GNRO-2010/00070, Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System

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

ML103490095
Person / Time
Site:	Grand Gulf
Issue date:	12/14/2010
From:	Krupa M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2010/00070, TAC ME2531
Download: ML103490095 (19)

Text

Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 Michael A. Krupa Director, Extended Power Uprate Grand Gulf Nuclear Station Tel. (601) 437-6694 GNRO-2010/00070 December 14, 2010 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

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

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

REFERENCES:

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

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

2. NRC letter to Entergy Operations, Inc. (GNRI-2010/00067),

Request for Additional Information Re: Power Range Neutron Monitoring System, May 4, 2010 (ADAMS Accession No. ML101190125)

3. Entergy Operations, Inc. letter to the NRC (GNRO-2010/00040),

Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System, June 3, 2010 (ADAMS Accession No. ML101790436)

Dear Sir or Madam:

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

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

In Reference 2, the NRC staff transmitted to Entergy requests for additional information (RAIs) needed to support their review and approval of the LAR. Entergy submitted responses to several of the RAIs via Reference 3; however, Entergy provided only a partial response to RAI No. 5 at that time. Entergy committed to provide the remaining information on or before January 17, 2011. By this letter, Entergy is providing a response to RAI No. 5, which includes the requested equipment qualification information, in Attachment 1.

GNRO-2010/00070 Page 2 of 2 In regards to the PRNMS LAR submitted via Reference 1, Entergy discovered a typographical error in proposed Note (e), which is to be incorporated into TS Table 3.3.1.1-1 via Insert E provided on page 14 of Attachment 3 of Reference 1. Specifically, Note (e) contains a sentence that currently reads, Setpoints more conservative that 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 sentence should read, 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. A corrected marked-up page is provided in Attachment 2.

Please replace the current page with the corrected page.

The No Significance Hazards Determination and the Environmental Consideration provided in Reference 1 are not impacted by the information contained in this letter.

This letter contains no new commitments.

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 December 14, 2010.

Sincerely, MAK/ghd Attachments: 1. Response to RAI No. 5

2. Corrected Page 14 of 20 of Attachment 3 to the PRNMS LAR cc: Mr. Elmo E. Collins, Jr.

Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 612 East Lamar Blvd., Suite 400 Arlington, TX 76011-4005 U. S. Nuclear Regulatory Commission ATTN: Mr. A. B. Wang, NRR/DORL Mail Stop OWFN/8 G14 11555 Rockville Pike Rockville, MD 20852-2378 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

ATTACHMENT 1 GNRO-2010/00070 RESPONSE TO RAI No. 5 to GNRO-2010/00070 Page 1 of 14 RESPONSE TO RAI No. 5 NRC RAI No. 5 In accordance with the NUMAC PRNM LTR, both the documentation of the qualification activities and the licensees confirmation should be included in the plant-specific licensing submittals; 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 Grand Gulf Power Range Neutron Monitoring (PRNM) System configuration are enveloped by the conditions to which GE NUMAC PRNM System equipment has been environmentally qualified (for example, Regulatory Guide 1.89, IEEE 323-1974, IEEE 323-1983, Regulatory Guide 1.100, 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 for the LTR requires plant-specific action to confirm appropriate qualification has been completed. However, as is indicated in the following table the LAR does not identify the applicable Grand Gulf environmental conditions nor confirm that they have been enveloped by equipment qualification or analysis.

LAR Qualification SER Attachment 2 RAI Issue to be Resolved Item Paragraph Entry Temperature 3.4.1 4.4.2.2.1.4 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.

Humidity 3.4.1 4.4.2.2.1.4 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.

Pressure 3.4.2 4.4.2.2.2.4 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.

Radiation 3.4.2 4.4.2.2.3.4 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.

Seismic 3.4.3 4.4.2.3.4 Please provide documentation of the qualification action and that the licensees confirmation has taken place.

to GNRO-2010/00070 Page 2 of 14 LAR Qualification SER Attachment 2 RAI Issue to be Resolved Item Paragraph Entry EMI 3.4.4 4.4.2.4.4 Please provide direct testing references to the Compatibility 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.

