1.
GRAND GULF B 3.4-8 LDC 98037 to GNRO-2009-00054 Page 48 of 49 BASES (continued)
REFERENCES Recirculation Loops Operating B 3.4.1 1.
UFSAR, Secti on 6.3.3.7.
2.
UFSAR, Section 5.4.1.1.
3.
UFSAR, Chapter 15, Appendix 15C.
4.
NEOO 32339 A, "Reactor Stability Long Term Solution:
EAhaAced O~tien ~
5.
De1eted GRAND GULF B 3.4-8 LDC 98037 to GNRO-2009-00054 Page 49 of 49 ASES APPLICABLE SAFETY ANALYSES (continued)
L 0 CROA analyses assume that the reactor operator follows prescribed withdrawal sequences.
For SDM tests performed within these defined sequences, the analyses of References 1 and 2 are applicable.
However', for some sequences developed for the SDM testing, the control rod patterns assumed in the safety analyses of References 1 and 2 may not be met.
Therefore, special CRDA analyses, performed in accordance i
will not result in DA occur during the protection provided applicable LCOs, in addition will maintain normal test accidents within the bounds (Refs. I and 2).
In cements for the Rod Pattern control rod coupling, the single pacified for out of sequence ingle notch withdrawal mode h, which limits i ng of occur during the tes i th an NRC approvea m demonstrate that the SDM test table consequences s testing.
For the purpos by the normally required M to the requirements of in operations as well as pos of the appropriate safety addition to the added requ Controller (RPC notch withdrawal mode is withdrawals.
Requiring th limits withdrawal steps to inserted reactivity, and all changes in neutron fl As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of the ARC Policy Statement apply.
Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs.
A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.
w SOM Test Refueling B 3.10.8 As described in LCO 3.0.7, compliance with this Special Operations LCO is optional.
SDM tests may be performs
.W while in MODE 2, in accordance with Table 1.1-1, wit u sting this Special Operations LCO or its ACTION.
For SDM tests performed while in MODE 5, additional re cements must be met to ensure that adequate protecti against ial reactivity excursions is avail a To provide additional scram protection, beyond the ormally required Ids, the APRMs are also required tt OPERABLE (LCO 3.3.1.1, Functions 2.a 2.
as though the reactor were in MODE 2.
Because Mm `ti pie control rods will be thdrawn and the reactor w 11 potentially become critica the approved control rod wi hdrawal sequence must be enforced by the RPC (LCO 3..2.1, Function 1b, MODE 2), or to GNRO-2009-00054 Page 49 of 49 SDM Test--Refueling B 3.10.8 BASES APPLICABLE SAFETY ANALYSES (continued) eRDA analyses assume that the reactor operator follows prescribed withdrawal sequences.
For SDM tests performed within these defined sequences, the analyses of References 1 and 2 are applicable.
However, for some sequences developed for the SOM testing, the control rod patterns assumed in the safety analyses of References 1 and 2 may not be met.
Therefore, special CRDA analyses, performed in accordance with an NRC approved methodology, are required to demonstrate that the SDM test sequence will not result in unacceptable consequences should a CRDA occur during the testing.
For the purpose of this test, protection provided by the normally required MODE 5 applicable LCOs, in addition to the requirements of this lCO, will maintain normal test operations as well as postulated accidents within the bounds of the appropriate safety analyses (Refs. 1 and 2).
In addition to the added requirements for,the Rod Pattern Controller (RPC), APRM, and control rod coupling, the single notch withdrawal mode is specified for out of sequence withdrawals.
Requiring the single notch withdrawal mode limits withdrawal steps to a single notch, which limits inserted reactivity, and allows adequate monitoring of changes in neutron flux, which may occur during the test.
As described in LCO 3.0.7, compliance with Special O'perations LCOs is optional t and therefore, no criteria of the NRC Policy Statement apply.
Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs.
