Text

License Amendment Request to Revise Technical Specification 3.3.1, Reactor Trip System (RTS) Instrumentation, to Incorporate Installed Bypass Test Capability for the Power Range RTS Functions
	ML21277A173
Person / Time
Site:	Prairie Island
Issue date:	10/02/2021
From:	Domingos C; Northern States Power Company, Minnesota, Xcel Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML21277A171	List: L-PI-21-006, License Amendment Request to Revise Technical Specification 3.3.1, Reactor Trip System (RTS) Instrumentation, to Incorporate Installed Bypass Test Capability for the Power Range RTS Functions;
References
	L-PI-21-006 WCAP-18651-NP
	Download: ML21277A173 (63)
	v • d • e

ENCLOSURE 4 CONTAINS PROPRIETARY INFORMATION WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390 1717 Wakonade Drive Welch, MN 55089 October 2, 2021 L-PI-21-006 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant, Units 1 and 2 Docket Nos. 50-282 and 50-306 Renewed Facility Operating License Nos. DPR-42 and DPR-60 License Amendment Request to Revise Technical Specification 3.3.1, Reactor Trip System (RTS) Instrumentation," to Incorporate Installed Bypass Test Capability for the Power Range RTS Functions Pursuant to 10 CFR 50.90, Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), is submitting a request for an amendment to the Technical Specifications for the Prairie Island Nuclear Generating Plant.

The proposed change revises Technical Specification 3.3.1, Reactor Trip System (RTS)

Instrumentation for the Power Range (PR) RTS instrumentation channels. This change will allow the PR RTS instrumentation channels to be bypassed during surveillance testing.

Additionally, this change will allow the input relays from the PR RTS instrumentation channels to be excluded from the Channel Operational Test (COT). This change will allow testing of the PR RTS instrumentation channels, with a permanently installed PR RTS bypass capability.

provides a description and assessment of the proposed changes. Enclosure 2 contains a non-proprietary version of the Westinghouse document. An affidavit supporting withholding proprietary information included with this request is contained in Enclosure 3. contains information proprietary to Westinghouse Electric Company, LLC (Westinghouse). Westinghouse requests that the document be withheld from public disclosure in accordance with 10 CFR 2.390(b)(4).

Approval of the proposed amendment is requested within 12 months of the acceptance of this request. Once approved and following installation of permanent bypass capability, the amendment shall be implemented within 30 days.

In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Minnesota State Official.

Please contact Mr. Jeff Kivi at (612) 330-5788 or Jeffrey.L.Kivi@xcelenergy.com.

~

Xcel Energy

Document Control Desk Page 2 Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.

I declare under penalty of perjury, that the foregoing is true and correct.

Executed on CQ~-'tr~P-_=D~o~m E-"""'in~g=o~s~;;A.--.!:~---""'IE...a~--

Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosures (4) cc:

Administrator, Region 111, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC State of Minnesota (Non-proprietary Enclosures 1, 2, and 3 only)

Page 1 of 10 ENCLOSURE 1 PRAIRE ISLAND NUCLEAR GENERATING PLANT Evaluation of Proposed Change License Amendment Request Revise Technical Specification 3.3.1, Reactor Trip System (RTS) Instrumentation," to Incorporate Installed Bypass Test Capability for the Power Range RTS Functions 1.0

SUMMARY

DESCRIPTION............................................................................................ 2 2.0 DETAILED DESCRIPTION............................................................................................. 2 2.1 Background.......................................................................................................... 2 2.2 Reason for Proposed Change.............................................................................. 2 2.3 Proposed Changes.............................................................................................. 3

3.0 ASSESSMENT

.............................................................................................................. 4 3.1 Evaluation of Proposed Changes......................................................................... 4

4.0 REGULATORY ANALYSIS

........................................................................................... 5 4.1 Applicable Regulatory Requirements................................................................... 5 4.2 Precedent............................................................................................................. 7 4.3 No Significant Hazards Consideration Determination.................................. 8 4.4 Conclusions........................................................................................................ 9 5.0 ENVIRONMENTAL EVALUATION.............................................................................. 9

6.0 REFERENCES

............................................................................................................ 10 ATTACHMENTS:

1. Technical Specification Pages (Mark-up)

2. Technical Specification Pages (Re-typed)

3. Technical Specification Bases Pages (Mark-up - Provided for Information Only)

L-PI-21-006 NSPM Page 2 of 10 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90 Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM) proposes to revise Technical Specifications section 3.3.1, Reactor Trip System (RTS) Instrumentation for the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2. This change will allow the Power Range (PR) RTS instrumentation channels to be bypassed during surveillance testing with permanently installed PR bypass capability. Additionally, this change will allow the input relays from the PR RTS instrumentation channels to be excluded from the Channel Operational Test (COT).

This change to the NIS power range functions is supported by Westinghouse Electric Company LLC (Westinghouse) report WCAP-18651-P, Power Range Nuclear Instrumentation System Bypass Test Instrumentation for Prairie Island Units 1 and 2, (Enclosure 4) and the nonproprietary version (Enclosure 2). Changes associated with the bypass testing of the RTS functions utilizing permanently installed bypass capability are discussed below.

2.0 DETAILED DESCRIPTION

2.1 Background

Operating plants have experienced many inadvertent reactor trips during the performance of instrumentation surveillances, causing unnecessary transients and challenges to safety systems. In the early 1980s, in response to growing concern regarding the impact of TS surveillance testing and maintenance activities on plant operations, particularly as related to instrumentation systems, the Pressurized Water Reactor Owners Group (PWROG) (formerly the Westinghouse Owners Group) initiated a program to justify extending the RTS and Engineered Safety Feature Actuation System (ESFAS) bypass test times, Completion Times, and Surveillance Frequencies, to provide additional time to perform surveillance and maintenance activities. WCAP-10271-P-A (Reference 1) and its Supplements (References 2 and 3) justified extending the RTS and ESFAS bypass test times, Completion Times, and Surveillance Frequencies. One of the provisions discussed was to allow routine surveillance testing of the RTS and ESFAS channels in a bypassed condition rather than a tripped condition. The NRC Safety Evaluations (SEs) for WCAP-10271-P-A and Supplement 1 (Reference 2) concluded that using temporary jumpers or lifting leads was not an acceptable method of performing a channel bypass during routine surveillance testing.