Response

This RAI requests Entergy to:

(1) Provide the worst-case environmental conditions in which the equipment is required to remain operable for temperature, humidity, pressure, and radiation (LAR Attachment 2, Sections 4.4.2.2.1.4, 4.4.2.2.2.4, and 4.4.2.2.3.4);

(2) Confirm these worst-case conditions have been enveloped by equipment qualification or analysis; and (3) Provide documentation to confirm qualification actions for seismic conditions and electromagnetic interference (EMI) compatibility have taken place (LAR Attachment 2, Sections 4.4.2.3.4 and 4.4.2.4.4).

Responses to each of the above items are provided below.

(1) Provide the worst-case environmental conditions in which the equipment is required to remain operable for temperature, humidity, pressure, and radiation (LAR Attachment 2, Sections 4.4.2.2.1.4, 4.4.2.2.2.4, and 4.4.2.2.3.4).

Response

The GGNS PRNM System equipment is to be installed at various locations in the GGNS control room environment envelope. This envelope is classified as a mild environment in accordance with 10 CFR 50.49(c) in that the control room environment would at no time be significantly more severe than the environment that would occur during normal plant operation, including anticipated operational occurrences.

Attachment 2 of the PRNM System LAR contains GE-Hitachi Nuclear Energy Report 0000-0102-0888-R0, Grand Gulf Nuclear Station - Plant-Specific Responses Required by NUMAC PRNM Retrofit Plus Option III Stability Trip Function Topical Report (NEDC-32410P-A). Entergy revised the information contained in Sections 4.4.2.2.1.4, 4.4.2.2.2.4, and 4.4.2.2.3.4 of this report to indicate the ranges of values reflecting the worst-case conditions for the identified parameters, as requested. These ranges of values were contained in NEDC-32410P-A for the generic PRNMS equipment. A revised report, 0000-0102-0888-R1, was provided to the NRC in Attachment 5 of Entergys letter to the NRC (GNRO-2010/00040), Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System, dated June 3, 2010 (ADAMS Accession No.

to GNRO-2010/00070 Page 3 of 14 ML101790436). Since that submittal, GEH has performed equipment qualification tests on the GGNS-specific PRNMS equipment. Based on these tests, GEH has determined the NUMAC qualification environmental levels for the GGNS PRNMS equipment to be as presented in Table 1-1.

Table 1-1 NUMAC PRNM Qualified Environmental Levels Parameter Minimum Nominal Maximum Temperature, Operating (°F) 40 77 122 1

Humidity, Operating (% RH) 20 50 90 Pressure, Static (psia) 13 16 Radiation, Gamma Rate (rad/hr) 0.0005 Radiation, Gamma TID (rad) 1000 Therefore, the ranges of values presented in Table 1-1 for temperature, humidity, and radiation supersede the information provided in Sections 4.4.2.2.1.4, 4.4.2.2.2.4, and 4.4.2.2.3.4 of revised report 0000-0102-0888-R1.

(2) Confirm these worst-case conditions (for temperature, pressure, humidity, and radiation) have been enveloped by equipment qualification or analysis.

Response

NUMAC PRNM Equipment List Table 2-1 lists the NUMAC PRNM hardware to be installed in the GGNS control room.

Table 2-1 NUMAC PRNM Hardware Item Component Name a Average Power Range Monitor (APRM) b PRNM Communication Interface (PCI) c Quad Low Voltage Power Supply (QLVPS) d Two-Out-Of-Four Logic Module e LPRM Connector Panels f 4-Channel Analog Isolator g Fiber Optic Bypass Switch 1

Non-condensing to GNRO-2010/00070 Page 4 of 14 Item Component Name h PRNM Calibration and Monitoring Panel i Fiber Optic Cables j Cables (electrical) k LPRM Display / Flow Interface Panel l PRNM Cabinet (installation parts) m NUMAC Interface Computer (NIC)

The APRM module (Item a) is a newer design than the component that was previously used in the PRNM System. The PCI module (Item b) is specific to the BWR/6 design.

The remaining items are generic to all PRNM System designs.

The PRNM equipment, except the fiber optic bypass switch (Item g) and the NUMAC Interface Computer (NIC) (Item m), are to be installed in safety-related panels Q1H13-P669, P670, P671, and P672. The fiber optic bypass switch is to be installed in panel Q1H13-P680, the operator bench board, replacing the two current APRM bypass switches in the panel while the two NIC modules are to be installed in non-safety-related panels N1C91-P865 and P866.

GGNS Environmental Qualification Requirements Table 2-2 lists the GGNS control room environment requirements, which encompass the PRNM equipment mounting locations.