A discussion of the criteria satisfied for the other LeOs is provided in their respective Bases.
continued Revision No. 0 B3.10-33 As described in LCO 3.0.7, compliance with this Special Operations lCO 1s optional.
SOH tests may be performe while in MODE 2, in accordance with Table 1.1-1, wit ut meeting this Special Operations LCO or its ACTION.
For SDM tests performed while in MODE 5, additional re rements must be met to ensure that adequate protecti against potential reactivity excursions is avai1ab To provide additional scram protection, beyond the ormally required IRMs, the APRMs are also required t OPERABLE
{lCO 3.3.1.1, Functions 2.a ~ 2.e as though the reactor were in MODE 2.
Because m iple control rods will be withdrawn and the reactor w 11 potentially become critical, the approved control rod wi hdrawal sequence must be enforced by the RPC (LCO 3.3.2.1, Function Ib, MODE 2), or LCO GRAND GULF
GE HITACHI NUCLEAR ENERGY REPORT 0000-0107-7607-NP-R1 GRAND GULF NUCLEAR STATION-GRAND GULF PRNM UPGRADE PROJECT OPTION III STABILITY DEVIATIONS (NO ATTACHMENT 6 G N RO-2009-00054
-PROPRIETARY VERSION)
ATTACHMENT 6 GNRO-2009-00054 GE HITACHI NUCLEAR ENERGY REPORT 0000-0107-7607-NP-R1 GRAND GULF NUCLEAR STATION - GRAND GULF PRNM UPGRADE PROJECT OPTION III STABILITY DEVIATIONS (NON-PROPRIETARY VERSION)
Non-proprietary Version Grand Gulf Nuclear Station Grand Gulf PRNM Upgrade Project Option-III Stability Deviations Principal Contributor Juswald Vedovi Principal Verifier Alan Chung Approving Manager Erik Kirstein GE Hitachi Nuclear Energy P.O. Box 780 3901 Castle Hayne Rd Wilmington, NC 28402 0000-0107-7607-NP-R1 DRF 0000-0102-6642 Revision 1 Class III October 2009 GE Hitachi Nuclear Energy P.O. Box 780 3901 Castle Hayne Rd Wilmington, NC 28402 0000-0107-7607-NP-Rl DRF 0000-0102-6642 Revision 1 Class III October 2009 Non-proprietary Version Grand Gulf Nuclear Station Grand Gulf PRNM Upgrade Project Option III Stability Deviations Principal Contributor Juswald Vedovi Principal Verifier Alan Chung Approving Manager Erik Kirstein
0000-0107-7607-NP-R1 GEH NON-PROPRIETARY INFORMATION REVISION
SUMMARY
Rev Required Changes to Achieve Revision I
Editorial change : the header was modified from "GEH Proprietary Information" to "GEH Non-Proprietary Information" since this is the Non-Proprietary version of the report.
OOOO-Ol07-7607-NP-Rl GEH NON-PROPRIETARY INFORMATION REVISION
SUMMARY
1 Editorial change: the header was modified from "GEH Proprietary Information" to "GEH Non-Proprietary Information" since this is the Non-Proprietary version ofthe report.
0000-0107-7607-NP-R1 GEH NON-PROPRIETARY INFORMATION INFORMATION NOTICE This is a non-proprietary version of the document GE-NE-0000-0 I 07-7607-NP-RO, which has the proprietary information removed. Portions of the document that have been removed are indicated by an open and closed bracket as shown here ((
)).
IMPORTANT NOTICE REGARDING CONTENTS OF THIS REPORT PLEASE READ CAREFULLY The information contained in this document is furnished for the purpose to support the NRC review of the Grand Gulf Nuclear Station license application for implementation of the power range neutron monitor.
The only undertakings of GEH with respect to information in this document are contained in contracts between GEH and the parent company of Grand Gulf Nuclear Station, and nothing contained in this document shall be construed as changing those contracts. The use of this information by anyone other than those participating entities and for any purposes other than those for which it is intended is not authorized ; and with respect to any unauthorized use, GEH makes no representation or warranty, and assumes no liability as to the completeness, accuracy, or usefulness of the information contained in this document.
