GNRO-2011/00045, Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System

Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System

ML111800505
Person / Time
Site:	Grand Gulf
Issue date:	06/28/2011
From:	Krupa M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML111800503	List: GNRO-2011/00045, Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System
References
GNRO-2011/00045, TAC ME2531
Download: ML111800505 (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 Attachment 1 contains PROPRIETARY information.

GNRO-2011/00045 June 28, 2011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

Supplemental 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. Entergy Operations, Inc. letter to the NRC (GNRO-2011/00032),

Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System, May 3, 2011 (ADAMS Accession No. ML111230756)

Dear Sir or Madam:

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

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

In Reference 2, Entergy submitted to the NRC staff responses to eight Requests for Additional Information (RAIs) pertaining to the PRNMS LAR. Upon further communication with the staff, Entergy is supplementing the responses to RAIs 4, 13, 16, and 26 provided in Reference 2 with additional information provided in Attachment 1.

GEH considers certain information contained in Attachment 1 to be proprietary and, therefore, requests it be withheld from public disclosure in accordance with 10 CFR 2.390. A non-proprietary, redacted version of Attachment 1 is provided in Attachment 2, with the associated affidavit provided in Attachment 3.

When Attachment 1 is removed from this letter, the entire document is NON-PROPRIETARY.

GNRO-2011/00045 Page 2 of 3 The No Significance Hazards Determination and the Environmental Consideration provided in Reference 1 are not impacted by these responses.

This letter contains new commitments, which are identified in Attachment 4.

If you have any questions or require additional information, please contact Mr. Guy Davant at (601) 368-5756.

I declare under penalty of perjury that the foregoing is true and correct; executed on June 28, 2011.

Sincerely, MAK/ghd Attachments: 1. Supplemental Information Pertaining to License Amendment Request -

Power Range Neutron Monitoring System Upgrade (Proprietary Version)

2. Supplemental Information Pertaining to License Amendment Request -

Power Range Neutron Monitoring System Upgrade (Non-Proprietary Version)

3. GEH Affidavit Supporting Proprietary Information provided in Attachment 1

4. List of Regulatory Commitments

GNRO-2011/00045 Page 3 of 3 cc: Mr. Elmo E. Collins, Jr.

Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 612 East Lamar Blvd., Suite 400 Arlington, TX 76011-4005 U. S. Nuclear Regulatory Commission ATTN: Mr. A. B. Wang, NRR/DORL (w/2)

ATTN: ADDRESSEE ONLY ATTN: Courier Delivery Only Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378 State Health Officer Mississippi Department of Health P. O. Box 1700 Jackson, MS 39215-1700 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

ATTACHMENT 1 GNRO-2011/00045 SUPPLEMENTAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE (PROPRIETARY VERSION)

The header of each page in this attachment carries the notation GEH Proprietary Information. The GEH proprietary information is identified by double square brackets. ((This sentence is an example. {3}))

The superscript notation {3} refers to Paragraph (3) of the accompanying affidavit contained in Attachment 3, which provides the basis for the proprietary determination. Specific information that is not so marked is not GEH proprietary.

ATTACHMENT 2 GNRO-2011/00045 SUPPLEMENTAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE (NON-PROPRIETARY VERSION) to GNRO-2011/00045 Page 1 of 8 NON-PROPRIETARY INFORMATION SUPPLEMENTAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE By application dated November 3, 2009, Entergy Operations, Inc. (Entergy) requested NRC staff approval of an amendment to the Grand Gulf Nuclear Station, Unit 1 (GGNS) Technical Specifications (TS) to reflect installation of the digital General Electric - Hitachi (GEH) Nuclear Management Analysis and Control (NUMAC) Power Range Neutron Monitoring System (PRNMS).1 On May 3, 2011, Entergy submitted to the NRC staff responses to eight Requests for Additional Information (RAIs) pertaining to the PRNMS LAR.2 Upon further communication with the staff, Entergy is supplementing the responses to RAIs 4, 13, 16, and 26 provided in the May 3 submittal with additional information provided below.

Request for Information - RAI 4 Response A remaining issue is acceptability of the proposed inclusion of DSS-CD software in the PRNMS of this LAR when it is not required by the safety functions that are currently proposed for licensing.

