ML20210L625
| ML20210L625 | |
| Person / Time | |
|---|---|
| Issue date: | 08/15/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20210L597 | List: |
| References | |
| NUDOCS 9708210245 | |
| Download: ML20210L625 (11) | |
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'j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30M6-4001 I
SAFETY EVALUATION l
BY THE OFFICE OF NUCLEAR REACTOR REGULATION l
NEDC-32410P. SUPPLEMENT 1.
NVCLEAR MEASUREMENT ANALYSIS AND CONTROL l
E0WER RANGE REUTRON MONITOR (NUMAC PRNM) RETROFIT l
l PLUS OPTION 111 STABILITY TRIP FUNCTION
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1.0 JNTRODUCTION General Electric Measurement Analys(GE) Licensing Topical Report NEDC-32410P-A, " Nuclear is and Control Power Range Neutron Monitor (NUMAC PRNM)
Retrofit Plus Option Ill Stability Trip Function " dated October 1995, (the base report) described a modification to replace,the Power Range Monitor portion of the existing Neutron Monitoring System in BWR power plants with a GE digital NUMAC PRNM retrofit system.
included in the modification is an the plant, as required by General Design Criterion 12, Append Part 50.
The new automatic trip function implements the BWROG Option III alternative.
The topical report provided specific proposed technical s)ecification changes for the Average Power Range Monitor tie replacement system, and generally described technical s(APRM) portion of changes proposed for the addition of the Oscillation Power Range Monitor pecification (OPRM) functions.
safety evaluation transmitted
)y letter dated September S, 1995.The base resort was revie APRM technical specifications, and has drseloped specific pr specifications to implement the OPRM.
These clarifications and proposed technical specification amendments were submitted to the NRC by GE in a letter dated May 24, 1995 which provided NEDC-32410P, Supplement 1, " Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM Retrofit Plus Option III Stability Trip Function," dated May 1996.
32410P, Su mlement 1. safety evaluation report summarizes the staff's review and approv This 2.0 DE 2(
NEDC-32410P, Supplement 1 is intended to be used in conjunction with the base report.
The supplement is organized and numbered consistent with the base
-5 report, with changes, clarifications, and additions to the base report shown in the same paragraph and section as the related information in the b&se report.
Additionally, Appendix H of the supplement provides specific Technical Specification (TS) changes to implement the OPRM functions, proposed consistent with changes that implement the NUMAC PRNM.
clarificationsthe base report should also reference Supplement I to ensure theLicensees referencin The staff accep,ts revisions to the Standard Technical Specificatio (NUREG-1433, Rev. 1), which are describe'] in Section H.1.1.
Section H.I.2 ENN Nb m
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2 provides proposed TS changes for the original STS, which is not referenced in current TS amendment reviews. Section ti.l.3 provides proposed TS changes for custom TS, for which no industry standard exists. Consequently, this safety evaluation applies only to the proposed TS changes described in Section H.1.1.
Sect hn 2.1.1.1, Power Range Monitor Functions, clarifies the difference betwun AC power source redundancy in BWR6 plants by stating that non-BWR6 plants will have additional redundancy against loss of RPS AC )ower when the new APRM configuration it. implemented. This is consistent witi existing non-BWR6 design configurations, and is acceptable.
Section 2.1.2, Hardware Impact, clarifies the use of the terms ' indication' and ' indicator' to include any type of display that conveys information to the operator or other user. Typically, these terms have been used to identify individual incandescent lamps. The clarification also identifies light emitting diodes and electro-luminescent ditplays or indicators. Additionally, the supplement states that critical system information should be continuously available for any plant operating conditions that require operability of the associated PRNM function:
This clarification addresses technology that has been found by the staff to be acceptable for use in other nuclear power plant safety systems (e.g., GE NUMAC product line equipment), and is, therefore, acceptable.
Section 2.1.2 provides further recommendations regarding plant human factors reviews concerning the availability and form of status information and indications related to the aisplays. These recommendations are consistent with the base report, and are, therefore, acceptable.
The plant computer and AC power source interface for BWR6 plants were described in greater detail in the supplement, and another figure was added to show the BWR6 configuration. As with the non-BWR6 plants, the power sources meet the separation, redundancy, isolation, and independence requirements of the regulations. The staff, therefore, concludes that these changes are acceptable.
A plant computer interface (PCI) has been added to the BWR6 design to process communications between each division and the plant computer. The four PCIs are isolated from the safety system via fiber optic connections. The PCIs do not transmit information from the plant computer to the safety system.
Fiber optic cable is an accentable method of isolating nonsafety components from safety-related systems. The staff, therefore, concludes that this design f0ature is acceptable.
The description of the low voltage power supply (LVPS) interface was amended to state that the power supplies for converting AC power to low voltage DC have been replaced with NUMAC power supply assemblies.
These assemblies replace the existing non-redundant power supplies with redundant power supplies in the non-BWR6 plants.
BWR6 plants already have redundant power supplies. The change in design description does not change the staff's original conclusion of adequate power supply redundancy and separation, and is, therefore, acceptable.
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Section 3.2.3.2.2, PRNM System - 4 Flow Channels, has been modified to reflect the planned BWR6 configuration, which incorporates a PCI chassis in each j
channel. Additionally, the description of the configuration was changed to reflect the difference between the non-BWR6 designs, which do not use the PCI chassis, and the BWR6 design.
The safety-related features of both designs remain unchanged, and are, therefore, acceptable.
Section 3.3.2, Safety Functions and Response Times of the NUMAC PRNMS, was changed to clarify the safety function of the OPRM Upscale function, which provides the instability detect-and-suppress trip.
The clarification states that all three instability detect-and-suppress algorithms are included in the function; however, the period-based detection algorithm is the only function credited in the safety analyses. The other two algorithms (growth-based and amplitude-based) provide defense-in-depth for the period-based detection algorithm. The staff concurs with the use of the period-based algorithm in the safety analyses, and hclusion of the growth-based and amplitude-based algorithms as defense-in-depth features.
The base report has been changed to include the algorithm response time in the time required to complete the transition to the trippen state after the plant parameters reach a trip setpoint, as detected by the LPRMs.
This change more accurately reflects the total channel response time.
The revised channel response time is 400 ms, which is significantly less than the existing manual actuation response time. The staff, therefore, concludes that this change is acceptable.
Section 4.4.1.5, ANSI NQA 2, Part 2.7, references a comparison matrix in Appendix A to the base report that correlates the requirements of ANSI NQA 2, Part 2.7, with the requirements that define the development program.
This matrix was not included in Appendix A of the base report until this amendment.
The staff concludes that this administrative change is acceptable.
Ir Section 4.4.2.4.2, Requirements, the figure referance for item number 7, Conducted susceptibility, bulk cable injection, was changed from Mil-Std-461D, Figure CS114-2, to CS114-1, Curve #2.
This changed correctly reflects the appropriate figure number and is, therefore, acceptable.
Section 5.3.2.3, Two-0ut-of-Four Logic Module, was amended to include a discussion of the response to a loss of a signal from an APRM channel to the Two-Out-of-Four Logic Module. The loss of signal will be treated the same as an APRM flux trip from that channel.