Copyright GE Hitachi Nuclear Energy Americas 2009 0000-0107-7607-NP-Rl GEH NON-PROPRIETARY INFORMATION INFORMATION NOTICE This is a non-proprietary version of the document GE-NE-0000-OI07-7607-NP-RO, which has the proprietary information removed. Portions of the document that have been removed are indicated by an open and closed bracket as shown here ((
)).
IMPORTANT NOTICE REGARDING CONTENTS OF THIS REPORT PLEASE READ CAREFULLY The information contained in this document is furnished for the purpose to support the NRC review of the Grand Gulf Nuclear Station license application for implementation of the power range neutron monitor.
The only undertakings of GEH with respect to information in this document are contained in contracts between GEH and the parent company of Grand Gulf Nuclear Station, and nothing contained in this document shall be construed as changing those contracts. The use of this information by anyone other than those participating entities and for any purposes other than those for which it is intended is not authorized; and with respect to any unauthorized use, GEH makes no representation or warranty, and assumes no liability as to the completeness, accuracy, or usefulness ofthe information contained in this document.
Copyright GE Hitachi Nuclear Energy Americas 2009 ii
0000-0107-7607-NP-R1 GEH NON-PROPRIETARY INFORMATION Grand Gulf Option III Stability Deviations Grand Gulf Nuclear Station (GGNS) will submit a license application for the implementation of Power Range Neutron Monitor (PAM) using the Long Term Stability Solution Option 111. The basis for the license application is contained in the relevant licensing topical reports (References I - 6) and Safety Communications (References 7 -12).
The special Long Term Stability Solution Option III developed for GGNS has two deviations from the referenced documents. Each deviation is justified as being conservative relative to the relevant licensing documents as is summarized in Table 1. A more detailed discussion of the justification is presented below.
Technical Justifications :
The justifications for these two deviations in Table I are provided below.
a) Base Period Definition for PBDA The Option III licensing basis defines the base period as the average of all successively confirmed periods (Reference 1). The GGNS Option III defines the successive base period as equal to the previous period that is within PBDA Tmin and Tm,,,, limits.
Tma, is defined as the oscillation period upper time limit for the Period Based Detection Algorithm (PBDA) while Tmin is defined as the oscillation period lower time limit for the PBDA. ((
)) Therefore, this change does not significantly increase the frequency of spurious scrams during normal operation, precluding any anomalous oscillatory behavior with a OOOO-Ol07-7607-NP-Rl GEH NON-PROPRIETARY INFORMATION Grand Gulf Option III Stability Deviations Grand Gulf Nuclear Station (GGNS) will submit a license application for the implementation of Power Range Neutron Monitor (PRNM) using the Long Term Stability Solution Option III. The basis for the license application is contained in the relevant licensing topical reports (References 1-6) and Safety Communications (References 7 12).
The special Long Term Stability Solution Option III developed for GGNS has two deviations from the referenced documents. Each deviation is justified as being conservative relative to the relevant licensing documents as is summarized in Table 1. A more detailed discussion of the justification is presented below.
Technical Justifications:
The justifications for these two deviations in Table 1 are provided below.
a) Base Period Definition for PBDA The Option III licensing basis defines the base period as the average of all successively confirmed periods (Reference 1). The GGNS Option III defines the successive base period as equal to the previous period that is within PBDA Tmin and Tmax limits.
Tmax is defined as the oscillation period upper time limit for the Period Based Detection Algorithm (PBDA) while Tmin is defined as the oscillation period lower time limit for the PBDA. ((
))
Therefore, this change does not significantly increase the frequency of spurious scrams during normal operation, precluding any anomalous oscillatory behavior with a
- Page 1 -
0000-0107-7607-NP-R1 GEH NON-PROPRIETARY INFORMATION frequency range typical of thermal-hydraulic instability, or adversely impact the plant ability to provide SLMCPR protection.