Table 2-2 GGNS Control Room Environment Requirements Parameter Minimum Nominal Maximum Temperature (°F) 60 72 to 78 90 Humidity, Operating (% RH) 20 50 Pressure, Static (inch w.g.) 0.1 1.0 Radiation, Gamma Rate (rad/hr) 0.0005 Radiation, Gamma TID (rad) 180 NUMAC Qualified Environmental Levels The NIC modules (Item m of Table 2-1) are non-safety-related and, therefore, not Class 1E. As such, they are not required to be environmentally qualified. Therefore, the information contained in this section is not pertinent to the NIC.

Qualification is based on type testing -- either an assembly of the same design as the final product or an assembly that is sufficiently similar that an analysis can demonstrate equivalency for qualification purposes. Qualification tests include measurement of to GNRO-2010/00070 Page 5 of 14 critical parameters to assure performance within module specifications over the full environmental range.

As part of the original system qualification, the generic components of the PRNM System design (Items c through l of Table 2-1) were tested in accordance with IEEE Standard 323-1983, Standard for Qualification of Class 1E Equipment for Nuclear Power Generating Stations. The APRM and the PIC (Items a and b of Table 2-1) were tested in accordance with IEEE Standard 323-2003.

The identified GGNS PRNM components are qualified to function without degradation when subjected to the environmental conditions listed in Table 1-1, above.

Evaluation of Environmental Conditions The qualification evaluations for temperature, pressure, humidity, and radiation are discussed separately below.

x Temperature To demonstrate qualification of the PRNM equipment at each installed location, it is necessary to determine the temperature rise in the mounting cabinet, and demonstrate that the temperature rise added to the maximum room ambient temperature does not exceed the equipments qualified limits. Because the equipment is stacked in panels P669, P670, P671, and P672 (resulting in lower equipment becoming heat sources for higher equipment), it is concluded that the maximum temperature to which PRNM equipment will be exposed is higher in these panels than in panel P680. If the maximum temperature at the mounting locations in panels P669 through P672 can be demonstrated to be enveloped by the PRNM equipment qualification levels, then the maximum temperature at the mounting location in panel P680 will also be enveloped by the PRNM equipment qualification levels.

To determine the maximum temperature at the equipment locations in panels P669 through P672, the maximum environmental temperature is added to the maximum temperature rise in the panel due to the heat generated by the equipment. The maximum operating environmental temperature at GGNS is 90qF (see Table 2-2, above). GEH performed temperature rise measurements on generic PRNM equipment installed in staging panels with the same layout and arrangement as the actual plant panels. The maximum temperature rise recorded was less than 15qF, with the temperature rise in most areas less than 10qF. For conservatism, the temperature rise test report recommends a temperature rise of 20qF for qualification analyses. Due to similarity in the equipment (heat source) and between the staged panel layout and the GGNS panel design, it is concluded that the temperature rise within the GGNS panels will be essentially the same as observed in the tests.

Therefore, the estimated maximum temperature at the equipment locations in panels P669 through P672 is 110qF (the sum of 90qF and 20qF). The qualified temperature of the PRNM equipment is 122qF (see Table 1-1), which is greater than the in-panel maximum temperature of 110qF.

to GNRO-2010/00070 Page 6 of 14 The minimum temperature at the equipment locations is conservatively assumed to be the same as the panel minimum temperature (i.e., assuming no temperature rise). The minimum control room temperature is 60qF (see Table 2-2), which is greater than the minimum qualified temperature of 40qF (see Table 1-1).

x Pressure The control room is classified as a mild environment. A comparison of Tables 1-1 and 2-2 concludes that the pressure levels in the control room of 0.1 to 1.0 inch w.g.

(14.70361 to 14.7361 psia) given in Table 2-2 are within the NUMAC PRNM qualified environmental levels of 13 to 16 psia given in Table 1-1.

x Humidity The control room is classified as a mild environment. A comparison of Tables 1-1 and 2-2 concludes that the humidity levels in the control room of 20% to 50%

relative humidity (RH) given in Table 2-2 are within the NUMAC PRNM qualified environmental levels of 20% to 90% RH given in Table 1-1.

x Radiation The control room panels are in a low radiation area with levels below those to which the NUMAC equipment is qualified. The NUMAC PRNM equipment is qualified to a radiation Gamma Rate of 0.0005 rad/hr and a Gamma Total Integrated Dose of 1000 rad given in Table 1-1, which are greater than or equal to the control room values of 0.0005 rad/hr and 180 rad given in Table 2-2.