For plants with only one AC power source to the APRM channel (most BWR6 plants), loss of signal from one or two APRM channels will result in only one APRM trip, but will also result in an immediate self-test alarm.
Loss of signal from three or four APRM channels or an actual trip from one or more channels combined with loss of signal from one or two channels will result in a full RPS trip from that voter logic. This logic allows for a loss of one RPS bus without a scram, while maintaining scram capability in the event of one other APRM channel in bypass.
This design feature provides adequate protection against loss of function from a single failure, and is, therefore, acceptable.
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Section 5.3.8.1, Loss of Input Power, was changed to clarify the treatment of RPS AC power input for BWR6 plants. The Quad LVPS chassis receives two AC power inputs, one from each RPS bus for non-BWR6 plants, and two AC power inputs from one RPS bus for BWR6 plants.
There is one Quad LVPS in each APRM channel. The revised wording clarifies the difference between )ower supply sources, and does not chango the approved design. The staff, t1erefore, therefore concludes that this change is acceptable.
Section 5.3.8.2, Abnormal Conditions Leading to Inoperative Status, was changed to clarify the voting logic for IN0P conditions by adding a note at the end of the section. The note clarifies that loss of a signal from one or two APRM channels in most BWR6 )lants will result in only one APRM trip.
Loss of-a signal from a third APRM ciannel or a trip of one of the other unbypassed APRM channels will result in a full RPS trip from that voter logic.
This logic allows for loss of an RPS bus without a scram, while ensuring the scram capability is not lost when another APRM channel is bypassed. Therefore, the staff concludes that this design approach meets the single failure criterion and is acceptable.
Section 6.3.3, Methodology for Unavailability Analysis, was amended to clarify the unavailability analysis methodology for the interfacing relays between the APRM and the RPS, which will be unchanged by the PRNMS replacement.
The revised portion of this section changes the channel functional test interval from 3 months to 6 months.
Based on the staff's review of the uncertainty analysis, the staff finds the channel functional test interval acceptable.
Section 6.3.4, Data Used for Unavailability Analysis, was amended by replacing the existing Tables and Table Notes with updated failure data, which now includes the failure rate data for the K12-relays, which had been omitted from the original tables.
The staff reviewed the revistd failure data and concludes that they are acceptable.
Section 6.3.5, Self-Test Coverage, clarifies the secpe of the self-test coverage by stating that the self-testing does not include the final solid state output relays from the Two-Out-Of-Four Voter Module.
Since these relays are tested with the K12 relays, the staff concludes that this test coverage is acceptable.
Section 6.3.6, Conclusions of the Analysis, bases the APRM function unavailability on failure rate estimates assuming a 184 day functional test frequency. This assumed 184-day test frequency is longer than the BWR STS frequency of 92 days and, therefore, is conservative. Additional details regarding the unavailability analysis were provided by the vendor in Section 6.3.6.1, Discussion of Conclusions of the Analysis, and Section 6.3.6.2, Discussion of Sensitivity of Result Conclusions.
The staff reviewed these added sections and concludes that the conclusions are acceptable.
Section 8.3.4.4.1, Current Tech Spec Requirements, item 2, APRM Flow-biased Simulated Thermal Power Upscale Trip, and item 3, APRM Fixed Neutron Flux Upscale Trip, were changed to reflect a staggered test basis for either six or eight channels. These changes are consistent with the STS requirements and are acceptable.
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-Section 8.3.4.4.2, Changes to. Response Time Testing Requirements, was changed to include a requirement for response time testing of the 2-out-of-4 Voter Function, which has been added to the channels in the PRNMS. Additionally, staggered testing will be based on four channels at a refueling outage interval (up to 24 months), with one of the redundant two APRM/RPS interface relays driven by each voter being tested. The redundancy provided by the two interface relays per voter is not required for the PRNMS design to meet the single failure criterion; consequently, testing one interface relay per voter is acceptable.
Section 8.3.4.4.3, Justification, was amended to justify the testing frequency of the solid state voter output relay. The amended text states that at least one voter output relay will be tested for each "K12" test, which is-acceptable.
Section 8.3.4.4.4, Utility Action to Implement Changes, was changed by adding a definition of test frequency. The licensees are instructed to determine the frequency of response time testing using 2-out-of-4 voter channels, although the tests may alternate 2-out-of-4 voter outputs provided one of the APRM/RPS interfacing relays in each channel is tested at least once per eight refueling cycles (based on a maximum 24 month cycle), and one of the four RPS scram contactors in each channel is tested at least once per four refueling cycles.
This clarification is consistent with the existing requirements for response time testing, in that one channel of the APRM system is tested on a staggered test basis every fuel cycle. Note that there are redundant interfacing relays in each channel of the APRM. Therefore, this testing frequency is acceptable.
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Section 8.4.1.2, Changes to Functions (0PRM Related RPS Trip Functions),
states that the only function added to the technical specifications is the OPRM Upscale (period-based algorithm). A further clarification replaces "0PRM Trip" terminology in the base report with "0PRM Upscale". This change is consistent with the staff safety evaluation report (SER) accepting the BWROG topical report NEDO-31960-A, "BWR Owner's Group Long-Term Stability Solutions Licensing Methodology," dated November 1995.
The staff, therefore, concludes that this change is acceptable.
Section 8.4.1.3, Justification, has been changed to provide additional information regarding the basis for using the OPRM Upscale function in the safety analysis for the OPRM function. The other two algorithms will be included in the TS Bases sections as defense in depth features, but not as required for OPRM operability. This discussion is consistent with the base document, and is, therefore, acceptable.
Additionally, Section 8.4.1.3 describes the relationship between APRM and OPRM Inops and the OPRM Upscale trip function. The OPRM Inop function is integrated into the APRM Inop function. However, the OPRM Upscale trip function is voted as a trip separate from the APRM functions.
Consequently, an APRM/0PRM Inop trip in one channel and an OPRM Upscale trip in another channel will not result in two half-trips in each of the 2-out-of-4 voter 3
channels.
Based on this discussion, the addition of only the OPRM Upscale function to the Tech Spec-is consistent with the base document design description and is acceptable.
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-Section 8.4.1.4, Utility Action to Implement Changes, directs the utility to add the OPRM Upscale function as an "APRM function" in the RPS Instrumentation
" function" table. - Additionally, the utility is directed to add the related surveillance requirements, the related setpoint, if applicable, and the related discussions and descriptions to the Bases sections. These additions are acceptable.
Section 8.4.2.2.' Changes to Minimum 0)erable OPRM Channels, changes the base -
document to reflect the-use of only t1e OPRM U) scale function in the Tech Spec.- Additionally, another action statement 1as been added that requires, in addition to restoration of the OPRM trip capability within 120 days, that the utility reduce the reactor power below 25% RTP within four hours if an alternate method of detecting instability conditions and initiating mitigating actions cannot be performed. _The basis for the four hours.is consistent with the time required for equivalent actions covered by the Tech Specs. Reducing the reactor power to below 25% RTP ensures the reactor will operate outside the envelope of possible neutron flux instabilities. The staff concludes that these actions are acceptable.