Under the Process Characteristics in BTP 7-14, provisions for correctness state that unused or unneeded functions should not be in safety-related software even if it is provided for future development or other reasons. Stated in the positive, safety-related software should only include used and needed functions, and this precludes other functions whose inclusion supports future development. BTP 7-14 goes on to state that the system and software requirements and the final code should be examined to ensure that only those features necessary to implement the safety functions and to perform system and software testing are included.

Based upon the licensees stated advantage to include the DSS-CD software as part of this LAR, one conclusion that could be reached is that the DSS-CD software is included as a cost/time-saving measure in preparation for a potential pursuit of a MELLLA+ LAR. However, this conclusion would not be based on safety considerations. The DSS-CD software is not currently used by the proposed safety functions even though the DSS-CD software is planned to actively execute within the safety system. If the licensee specified the DSS-CD software as a requirement then the licensee should justify it by providing statements that demonstrate the function is needed to implement safety functions or to perform system and software testing.

1 Entergy Operations, Inc. letter to the NRC, License Amendment Request - Power Range Neutron Monitoring System Upgrade, dated November 3, 2009 (ADAMS Accession No. ML093140463) 2 Entergy Operations, Inc. letter to the NRC (GNRO-2011/00032), Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System, May 3, 2011 (ADAMS Accession No. ML111230756) to GNRO-2011/00045 Page 2 of 8 NON-PROPRIETARY INFORMATION The staff also requests Entergy to describe any DSS-CD functions other than the trip function that is being jumpered out that may be available and utilized by plant personnel and how these functions are beneficial.

The wording of the RAI response states that including the DSS-CD software provides a period during which the DSS-CD algorithm may be observed while it operates in the background at the plant; however, this does not commit the licensee to use DSS-CD algorithm to perform system and software testing. Additionally, an observation period is typically required as part of a MELLLA+ LAR that relies upon the DSS-CD algorithm. Furthermore, there is neither a commitment for the licensee to pursue a MELLLA+ LAR nor is there is a guarantee that the proposed MELLLA+ LAR would be approved following its review.

The staff requests that the licensees response be supplemented to directly address the identified issue. The following may be considered in suitable combinations when addressing this issue:

• Removal of the DSS-CD software from this PRNMS LAR

• A licensing commitment to observe and document the DSS-CD performance as part of system testing following the PRNMS installation in preparation of the follow-up MELLLA+

LAR.

• An appropriate licensing condition to submit a MELLLA+ LAR by a specified date that would require use of the DSS-CD software.

• An appropriate licensing condition to have obtained approval of a MELLLA+ LAR that requires use of the DSS-CD by a specified date, or to remove the DSS-CD software.

• Other acceptable approaches Additional Information Regarding the presence of the Detect and Suppress-Confirmation Density (DSS-CD) stability solution software and its application to the Maximum Extended Load Line Limit Analysis -

Plus (MELLLA+) operating domain, Entergy commits to:

1. Monitor DSS-CD and evaluate data on performance during startup testing and plant operation in preparation for a MELLLA+ LAR;

2. Submit a MELLLA+ LAR by December 31, 2012, which requires the use of the DSS-CD software; and

3. Remove the jumpers from the DSS-CD trip function outputs once the MELLLA+ LAR has been approved and implemented.

During plant operation, the OPRM DSS-CD displays to the operators are available; however, the reactor trip outputs will be disabled with jumper wires as discussed in the response to RAI 4 provided in Attachment 1 to Entergy letter GNRO-2011/00032 (ADAMS Accession No. ML111230756).

to GNRO-2011/00045 Page 3 of 8 NON-PROPRIETARY INFORMATION Presented below is a discussion of the OPRM functions, including indications, that are available and utilized by plant personnel and how they are beneficial.

Discussion The OPRM channels detect reactor power oscillations using two stability solutions: Option III and DSS-CD.

• Option III uses three algorithms: Period-Based Detection, Amplitude-Based, and Growth-Rate-Based. These algorithms were generically approved by the NRC in the safety evaluation report (SER) for 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.

• DSS-CD uses the Confirmation Density Algorithm. This stability solution and its algorithm were generically approved by the NRC in the SER for GEH LTR NEDC-33075P, General Electric Boiling Water Reactor Detect and Suppress Solution - Confirmation Density.