The SEs further discussed that routine channel testing in the bypass mode should ensure that the plant design allows testing in bypass without lifting leads or installing temporary jumpers.

2.2 Reason for Proposed Change The proposed change is needed to support utilization of permanently installed bypass testing capability, which will reduce the potential for an inadvertent reactor trip due to a failure or spurious transient in a redundant channel.

L-PI-21-006 NSPM Page 3 of 10 2.3 Proposed Changes The proposed change to PINGP Units 1 and 2 TS will allow testing of the NIS PR RTS functions in bypass following the installation of permanent test panels for each NIS PR channel. As discussed in detail in Enclosure 4, the permanently installed test panels will allow performance of the COT by placing the channel in bypass instead of placing the channel in a tripped condition. The test panel LEDs on the test panels will provide positive indication of channels placed in bypass. Annunciator signals will be provided to the main control board by the test panels when the test panel is switched to the bypass mode. This change will not make use of temporary jumpers. Details of the NIS PR bypass test capability are contained in.

The following functions in the RTS instrumentation will be capable of being bypassed for testing:

Function 2a - Power Range Neutron Flux - High Function 2b - Power Range Neutron Flux - Low Function 3a - Power Range Neutron Flux Rate - High Positive Rate Function 3b - Power Range Neutron Flux Rate - High Negative Rate The proposed change will revise the Required Actions Note in TS 3.3.1, Condition D, and the Notes in Surveillance Requirements 3.3.1.7 and 3.3.1.8. The Condition D Note will be revised to allow testing a channel in bypass, and the Surveillance Requirements Notes are being revised to exclude the RTS input relays during the performance of a COT to allow testing in bypass. However, the RTS input relays will continue to be tested (i.e., tripped) during the Channel Calibration (SR 3.3.1.11) in accordance with the Frequency specified in the Surveillance Frequency Control Program.

When a PR RTS instrumentation channel is placed in bypass, the two-out-of-four logic will become a two-out-of-three logic; therefore, the Function will still provide the necessary RTS function. After implementation of this TS change, a spurious reactor trip will be avoided, since the partial trip condition of testing a channel in the tripped condition will be eliminated by placing the channel in bypass, and the coincident logic will be maintained by requiring signals from two channels to actuate the RTS function.

The detailed proposed changes to the PINGP TS are provided in mark-up form in Attachment 1 to this enclosure. The detailed proposed changes to the PINGP TS Bases are provided in mark-up form for information only in Attachment 3 to this enclosure. Changes to the TS Bases will be incorporated in accordance with the TS Bases Control Program (TS 5.5.12) following NRC approval of this amendment request.

L-PI-21-006 NSPM Page 4 of 10

3.0 ASSESSMENT

3.1 Evaluation of Proposed Changes The proposed changes discussed in Enclosure 4 do not modify the PR RTS Allowable Values or the RTS functions credited in the safety analyses. Hardware modifications will be made so that testing in bypass can be accomplished without lifting leads or installing temporary jumpers. This satisfies the condition specified by the NRC in SEs issued during the review of WCAP-10271-P-A and its Supplements. The impact of testing in bypass was previously evaluated and approved by the NRC during the review of WCAP-10271-P-A and was determined to be acceptable.

The NRC Final Safety Evaluation (SE) included in References 1 and 2 stated that:

Testing In The Bypassed Mode The WCAP proposes that operational testing of the analog channels be performed with the channel being tested in a bypassed condition instead of a tripped condition. The analyses conducted by Westinghouse and the NRC staff and its contractors included this proposal in the calculational models. Therefore, the staff concludes that the proposal is acceptable. However, the staff is aware that the design of the RTS circuitry at many plants does not include provisions to perform testing in a bypassed condition without operator actions such as lifting leads or installing temporary jumpers. Testing of RTS analog channels in the bypassed conditions by use of temporary jumpers or by lifting leads is not acceptable. The chance of personnel errors leaving a number of channels in a bypassed condition would be too large for the routine use of such methods. Therefore, licensees choosing the option to perform routine channel testing in the bypass mode should ensure that the plant design allows testing in bypass without lifting leads or installing temporary jumpers. The staffs acceptance of this option is contingent on confirmation of this capability.

The hardware modifications necessary to facilitate testing in bypass will be implemented in accordance with 10 CFR 50.59. This License Amendment Request addresses the TS changes required to support this modification.

NUREG-1431 (Reference 4) contains the following Reviewers Note that should be used for plants with installed bypass test capability:

One channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing and setpoint adjustment.

The current TS allows an inoperable channel to be placed in bypass for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to allow surveillance testing or setpoint adjustment of other channels; however, the channel is currently placed in the tripped state during testing. The proposed TS change does not change the allowed bypass time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or the Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , which was approved by the

L-PI-21-006 NSPM Page 5 of 10 NRC in Reference 5. The capability to place a PR RTS channel in trip will still exist after the installation of the new bypass test panel hardware; therefore, the PR RTS functions are not affected. With the proposed TS change, the plant would be able to perform routine testing with a channel in bypass instead of placing the channel that is tested in a tripped condition.

