GNRO-2011/00066, Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System
| ML112720128 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 09/28/2011 |
| From: | Krupa M Entergy Operations |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML112720127 | List: |
| References | |
| GNRO-2011/00066, TAC ME2531 | |
| Download: ML112720128 (11) | |
Text
When Attachment 1 is removed from this letter, the entire document is NON-PROPRIETARY.
to this letter contains PROPRIETARY information.
GNRO-2011/00066 September 28, 2011 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.
Entergy Operations, Inc. letter to the NRC (GNRO-2011/00042),
Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531), May 31, 2011 (ADAMS Accession No. ML111520123)
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 installing the digital General Electric-Hitachi (GEH)
Nuclear Measurement Analysis and Control (NUMAC) Power Range Neutron Monitoring (PRNM) System.
In Reference 2, Entergy submitted to the NRC responses to several Requests for Additional Information (RAIs) to support the staffs review and approval of Reference 1. In a telephone conversation held on September 28, 2011, Entergy discussed with the NRC Project Manager for GGNS the response to RAI 24, which was included in Attachment 1 of Reference 2.
Specifically, Entergy is revising its response to RAI 24, which discusses PRNM component calibration, with additional information provided to further explain compliance with Technical Specifications Task Force (TSTF) - 493, Clarify Application of Setpoint Methodology for LSSS Functions. Entergy is providing the revised pages of the response in Attachment 1.
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-2011/00066 Page 2 of 3 These pages replace those of the original response. Changes are indicated by revision bars in the margins of the replacement pages. Note the page numbers in Attachment 1 are consistent with the page numbers in Attachment 1 of Reference 2.
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. The associated affidavit is provided in Attachment 3.
The No Significance Hazards Determination and the Environmental Consideration provided in Reference 1 are not impacted by these responses.
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 September 28, 2011.
Sincerely, MAK/ghd Attachments: 1. Changed Pages to the Response to NRC Request for Additional Information 24 Pertaining to License Amendment Request - Power Range Neutron Monitoring System Upgrade (Proprietary Version)
- 2. Changed Pages to the Response to NRC Request for Additional Information 24 Pertaining to License Amendment Request - Power Range Neutron Monitoring System Upgrade (Non-Proprietary Version)
GNRO-2011/00066 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 2 GRAND GULF NUCLEAR STATION GNRO-2011/00066 CHANGED PAGES TO THE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION 24 PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE (NON-PROPRIETARY VERSION)
Note The page numbers specified in this attachment are consistent with those in Attachment 2 of the original RAI response submittal (NRC ADAMS Accession No. ML1111520123).
to Revised Page 70 of 101 NON-PROPRIETARY INFORMATION end of the PRNM equipment is calibrated once every 24 months. (The LPRM detectors are excluded from calibration per Note 1 of SR 3.3.1.1.10.) The reactor recirculation flow transmitters are calibrated separately in accordance with SR 3.3.1.1.17. The calibration is performed by the PRNM Auto-Calibration procedure, which involves sending a known calibrated current into each LPRM and flow amplifier and internally adjusting the output after it is processed by the amplifier, and the associated sample-and-hold and A/D converter circuits, for any drift that may have occurred since the previous calibration.
A simple way of determining drift since the last Auto-Calibration is to run the PRNM Cal Check procedure on each LPRM or flow amplifier just before running the Auto-Calibration procedure to bring the device back into calibration. When Cal Check is performed, the embedded software (firmware) in the PRNM internally disconnects the actual LPRM detector or flow amplifier input and connects it to a precision current source designed to give a specified output if the amplifier has not drifted and is at its desired value. If the amplifier has drifted since the last Auto-Calibration, the amount of drift can be determined by plant personnel from the outputs displayed on the PRNM/APRM screen. No manual calibration equipment is required when this Cal Check process is used. Plant personnel can compare the measured ((
)) As Found Values (AFVs) to predetermined ((
)) AFTs, which are based on specific ((
)) accuracy and drift (for 24 months), and calibration tool errors. These actions are compliant with TSTF-493 guidance. If the AFV for ((
)) is beyond the ((
)) AFT tolerance limit, then additional instrument evaluations are performed by plant personnel in accordance with TSTF-493 guidance, and, if necessary, the ((
)) may be repaired or replaced before Auto-Calibration is performed to bring the device into calibration.
Assuming the ((
)) AFVs are within the ((
)) AFTs per the Cal Check procedure, the Auto-Calibration procedure is performed. When Auto-Calibration is performed, the gain and offset of each amplifier are adjusted automatically by the PRNM firmware to compensate for instrument drift and to provide the correct output. This automatically assures the As Left Values (ALVs) after Auto-Calibration are within the predetermined ((
)) ALTs, which are based on ((
)) accuracy and calibration tool errors. At the conclusion of the Auto-Calibration procedure, the analog front-end processor is automatically returned to its desired design state ready for operation. No further manual adjustments are required. These actions are also compliant with TSTF-493 guidance.
Note that the pertinent portions of the GGNS Surveillance Requirement SR 3.3.1.1.10 tests and calibrates all the analog LPRM neutron flux and Recirculation Flow signal processing devices at the front end of the PRNM, because these devices can drift. It does not test the portion of the PRNM that performs the downstream processing of these signals in firmware.