Although the DSS-CD trip outputs will be disabled, the indications of the trip output signals, which are unaffected by the presence of the jumper wires, will be available. The front panels of the 2-Out-Of-4 Logic Modules include information about the three types of voted trip signals, which are OPRM DSS-CD, OPRM Option III, and APRM Upscale/INOP.

If an OPRM trip condition (either Option III or DSS-CD) occurs, the OPRM alarm annunciator will alert the operators whether or not the associated outputs to the Reactor Protection System (RPS) are disabled. Plant personnel can observe the specific details of the condition (type of trip input, which channels detected it, and type of trip output signal), even if the condition clears before there is an opportunity to take note of the 2-Out-Of-4 Logic Module Front Panel. ((

{3}

))

In addition, PRNMS constantly transmits information to the Plant Process Computer (PPC) via the NUMAC Interface Computer (NIC). This stream of information includes the real-time status of the OPRM trips and alarms, as well as the reactor condition as detected by each OPRM cell.

As noted above, Entergy will monitor the OPRM functions and evaluate data on the performance of the DSS-CD stability solution during startup testing and plant operation. Data to be considered in this evaluation includes OPRM cell signals (e.g., confirmation counts, amplitude, and oscillation periods) and DSS-CD trip/alarm logs. These data will confirm system performance in the actual operating environment, and determine the plant-specific noise level, which is a key input to the plant-specific DSS-CD setpoints provided in the planned MELLLA+ LAR. Monticello is undergoing a similar process for their transition from Option III to DSS-CD.

to GNRO-2011/00045 Page 4 of 8 NON-PROPRIETARY INFORMATION Conclusion Both the Option III and the DSS-CD stability solutions have been approved by the NRC. Both solutions provide safety-related functions that adequately detect and suppress reactor core instability events, as documented in their respective LTRs.

During plant operation following installation of PRNMS when the OPRM stability solutions (both Option III and DSS-CD) are running in the NUMAC APRM channels but the RPS outputs are disabled, there is sufficient information available to alert plant personnel of reactor conditions and to determine the nature of them. After Option III is placed into service, the outputs from the DSS-CD algorithm will continue to run with its indications available and monitored by operators, but with its trip outputs disabled until GGNS is licensed to operate in the MELLLA+ domain.

Request for Information - RAI 13 Response (Item 2)

A remaining issue is the classification and qualification of the RACS equipment which has been identified as non-safety-related even though it contains the isolators which the licensee has stated are used to establish the safety grade isolation boundary between it and the safety-related PRNMS 2-out-of-4 voters.

IEEE Std 603-1998 Clause 5.6.3.1, Interconnected equipment, states in part that Isolation devices used to effect a safety system boundary shall be classified as part of the safety system. and goes on to state that IEEE Std 384-1992 provides detailed criteria for the independence of Class 1E equipment and circuits.

The licensee response identifies RACS as non-safety and states that the RACS interface to the PRNMS is the same as currently exists with the APRM. The licensee states that isolators are provided at the RACS in RC&IS so that a failure in the equipment in the RACS will not affect the safety-related PRNMS equipment.

The staff requests that the licensees response be supplemented to directly address the identified issue. The licensee is requested to describe the RACS sufficiently to determine whether it satisfies the criteria for the independence of Class 1E equipment and circuits as identified in IEEE Std 384-1992 or explain how the approach provides equivalent safety assurance. Alternatively or additionally, if the licensee statement that RACS interface to the PRNMS is the same as currently exists with the APRM means that no changes have been made to the equipment associated with this interface and that the licensees position is that application of IEEE Std 603-1998 Clause 5.6.3.1 does not apply to this unchanged interface, then this licensee position should be clearly stated.

Additional Information The new PRNMS rod block circuits have relay outputs to the RACS that are compliant with IEEE Standard 603-1998 Clause 5.6.3.1. This is the same design approach used with the existing APRM system. The rod block circuits at the RACS end are also isolated, but are not compliant with IEEE Standard 603-1998 Clause 5.6.3.1. The RACS remains unchanged after PRNMS installation.

to GNRO-2011/00045 Page 5 of 8 NON-PROPRIETARY INFORMATION The PRNMS APRM rod block signals are provided to the RACS via Relay Logic Cards in the 2-Out-Of-4 Logic Module. The Relay Logic Cards are classified as part of the safety system consistent with IEEE Standard 603-1998 Clause 5.6.3.1 and provide the credited electrical isolation between the safety-related APRM instruments and the non-safety-related RACS.