Physical and administrative controls will be provided to prevent the simultaneous bypassing of more than one redundant protection set channel at any one time and to restore the channel to its normal, unbypassed state.

The changes to SR 3.3.1.7 and SR 3.3.1.8 exclude the RPS input relays from these COTs. If the RPS input relays were included during the performance of the COTs (i.e., tripped) and a second PR channel spuriously tripped during a COT, the reactor would spuriously trip.

Excluding the RPS input relays from these COTs supports testing in bypass to eliminate this potential for spurious reactor trips.

Although the input relays will no longer be testing as part of the COTS, they will continue to be tested during Channel Calibrations of SR 3.3.1.11. Excluding RPS input relays from the COTs reduces the frequency of testing the RPS input relays. NSPM evaluated the reduction in test frequency and determined, based on maintenance history, the increased time between tests is not expected to result in an increase in undetected failures of the RPS input relays.

Specifically, there have been no RPS input relay failures to trip during testing in the past ten years, which is over 3500 demands. Also, RPS input relays de-energize to trip and the trip is annunciated in the control room further reducing the likelihood of an undetected failure.

4.0 REGULATORY ANALYSIS

4.1 Applicable Regulatory Requirements PINGP was not licensed to the 10 CFR 50, Appendix A, General Design Criteria (GDC).

PINGP was designed and constructed to comply with NSPs understanding of the intent of the AEC General Design Criteria for Nuclear Power Plant Construction Permits, as proposed on July 10, 1967. Since the construction of the plant was significantly completed prior to the issuance of the February 20, 1971, 10CFR50, Appendix A GDC, the plant was not reanalyzed and the Final Safety Analysis Report (FSAR) was not revised to reflect these later criteria.

However, the AEC Safety Evaluation Report acknowledged that the AEC staff assessed the plant, as described in the FSAR, against the Appendix A design criteria and...are satisfied that the plant design generally conforms to the intent of these criteria.

discusses how the following 10 CFR 50, Appendix A, GDCs are applicable to the PR NIS bypass test hardware:

GDC 2, Design Bases for Protection Against Natural Phenomena GDC 19, Control Room GDC 20, Protection System Functions GDC 21, Protection System Reliability and Testability

L-PI-21-006 NSPM Page 6 of 10 GDC 22, Protection System Independence GDC 23, Protection System Failure Modes GDC 24, Separation of Protection and Control Systems discusses how the following Regulatory Guides (RGs) are applicable to the PR NIS bypass test hardware:

RG 1.47, Revision 1, Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety Systems RG 1.53, Revision 2, Application of Single Failure Criterion to Nuclear Power Plant Protection Systems RG 1.75, Revision 3, Physical Independence of Electric Systems RG 1.89, Revision 1, Qualification of Class 1E Equipment for Nuclear Power Plants RG 1.100, Revision 3, Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants RG 1.118, Revision 3, Periodic Testing of Electric Power and Protection Systems RG 1.22, Revision 0, Periodic Testing of Protection System Actuation Functions RG 1.30, Revision 0, Quality Assurance Requirements for the Installation Inspection, and Testing Instrumentation and Electric Equipment discusses how the following Institute of Electrical and Electronics Engineers (IEEE) Standards are applicable to the PR NIS bypass test hardware:

IEEE 603-1991, IEEE Standard: Criteria for Protection Systems for Nuclear Power Generating Stations IEEE 379-2000, Trial Use Guide for the Application of the Single Failure Criteria to Nuclear Power Generating Station Protection Systems IEEE 384-1974, Trial Use Standard for Separation of Class 1E Equipment and Circuits IEEE 344-2004, IEEE Recommended Practices for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations IEEE 338-1987, IEEE Standard Criteria for the Periodic Testing of Nuclear Power Generating Station Class 1E Power and Protection Systems IEEE 323-1974. IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations 10 CFR 50.36(c)(2) states:

Limiting conditions for operation. (i) Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

10 CFR 50.36(c)(2) continues to be met because the LCO and Actions in TS 3.3.1 are not being eliminated.

L-PI-21-006 NSPM Page 7 of 10 10 CFR 50.36(c)(3) states:

Surveillance requirements. Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

10 CFR 50.36(c)(3) continues to be met because the Surveillance Requirements in TS 3.3.1 are not being eliminated 4.2 Precedent The NRC has approved similar submittals as indicated below:

1) Byron and Braidwood a) Letter from B. L. Mozafari (U.S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), "Braidwood Station, Units 1 and 2 and Byron Station, Unit Nos. 1 and 2 - Issuance of Amendments RE: Revision of Technical Specifications (TS) 3.3.1, Reactor Trip System Instrumentation, and TS 3.3.2, Engineered Safety Feature Actuation System Instrumentation (TAC Nos. ME5836, ME5837, ME5838, and ME5839)," dated March 30, 2012. [ML120660494]

b) Letter from J. Wiebe (U.S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), "Braidwood Station, Units 1 and 2, and Byron Station, Unit Nos. 1 and 2 - Issuance of Amendments to Clarify Technical Specifications 3.3.1,

'Reactor Trip System Instrumentation, and TS 3.3.2, Engineered Safety Feature Actuation System Instrumentation (TAC Nos. MF4023, MF4024, MF4025, and MF4026)," dated December 7, 2014. [ML14239A427]

2) Salem a) Letter from T. Wengert (U.S. Nuclear Regulatory Commission) to R. Braun (PSEG Nuclear LLC), "Salem Nuclear Generating Station, Unit Nos. 1 and 2 - Issuance of Amendments RE: Revision to Reactor Trip System Instrumentation Technical Specifications (CAC Nos. MF6067 and MF6068)," dated March 28, 2016.

