ML101470385
| ML101470385 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 05/25/2010 |
| From: | Entergy Operations, GE-Hitachi Nuclear Energy Americas |
| To: | Lyon C Plant Licensing Branch IV |
| Lyon C Fred, NRR/DORL/LPL4, 301-415-2296 | |
| Shared Package | |
| ML101470378 | List: |
| References | |
| TAC ME2531 | |
| Download: ML101470385 (42) | |
Text
1 NRC RAIs Regarding GGNS PRNM System LAR Entergy Operations, Inc.
GE Hitachi Nuclear Energy May 25, 2010 THIS PRESENTATION CONTAINS GEH PROPRIETARY INFORMATION.
WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390.
2 Purpose of the Meeting
Discuss RAIs
Ensure RAIs are understood
Discuss approach to responses
3 Non-Proprietary Discussion 4
PRNM System Overview The GGNS PRNM System will apply GEH NUMAC standard processes, modules and chassis, which are then configured for the GGNS BWR/6-specific design.
Primary Chassis:
NUMAC Standard - APRM / LPRM / 2of4 / QLVPS / NIC
BWR6 Specific - PCI, which is based on the RBM Stability:
Changing from Option E-1-A to Option III stability solution
DSS-CD functions will be included (hardware disabled)
Project Execution:
PRNM is to be installed during the spring 2012 outage
EPU Project & Licensing Submittal goal (Q3-2010) is the primary driver for PRNM Licensing Submittal earlier than typically assembled.
5 Plants with PRNM System
- - DSS-CD Upgrade in process 6
RAI No. 2 NUMAC PRNM LTR section 4.4.1.11 requires the Utility Action to "identity the specific requirements applicable to the plant, confirm that any clarifications included in NEDC-32410P-A apply to the plant, and document the specific requirements that the replacement PRNM is intended to meet for the plant." However, the entry for 4.4.1.11 in of the license amendment does not document specific GGNS PRNM requirements. For example, no discussion of response time requirements could be identified.
Therefore, to support the NRC staff's review using current criteria, please identify the GGNS specific requirements applicable to the GEH NUMAC PRNM System application (e.g., application software). When considering the requirements documentation. please address the related documentation that is identified under Section B.2 of SRP, NUREG-0800, Branch Technical Position 7-14, Revision 5.
7 RAI No. 2
Confirm plant requirements are met
Review UFSAR to identify requirements for current APRM subsystem
Site-specific requirements bounded by PRNM LTR
Compare to codes and standards specified in the PRNM LTR
Revise Attachment 2 to reflect information (similar to MNGP approach)
Application software and BTP 7-14 (discussed under RAI No. 1) 8 RAI No. 5 In accordance with the NUMAC PRNM LTR, both the documentation of the qualification activities and the licensee's confirmation "should be included in the plant-specific licensing submittal"; however, this information was not addressed in the LAR.
Please provide the analyses or reference documents (such as the referenced "Qualification Summary") that demonstrate the environmental conditions for the GGNS PRNM System configuration are enveloped by the conditions to which GEH NUMAC PRNM System equipment has been environmentally qualified (for example, NRC Regulatory Guide (RG) 1.89, "Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants"; Institute of Electrical and Electronics Engineers (IEEE) 323-1974; IEEE 323-1983: NRC RG 1.100 "Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants"; IEEE 344-1975, etc.) as discussed in section 4.4.2 of GE LTR NEDC-32410P-A. Paragraph 5.0, Item 4) in the original Safety Evaluation Report (SER) for the LTR requires plant-specific action to confirm appropriate qualification has been completed. However, as indicated in the following table, the LAR does not identify the applicable GGNS environmental conditions nor confirm that they have been enveloped by equipment qualification or analysis.
9 RAI No. 5 (contd)
Please provide direct testing references to the EMI requirements under 4.4.2.4.2 or compliance per 4.4.2.4.3 of the NUMAC PRNM LTR. Please provide documentation of the qualification action and the licensees confirmation has taken place.
4.4.2.4.4 3.4.4 EMI Compatibility Please provide documentation of the qualification action and that the licensees confirmation has taken place.
4.4.2.3.4 3.4.3 Seismic The LAR identifies the normal control room dose rates. Please indicate if the identified dose rates apply to the worst-case conditions in which the equipment is required to remain operable.
4.4.2.2.3.4 3.4.2 Radiation The LAR identifies the normal control room pressure. Please indicate if the identified pressure applies to the worst-case conditions in which the equipment is required to remain operable.
4.4.2.2.2.4 3.4.2 Pressure The LAR identifies the normal control room relative humidity.
Please indicate if the identified relative humidity applies to the worst-case conditions in which the equipment is required to remain operable.
4.4.2.2.1.4 3.4.1 Humidity The LAR identifies the normal control room temperature. Please indicate if the identified temperature applies to the worst-case conditions in which the equipment is required to remain operable.