Section 5.3.5.5 (2nd paragraph) of NEDC-32410P-A describes the isolation method as follows:

Digital signals (from the APRM to non-safety equipment) are sent through optically coupled relays rated at over 3000 volts input to output.

Per Section 6.4.3 of the Relay Logic Card Performance Specification 24A5250, the control input to contact output isolation voltage ratings for each Solid State Relay exceed the 3000-volt level stated in NEDC-32410P-A. No credible failure on the non-safety side of the isolation device can prevent the safety system from meeting its minimum performance requirement during and following any design basis event requiring the safety function.

As a clarification to the response to RAI 13 provided in Entergy letter GNRO-2001/00032, the isolation devices in the RACS provide additional protection and, therefore, result in a more conservative design. They do not, however, provide the credited isolation from the safety-related PRNMS equipment.

Request for Information - RAI 13 Response (Item 4)

A remaining issue is the definition of what the licensee has characterized as a hardware-based repeater and whether the implementation should be considered subject to evaluation for common-cause programming error. If common-cause programming errors are applicable, an evaluation that satisfies BTP 7-19 or provides equivalent safety assurance would apply to the program associated with the programmable devices.

The staff requests that the licensees response be supplemented to directly address whether a programmable device (PLD or other) is used to effect what has been termed as a hardware-based repeater and to provide sufficient analysis to evaluate common-cause programming errors, if applicable. In consideration of the licensees communication of its intended response to RAI #27, the staff request the licensee indicate whether any PLD logic has changed since the original LTR approval.

Additional Information The hardware-based repeater in each 2-Out-Of-4 Logic Module takes the home channel bypass signal, buffers it, and retransmits it using three fiber-optic transmitters to the other three 2-Out-Of-4 Logic Modules. This sharing of APRM bypass information between divisions is implemented entirely in hardware. Each bypass signal is a pulse train whose presence indicates the associated APRM channel is bypassed.

A PLD in each of the 2-Out-Of-4 Logic Modules detects the four pulse train signals (the home signal and the signals from the other three channels). The response to RAI 14 provided in Entergy letter GNRO-2011/00039 (ADAMS Accession No. ML111460590) provides a detailed discussion of this PLD and the other PLDs in the 2-Out-Of-4 Logic Module, including evaluation for common cause programming errors.

to GNRO-2011/00045 Page 6 of 8 NON-PROPRIETARY INFORMATION No PLD logic has changed since the original PRNMS LTR, NEDC-32410P-A, was approved; all functions performed in PLD devices are as described in the LTR. Some PLD-related changes have been required to address obsolescence issues and to correct problems, but these changes do not result in a deviation from the PLD logic described in the LTR.

Request for Information - RAI 16 Response A remaining issue is whether the potential for common-cause programming errors exists by which all safety divisions might accept pending gain adjustments without operator acceptance, because both the password and key-lock provide only software disables and the signals that provide gain data to the APRM/LPRM always remain active.

The staff requests that the licensee supplement its response to directly address the potential for software that is common to all four safety channels to effect APRM safety functions. This description should provide sufficient analysis to evaluate the postulated common-cause programming error. In consideration of the licensees intended response to RAI #8, the staff requests the licensee to describe the degree, if any, that this response addresses plant vulnerabilities from common-cause programming error that has been postulated.

Additional Information The responses to RAIs 8 and 9 provided in Attachment 1 to Entergy letter GNRO-2011/00039 address common-cause programming failures and how the plant maintains its ability to cope with any such failures in PRNMS. A worst-case common-cause failure (CCF) in PRNMS was postulated in order to perform the Diversity and Defense-in-Depth (D3) assessment. Rather than postulating individual CCFs in each of the programmable entities (((

{3}

))), a single CCF that completely impairs PRNMS was assumed. The postulated CCF in PRNMS was assumed to remain latent and non-detectable until the system is stressed by an event or accident, at which time all PRNMS outputs from all four channels are absent or incorrect. In other words, the system was assumed to:

• Provide no advanced notice of trouble,

• Fail to provide the correct responses such as rod blocks and trips during a transient, and

• Provide misleading indications of plant parameters during the transient.