Conclusion Based on the information presented above, Entergy confirms the NUMAC qualified environmental levels for the GGNS PRNM equipment envelope the GGNS environmental qualification requirements.

(3) Provide documentation to confirm qualification actions for seismic conditions and EMI compatibility have taken place (LAR Attachment 2, Sections 4.4.2.3.4 and 4.4.2.4.4).

Response

Seismic qualification and EMI compatibility are each discussed below.

1. Seismic Qualification NUMAC Qualified Seismic Levels The GGNS PRNM System safety-related electronics are seismically qualified by type testing and analysis to demonstrate that the PRNMS will perform all specified functions correctly when mounted in accordance with specified mounting methods and operated within the specified seismic limits.

to GNRO-2010/00070 Page 7 of 14 As part of the original system qualification, the generic components of the PRNM System design (Items c through l of Table 2-1) were tested in accordance with IEEE Standard 344-1975, Recommended Practices for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations. This testing was later performed to IEEE Standard 344-1987 requirements. The APRM and the PIC (Items a and b of Table 2-1) were tested in accordance with IEEE Standard 344-2004.

The generic components of the PRNM System design (Items c through l of Table 2-1) are qualified to function without degradation when subjected to Safe Shutdown Earthquake (SSE) and Operating Basis Earthquake (OBE) seismic Required Response Spectra (RRS) in accordance with IEEE Standard 344-1987 and specified in Table 3-1.

Table 3-1 Required Response Spectra for Generic Components (3% damping)

Acceleration Frequency Fault (SSE) Upset (OBE) 1 Hz 1.0 g 1.0 g 4 Hz 10.8 g 7.2 g 19 Hz 10.8 g 7.2 g 30 Hz 6.0 g 4.0 g 100 Hz 6.0 g 4.0 g The APRM and the PIC (Items a and b of Table 2-1) are qualified to function without degradation when subjected to the SSE and OBE RRS in accordance with IEEE Standard 344-2004 and specified in Table 3-2.

Table 3-2 Required Response Spectra for APRM and PCI (3% damping)

Acceleration Frequency Fault (SSE) Fault (SSE) Upset (OBE) Upset (OBE)

Horizontal Vertical Horizontal Vertical 1 Hz 1.1 g 1.1 g 1.1 g 1.1 g 4 Hz 11.8 g 11.8 g 7.9 g 7.9 g 6 Hz 11.8 g 11.8 g 7.9 g 7.9 g 7 Hz 11.8 g 12.4 g 7.9 g 10.2 g 10 Hz 11.8 g 12.4 g 7.9 g 10.2 g 10.50 Hz 11.8 g 11.8 g 7.9 g 9.0 g 13 Hz 11.8 g 11.8 g 7.9 g 9.0 g to GNRO-2010/00070 Page 8 of 14 Acceleration Frequency Fault (SSE) Fault (SSE) Upset (OBE) Upset (OBE)

Horizontal Vertical Horizontal Vertical 13.50 Hz 11.8 g 11.8 g 7.9 g 8.26 g 18 Hz 11.8 g 11.8 g 7.9 g 8.26 g 19 Hz 11.8 g 11.8 g 7.9 g 7.9 g 30 Hz 6.6 g 6.6 g 4.4 g N/A 40 Hz 6.6 g 6.6 g 4.4 g 4.4 g 100 Hz 6.6 g 6.6 g 4.4 g 4.4 g The RRS defined in Tables 3-1 and 3-2 do not apply to the NIC (Item m in Table 2-1), which is non-safety-related and is to be installed in non-safety-related panels 1C91-P865 and P866.

GGNS Seismic Qualification Requirements The GGNS seismic floor input spectra for the OBE and the SSE are provided in Figures 3-1 and 3-2.

to GNRO-2010/00070 100.00 Page 9 of 14 10.00 1500 FREQUENCY (cps) 0700 0300 0200 1.00 DAMPING VALUES 0050 0100 1.00 0.00 0.00 ACCELERATION (g)

Control Building OBE Floor Spectrum - El. 166' (3% Damping)

Figure 3-1 to GNRO-2010/00070 Page 10 of 14 FREQUENCY (Hz)

ACCELERATION (g)

Control Building SSE Floor Spectrum - El. 166' (3% Damping)

Figure 3-2 to GNRO-2010/00070 Page 11 of 14 Evaluation of Seismic Conditions x Panels 1H13-P669, P670, P671, and P672 GGNS control room panels P669 through P672 were analyzed based on the GGNS control room floor seismic spectrum to determine the seismic spectrum at the equipment mounting locations.