Section 8.4.2.3, Justification, modifies-the _last paragraph of the
-justification in the base report to be consistent with Paragraph 8.4.2.2.
The amended paragraph changes the time for fault identification and corrective action from 30 days to 120 days.
This 120-day time to identify and repair a fault in the OPRM system was approved in the base report, and is -therefore, acceptable.
Section 8.4.2.4, Utility Action to Implement Changes, is amended to more-accurately describe the as-designed OPRM, and to change references'in the Tech Specs from OPRM Tr_ip-to OPRM Upscale function. Additional guidance was provided to. add descriptions of the OPRM system to the. Tech Spec Bases. 'These changes-are acceptable, z
Section 8.4.3.2, Changes to Applicable Modes of Operation, has been amended to change the requirement for OPRM Upscale trip function operability from
" operable at all _ power levels in Mode 1 (run)" to " operable in Mode I when the Thermal Power is h25% RTP." This change is acceptable because the OPRM is automatically bypassed when the Thermal Power is <30%.
Section 8.4.3.3, Justification, has been replaced with more detailed information that acceptably addresses the requirement for-0PRM Upscale-operability in Mode 1 (run). OPRM Upscale-operability above 60% rated core flow is required because there are identified events that can reduce the plant from 100% power and flow to less than 60% flow without operator action. The topical report-identifies loss of feedwater heating as the only event in which power less than 30% RTP increases above 30% RTP without operator intervention.
Consequently, OPRM Upscale operability is required above 25% RTP to provide margin. These limits are nominal values, which must be addressed by each licensee to account for plant-specific design features. The staff concludes that this justificatier, is acceptable.
Section 8.4.3.4, Utility Action to Implement Changes, requires the utilities to add to the technical specifications the requirement for OPRM Upscale
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function operability in Mode 1 (run) when the thermal power is 225% RTP, and to add to the Bases description as required.
These changes are consistent with the discussion in Section 8.4.3.3, Justification, and are, therefore.
acceptable.
~l Section 8.4.4.1.2 Changes to Channel Check Requirements, adds Channel Check or Instrument Check requirements for the OPRM Upscale function.
The once-per-12 hours or once-per-day interval is consistent with the APRM interval and is acceptable.
Section 8.4.4.1.4, Utility Action to Implement Changes, requires the utilities 5
to add the OPRM Upscale function channel check requirements to the technical specifications. These changes are appropriate and acceptable.
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Section 8.4.4.2.2, Changes to Channel Functional Test Requirements, adds a requirement for functional testing of the OPRM Upscale function and the 2-out-of-4 voter channels every 184 days (6 months).
This interval is consistent with the approved interval for the APRM functions, and is, therefore, acceptable, f
A once-per-outage basis up to a 24-month interval for confirming the OPRM b_
Upscale function is enabled when the APRM Simulated Thermal Power is 2(30%)
RTP and recirculation flow is <[60%) rated recirculation flow will also be added to the base report. This confirmation of the OPRM Upscale function auto-enable function will result in changes in the auto-enable settings if the functional test fails. Consequently, the functional test may be treated as a calibration if it fits a plant-specific technical specification structure better, and it meets the TS definition for calibration.
The staff concludes that these changes are acceptable.
I Section 8.4.4.2.3, Justification, is changed to provide more detailed information concerning the channel functional test requirements. The justifications for selecting the channel functional test interval acceptably relate the OPRM Upscale function to the APRM equipment in which it is located.
Additionally, surveillances of the APRM associated inputs to the OPRM Upscale function, combined with the surveillance of the OPRM Upscale function auto-enable ensure the OPRM Upscale function is enabled in the intended region of the power / flow map.
The justification for a once per outage basis, up to a 24-month interval, is based on the use of nondrifting digital equipment and the automatic self-test functions for detecting hardware failures.
The staff concludes that these changes are acceptable.
Section 8.4.4.2.4, Utility Action to Implement Changes, is amended to require Channel Functional testing every 184 days (6 months), to include the 2-out-of-4 Voter function, and to confirm operability of the auto-enable function on a once-per-outage basis u) to a 24-month interval. The staff concludes that these changes are accepta)le.
l Section 8.4.4.3.2, Changes to Channel Calibration Requirements, is amended to require an OPRM Upscale function calibration at a frequency of once-per-fuel cycle (up to a 24-month interval). This change is consistent with the existing requirements for the APRM and is, therefore, acceptable.
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Section 8.4.4.3.3, Justification, and Section 8.4.4.3.4, Utility Action to Implement Changes, replace "0PRM Trip" with "0PRM Upscale". These changes are administrative and are acceptable.
Section 8.4.4.4.2 Changes to Response Time Testing Requirements, will be amended to include the OPRM Upscale output relays in the response time testing of the 2-out-of-4 voter channels. The test frequency and the required response time of the OPRM trip output relays (0.05 second) will be the same as for the APRM flux trip output relays. This change is acceptable.
Section 8.4.4.4.3, Justification, is amended to describe the allocation of the total res channels.ponse time to the software and hardware portions of the APRM and OPRM Additionally,-the calibration interval has been changed to a once per outage basis, up to a 24 month interval.
The requirement for testing the OPRM Upscale output relays at the same frequency as the APRM flux relays is acceptable.
Section 8.4.4.4.4, Utility Action to Implement Changes, requires the licensee to modify the response time testing procedure for the 2-out-of-4 voter function to include the voter OPRM output solid-state relays as part of the response time tests, and alternating the voter OPRM output testing with the voter APRM output testing. Since the relays are identical, alternating the tests is acceptable.
Section 8.5.2.2, Changes to Minimum Operable Control Rod Block Channels, changes the minimum number of APRh rod block channels from four to three.
This change meets the single failure design criterion, and is, therefore, acceptable. Additionally, the first paragraph has been amended to state that the minimum number of APRM channels is three, instead of the previously stated two channels. This change is also acceptable.
Section 8.5.2.3, Justification, adds a discussion concerning the requirement for the minimum number of APRM channels. The base report justification did not discuss the APRM channel requirement. The justification for the minimum number of APRM channels is consistent with the single failure criterion and is, therefore, acceptable.
Section 8.5.2.4, Utility Action to Implement Changes, increases the minimum number of APRM channels from two to three, if the APRM functions are retained in the technical specifications. This change is acceptable.
Section 8.5.4.2.3, Justification, is amended to correct a grammatical error.
This change is acceptable.
Section 8.6, Shutdown Margin Testir.g - Refueling, was added to the base report. This section consists of instructions to the plants to update the TS to address provisions or limitations related to APRM functions.
Specific changes are to be consistent with the APRM TS changes implemented for the PRNM. The staff concludes that this instruction is acceptable.