The analyses provided in the responses to RAIs 8 and 9 document that the plant is able to cope with a CCF in PRNMS. Refer to those responses for more information.

Request for Information - RAI 16 Response [Item (b)]

1. For which, if any, of the following activities performed on a PRNMS instrument will that channel be placed into BYPASS via the common APRM bypass switch?

a. OPERATE-SET (password only for APRM gain adjustments)

b. INOP-SET (keylock and password for LPRM gain adjustments and APRM gain adjustments) to GNRO-2011/00045 Page 7 of 8 NON-PROPRIETARY INFORMATION

c. INOP-CAL (keylock only for calibration mode that takes the instrument out of service)

2. Since the NUMAC PRNMS design allows for the APRM gain adjustments to be performed in either OPERATE-SET or INOP-SET, will GGNS procedurally require INOP-SET or allow OPERATE-SET as well?

Additional Information When performing APRM and LPRM gain adjustments via the INOP-SET mode or when performing calibration activities via the INOP-CAL mode, the PRNMS instrument initiates an INOP trip condition, which is transmitted to RPS. In order avoid this condition, the PRNMS channel must be placed in BYPASS. (Gain adjustments are not performed when in INOP-CAL.) Unlike the INOP-SET and INOP-CAL modes, the PRNMS instrument does not initiate an INOP trip condition when in OPERATE-SET.

To ensure APRM gain adjustments are performed only on bypassed PRNMS instruments, Entergy commits to implement procedure controls that require the instrument to be placed in BYPASS when making these adjustments.

Request for Information - RAI 26 Response A remaining issue is adequacy of the justification for transmitting the Recirculation Flow channel check alarm status from the PCI (non-safety-related) to the APRM (safety-related) in order to have the APRM create an associated alarm indication output.

As described in the licensees RAI responses, each PCI (non-safety-related) performs the algorithm to determine Recirculation Flow channel check alarm status. This algorithm requires status data that originates from independent safety channels and divisions via one-way safety-to-non-safety communications and via non-safety-to-non-safety communications, respectively. Therefore, each indication subsequently produced by an APRM is dependent on all other channels data.

The licensee response characterizes the APRM operations to process the Recirculation Flow channel check alarm status data and create the indication output as simple, and states that this process is executed on a lower priority basis than the safety functions. However, the licensees response to this RAI did not describe the format and protocol associated with the Recirculation Flow channel check alarm status. Regardless, the Recirculation Flow channel check alarm indication function is not a safety-related function, and ISG-04 position 1.3 states in part that A safety channel should not receive any communication from outside its own safety division unless that communication supports or enhances the performance of the safety function. Receipt of information that does not support or enhance the safety function would involve the performance of functions that are not directly related to the safety function.

This point goes on to state that such functions executed within a safety system could also result in unacceptable influence of one division over another, or could involve functions not directly related to the safety functions, and should not be executed within the safety system.

The staff requests that the licensee supplement its response to specifically address ISG-04 position 1.3 and explain how the proposed approach supports or enhances the performance of the safety function, or alternatively provides equivalent safety assurance by demonstrating that performing this function does not result in an unacceptable influence.

to GNRO-2011/00045 Page 8 of 8 NON-PROPRIETARY INFORMATION Additional Information Staff Position 1.3 of DI&C-ISG-04 states in part:

A safety channel should not receive any communication from outside its own safety division unless that communication supports or enhances the performance of the safety function.

The recirculation flow-compare alarm complies with this aspect of the Staff Position because it enhances the flow-biased APRM safety functions by alerting the operator to flow measurement problems that could have an adverse effect on the ability of the affected APRM channel to correctly perform its flow-biased safety functions. Alerting the operator to an abnormal condition allows the operator to initiate corrective action in a timely manner.

((

{3}

)) This design approach is consistent with Staff Position 1.3 that, Functions that are not necessary for safety, even if they enhance reliability, should be executed outside the safety system.