4.4.2.2.1.4 3.4.1 Temperature RAI Issue to be Resolved LAR Entry SER Paragraph Qualification Item 10 RAI No. 5 (contd)
Environmental Qualification (EQ)
Document EQ conditions in Attachment 2
Compare GGNS parameters with PRNM LTR
Control Room classified as a mild environment.
Final system configuration qualification performed after fabrication and prior to installation (~ 4th quarter 2010)
Documented in a Qualification Summary Report
Propose a License Condition to provide the requested information to NRC prior to startup from the 2012 refueling outage.
11 RAI No. 8 Please identify how the failure rate data for the identified hardware items, as provided in NEDC-32410P-A Table F.2, is affected by the GGNS BWR/6 equipment configuration.
12 RAI No. 8 (contd)
Failure Rate Data
Updating information from Table F.2 of the PRNM LTR to specifically reflect BWR/6 design
PRNM Communications Interface (PCI) chassis replaces Rod Block Monitor (RBM)
Hardware subcomponents similar
Developed on similar time schedule as the Qualification Summary Report
Propose a License Condition to provide the requested information to NRC prior to startup from the 2012 refueling outage.
13 RAI No. 3 Please describe how a software common-cause failure of the GGNS PRNM System upgrade application is addressed or coped with, such that upon its failure GGNS remains within its design basis for all design-basis accidents and anticipated operational occurrences.
14 RAI No. 3
Address software common-cause failure
Diversity provided via RPS.
RPS is a redundant fail-safe system.
Same as other NRC-approved PRNM applications.
15 RAI No. 7 As required by Item 6 of paragraph 5.0 in the original SER for the LTR, please provide the information necessary to demonstrate that any changes to GGNS' operator's panel have received human factors reviews per plant-specific procedures.
Contrary to the SER, Section 2.3.4 in Attachment 2 does not contain the results of the human factors engineering (HFE) review.
Please provide the HFE information that is representative of the statement made in 2.3.3.6.2.1 that the GGNS operator panel will "maintain the current interface feel."
16 RAI No. 7
Human Factors - Maintain current interface feel
PRNM data to be presented on flat screen monitors currently used by control room operators
GGNS-specific Human Factors Evaluation (HFE) to be performed following design completion
(~ 2nd quarter 2011)
Propose a License Condition to provide the requested information to NRC prior to startup from the 2012 refueling outage.
17 RAI No. 9 The original SER for the L TR requires a plant-specific action to confirm administrative controls for channel bypass or removal for operation, as well as access to the PRNM operating panel and the Average Power Range Monitor/Oscillation Power Range Monitor (APRM/OPRM) channel bypass switch will be provided (see paragraphs 3.10, 3.17 and 5.0, Item 5).
Please describe the administrative controls that GGNS will provide for the GEH NUMAC PRNM System upgrade. Please demonstrate in your response that the administrative controls are provided for manually bypassing APRM/OPRM channels, or protective function, and for controlling access to the GGNS PRNM System panel and the APRM/OPRM channel bypass switch.
Also, please identify and describe any administrative controls requiring operator involvement in the generation, review, and use of new Local Power Range Monitor gain and calculated core thermal power values, which can affect APRM and OPRM setpoints.
18 RAI No. 9
Administrative Controls
Access to GGNS Control Room granted via keycard
Standard NUMAC access control features
Utilize existing site procedures governing access controls and equipment manipulation.
19 Proprietary Discussion 20 RAI No. 1 Please identify the changes to the GEH NUMAC PRNM System platform from that defined and approved within GE L TR NEDC-3241 OP-A. For example, the identified changes should include those to hardware, programmable devices, software, applicable development processes, and the like, that will be reflected within the GGNS PRNM System upgrade.
When considering the software development processes for the platform, the response should address changes (from that previously approved for the GE L TR NEDC-32410P-A) to the applicable documentation that is identified under Section B.2 of Standard Review Plan (SRP), NUREG-0800, Branch Technical Position 7-14, Guidance on Software Reviews for Digital Computer-Based Instrumentation and Control Systems," Revision 5, March 2007 (ADAMS Accession No. ML070670183).
21 RAI No. 6 Please provide the information necessary to evaluate the equipment configuration (for example, identify the revisions/version of hardware, programmable devices, software, etc.) for the Grand Gulf PRNM System.
Item 1) of paragraph 5.0 in the original Safety Evaluation Report for the LTR, requires the applicant to provide information that reconciles differences between the specific plant design, which is a BWR6 for Grand Gulf, and the topical report design description, whose supporting analysis is largely non-BWR6 based. While Attachment 2 of the license amendment does define changes to the plant configuration, it does not define the upgraded equipments configuration. The entry for Section 2.3.4 in Attachment 2 of the license amendment identifies Grand Gulfs options, but the information provided does not define the equipment configuration specific to its BWR6 application in sufficient detail to support the safety evaluation. For example, BWR6 application incorporates replacement of the Rod Block Monitor with the Computer Interface Units, which is not described within the GE LTR NEDC-32410P-A. Furthermore, GE LTR NEDC-32410P-A recognizes the Plant Computer and its data communications as plant specific items.