[ML16054A068]

3) Ginna a) Letter from V. Sreenivas (U. S, Nuclear Regulatory Commission) to B. C. Hanson (Exelon Generation Company, LLC), R. E. Ginna Nuclear Power Plant - Issuance of Amendment No. 132 to Revise Technical Specifications 3.3.1, Reactor Trip System Instrumentation, and 3.3.2, Engineered Safety Feature Actuation System Instrumentation (EPID L-2017-LLA0388), dated November 13, 2018 [ML18213A369].

L-PI-21-006 NSPM Page 8 of 10 4.3 No Significant Hazards Consideration Determination Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM) proposes to revise Technical Specifications section 3.3.1, Reactor Trip System (RTS) Instrumentation for the Prairie Island Nuclear Generating Plant (PINGP),

Units 1 and 2. The proposed change revises the Required Actions Note in TS 3.3.1, Condition D to allow testing of the power range (PR) reactor trip system (RTS) functions in bypass instead of a tripped condition and to exclude the RTS input relays during the performance of a Channel Operational Test (COT) in the Notes in Surveillance Requirements 3.3.1.7 and 3.3.1.8.

NSPM has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of Amendment, as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The PR RTS functions trip the reactor in response to certain events. The PR RTS functions do not themselves act as a precursor or an initiator for any transient or design basis accident; therefore, the proposed change does not significantly increase the probability of any accident previously evaluated.

The structural and functional integrity of the RTS is unaffected by the proposed change.

The proposed change does not alter or prevent the capability of structures, systems, and components to perform their intended function to mitigate the consequences of an initiating event within the assumed applicable acceptance limits.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No No new operating configuration is being imposed by the surveillance testing in bypass that would create a new failure scenario. In addition, no new failure modes are being created for any plant structures, systems, or components. Testing of the PR RTS functions in bypass does not result in any new or different accident scenarios. The accidents evaluated in the Updated Safety Analysis Report (USAR) are not impacted and remain valid.

L-PI-21-006 NSPM Page 9 of 10 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No No safety analyses are impacted by the proposed change to test a PR RTS channel in bypass. The proposed change does not alter the safety limits, limiting safety system settings, or limiting conditions for operation. The margins associated with the safety analyses and applicable acceptance criteria are not impacted. The safety analyses are bounding since they are not impacted by performing surveillance testing of a PR RTS channel in bypass. The systems assumed in the safety analyses will continue to be capable of performing their mitigation functions.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, NSPM concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Therefore, it is concluded that the requested amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

5.0 ENVIRONMENTAL EVALUATION NSPMs review of the proposed amendment has determined it would change a requirement with respect to the installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Therefore, the proposed amendment meets the eligibility criterion for categorical exclusion

L-PI-21-006 NSPM Page 10 of 10 set forth in 10 CFR 51.22(c)(9) and pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Westinghouse WCAP-10271-P-A, Revision 0, Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System, May 1986.

2. Westinghouse WCAP-10271, Supplement 1-P-A, Revision 0, Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System Supplement 1, May 1986.

3. Westinghouse WCAP-10271-P-A, Supplement 2, Revision 1, Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System, June 1990.

4. NUREG-1431, Volumes 1 and 2, Revision 4.0, Standard Technical Specifications Westinghouse Plants, USNRC, April 2012.

5. NRC letter dated August 18, 1994, Prairie Island Nuclear Generating Plant, Unit NOS. 1 AND 2 Reissuance of Amendments RE: Instrumentation Specification Changes (TAC NOS M84671 AND M84672). (NRC ADAMS Accession No. ML022250056)

L-PI-21-006 ENCLOSURE 1, ATTACHMENT 1 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 License Amendment Request:

Revise Technical Specification 3.3.1, Reactor Trip System (RTS) Instrumentation," to Incorporate Installed Bypass Test Capability for the Power Range RTS Functions PROPOSED TECHNICAL SPECIFICATION CHANGES (Mark-up)

(3 pages follow)

RTS Instrumentation 3.3.1 Prairie Island Units 1 and 2 3.3.1-2 Unit 1 - Amendment No. 23

Unit 2 - Amendment No. 22

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One channel or train inoperable.

C.1 Restore channel or train to OPERABLE status.

OR C.2.1 Initiate action to fully insert all rods.

AND C.2.2 Place the Rod Control System in a condition incapable of rod withdrawal.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 48 hours 49 hours5.671296e-4 days 0.0136 hours 8.101852e-5 weeks 1.86445e-5 months D. One Power Range Neutron Flux channel inoperable.

NOTE-----------------

The inoperable channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing and setpoint adjustment of other channels.

D.1.1 Place channel in trip.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OR In accordance with the Risk Informed Completion Time Program One

~

TBD TBD

RTS Instrumentation 3.3.1 Prairie Island Units 1 and 2 3.3.1-15 Unit 1 - Amendment No. 23

Unit 2 - Amendment No. 22

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.6 ----------------------------NOTE----------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is > 75% RTP.

Calibrate excore channels to agree with core power distribution measurements.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.7

NOTE----------------------------

Not required to be performed for source range instrumentation prior to entering MODE 3 from MODE 2 until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after entry into MODE 3.

Perform COT.

In accordance with the Surveillance Frequency Control Program S

1.

2. The RPS input relays are excluded from this Surveillance for Functions 2. a. and 3.

TBD TBD

RTS Instrumentation 3.3.1 Prairie Island Units 1 and 2 3.3.1-16 Unit 1 - Amendment No. 23

Unit 2 - Amendment No. 22

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.8

NOTES--------------------------

1. This Surveillance shall include verification that interlocks P-6 and P-10 are in their required state for existing unit conditions.

2. Not required to be performed for intermediate and source range instrumentation prior to reactor startup following shutdown < 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

Perform COT.