Section 10, References, has been changed to reflect NRC approval of NED0-31960, and NED0-31960, Supplement 1, "BWR Ow'iers' Group Long-Term Stability l
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- Solutions Licensing Methodology." A Reference for the NRC-approved base report, NEDC-32410P-A,
- Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC-PRNM) Retrofit Plus Option III Stability Trip Function," has also been added. These changes are acceptable.
Appendix A has t.een changed to reflect compliance with NQA-2, Part 2.7, in addition to Reg. Guide 1.152 and IEEE 7-4.3.2-1993.
Section A.3 was added to provide a comparison of the NUMAC PRNM design process with NQA-2, Part 2.7 requirements.
The staff reviewed this appendix and concludes that the relationships between the PRNM Design Process and the ANSI NQA-2, Part 2.7, are acceptable.
Figure E.1.6, " Replacement 4 APRM Configuration, BWR6, Smaller Core," and Figure E.1.7, " Replacement 4 APRM Configuration, BWR6, larger Core," were changed to add the PCI blocks for each APRM channel. Additionally, a reference to these two figures was added to the caption for Figure E.3.6-4, "APRM Replacement Configuraticn, BWR6, All Core Sizes," to reflect the addition of the PCI interconnections.
These changes are consistent with the revised design description for the BWR6 PRNM and are, therefore, acceptable.
Power distribution / interface block diagrams, Figure E.5.3 and Figure E.5.6, were added to show the BWR6 current and revised configurations for the power distribution interfaces, respectively.
These changes are consistent with the BWR6 PRM and PRNM descriptions in the base report and are, therefore, acceptable.
Appendix F, Equipment Failure Analysis and Reliability Information, was added to the base report to include updated failure rate data tables and notes. The updated tables provide the data used in the unavailability analysis discussed in Section 6 of Supplement 1.
The staff confirmed the data and notes in the tables are consistent with the discussion in Section 6 and are, therefore, acceptable.
Anoendix H. Samole Markuns of Tech Specs. OPRM The sample technical specification markups in Supplement I are based on the assumption that changes defined in Appendix H, Section H.I.1, of the base report have been incor> orated into the technical specifications.
Consequently, the striceouts and additions in Appendix H to Supplement I apply to Section 8.4 (0PRM) of the base report, as amended by the supplement.
Conditions A and B of LC0 3.3.1.1 and the associated Bases were amended to add the OPRM Upscale function (Function 2.f in Table 3.3.1.1-1, Reactor Protection System Instrumentation) to the list of functions in the Note for Required Action A.2, and Condition B.
The notes exclude the applicability of the APRM functions from Required Action A.2, and Condition B.
APRM functions, including the OPRM upscale function are associated with all four RPS trip channels. Consequently, A.2 & B cannot be performed. Additionally, the associated Bases were changed in accordance with the guidance provided in the body of the approved NEDC-32410P.
Therefore, these changes are acceptable.
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10 Condition I for BWR/4 plants (which is Condition J for BWR/6 plants), with changes justified in the associated Bases, was added to LCO 3.3.1.1 to require the licensee to initiate an alternate method to detect and suppress thermal-hydraulic instability oscillations within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of determining that there are less than 3 OPERABLE OPRM Upscale function channels. Additionally, the licensee is required to restore the inoperable channels to OPERABLE within 120 days.
These actions and completion times, and the associated changes to the Bases, are acceptable.
Condition J with changes justified in the associated Bases, was added to LCO 3.3.1.1 to require the licensee to reduce THERMAL POWER to (25%? within (4?
hours if both required actions for Condition I are not met with<n the requ< red completion time. The required action and 4-hour completion time are acceptable.
The Frequency requirement for Surveillance Requirement (SR) 3.3.1.1.8, Calibrate the local power range monitors, was changed from 1000 MWD /T to (1000 MWD /T] to account for those plants that have justified a frequency of 2000 MWD /T average core exposure.
This change is not related to the OPRM and does not affect the APRM changes required by the plant.
Each licensee must justify changes in the SR Frequency; therefore, this change is acceptable.
SR 3.3.1.1.18, with associated Bases, was added to require verification that the OPRM is not bypassed when APRM Simulated Thermal Power is 2(30]% and recirculation drive fl.v is <[60]% of rated recirculation drive flow. The frequency is 18 montin, which corresponds to a fuel cycle interval.
These changes are co(ns]istent with the staff's approval of the design description, and are, therefore, acceptable.
The OPRM Upscale function was added to Table 3.3.1.1-1, Reactor Protection System Instrumentation, as Function 2.f.
The applicable mode (2 (25]% RTP),
number of required channels (3), the associated footnote (c), the reference to Required Action D.1 (I for BWR/4 plants and J for BWR/6 plants), the surveillance requirements, and the associated Bases are in accordance with the staff-a) proved discussion in the body of Supplement 1 and are, therefore, accepta)1e.
3.0 CONCLUSION
NEDC-32410P, Supplement 1, " Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," clarifies issues related to the APRM part of the PRNM design and APRM Technical Specifications. Additionally, Supplement 1 proposes technical specifications for the OPRM function of the PRNMS. The staff reviewed the proposed changes and additions to NEDC-32410P-A, as proposed in Supplement 1, and concludes that the requested amendments and proposed technical specifications are consistent with the BWR standard TS and the staff's acceptance of NEDC-32410P, and are, therefore, acceptable. The conditions stated in the sthff's safety evaluation dated September 5,1995, approving NEDC-32410P, also apply to Supplement 1.
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GE Nuclear Energy cc:
Gary L. Sozzi, Manager Technical and Modification Services GE Nuclear Energy 175 Curtner Avenue San Jose, CA 95125 George B. Stramback GE Nuclear Energy 175 Curtner Avenue San Jose, CA 95125 James F. Klapproth GE Nuclear Energy P.O. Box 780 Wilmington, NC 28402 Ralph J. Reda, Manager Fuel and Facility Licensing General Electric Company P.O. Box 780 Wilmington, NC 28402
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D C. 30e06-0001 August 15, 1997 Mr. David W. Reigel Project Manager Generic NUMAC PRNM Licensing General Electric Company 175 Curtner Avenue San Jose, California 95125
SUBJECT:
LICENSING TOPICAL REPORT NEDC-32410P, SUPPLEMENT 1. NUCLEAR MEASUREMENT ANALYSIS AND CONTROL POWER RANGE NEUTRON MONITOR (NUMAC-PRNM) RETROFIT PLUS OPTION III STABILITY TRIP FUNCTION (TAC NO. M95746)
Dear Mr. Reigel:
The staff has completed its review of Supplement I to the Topical Report NEDC-32410P, " Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC-PRNM) Retrofit Plus Option III Stability Trip Function," submitted by General Electric Company (GE) by letter dated May 24, 1996. Additional information concerning this topical report was provided in a letter dated September 30, 1996.
This topical report clarifies issues related to the Average Power Range Monitor (APRM) and APRM technical specifications, and proposed technical specifications for the Oscillation Power Range Monitor (OPRM). The staff previously approved Topical Report NEDC-32410P in its safety evaluation transmitted by letter dated September 5,1995. The staff has reviewed NEDC-32410P, Supplement 1, and concludes that it is acceptable.