The analysis concluded that the NUMAC PRNM equipment is dynamically qualified for the GGNS seismic input motions (see Figures 3-1 and 3-2, above).

This is demonstrated by showing that NUMAC test input motion RRS specified in Table 3-1 and 3-2, above, envelops the corresponding upper bound NUMAC in-panel response spectra throughout the frequency range of interest.

Stresses in the modified panels have been evaluated at critical locations (corner posts and unistrut) for the SSE event and found to be within acceptable limits.

x Panel 1H13-P680 The two existing APRM bypass switches, located on either side of the central reactor core display in the P680 panel, are to be replaced with one new fiber optic bypass switch. The new bypass switch, which maintains the same look, feel, and function of the existing switches, will be installed in the location vacated by the existing left-hand switch. (The location of the right-hand switch will be blanked off.) Because the P680 panel is safety-related and, therefore, seismically-qualified, Entergy performed a seismic evaluation reflecting the new bypass switch. This evaluation determined the new fiber optic bypass switch has no impact on the seismic qualification of the P680 panel.

x Panels 1C91-P865 and P866 The NIC modules are non-safety-related and are to be installed in non-safety-related panels 1C91-P865 and P866. These panels are in proximity (~15 feet) to safety-related panel Q1H13-P879. Although the NIC modules themselves are not required to be seismically qualified, Entergy performed a seismic evaluation to ascertain the potential impact of panels P865 and P866 with the NIC modules installed on panel P879. Taking into account panels P865 and P866 are rigidly mounted to the floor and are an appropriate distance from P879, the evaluation concluded P865 and P866 present no seismic concern.

Conclusion The information presented above documents and confirms qualification actions for seismic conditions have taken place, and that the NUMAC qualified seismic levels bound the GGNS seismic qualification requirements.

to GNRO-2010/00070 Page 12 of 14

2. EMI Compatibility NUMAC Qualified Electromagnetic Compatibility (EMC) Levels The GGNS PRNM System components in panels 1H13-P669, P670, P671, and P672, when mounted in accordance with the specified methods, are qualified by type testing and analysis to demonstrate that the PRNM System will perform all specified functions when operated with the specified EMC limits contained in Tables 3-3 and 3-4. Tests and levels/frequencies chosen meet the latest requirements provided in Regulatory Guide (RG) 1.180, Revision 1, Guidelines for Evaluating Electromagnetic and Radio-Frequency Interference in Safety-Related Instrumentation and Control Systems.

Table 3-3 Qualified EMC Susceptibility Levels EMC Test Test Levels Electrostatic IEC 61000-4-2 8 kV contact, 15 kV air Discharge (ESD)

High Frequency Radiated IEC 61000-4-3 / RS103 10 V/M (26 MHz to 18 GHz)

Electromagnetic Field Immunity Electrical Fast IEC 801-4 /

Transient (EFT) / +/- 2 kV power lines, +/- 1 kV other lines IEC 61000-4-4 Burst IEC 61000-4-5 / +/- 4 kV power, +/- 2 kV shields & grounds Surge Immunity IEC 61000-4-12 100 kHz & 1 MHz ring waves High Frequency IEC 61000-4-6 / CS114 Conducted 97 dBA (10 kHz to 200 MHz)

(as allowed by RG 1.180)

Susceptibility Low Frequency 136 dBV (30 Hz to 5 kHz) to 116 dBV MIL Std 461E CS101-1 Conducted (150 kHz)

Low Frequency 180 dBpT (30 Hz to 60 Hz) to 116 dBpT MIL Std 461E RS101-2 Radiated (100 kHz) to GNRO-2010/00070 Page 13 of 14 Table 3-4 Qualified EMC Emission Levels EMI Test Test Levels 120 dBA (60 Hz) to 86 dBA (10 kHz) Pwr < 1 kVA, 90 dBA (120 Hz to 1.92 kHz) to 76 dBA (10 kHz)

Power Leads, Low MIL Std 461E Pwr > 1k VA Frequency Conducted CE101-2 For fundamental current > 1 A, curve can be relaxed by dB relax = 20 Log (fundamental current)