((

{3}

)), thereby complying with Staff Position 1.3 that safety systems should be as simple as possible.

((

{3}

))

This complies with Staff Position 1.3 that performing this function does not result in unacceptable influence of one division over another.

ATTACHMENT 3 GNRO-2011/00045 GEH AFFIDAVIT SUPPORTING PROPRIETARY INFORMATION PROVIDED IN ATTACHMENT 1

GE Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Edward D. Schrull, state as follows:

(1) I am the Vice President, Regulatory Affairs, Services Licensing, GE-Hitachi Nuclear Energy Americas LLC (GEH), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in Enclosure 1 of GEH letter, GG-PRNM-168777-EC138, Supplement Information for NRC Instrumentation and Controls Branch RAIs 4, 13, & 26, dated June 23, 2011. The GEH proprietary information in Enclosure 1, which is entitled GEH Supplement Information to GGNS NRC I&CB RAIs 4, 13, & 26, is identified by a dotted underline inside double square brackets. ((This sentence is an example.{3})) In each case, the superscript notation {3} refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Information Act (FOIA), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought also qualifies under the narrower definition of trade secret, within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC Cir. 1983).

(4) The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's competitors without license from GEH constitutes a competitive economic advantage over other companies;

b. Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c. Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;

d. Information that discloses trade secret and/or potentially patentable subject matter for which it may be desirable to obtain patent protection.

Affidavit for Enclosure 1 of GG-PRNM-168777-EC138 Affidavit Page 1 of 3

GE Hitachi Nuclear Energy Americas LLC (5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GEH, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GEH, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary and/or confidentiality agreements that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in the following paragraphs (6) and (7).

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH. Access to such documents within GEH is limited to a need to know basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist, or other equivalent authority for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary and/or confidentiality agreements.

(8) The information identified in paragraph (2), above, is classified as proprietary because it contains detailed GEH design information of the instrumentation and control equipment used in the design and analysis of the power range neutron monitoring system for the GEH Boiling Water Reactor (BWR). Development of these methods, techniques, and information and their application for the design, modification, and analyses methodologies and processes was achieved at a significant cost to GEH.

The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the extensive experience databases that constitute a major GEH asset.

Affidavit for Enclosure 1 of GG-PRNM-168777-EC138 Affidavit Page 2 of 3

GE Hitachi Nuclear Energy Americas LLC (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.

The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial. GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.

I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Executed on this 23th day of June 2011.

Edward D. Schrull, PE Vice President, Regulatory Affairs Services Licensing GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Rd.

Wilmington, NC 28401 Edward.Schrull@ge.com Affidavit for Enclosure 1 of GG-PRNM-168777-EC138 Affidavit Page 3 of 3

ATTACHMENT 4 GNRO-2011/00045 LIST OF REGULATORY COMMITMENTS to GNRO-2011/00045 Page 1 of 1 LIST OF REGULATORY 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)

COMMITMENT COMPLETION ONE-CONTINUING DATE TIME COMPLIANCE (If Required)

ACTION Additional Information - RAI 4 Response Regarding the presence of the Detect and Suppress-Confirmation Density (DSS-CD) stability solution software and its application to the Maximum Extended Load Line Limit Analysis - Plus (MELLLA+) operating domain, Entergy commits to:

1. Monitor DSS-CD and evaluate data on 3 During performance during startup testing and plant Cycle 19 operation in preparation for a MELLLA+ LAR;

2. Submit a MELLLA+ LAR by December 31, 2012, 3 December 31, which requires the use of the DSS-CD software; 2010 and

3. Remove the jumpers from the DSS-CD trip function 3 Upon approval outputs once the MELLLA+ LAR has been of the approved and implemented. MELLLA+ LAR Additional Information - RAI 4 Response After Option III is placed into service, the outputs from 3 Upon approval the DSS-CD algorithm will continue to run with its of the indications available and monitored by operators, but MELLLA+ LAR with its trip outputs disabled until GGNS is licensed to operate in the MELLLA+ domain.

Additional Information - RAI 16 Response [Item (b)]

To ensure APRM gain adjustments are performed only 3 on bypassed PRNMS instruments, Entergy commits to implement procedure controls that require the instrument to be placed into BYPASS when making these adjustments.