The staff safety evaluation approving NEDC-32410P, Supplement 1, is attached.
The conditions for implementing the Supplement I technical specifications amendments are as stated in the staff's September 5, 1995 safety evaluation approving NEDC-32410P.
The staff does not intend to repeat its review of the matters found acceptable as described in NEDC-32410P, Supplement 1, when tne topical report is referenced in plant specific license amendment applications, except to ensure that the material presented is applicable to the specific plant involved.
The staff's acceptance applies only to the matters described in the application of NEDC-32410P, and Supplement 1.
In accordance with procedures established in NUREG-0390, the staff requests that GE publish accepted versions of this topical report within three months of receipt of this letter. The accepted versions should include an "A" (designating accepted) following the report identification symbol, and the staff's safety evaluation report.
D.- n C J / n, y f
( IVO w vc./ W
David W. Reigle August 15, 1997 Should NRC criteria or regulations change so as to invalidate the conclusions concerning acceptability-of the report, GE or the applicants referencing the topical report will be expected to revise or resubmit their respective documentation, or submit justification for the continued effective applicability of the topical report without revision of their respective documentation.
This letter is being reissued to correct an error in our previous letter to you dated December 26, 1997, and supercedes that previous letter in its entirety.
If you have any questions concerning the staff's safety evaluation, please contact the NRC project manager, Jim Wilson, at (301) 415-1108.
Sincerely, David B. Matthews, Chief Generic Issues and Environmental Projects Branch, Division of Reactor Program Management
Attachment:
as stated cc: see attached list l
l
David W. Reigle August 15, 1997 Should NRC criteria or regulations change so as to invalidate the conclusions concerning acceptability of the report, GE or the applicants referencing the topical report will be expected to revise or resubmit their respective documentation, or submit justification for the continued effective applicability of the topical report without revision of their respective documentation.
This letter is being reissued to correct an error in our previous letter to you dated December 26, 1997, and supercedes that previous letter in its entirety.
If you have any questions concerning the staff's safety evaluation, please contact the NRC project manager, Jim Wilson, at (301) 415-1108.
Sincerely, David B. Matthews, Chief Generic Issues and Environmental Projects Branch, Division of Reactor Program Management
Attachment:
as stated cc: See next page D
J ISTRIBUTION:
VPUBLIC PGEB r/f BBoger JWermiel MCase MWaterman Central DMatthews JMauck JHWilson JRoe BZalcman Document Name: GEREIGLE.LTR
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OFC PGEBOnd (A)SC:fGEB (b M C:PGJ Bfh NAME JHWilloS:sw MJCaseM Mbs DBMaNhews DATE 08//f/97 08/6~/[7 Ob//h97 08//If97 0FFICIAL RECORD COPY
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g UNITED STATES j
NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D.C. sneeHo01 SAFETY EVALVATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION NEDC-32410P. SUPPLEMENT 1.
HUCLEAR MEASUREMENT ANALYSIS AND CONTROL E0WER RANGE NEUTRON MONITOR (NUMAC PRNM) RETROFIT PLUS OPTION 111 STABILITY TRIP FUNCTION 1.0 JNTRODUCTION General Electric Measurement Analys(GE) Licensing Topical Report NEDC-32410P-A, " Nuclear Retrofit Plus Option III Stability Trip Function " dated October 1995 base report) described a modification to replace,the Power Range Monito
, (the portion of the existing Neutron Monitoring System in BWR power plants with a r
GE digital NUMAC PRNM retrofit system.
Included in the modification is an the plant, as required by General Design Criterion 12 automatic trip Part 50.
The new automatic trip function implements the BWROG Option III, Appendix alternative.
The topical report provided specific proposed technical tie replacement system, and generally described technical changes proposed for the addition of the Oscillation Power Raage Monitor (OPRM) functions.
safety evaluation transmitted by letter dated September 5, 1995.The b APRM technical specifications, and has developed spec and specifications to implement the OPRM.
cal These clarifications and proposed technical specification amendments were submitted to the NRC by GE in a l t dated May 24, 1996 which provided NEDC-32410P, Supplement 1, " Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUM e er Retrofit Plus Option III Stability Trip Function," dated May 1996 safety evaluation report summarizes the staff's review and approval of NEDC This 32410P, Supplement 1.
2.0 EVALUATION NEDC-32410P, Supplement 1 is intended to be used in report.
e base report, with changes, clarifications, and additions to the base report shown in the same paragraph and section as the related inform eport.
technical Specification (TS) changes to implement the OPRM functio e
- onsistent with changes that implement the NUMAC PRNM.
ns,
,he base report should also reference Supplement I to ensure theLicensees referencing larifications he staff accep,ts revisions to the Standard Technical Specif NUREG-1433, Rev. 1), which are described in Section H.I 1 Section H.I.2
=
m m 2
current TS amendment reviews.provides proposed TS changes for the original STS custom TS, for which no industry standard exists.Section H.I.3 provides proposed TS changes evaluation applies only to the propo W TS changes described in Section H.1.1.
Consequently, this safety Section 2.1.1.1 Power Range Monitor Functions, clarifies the difference between AC power, source redundancy in BWR6 plants by stating that non-BWR6 plants will have additional redundancy against loss of RPS AC power when the new APRM configuration is implemented.
non-BWR6 design configurations, and is acceptable.This is consistent with existing Section 2.1.2, Hardware Impact, clarifies the use of the term cperator or other user.
individual incandescent lamps. Typically, these terms have been used to identify smitting diodes and electro-luminescent displays or indicators.The clarification also available for any plant operating conditions that require ope Additionally, associated PRNM functions.
This clarification addresses technology that has been found by the staff to be acceptable for use in other nuclear power plant safety systems (e.g., GE NUMAC product line equipment), and is, therefore, acceptable.
Section 2.1.2 provides further recommendations regarding plant human factors reviews concerning the availability and form of status information and indications related to the dis with the base report, and are, plays.
These recommendations are consistent therefore, acceptable.
The plant computer and AC power source interface for BWR6 plants were described in greater detail in the supplement, and another figure was added to show the BWR6 configuration.
As with the non-BWR6 plants, the power sources meet the separation, redundancy, isolation, and independence requirements of the regulations.
The staff, therefore, concludes that these changes are acceptable.
A plant computer interface (PCI) has been added to the BWR6 design to process communications between each division and the plant computer.
are isolated from the safety system via fiber optic connections.The four PCIs not transmit information from the plant computer to the safety system.
The PCIs do optic cable is an acceptable method of isolating nonsafety components from Fiber safety-related systems.
feature is acceptable.
The staff, therefore, concludes that this design The descriation of the low voltage power supply (LVPS) interface was amended to state tlat the power supplies for converting AC power to low voltage DC have been replaced with nut %C power supply assemblies.
replace the existing non-redundant power supplies with redundant power These assemblies supplies in the non-BWR6 plants.