NOTE-------

Only required when not performed within the Frequency specified in the Surveillance Frequency Control Program Prior to reactor startup AND Twelve hours after reducing power below P-10 for power and intermediate range instrumentation AND Four hours after reducing power below P-6 for source range instrumentation AND In accordance with the Surveillance Frequency Control Program

3. The RPS input relays are excluded from this Surveillance for Function 2. b.

TBD TBD

L-PI-21-006 ENCLOSURE 1, ATTACHMENT 2 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 License Amendment Request:

Revise Technical Specification 3.3.1, Reactor Trip System (RTS) Instrumentation," to Incorporate Installed Bypass Test Capability for the Power Range RTS Functions PROPOSED TECHNICAL SPECIFICATION CHANGES (Re-typed)

(4 pages follow)

RTS Instrumentation 3.3.1 Prairie Island Unit 1 - Amendment No. XXX Units 1 and 2 3.3.1-2 Unit 2 - Amendment No. YYY ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One channel or train inoperable.

C.1 Restore channel or train to OPERABLE status.

OR C.2.1 Initiate action to fully insert all rods.

AND C.2.2 Place the Rod Control System in a condition incapable of rod withdrawal.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 48 hours 49 hours5.671296e-4 days 0.0136 hours 8.101852e-5 weeks 1.86445e-5 months D. One Power Range Neutron Flux channel inoperable.

NOTE-----------------

One channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing and setpoint adjustment.

D.1.1 Place channel in trip.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OR In accordance with the Risk Informed Completion Time Program

RTS Instrumentation 3.3.1 Prairie Island Unit 1 - Amendment No. XXX Units 1 and 2 3.3.1-15 Unit 2 - Amendment No. YYY SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.6 ----------------------------NOTE----------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is > 75% RTP.

Calibrate excore channels to agree with core power distribution measurements.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.7

NOTE----------------------------

1. Not required to be performed for source range instrumentation prior to entering MODE 3 from MODE 2 until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after entry into MODE 3.

2. The RPS input relays are excluded from the Surveillance for Functions 2.a and 3.

Perform COT.

In accordance with the Surveillance Frequency Control Program

RTS Instrumentation 3.3.1 Prairie Island Unit 1 - Amendment No. XXX Units 1 and 2 3.3.1-16 Unit 2 - Amendment No. YYY SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.8

NOTES--------------------------

1. This Surveillance shall include verification that interlocks P-6 and P-10 are in their required state for existing unit conditions.

2. Not required to be performed for intermediate and source range instrumentation prior to reactor startup following shutdown < 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

3. The RPS input relays are excluded from this Surveillance for Function 2.b.

Perform COT.

NOTE-------

Only required when not performed within the Frequency specified in the Surveillance Frequency Control Program Prior to reactor startup AND Twelve hours after reducing power below P-10 for power and intermediate range instrumentation AND Four hours after reducing power below P-6 for source range instrumentation AND

RTS Instrumentation 3.3.1 Prairie Island Unit 1 - Amendment No. XXX Units 1 and 2 3.3.1-17 Unit 2 - Amendment No. YYY SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.1.8 (continued)

In accordance with the Surveillance Frequency Control Program SR 3.3.1.9

NOTE----------------------------

Verification of setpoint is not required.

Perform TADOT.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.10 ---------------------------NOTE-----------------------------

This Surveillance shall include verification that the time constants are adjusted to the prescribed values.

Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.11 --------------------------NOTE------------------------------

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program

L-PI-21-006 ENCLOSURE 1, ATTACHMENT 3 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 License Amendment Request:

Revise Technical Specification 3.3.1, Reactor Trip System (RTS) Instrumentation," to Incorporate Installed Bypass Test Capability for the Power Range RTS Functions PROPOSED CHANGES TO TECHNICAL SPECIFICATION BASES PAGES (Provided for Information Only)

(3 pages follow)

RTS Instrumentation B 3.3.1 BASES Prairie Island Units 1 and 2 B 3.3.1-43 Revision 250 ACTIONS D.1.1 and D.1.2 (continued)

If Condition D is entered while performing PHYSICS TESTS in accordance with LCO 3.1.8, a total of two channels may be inoperable.

The Required Actions have been modified by a Note that allows placing the inoperable channel in the bypass condition for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months while performing routine surveillance testing of other channels. The Note also allows placing the inoperable channel in the bypass condition to allow setpoint adjustments of other channels when required to reduce the setpoint in accordance with other Technical Specifications. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months time limit is justified in Reference 6.

Required Action D.1.2 has been modified by a Note which only requires SR 3.2.4.2 to be performed if THERMAL POWER is > 85% RTP and the Power Range Neutron Flux input to QPTR becomes inoperable. Failure of a component in the Power Range Neutron Flux Channel which renders the High Flux Trip Function inoperable may not affect the capability to monitor QPTR. As such, determining QPTR using the core power distribution measurement information once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months may not be necessary.

E.1 Condition E applies to the following reactor trip Functions:

x Overtemperature ¨T; x

Overpower ¨T; x

Pressurizer Pressure-High; and x

SG Water Level-Low Low.

one one 0

TBD

RTS Instrumentation B 3.3.1 BASES Prairie Island Units 1 and 2 B 3.3.1-59 Revision 250 SURVEILLANCE SR 3.3.1.7 (continued)

REQUIREMENTS The difference between the current as-found values and the previous test as-left values must be consistent with the drift allowance used in the setpoint methodology. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology.

The as-found and as-left values must also be recorded and reviewed for consistency with the assumptions of Reference 5.