This change is conservative relative to the Option III licensing basis.
b) Period Tolerance Offset The period tolerance offset is a feature to maximize the ability of the PBDA to recognize the initiation of oscillations following a fast flow runback event. ((
))
The comparison is based on a simulated instability event and shows that the indicated signal will confirm successive confirmation counts much sooner with the period tolerance offset. ((
)) Therefore, this change does not significantly increase the likelihood of spurious scram or adversely impact the plant ability to provide SLMCPR protection.
This change is conservative relative to the Option III licensing basi 0000-0107-7607-NP-R1 GEH NON-PROPRIETARY INFORMATION frequency range typical of thermal-hydraulic instability, or adversely impact the plant ability to provide SLMCPR protection.
This change is conservative relative to the Option III licensing basis.
b) Period Tolerance Offset The period tolerance offset is a feature to maximize the ability of the PBDA to recognize the initiation of oscillations following a fast flow ronback event. ((
))
The comparison is based on a simulated instability event and shows that the indicated signal will confirm successive confirmation counts much sooner with the period tolerance offset. ((
)) Therefore, this change does not significantly increase the likelihood of spurious scram or adversely impact the plant ability to provide SLMCPR protection.
This change is conservative relative to the Option III licensing basis.
- Page 2 -
References
- 5.
GEH 0000-0107-7607-NP-R1 ON-PROPRIETARY INFORMATION 1. NEDO-31960-A Supplement 1, "BWR Owners' Group Long-Term Stability Solutions Licensing Methodology," November 1995.
2. NEDO-31960-A, "BVV-R Owners' Group Long-Term Stability Solutions Licensing Methodology," November 1995.
- 3. NEDO-32465-A, "Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications," August 1996.
4. NEDC-32410P-A Volume 1, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PAM) Retrofit Plus Option III Stability Trip Function,"
October 1995.
DC-324 I OP-A Volume 2 -- Appendices, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor SUMAC PRNM) Retrofit Plus Option III Stability Trip Function," October 1995.
- 6. NEDC-32410P-A, Supplement 1, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PAM} Retrofit Plus Option III Stability Trip Function," November 1997.
- 7. Safety Communication 02-09, "Stability Option III Trip Adequacy for Instability During Fast Transients," July 26, 2002.
- 8. Safety Communication 02-21, "Stability Option III : OPT Tmin Specification,"
November 22, 2002.
- 9. Safety Communication 03-20, "Stability Option III Period Based Detection Algorithm Allowable Settings," October 4, 2003.
10. Safety Communication 03-02, "Stability Option III OPT Armed Region Boundary,"
February 17, 2003.
11. Safety Communication 07-18 Rev. l,"OPRM Armed Region Boundary," October 19, 2007.
12. Safety Communication 07-19 Rev. l,"OPRM Armed Region Boundary," October 19, 2007.
13. NEDC-33075P-A Revision 6, "General Electric Boiling Water Reactor Detect and Suppress Solution - Confirmation Density," January 2008.
0000-0107-7607-NP-Rl GEH NON-PROPRIETARY INFORMATION References
- 1. NEDO-31960-A Supplement 1, "BWR Owners' Group Long-Term Stability Solutions Licensing Methodology," November 1995.
- 2. NEDO-31960-A, "BWR Owners' Group Long-Term Stability Solutions Licensing Methodology," November 1995.
- 3. NEDO-32465-A, "Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications," August 1996.
4.
NEDC-32410P-A Volume 1, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function,"
October 1995.
- 5. NEDC-32410P-A Volume 2 -- Appendices, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," October 1995.
6.
NEDC-32410P-A, Supplement 1, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," November 1997.
7.
Safety Communication 02-09, "Stability Option III Trip Adequacy for Instability During Fast Transients," July 26, 2002.
8.
Safety Communication 02-21, "Stability Option III: OPRM Tmin Specification,"
November 22,2002.
9.