The change in design description does not change the staff'sBWR6 pla supplies.
original conclusion of adequate power supply redundancy and separation, and is, therefore, acceptable.
e 3
Section 3.2.3.2.2, PRNM System - 4 Flow Channels, has been modified to reflect the planned BWR6 configuration, which incorporates a PCI chassis in each channel. Additionally, the description of the configuration was changed to reflect the difference between the non-BWR6 designs, which do not use the PCI chassis, and the BWR6 design. The safety-related features of both designs remain unchanged,-and are, therefore, acceptable.
Section 3.3.2, Safety Functions and Response Times of the_ NUMAC PRNMS, was changed to clarify the safety function of the OPRM Upscale function, which
.provides the instability detect-and-suppress trip.
The clarification states that all three-instability detect-and-suppress algorithms are included in the function; however, the period-based detection algorithm is the only function i
credited in the safety analyses. The other two algorithms _(growth-based and amplitude-based) provide defense-in-depth for the period-based detection algorithm. The staff concurs with the use of the period-based algorithm in the safety analyses, and inclusion of the growth-based and amplitude-based-algorithms as defense-in-depth features.
--The base report has been changed to include the algorithm response time in the time-required to parameters reach _completa the transition to the tripped state after the plant a-trip setpoint, as detected by the LPRMs.
This change more accurately reflects the total channel response time. _ The revised channel response time is 400 ms,.which is significantly less than the existing manual actuation response time. The staff, therefore, concludes that this change is acceptable.
.Section 4.4.1.5, ANSI NQA 2 Part 2.7, references a-comparison matrix in
- Appendix A to the base report-that correlates the tequirements of ANSI NQA 2,
' Part 2.7, with the requirements that define the development program. This matrix-was not included in Appendix A of the base report until this amendment.
The staff concludes that this administrative change is acceptable.
In Section_4.4.2.4.2, Requirements, the figure reference for item number 7, Conducted' susceptibility. bulk cable injection, was changed from Mil-Std-461D, Figure CS114-2, to CS114-1, curve #2.
This changed correctly reflects the -
-appropriate figure number and is, therefore, acceptable.
Section 5.3.2.3, Two-Out-of-Four Logic Module, _was amended to include a discussion of the response to a loss of.a signal from an: APRM channel to the
- Two-Dut-of-Four Logic Module. The loss of signal will be treated the same as an APRM flux trip from that channel. For plants with only-one AC_ power source
channels will result-in only one APRM trip, but will also result in an -
immediate self-test-alarm.
Loss of signal from three or four APRM channels or an actual trip from one or more channels combined with loss of. signal from one or two channels will result in a ful1~ RPS trip from that voter logic.- This logic allows for a loss of one RPS bus without a scram, while maintaining-scram capability in the event of one other APRM channel in bypass. This design feature provides adequate protection against loss of function from a single failure, and is, therefore, acceptable.
_ _ - _ = _ _.
2..... _
4 Section 5.3.8.1, Loss of Input Power,-was changed to clarify the treatment of RPS AC power input for BWR6 plants. The Quad LVPS chassis receives two AC
. power inputs,=one from each RPS bus for non-BWR6 plants, and two AC power-inputs from one RPS bus for BWR6 plants.
There is one Quad LVPS in each APRM channel._ The revised wording clarifies the difference between power supply sources, and does not change the approved design. The staff, therefore, therefore concludes that this change is acceptable.
Section 5.3.8.2, Abnormal Conditions Leading to Inoperative Status, was changed to clarify the voting logic-for INOP conditions by adding a note at the end of-the section. : The note clarifies that loss of a signal from one or two APRM channels in most BWR6 plants will result in only one APRM trip. Loss of a signal from a third APRM channel or a trip of one of the other unbypassed APRM channels will result in a full RPS trip from that voter logic.
This logic allows for loss of an RPS bus without a scram, while ensuring the scram bility-is not lost when another APRM channel is bypassed. Therefore, the f concludes that this design approach meets the single failure criterion s-acceptable.
Section 6.3.3, Methodology for Unavailability Analysis, was amended to clarify the unavailability analysis methodology for the interfacing relays between the APRM and the RPS, which will be unchanged by the PRNMS replacement.
The revised portion of this section changes the channel functional test interval from 3 months to 6 months.
Based on the staff's review of the uncertainty analysis, the staff finds the channel functional test interval acceptable.
Section 6.3.4. Data Used for Unavailability Analysis, was amended by replacing the existing Tables and Table Notes with updated failure data, which now-includes the failure rate data-for. the K12 relays, which had been omitted from the original tables. The staff reviewed the revised failure data and concludes that they are acceptable.
Section 6.3.K Self-Test Coverage, clarifies the scope of the self-test coverage by stating that the self-testing does' not-include the final solid state output relays from the Two-Out-Of-Four Voter Module.
Since these relays
' are tested with the K12 relays, the staff concludes that this test coverage is acceptable.
Section 6.3.6, Conclusions of the Analysis, bases the APRM function unavailability-on-failure rate estimates assuming a 184 day functional test frequency. This assumed 184-day test-frequency is longer than the BWR STS frequency of 92' days and - therefore,. is conservative. : Additional details regarding the unavailability analysis were provided by the vendor in Section 6.3.6.1.- Discussion of Conclusions of the Analysis, and Section 6.3.6.2, Discussion of Sensitivity of Result Conclusions.
The staff reviewed'these added sections and concludes-that the conclusions are acceptable.
Section-8.3.4.4.1, Current Tech-Spec Requirements, item 2, APRM Flow-biased Simulated Thermal Power Upscale Trip, and item 3, APRM Fixed Neutron Flux Upscale Trip, were changed to reflect a staggered test basis for either six or eight channels. These changes are consistent with the STS requirements and are acceptable.
_m--
Section b.3.4.4.2, Changes to Response Time Testing
, was changed Function, which has been added to the channels in the PRNMS. r staggered testing will be based on four channels at a Additionally,
]~
relays driven by each voter being tested.
interface relays per voter is not required for the PRNMS design to meet t single failure criterion; consequently, testing one interface relay per vote is acceptable.
of the solid state voter outaut relay.Section 8.3.4.4.3, Justification d-one voter output relay will be tested for each "K12" test, which isThe amende cy acceptable.
a definition of test frequency.Section 8.3.4.4.4, Utility Action to Impleme frequency of response time testing using 2-out-of-4 voter channelsThe lic g
the tests may alternate 2-out-of-4 voter outputs provided one of the AP
, although interfacing relays in each channel is tested at least once per eight refu li B
cycles (based on a maximum 24 month cycle), and one of the four RPS scra e ng n
contactors in each channel d
is tested at least once per four refueling cycles This clarification is consistent with the existing requirements for respon time testing, in that one channel of the APRM system is tested on a sta test basis every fuel cycle.
Therefore, this testing frequency is acceptab e
in each channel of the APRM.
Section 8.4.1.2, Changes to Functions (OPRM Related RFS Trip Funct states that the only function added to the technical specifications is the OFRH Upscale (period-based algorithm).
Trip" terminology in the base report with "0PRM Upscale".A further clarification replace consistent with the staff safety evaluation report (SER) accepting the BWRO This change is topical report NED0-31960-A, "BWR Owner's Group Long-Term Stability S Licensing Methodology," dated Noverber 1995.
that this change is acceptable.