SR 3.3.1.7 is modified by a Note that provides a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months delay in the requirement to perform this Surveillance for source range instrumentation when entering MODE 3 from MODE 2. This Note allows a normal shutdown to proceed without a delay for testing in MODE 2 and for a short time in MODE 3 until the RTBs are open and SR 3.3.1.7 is no longer required to be performed. If the unit is to be in MODE 3 with the RTBs closed for > 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months this Surveillance must be performed prior to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after entry into MODE 3.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.8 SR 3.3.1.8 is the performance of a COT as described in SR 3.3.1.7, except it is modified by two Notes. Note 1 requires that this test shall include verification that the P-6 and P-10 interlocks are in their required state for the existing unit condition. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay.

Verification that P-6 and P-10 are in their required state for existing plant conditions can also be accomplished by observation of the permissive annunciator window. This clarifies what is an acceptable CHANNEL OPERATIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by Note 2 states that the RPS input relays are excluded from this Surveillance for Functions 2. a. and 3.,

which have bypass test capability. For Functions with bypass test capability, the channel is tested in a bypassed versus a tripped condition. To preclude tripping the RPS input relays, the RPS input relays are excluded from this Surveillance.

1 two Notes.

~

£° three TBD

RTS Instrumentation B 3.3.1 BASES Prairie Island Units 1 and 2 B 3.3.1-60 Revision 250 SURVEILLANCE SR 3.3.1.8 (continued)

REQUIREMENTS other Technical Specifications and non-Technical Specification tests at least once per refueling interval with applicable extensions.

Note 2 provides an exception from performance of this SR prior to reactor startup for the intermediate and source range instrumentation when the reactor has been shutdown less than or equal to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

The Frequency is modified by a Note that allows this surveillance to be satisfied if it has been performed within the previous Frequency specified in the Surveillance Frequency Control Program. The Frequency of prior to reactor startup ensures this surveillance is performed prior to critical operations and applies to the source, intermediate and power range low instrument channels. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reducing power below P-10 (applicable to intermediate and power range low channels) and 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after reducing power below P-6 (applicable to source range channels) allows a normal shutdown to be completed and the unit removed from the MODE of Applicability for this surveillance without a delay to perform the testing required by this surveillance. The Frequency thereafter applies if the plant remains in the MODE of Applicability after the initial performances of prior to reactor startup and twelve and four hours after reducing power below P-10 or P-6, respectively.

The MODE of Applicability for this surveillance is < P-10 for the power range low and intermediate range channels and < P-6 for the source range channels. Once the unit is in MODE 3, this surveillance is no longer required. If power is to be maintained

< P-10 for more than twelve hours or < P-6 for more than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , then the testing required by this surveillance must be performed prior to the expiration of the time limit. Twelve hours and four hours are reasonable times to complete the required testing or place the unit in a MODE where this surveillance is no longer required.

This test ensures that the NIS source, intermediate, and power range low channels are OPERABLE prior to taking the reactor critical and after reducing power into the applicable MODE ( < P-10 or < P-6 )

for periods > 12 and 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , respectively.

Note 3 states that the RPS input relays are excluded from this Surveillance for Function 2. b., which has bypass test capability. For Functions with bypass test capability, the channel is tested in a bypassed versus a tripped condition.

To preclude tripping the RPS input relays, the RPS input relays are excluded from this Surveillance.

TBD

L-PI-21-006 ENCLOSURE 2 WCAP-18651-NP, Revision 0, Power Range Nuclear Instrumentation System Bypass Test Instrumentation for Prairie Island Units 1 and 2 (Non-Proprietary Version)

(33 pages follow)

Westinghouse Non-Proprietary Class 3 WCAP-18651-NP July 2021 Revision 0 Power Range Nuclear Instrumentation System Bypass Test Instrumentation for Prairie Island Units 1 and 2

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

@ Westinghouse

Westinghouse Non-Proprietary Class 3

Electronically approved records are authenticated in the electronic document management system.

Westinghouse Electric Company LLC 1000 Westinghouse Drive Cranberry Township, PA 16066, USA

© 2021 Westinghouse Electric Company LLC All Rights Reserved WCAP-18651-NP Revision 0 Power Range Nuclear Instrumentation System Bypass Test Instrumentation for Prairie Island Units 1 and 2 John D. Moorehead*

Licensing Engineering July 2021 Reviewer:

James D. Andrachek*

PWR Owners Group PMO Edward W. Jaszcar*

Safety & Reactor Systems Engineering Approved: Anthony J. Schoedel*, Manager Licensing Engineering Miguel A. Vallarta*, Manager Safety & Reactor Systems Engineering

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 i

WCAP-18651-NP July 2021 Revision 0 ABSTRACT In order to reduce the potential for spurious reactor trips, which reduces the potential transient associated with a reactor trip, a modification can be implemented that allows testing of the Power Range (PR)

Reactor Trip System (RTS) channels in a bypassed condition, as opposed to the tripped condition. If a channel is in the tripped condition, and a second comparator trips in a redundant channel, which can be caused by a human error, spurious transient, or channel failure, this will result in a reactor trip. With the Bypass Test Instrumentation (BTI), a spurious reactor trip will be avoided, which reduces the potential transient associated with a reactor trip. Routine bypass testing capability is being provided for the Power Range Nuclear Instrumentation System (NIS) reactor trip functions.

Various aspects of the PR NIS BTI installation are addressed in this topical report (TR). These aspects include a demonstration of the functionality of the PR NIS BTI hardware, the PR NIS BTI design features which comply with the applicable U.S. Nuclear Regulatory Commission (NRC) regulations, regulatory guidance, and industry standards associated with testing in bypass. The administrative controls that will be implemented are also identified.