Safety Communication 03-20, "Stability Option III Period Based Detection Algorithm Allowable Settings," October 4, 2003.
- 10. Safety Communication 03-02, "Stability Option III OPRM Armed Region Boundary,"
February 17,2003.
- 11. Safety Communication 07-18 Rev. 1,"OPRM Armed Region Boundary," October 19, 2007.
- 12. Safety Communication 07-19 Rev. 1,"OPRM Armed Region Boundary," October 19, 2007.
- 13. NEDC-33075P-A Revision 6, "General Electric Boiling Water Reactor Detect and Suppress Solution - Confirmation Density," January 2008.
- Page 3 -
0000-0107-7607-NP-RI GEH NON-PROPRIETARY INFORMATION Table 1. GGNS Option III Deviations a
11 following a fast flow reduction event (Reference 13).
Conserv Conservativ Base Period definition Average of all The previous for PBDA successively successively confirmed confirmed periods period (Reference 13) ce 1)
Period Tolerance Not a solutio Offset feature.
0000-0107-7607-NP-Rl GEH NON-PROPRIETARY INFORMATION Table 1. GGNS Option III Deviations a
Base Period definition Average of all The previous Conservative forPBDA successively successively confirmed confirmed periods period (Reference 13)
(Reference 1) b Period Tolerance Not a solution
((
Conservative Offset feature.
)) following a fast flow reduction event (Reference 13).
- Page 4-
Figure 1. Effect of 0000-0107-7607-NP-R1 GEH NON-PROPRIETARY INFORMATION eriod Tolerance Offset on the Successive Confirmation Count Response*
((
- ((
0000-0107-7607-NP-Rl GEH NON-PROPRIETARY INFORMATION Figure 1. Effect of Period Tolerance Offset on the Successive Confirmation Count Response*
- Page 5 -
))
))
ATTACHMENT 7 G N RO-2009-00054 LICENSEE-IDENTIFIED COMMITMENTS ATTACHMENT 7 GNRO-2009-00054 LICENSEE-IDENTIFIED COMMITMENTS to GNRO-2009-00054 Page 1 of 2 LICENSEE-IDENTIFIED COMMITMENTS The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
TYPE SCHEDULED (Check one)
COMPLETION COMMITMENT NE-TIME CONTINUING DATE ACTION COMPLIANCE (If Required) 1.
Entergy will conduct a monitoring period of the Following OPRM for a minimum of 90 days not to completion of the exceed one fuel cycle after plant startup OPRM Monitoring following the 2012 refueling outage to be Period successfully completed prior to enabling the OPRM.
2.
During the OPRM Monitoring Period, the During the OPRM outputs from the OPRM Upscale function will Monitoring Period not be connected to the RPS trip output relays while the OPRM alarms and indications will be provided to the operators.
3.
Entergy will perform OPRM surveillances that Prior to and during can be performed, or partially performed, prior the OPRM to startup from the 2012 refueling outage or Monitoring Period on-line as part of post-modification testing, industry experience, and factory acceptance testing of the NUMAC PRNM System.
4.
During the OPRM Monitoring Period, the During the OPRM OPRM Upscale function will not be relied upon Monitoring Period to mitigate a stability event; rather GGNS will implement Backup Stability Protection (BSP) specified in BWROG document OG 02-0119-260, GE to BWROG Detect and Suppress //
Committee, "Backup Stability Protection (BSP) for Inoperable Option /// Solution," as an alternate method for detecting and suppressing instabilities until the OPRM Monitoring Period has been successfully completed.
5.
The BSP measures will be implemented via plant procedures. to GNRO-2009-00054 Page 1 of 2 LICENSEE-IDENTIFIED COMMITMENTS The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
1.
Entergy will conduct a monitoring period of the Following OPRM for a minimum of 90 days not to completion of the exceed one fuel cycle after plant startup OPRM Monitoring following the 2012 refueling outage to be Period successfully completed prior to enabling the OPRM.
2.