The staff, therefore, enncludes Section 8.4.1.3, Justification, has been changed to pr safety analysis for the OPRM function.
included in the TS Bases sections as defense in depth featuresThe other two algo required for OPRM operabilit
, but not as document, and is, therefore,y. This discussion is consistent with the base acceptable.
Additionally, Section 8.4.1.3 describes the relationship between APRM an Inops and the OPRM Upscale trip function.
integrated into the APRM Inop function.
The OPRM Inop function is function is voted as a trip separate from the APRM functions.However, the OPRM U channel will not result in two half-trips in each of the 2-o Consequently, channels.
Based on this discussion, the addition of only the OPRM Upscale function to the Tech Spec is consistent with the base document design description and is acceptable.
6 Section 8.4.1.4, Utility Action to Implement Changes, directs the utility to add the OPRM Upscale function as an *APRM function" in the RPS Instrumentation
" function" table. Additionally, the utility is directed to add the related surveillance requirements, the related setpoint, if applicable, and the
]
related discussions and descriptions to the Bases sections.
These additions are acceptable.
Section 8.4.2.2, Changes to Minimum Operable OPRM Channels, changes the base I
document to reflect the use of only the OPRM U) scale function in the Tech Spec. Additionally, another action statement ;1as been added that requires, in addition to restoration of the OPRM trip capability within 120 days, that the utility reduce the reactor power below 25% RTP within four hours if an
_j alternate method of detecting instability conditions and initiating mitigating actions cannot be performed. The basis for the four hours is consistent with the time required for equivalent actions covered by the Tech Specs. Reducing the reactor power to below 25% RTP ensures the reactor will operate outside the envelope of possible neutron flux instabilities.
The staff concludes that these actions are acceptable.
Section 8.4.2.3, Justification, modifies the last paragraph of the justification in the base report to be consistent with Paragraph 8.4.2.2.
The amended paragraph changes the time for fault identification and correctivt action from 30 days to 120 days. This 120-day time to identify and repair a fault in the OFR'i system was approved in the base report, and is, therefore, acceptable.
Section 8.4.2.4, Utility Action to Implement Changes, is amended to more accurately describe the as-designed OPRM, and to change references in the Tech Specs from OPRM Trip to OPRM Upscale function. Additional guidance was provided to add descriptions of the OPRM system to the Tech Spec Bases. These changes are acceptable.
Section 8.4.3.2, Changt to Applicable Modes of Operation, has been amended to change the requirement for OPRM Upscale trip function operability from
" operable at all power levels ir Mode 1 (run)" to " operable in Mode I when the Thermal Power is ;t25% RTP." This change is acceptable because the OPRM is automatically bypassed when the Thermal Power is <30%.
Section 8.4.3.3, Justification, has been replaced with more detailed information that acceptably add,erses the requirement for OPRM Upscale operability in Mode 1 (run). OPRM Upscale operability above 60% rated core flow is required because there are identified events that can reduce the plant from 100% power and flow to less than 60% flow without o)erator action. The topical report identifies loss of feedwater heating as tie only event in which power less than 30% RTP increase: above 30% RTP without operator intervention.
Consequently, OPRM Upscale operability is required above 25% RTP to provide margin. These limits are ncminal values, which must be addressed by each licensee to account for plant-specific design features. The staff concludes that this justification is acceptable.
Section 8.4.3.4, Utility Action to implement Changes, requires the utilities to add to the technical specifications the requirement for OPRM Upscale
.a=_..
function operability in Mode 1 (run
\\
to add to the Bases description as r)equired.when the thermal power is 225% RTP, and These changes are consistent with the discussion in Section 8.4.3.3, Justification, and are, therefore, acceptable.
Section 8.4.4.1.2 Changes to Channel Check Requirements, adds Channel Check or Instrument Check requirements for the OPRM Upscale function.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or once-per-day interval is consistent with the APRM interval and isThe acceptable.
Section 8.4.4.1.4, Utility Action to Implement Changes, requires the utilities to add the OPRM Upscale function channel check requirements to the technical specifications.
These changes are appropriate and acceptable.
M Section B.4.4.2.2. Changes to Channel Functional Test Requirements, adds a requirement for functional testing of the OPRM Upscale function and the 2-out-of-4 voter channels every 184 days (6 months).
with the approved interval for the APRM functions, and 1.1, therefore,This inte acceptable.
A once-psr-outage basis up to a 24-month interval for confirming the OPRM Upscale function is enabled when the APRM Simulated Thermal Power is 2 RTP and recirculation flow is 460%) rated recirculation flow will also(3 added to the base report. This confirmation of the OPRM Upscale function be auto-enable function will result in changes in the auto-enable settings if the functional test fails.
calibration if it fits a plant-specific technical specification structureCo better, and it meets the TS definition for calibration.
that these changes are acceptable.
The staff concludes Section 8.4.4.2.3, Justification, is changed to provide more detailed information concerning the channel functional test requirements.
justifications for selecting the channel functional test interval acceptably The Additionally, surveillances of the APRM associated inpu function, combined with the surveillance of the OPRM Upscale function auto-enable ensure the OPRM Upscale function is enabled in the intended region of the power / flow map.
24-month interval, is based on tha use of nondrifting digital equiTh the automatic self-test functions for detecting hardware failures.pment and concludes that these changes are acceptable.
The staff Section 8.4.4.2.4, Utility Action to Implement Changes, is amended to require Channel Functional testing every 184 days (6 months), to include the 2-out-of-4 Voter function, and to confirm operability of the auto-enable function on a once-per-outage basis up to a 24-month interval.
The staff concludes that these changes are acceptable.
require an OPRM Upscale function calibration at a frequ cycle (up to a 24-month interval).
This change is consistent with the existing requirements for the APRM and is, therefore, acceptable.
8 Section 8.4.4.3.3, Justification, and Section 8.4.4.3.4, Utility Action to Implement Changes, replace "0PRM Trip" with "0PRM Upscale".
administrative and are acceptable.
These changes are Section 8.4.4.4.2, Changes to Res onse Time Testing Re.luirements 3
amended to inciude the OPRM Upsca e output relays in *.he response, will be of the 2-out-of-4 voter channels.
The test frequency and the requiredtime testing response time of the OPRM trip output relays (0.05 sr:cond) will be the same for the APRM flux trip output relays.
This change is acceptable.
Section 8.4.4.4.3, Justification, is amended to describe the allocation of total res channels.ponse time to the software and hardware portions of the APRM and OPR e
Additionally, the calibration interval has been changed to a once per outage basis, up to a 24 month interval.
OPRM Upscale output relays at the same frequency as the APRM flux re acceptable.
Section 8.4.4.4 4 to modify the resp. Utility Action to implement Changes, requires the licensee onse time testing procedure for the 2-out-of-4 voter response time tests, and alternating the voter OPRM voter APRM output testing.
tests is acceptable.