22 RAI Nos. 1 & 6
Changes to GGNS PRNM System platform from PRNM LTR
Typical BWR/6 design platform is described in the PRNM LTR.
Will describe GGNS-specific PRNM System platform.
Will describe hardware and software being implemented in the GGNS-specific platform.
23 Current GGNS APRM Configuration 24 NMS-to-PRNM Comparison Current NM System
LPRM Subsystem
44 LPRM strings, 176 LPRM signals
APRM Subsystem
8 APRM channels
22 LPRM input signals to each APRM channel
8 outputs to RPS PRNM System
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GEH PROPRIETARY INFORMATION
25 NMS-to-PRNM Comparison (contd)
Current NM System
Flow Subsystem
4 channels, 8 transmitters
Option E-I-A Subsystem
Period-Based Detection System (PBDS)
PRNM System GEH PROPRIETARY INFORMATION
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26 BWR/6 PRNM Panel Layouts
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GEH PROPRIETARY INFORMATION
27 PRNM Configuration
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GEH PROPRIETARY INFORMATION 28 PRNM System - GGNS Block Diagram
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GEH PROPRIETARY INFORMATION
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29 2-Out-Of-4 Voter Logic
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GEH PROPRIETARY INFORMATION 30 RAI No. 4 For the GGNS application of the GEH NUMAC PRNM System, please clearly identify and define all safety to non-safety data communications, including the data communications between the PRNM system and the Plant Computer and between independent/redundant PRNM channels.
For the data communications among the four PRNM channels of the Grand Gulf PRNM System, include a demonstration of compliance with DI&C-ISG-04 (ML083310185) for intra-channel communications.
For the plant specific data communications between the Grand Gulf PRNM System and the Plant Computer, include a demonstration of compliance with DI&C-ISG-04 for safety to non-safety communications.
31 RAI No. 4 (contd)
Define data communications.
Assemble Architecture Diagram to depict data communication for Safety-to-Non-safety communications:
SN: Within PRNM, between Channels
NN: Between PRNM and the NUMAC Interface Computer (NIC)
NN: Between NIC and Plant Process Computer (PPC) 32 32 Communications within PRNM GEH PROPRIETARY INFORMATION
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33 33 PRNM-to-NIC Communications GEH PROPRIETARY INFORMATION
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34 NIC-to-PPC Communications GEH PROPRIETARY INFORMATION
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35 RAI No. 4 (contd)
Demonstrate compliance with ISG-04 for data communications among the four PRNM channels.
Will provide PRNM Compliance Matrix to ISG-04
Demonstrate compliance with ISG-04 between the PRNM System and the Plant Computer for Safety-to-Non-safety communications.
ISG-04 Compliance Matrix not developed for NIC-to-PPC communication since it is NN.
36 RAI No. 10 To support NRC assessment of the acceptability of the LAR for the Grand Gulf PRNM System setpoints, please provide documentation (including representative calculations) of the setpoint methodology used for establishing the limiting setpoint (or NSP) and the limiting acceptable values for the As-Found and As-Left setpoints.
Please indicate the related Analytical Limits and other limiting design values (and the sources of these values) for each setpoint.
In addition to demonstration of acceptable values for the new OPRM Upscale setpoint, the representative calculations should reflect the upgraded equipment to confirm values for existing setpoints, such as Neutron Flux-High (Setdown), Fixed Neutron Flux-High, and Flow Biased Simulated Thermal Power-High.
37 RAI No. 10 (contd)
Setpoint Methodology (Non-OPRM)
Setpoint calculations based on GEH methodology approved by NRC (NEDC-31336P-A)
Establishes margins between:
Analytical Limit (AL) to Allowable Value (AV)
AL to Nominal Trip Setpoint 1 (NTSP1) [Limiting Trip Setpoint (LTSP)]
AV to NTSP-Adjusted [NTSP(Adj)] (a measure of satisfactory instrument performance)
NTSP(Adj) is further from AL than NTSP1
Includes allowance for As-Left Tolerance (ALT)
Representative calculations available for review 38 GEH Setpoint Methodology GEH PROPRIETARY INFORMATION
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39 GEH LAT Adjustment GEH PROPRIETARY INFORMATION
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40 GEH NTSP Result Comparisons Example: APRM Neutron Flux Scram
41 RAI No. 10 (contd)
Setpoint Methodology - OPRM
Demonstration calculations for the nominal setpoints of the OPRM Upscale function follow standard stability methodology, previously approved by NRC (NEDO-32465-A).
Per the licensed methodology, stability analysis is based on nominal setpoints; there are no AL or AV values for the OPRM setpoints.
42 Closing Remarks