During the OPRM Monitoring Period, the During the OPRM outputs from the OPRM Upscale function will Monitoring Period not be connected to the RPS trip output relays while the OPRM alarms and indications will be provided to the operators.
3.
Entergy will perform OPRM surveillances that Prior to and during can be performed, or partially performed, prior the OPRM to startup from the 2012 refueling outage or Monitoring Period on-line as part of post-modification testing, industry experience, and factory acceptance testing of the NUMAC PRNM System.
4.
During the OPRM Monitoring Period, the During the OPRM OPRM Upscale function will not be relied upon Monitoring Period to mitigate a stability event; rather GGNS will implement Backup Stability Protection (BSP) specified in BWROG document OG 02-0119-260, GE to BWROG Detect and Suppress /I Committee, "Backup Stability Protection (aSP) for Inoperable Option 11/ Solution," as an alternate method for detecting and suppressing instabilities until the OPRM Monitoring Period has been successfully completed.
5.
The BSP measures will be implemented via plant procedures.
to G N RO-2009-00054 Page 2 of 2 TYPE--_
Check one SCHEDULED COMPLETION COMMITMENT ONE-TIME CONTINUING DATE ACTION COMPLIANCE (If Required) 6.
At the end of the OPRM Monitoring Period, Completion of the Entergy will review the operating data, OPRM Monitoring setpoints, and margins. Once the results are Period determined to be acceptable, Entergy will enable the OPRM (with applicable SRs met) by connecting it to the RPS trip relays.
7.
Entergy will notify the NRC when the OPRM Completion of the Monitoring Period has been successfully OPRM Monitoring completed.
Period 8.
The Period-Based Detection algorithm "tuning" parameters will be established in accordance with GGNS procedures as part of the system setup and calibration, and will be defined in plant procedures.
9.
The Period-Based Detection algorithm trip setpoint will be documented in the COLR.
10. Administrative controls will be provided for manually bypassing the APRM 1 OPRM channels or protective functions, and for controlling access to the APRM I OPRM panel and channel bypass switch.
11. Documenting the HFE review will be included Prior to startup in the final design packages for the PRNM from the 2012 System and available on-site for NRC refueling outage inspection.
12. The TRM will be revised to reflect the NTSP Prior to startup and methodologies used to determine the as-from the 2012 found and as-left tolerances prior to startup refueling outage from the 2012 refueling outage.
13. GGNS calibration procedures for APRM Prior to startup Functions 2.a, 2.b, 2.d, and 2.f will be revised from the 2012 to reflect the instructions given in new Notes refueling outage (d) and (e). to GNRO-2009-00054 Page 2 of 2 6.
At the end of the OPRM Monitoring Period, Entergy will review the operating data, setpoints, and margins. Once the results are determined to be acceptable, Entergy will enable the OPRM (with applicable SRs met) by connecting it to the RPS trip relays.
7.
Entergy will notify the NRC when the OPRM Monitoring Period has been successfully completed.
8.
The Period-Based Detection algorithm "tuning" parameters will be established in accordance with GGNS procedures as part of the system setup and calibration, and will be defined in plant procedures.
9.
The Period-Based Detection algorithm trip setpoint will be documented in the COLR.
- 10. Administrative controls will be provided for manually bypassing the APRM / OPRM channels or protective functions, and for controlling access to the APRM / OPRM panel and channel bypass switch.
- 11. Documenting the HFE review will be included in the final design packages for the PRNM System and available on-site for NRC inspection.
- 12. The TRM will be revised to reflect the NTSP and methodologies used to determine the as-found and as-left tolerances prior to startup from the 2012 refueling outage.
- 13. GGNS calibration procedures for APRM Functions 2.a, 2.b, 2.d, and 2.f will be revised to reflect the instructions given in new Notes (d) and (e).
Completion of the OPRM Monitoring Period Completion of the OPRM Monitoring Period Prior to startup from the 2012 refueling outage Prior to startup from the 2012 refueling outage Prior to startup from the 2012 refueling outage