Since the relays are identical, alternating the Section 8.5.2.2, Changes to Minimum Operable Control Rod Block Channel changes the minimum number of APRM rod block channels from four to thre This change meets the single failure design criterion, and is, therefore acceptable.
Additionally, the first paragraph has been amended to state that the minimum number of APRM channels is three, instead of the previou two channels.
This change is also acceptable.
e Section 8.5.2.3, Justification, adds a discussion concerning the requireme for the minimum number of APRM channels.
not discuss the APRM channel requirement. The base report justification did number of APRM channels is consistent with the single failure criterion and is, therefore, acceptable.
Section 8.5.2.4, Utility Action to Implement Changes, increases the minimu number of APRM channels from two to three, if the APRM functions are re m
in the technical specifications.
This change is acceptable.
Section 8.5.4.2.3 This change is acc,eptable. Justification, is amended to correct a grammatical error.
Section 8.6, Shutdown Margin Testing - Refueling, was added to the base report.
to address provisions or limitations related to APRM functionsT changes are to be consistent with the APRM TS changes implemented for th Specific PRNM.
The staff concludes that this instruction is acceptable.
Section-10, References, has been chan 31960, and NED0-31960, Supplement 1, ged to reflect NRC approval of NEDO-
"BWR Owners' Group Long-Term Stability
9 Solutions Licensing Methodology." A Reference for the NRC-approved base report, NEDC-32410P-A,
- Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC-PRNM) Retrofit Plus Option III Stability Trip Function," has'also been added. These changes are acceptable.
Appendix A has been changed to reflect compliance with NQA-2, Part 2.7, in addition to Reg. Guide 1.152 and IEEE 7-4.3.2-1993. Section A.3 was added to provide a comparison of the NUMAC PRNM design process with NQA-2, Part 2.7 requirements. The staff reviewed this appendix and concludes that the relationships between the PRNM Design Process and the ANSI NQA-2, Part 2.7, are acceptable.
Figure E.1.6, " Replacement 4 APRM Configuration, BWR6, Smaller Core " and Figure E.1.7, ' Replacement 4 APRM Configuration BWR6, Larger Core," were changed to add the PCI blocks for each APRM channel. Additionally, a reference'to these two figures was added to the caption for Figure E.3.6-4, "APRM Replacement Configuration, BWR6, All Core Sizes " to reflect the addition of the PCI interconnections. These changes are consistent with the revised design description for the BWR6 PRNM and are, therefore, acceptable.
Power distribution / interface block diagrams, Figure E.5.3 and Figure E.5.6, were added to show the BWR6 current and revised configurations for the power distribution interfaces, respectively. These changes are consistent with the BWR6 PRM and PRNM descriptions in the base report and are, therefore, acceptable.
Appendix F Equipment Failure Analysis and Reliability Information, was added to the base report to include updated failure rate data tables and notes. The updated tables provide the data used in the unavailability analysis discussed in Section 6 of Supplement 1.
The staff confirmed the data and notes in-the tables are consistent with the discussion in Section 6 and are, therefore, acceptable.
Annendix H. Samole Markuos of Tech Soecs. OPRM The sample technical specification markups in Supplement I are based on the assumption that changes defined in Appendix H, Section H.I.1, of the base report have been incorporated into the technical specifications.
Consequently, the strikeouts and additions in Appendix H to Supplement I apply
-to Section 8.4 (OPRM) of the base report, as amended by the supplement.
Conditions A and B of LCO 3.3.1.1 and the associated Bases were amended to add the OPRM Upscale function (Function 2.f in Table 3.3.1.1-1, Reactor Protection System Instrumentation) to the list of functions in the Note for Required Action A.2, and Condition B.
The notes exclude the applicability of the APRM functions.from Required Action A.2, and Condition B.
APRM functions, including the OPRM upscale function are associated with all four RPS trip channels.
Consequently, A.2 & B cannot be performed.
Additionally, the associated Bases were changed in accordance with the guidance provided in the body of the approved NEDC-32410P. Therefore, these changes are acceptable.
10 Condition I for BWR/4 plants (which is Condition J for BWR/6 plants), with changes justified in the associated Bases, was added to LCO 3.3.1.1 to require the licensee to initiate an alternate method to detect and suppress thermal-hydraulic instability oscillations within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of determining that there are less than 3 OPERABLE OPRM U) scale function channels. Additionally, the licensee is required to restore tie inoperable channels to OPERABLE within 120 days. These actions and completion times, and the associated changes to the Bases, are acceptable.
Condition J with changes justified in the associated Bases, was added to LCO 3.3.1.1 to require the licensee to reduce THERMAL POWER to [25%] within [4]
hours if both required actions for Condition I are not met within the requ' red completion time. The required action and 4-hour completion time are acceptable.
The Frequency requirement for Surveillance Requirement (SR) 3.3.1.1.8, Calibrate the local power range monitors, was changed from 1000 MWD MWD /T average core ex)osure. plants that have justified a frequency MWD /T) to account for those f 2000 This change is not related to the OPRM and does not affect the APRM c1anges required by the plant.
Each licensee must justify changes in the SR Frequency; therefore, this change is acceptable.
SR 3.3.1.1.18, with associated Bases, was added to require verification that the. OPRM is not bypassed when APRM Simulated Thermal Power is 2[30]% and recirculation drive flow is <(60]% of rated recirculation drive flow. The frequency is 18 These changes are co[ns? months, which corresponds to a fuel cycle interval.
< stent with the staff's approval of the design description, and are, therefore, acceptable.
The OPRM Upscale function was added to Table 3.3.1.1-1, Reactor Protection System Instrumentation, as Function 2.f.
The applicable mode (2 [25]% RTP),
number of-required channels (3), the associated footnote (c), the reference to Required Action D.1 (I for BWR/4 plants and J for BWR/6 plants), the surveillance requirements, and the associated Bases are in accordance with the staff-approved discussion in the body of Supplement I and are, therefore, acceptable.
3.0 CONCLUSION
NEDC-32410P, Supplement 1, " Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," clarifies issues related to the APRM part of the PRNM design and APRM Technical Specifications. Additionally, Supplement 1 proposes technical specifications for the OPRM function of the PRNMS. The staff reviewed the proposed changes and additions to NEDC-32410P-A, as proposed in Supplement 1, and concludes that the requested amendment.s and proposed technical specifications are consistent with the BWd standard TS and the staff's acceptance of NEDC-32410P, and are, therefore, acceptati.e. The conditions stated in the staff's safety evaluation dated September 5,1995, approving NEDC-32410P, also apply to Supplement 1.
l
{
GE Nuclear Energy cc:
Gary L. Sozzi, Manager Technical and Mcdification Services GE Nuclear Energy 175 Curtner Avenue San Jose, CA 95125 George B. Stramback GE Nuclear Energy 175 Curtner Avenue San Jose, CA 95125 James F. Klapproth
'GE Nuclear Energy P.O. Box 780 Wilmington, NC 28402 Ralph J. Reda, Manager Fuel and Facility Licensing General Electric Company P.O. Box 780 Wilmington, NC 28402 1
9