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 ii WCAP-18651-NP July 2021 Revision 0 TABLE OF CONTENTS ABSTRACT................................................................................................................................................... i LIST OF TABLES....................................................................................................................................... iv LIST OF FIGURES...................................................................................................................................... v ACRONYMS............................................................................................................................................... vi 1

INTRODUCTION........................................................................................................................ 1-1 2

BACKGROUND.......................................................................................................................... 2-1 3

DETAILED DESIGN DESCRIPTION......................................................................................... 3-1 3.1 NIS BYPASS PANEL...................................................................................................... 3-1 3.2 FAULT CONDITIONS.................................................................................................... 3-2 3.3 FAILURE DETECTION................................................................................................. 3-2 3.4 HUMAN FACTORS/ADMINISTRATIVE CONTROL................................................. 3-3 3.5 RELIABILITY................................................................................................................. 3-4 3.6 INDICATION AND ANNUNCIATION.......................................................................... 3-4 3.7 OPERATOR ACTIONS................................................................................................... 3-4 3.8 EQUIPMENT QUALIFICATION................................................................................... 3-4 3.9 ELECTROMAGNETIC COMPATIBILITY................................................................... 3-5 3.10 DISCUSSION OF BTI PANEL....................................................................................... 3-5 4

COMPLIANCE WITH THE APPLICABLE REGULATIONS, REGULATORY GUIDES, AND INDUSTRY STANDARDS.......................................................................................................... 4-1 4.1 GDCs............................................................................................................................... 4-1 4.1.1 GDC 2 - Design Bases for Protection from Natural Phenomena.................... 4-1 4.1.2 GDC 19 - Control Room................................................................................. 4-1 4.1.3 GDC 20 - Protection System Functions.......................................................... 4-2 4.1.4 GDC 21 - Protection System Reliability and Testability................................ 4-2 4.1.5 GDC 22 - Protection System Independence................................................... 4-2 4.1.6 GDC 23 - Protection System Failure Modes.................................................. 4-2 4.1.7 GDC 24 - Separation of Protection and Control Systems............................... 4-3 4.2 RGs.................................................................................................................................. 4-3 4.2.1 RG 1.47, Rev. 1 - Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety Systems............................................................................ 4-3 4.2.2 RG 1.53, Rev. 2 - Application of Single Failure Criterion to Nuclear Power Plant Protection Systems................................................................................. 4-5 4.2.3 RG 1.75, Rev. 3 - Physical Independence of Electric Systems....................... 4-6 4.2.4 RG 1.89, Rev. 1 - Qualification of Class 1E Equipment for Nuclear Power Plants............................................................................................................... 4-6

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 iii WCAP-18651-NP July 2021 Revision 0 4.2.5 RG 1.100, Rev. 3 - Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants.............................................................. 4-9 4.2.6 RG 1.118, Rev. 3 - Periodic Testing of Electric Power and Protection Systems

......................................................................................................................... 4-9 4.2.7 RG 1.22, Rev. 0 - Periodic Testing of Protection System Actuation Functions

....................................................................................................................... 4-10 4.2.8 RG 1.30, Rev. 0 - Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment............. 4-11 4.3 IEEE STANDARDS...................................................................................................... 4-11 4.3.1 IEEE Standard 603-1991............................................................................... 4-12 4.3.2 IEEE Standard 379-2000............................................................................... 4-14 4.3.3 IEEE Standard 384-1974............................................................................... 4-15 4.3.4 IEEE Standard 344-2004............................................................................... 4-15 4.3.5 IEEE Standard 338-1987............................................................................... 4-15 4.3.6 IEEE Standard 323-1974............................................................................... 4-15 5

CONCLUSION............................................................................................................................. 5-1 6

REFERENCES............................................................................................................................. 6-1

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 iv WCAP-18651-NP July 2021 Revision 0 LIST OF TABLES Table 5-1: NIS Comparators to by Bypassed............................................................................................ 5-1 Table 5-2: NIS BTI Panel Part Numbers................................................................................................... 5-1

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 v

WCAP-18651-NP July 2021 Revision 0 LIST OF FIGURES Figure 5-1: NIS Bypass Panel Diagram.................................................................................................... 5-2

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 vi WCAP-18651-NP July 2021 Revision 0 ACRONYMS AOT Allowed Outage Time BTI Bypass Test Instrumentation ESF Engineered Safety Feature ESFAS Engineered Safety Feature Actuation System FAT Factory Acceptance Test GDC General Design Criteria IEEE Institute of Electrical and Electronics Engineers LED Light Emitting Diode LOCA Loss-of-Coolant Accident MCB Main Control Board MSLB Main Steam Line Break NIS Nuclear Instrumentation System NRC U.S. Nuclear Regulatory Commission OBE Operating Basis Earthquake PC Printed Circuit PR Power Range PWROG Pressurized Water Reactor Owners Group RG Regulatory Guide RPS Reactor Protection System RTS Reactor Trip System SER Safety Evaluation Report SSE Safe Shutdown Earthquake TR Topical Report TS Technical Specifications VAC Voltage Alternating Current WOG Westinghouse Owners Group

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 1-1 WCAP-18651-NP July 2021 Revision 0 1

INTRODUCTION The Reactor Trip System (RTS) Power Range (PR) Nuclear Instrumentation System (NIS) functions utilize a two-out-of-four coincidence logic from redundant channels to initiate a reactor trip. In the current design, the RTS PR NIS analog channel comparators are placed in the tripped condition during channel testing or if a channel is inoperable. In the current design of testing a channel in the tripped condition, a redundant channel cannot be tested without bypassing an inoperable channel that is in the tripped condition. Additionally, routine testing of a channel in the tripped condition can result in the potential for an unnecessary reactor trip if a second comparator trips in a redundant channel, which can be caused by a human error, spurious transient, or channel failure.

The benefits associated with the installation of the PR NIS Bypass Test Instrumentation (BTI) at Prairie Island Units 1 and 2 are:

Analog channel surveillance testing can be performed with the comparator outputs bypassed, rather than tripped, thus reducing the potential for unnecessary reactor trips due to a failure or transient in a redundant channel.