Thus, the SR does not test the APRM signal processing portion of the PRNM (which averages the signals from the various LPRM amplifiers) or the APRM flow processing (which adds the flow signals from the two Recirculation Flow loops), nor does it test the processing 3
Section 4.4.2.1 of the PRNMS License Amendment Request (LAR) provided in Entergy letter GNRO-2010-000054 (Reference 5) proposes and justifies extending the current 18-month surveillance frequency to 24 months.
to Revised Page 70a of 101 NON-PROPRIETARY INFORMATION that generates the APRM trip signal because this processing is done in PRNM firmware and is not subject to drift. So the As-Found and As-Left tolerances for any surveillance of this portion of the PRNM signal processing and trip signal generation are zero.
(c) The documentation of representative of the PRNM and OPRM sensor, signal conversion, and NUMAC chassis error performance data that has been (or will be) used within the calculation, to demonstrate that the analysis of this data for each PRNMS channel meets the NRC acceptance criteria of 95/95 for the margin between the analytical limit and the NTSP1.
See Sections (a), (b), and (d) for the response to this item for the APRM setpoints. The response in this section deals specifically with the OPRM setpoints.
to Revised Page 73 of 101 NON-PROPRIETARY INFORMATION For PRNMS, the setpoint calculation method described above is applicable to the APRM Neutron Flux High setpoint, which is used in a safety analysis and has an AL. On the other hand, no credit is taken for the APRM Flow Biased Simulated Thermal Power - High scram in any GEH safety analysis including the Minimum Critical Power Ratio (MCPR) determination.
So the APRM Flow Biased Simulated Thermal Power - High setpoint does not protect a plant Safety Limit and does not have an AL. However, this setpoint is part of the Reactor Protection System providing protection against slow flux excursions, and has an AV in the Technical Specifications. The setpoint calculation for the flow biased setpoint, and other APRM setpoints without an AL, is a subset of the calculation of setpoints with ALs, and starts from the AV as described in the General Description section, above.
AFT and ALT Calculations The calculation of the AFT and ALT ((
)) are described in Section (b), above. Note that in GEH methodology, the AFT and ALT are applied to NTSPF implemented in the equipment, and not to the interim setpoints (such as NTSP1) used in the calculation of NTSPF. The GEH AFT and ALT values also depend on the surveillance test and the devices or components tested in the surveillance test. The GEH AFT and ALT values are generally smaller, and never greater than the allowances in TSTF-493 and are therefore compliant with TSTF-493. The GEH AFT is a two-sided tolerance, so that as-found values outside GEH AFT on either side of the setpoint are to be dispositioned as described in TSTF-493.
For PRNMS, the TSTF-493 requirements are only applied to the GGNS Surveillance Requirement SR 3.3.1.1.10 for APRM Neutron Flux - High, Setdown, APRM Flow Biased Simulated Thermal Power - High, and APRM Fixed Neutron Flux - High setpoints. As described in Section (b), above, this SR calibrates the PRNMS analog input devices individually, so that after the SR is successfully completed, the entire PRNM equipment is calibrated to perform according to its design and performance specifications. The calibration required by SR 3.3.1.1.10 is to be performed once every 24 months (Reference 5), through the PRNM Auto-Calibration process. The Auto-Calibration process is initiated manually, and then performs the required calibration steps automatically. The Auto-Calibration procedure automatically assures that after Auto-Calibration, each device is reset to the desired value within the ((
)) ALT in compliance with TSTF-493 guidance. The procedure complies with TSTF-493 guidance and is described above in Section (b).
ATTACHMENT 3 GRAND GULF NUCLEAR STATION GNRO-2011/00066 GEH AFFIDAVIT SUPPORTING PROPRIETARY INFORMATION
GE Hitachi Nuclear Energy Americas LLC Affidavit for Enclosure 1 of GG-PRNM-168777-EC159 Affidavit Page 1 of 3 AFFIDAVIT I, James F. Harrison, state as follows:
(1) I am the Vice President, Fuel Licensing, Regulatory Affairs, 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-EC159, Revised Response to NRC Instrumentation and Controls Branch RAI 24, dated September 22, 2011. The GEH proprietary information in, which is entitled GEH Revised Response to GGNS NRC I&CB RAI 24, is identified by a dotted underline inside double square brackets. ((This sentence is an example.{3})) Large figures containing GEH proprietary information are identified with double square brackets before and after the object. 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;
GE Hitachi Nuclear Energy Americas LLC Affidavit for Enclosure 1 of GG-PRNM-168777-EC159 Affidavit Page 2 of 3
- d.
Information that discloses trade secret and/or potentially patentable subject matter for which it may be desirable to obtain patent protection.
(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.
GE Hitachi Nuclear Energy Americas LLC Affidavit for Enclosure 1 of GG-PRNM-168777-EC159 Affidavit Page 3 of 3 (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 22nd day of September 2011.
James F. Harrison Vice President, Fuel Licensing, Regulatory Affairs GE Hitachi Nuclear Energy Americas LLC