Power Leads, High MIL Std 461E 100 dBV (10 kHz) to 66 dBV (500 kHz to 10 MHz)

Frequency Conducted CE102-1 Magnetic Fields, Low MIL Std 461E 160 dBpT (30 Hz) to 90 dBpT (100 kHz)

Frequency Radiated RE101-1 Electric Fields, High MIL Std 461E Frequency Radiated 44 dBV/M (2 MHz to 100 MHz) to 89 dBV/M (18 GHz)

RE102-4 Emissions Tables 3-5 and 3-6 include the EMC qualification requirements for the NIC. These requirements are based on Revision 3 of EPRI TR-102323, Guidelines for Electromagnetic Interference Testing in Power Plants.

Table 3-5 Qualified EMC Susceptibility Levels for the NIC EMC Test Test Levels Electrostatic IEC 61000-4-2 8 kV contact, 15 kV air Discharge (ESD)

High Frequency Radiated IEC 61000-4-3 10 V/M (30 MHz to 10 GHz)

Electromagnetic Field Immunity Electrical Fast IEC 61000-4-4 +/- 2 kV power lines, +/- 1 kV other lines Transient (EFT)/Burst Surge Immunity IEC 61000-4-5 +/- 4 kV High Frequency Conducted IEC 61000-4-7 97 dBA (10 kHz to 200 MHz)

Susceptibility Low Frequency MIL Std 461E 136 dBV (30 Hz to 5 kHz) to 116 dBV (50 kHz)

Conducted CS101-1 Low Frequency MIL Std 461E 180 dBpT (30 Hz to 60 Hz) to 116 dBpT (100 kHz)

Radiated RS101-2 to GNRO-2010/00070 Page 14 of 14 Table 3-6 Qualified EMC Emissions Levels for the NIC EMI Test Test Levels Power Leads, Low MIL Std 461E 110 dBA (30 Hz to 1 kHz) to 90 dBA (10 kHz)

Frequency Conducted CE101-2 Power Leads, High MIL Std 461E 124 dBV (10 kHz) to 94 dBV (100 kHz) to Frequency Conducted CE102-1 74 dBV (10 MHz)

Magnetic Fields, Low MIL Std 461E 160 dBpT (30 Hz to 60 Hz) to 96 dBpT (100 kHz)

Frequency Radiated RE101-1 Electric Fields, High MIL Std 461E 95 dBV/m (10 kHz) to 80 dBV/m (80 kHz to 1 MHz) to Frequency Radiated RE102-4 66 dBV/m (100 MHz to 10 GHz)

Emissions GGNS EMC Qualification Requirements The GGNS control room is identified and administratively controlled in accordance with procedure EN-DC-217, Control of Temporary, Portable, or Hand Held EMI/RFI Emitting Equipment, as a radio exclusion zone in order to eliminate and/or mitigate radio frequency interference (RFI) that may affect safety-related instrumentation. This procedure requires that new equipment being installed in the plant be evaluated to determine its sensitivity to EMI/RFI and also its emission of EMI/RFI that may affect nearby equipment.

Evaluation of EMI Compatibility EMC susceptibility and emissions testing was performed by type testing using a representative system comprising the PRNM sub-assemblies, interconnecting cables and fluorescent fixtures and switches typically found in a panel. The equipment was mounted in a two-bay steel panel representative of the actual field mounting. The test results met the acceptance criteria levels specified in Tables 3-3 through 3-6, above, thereby confirming the PRNM components will neither be affected by nor affect other instrumentation within the control room. This conforms to the GGNS requirements specified in EN-DC-217 and maintains the control room as a radio exclusion zone.

Conclusion The information presented above documents and confirms qualification actions for EMI compatibility have taken place, and that the NUMAC PRNM components meet the GGNS EMC qualification requirements.

ATTACHMENT 2 GNRO-2010/00070 CORRECTED PAGE 14 OF 20 OF ATTACHMENT 3 TO THE PRNMS LAR

INSERT D - New APRM Functions 2.e and 2.f

e. 2-Out-Of-4 Voter 1, 2 2 H SR 3.3.1.1.19 NA SR 3.3.1.1.20 SR 3.3.1.1.21 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 (c), (d), (e), and (f)

(c) 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 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.

(f) The Allowable Value for the OPRM Upscale Period-Based Detection algorithm is specified in the COLR.