One channel of the PR reactor trip function can be bypassed for maintenance.

The PR NIS BTI is integral to the existing racks, thus eliminating the need for portable test equipment, lifting leads, or using jumpers to bypass the channel, which is prohibited on a routine basis.

This Topical Report (TR) provides the licensing basis for the PR NIS BTI for Prairie Island Units 1 and 2.

It contains five sections, as follows:

1. An introduction of the concept of the PR NIS BTI and its purpose.

2. A brief background of bypass testing and prior regulatory positions on bypass testing.

3. A detailed description of the design of the PR NIS BTI and a figure to illustrate the operation.

([

]a,c)

4. A discussion of how the PR NIS BTI design complies with the applicable General Design Criteria (GDC), Regulatory Guides (RGs), and Institute of Electrical and Electronics Engineers (IEEE)

Standards.

5. A conclusion supporting the implementation of the PR NIS BTI.

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 2-1 WCAP-18651-NP July 2021 Revision 0 2

BACKGROUND In response to a concern regarding the impact of RTS and Engineered Safety Features Actuation System (ESFAS) Technical Specification (TS) instrumentation surveillance testing and maintenance activities on plant operations, i.e., inadvertent reactor trips and ESF actuations, the Pressurized Water Reactor Owners Group (PWROG) (formerly the Westinghouse Owners Group [WOG]) initiated a program to justify extending the RTS and ESFAS instrumentation bypass test times, Completion Times (previously referred to as Allowed Outage Times (AOTs)), and Surveillance Frequencies to provide additional time to perform surveillance and maintenance activities. WCAP-10271-P-A and Supplements 1 and 2, Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System, (References 1 through 3) and WCAP-14333-P-A, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times, (Reference 4) justified extending the RTS and ESFAS instrumentation bypass test times, Completion Times, and Surveillance Frequencies*. One of the provisions for surveillance testing discussed in References 1 through 3 was to allow routine testing of the RTS and ESFAS instrumentation channels in a bypassed condition instead of a tripped condition.

The NRC Safety Evaluation Reports (SERs) for WCAP-10271-P-A and Supplements 1 and 2 that were issued in February 1985 (RTS instrumentation) and in February 1989 (ESFAS instrumentation) state that the use of temporary jumpers or the lifting of leads is unacceptable for bypassing a channel for routine surveillance testing.

The installation of the PR NIS BTI at Prairie Island Units 1 and 2 will allow testing of the RTS PR NIS channels in a bypassed condition using installed instrumentation and does not utilize temporary jumpers or the lifting of leads as discussed above.

The use of the installed PR NIS BTI for the PR RTS channels will result in a reduction in the potential number of inadvertent reactor trips that could potentially occur during testing in a tripped condition.

Testing in bypass eliminates the partial trip condition that is associated with testing in the tripped condition for the RTS PR reactor trip functions.

Notes:

WCAP-14333-P-A only justified extending the RTS and ESFAS instrumentation bypass test times and Completion Times.

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 3-1 WCAP-18651-NP July 2021 Revision 0 3

DETAILED DESIGN DESCRIPTION The PR NIS BTI allows the channel to be tested without tripping the channel. The PR NIS BTI accomplishes this by imposing a 118 VAC signal in parallel with the channel 118 VAC signal, thus maintaining the PR NIS channel in an untripped condition.

3.1 NIS BYPASS PANEL

[

]a,c The potential for failure of the PR NIS bypass panel is low based on the following:

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 3-2 WCAP-18651-NP July 2021 Revision 0 Based on the manufacturers reports, all of the components, which are mechanical or electro-mechanical will perform at least 50,000 operations without a failure.

3.2 FAULT CONDITIONS Each PR NIS bypass panel is separated by a protection set; therefore, a single fault in a PR NIS bypass panel would not prevent the other three channels from performing the specified safety function. The portions of the PR NIS BTI panels that are non-Class 1E are isolated from the Class 1E circuits by the K1 relay coil to contact as shown in Figure 5-1. Therefore, there is no possibility that a control system fault could propagate to all of the PR NIS bypass panels and simultaneously adversely affect all protection sets.

Subsection 4.2.3 discusses the isolation and separation of the Class 1E and non-Class 1E equipment in the PR NIS bypass panels.

The PR NIS bypass panels are protected by a circuit breaker to prevent damage to the PR NIS bypass panel. The breaker status is monitored by the same LED that indicates that the PR NIS bypass panel is enabled. This LED will not light if the breaker is tripped. Since this LED is also the indication that the PR NIS bypass panel is enabled, if this LED is not lit, due to a lack of power to the PR NIS bypass panel, the PR NIS bypass panel will not allow any PR channel to go into the bypass position. This will prevent a channel from being placed into bypass with no bypass signal available.

3.3 FAILURE DETECTION The different types of potential credible failure modes in the PR NIS bypass panel are as follows:

1. Power unavailable to the PR NIS bypass panel.

2. Breaker in the PR NIS bypass panel tripped (or any fuse opens).

3. An LED failure (including Bridge Rectifier failure).

4. A contact failure (including Relay Coil failure, or RC Suppressor failure).

With power unavailable to the PR NIS bypass panel, the panel is unable to put a channel in bypass. This is easily detected by the absence of a lit LED when the keylock switch is turned from NORMAL to BYPASS ENABLE.

The circuit breaker status is monitored by the same LED that indicates that the PR NIS bypass panel is enabled, i.e., that a channel is bypassed. This LED will not light if the breaker is tripped. Since this LED also provides the indication that the PR NIS panel is enabled, if this LED is not lit, due to a lack of power, the PR NIS bypass panel will not allow any channel to go into bypass. This will prevent a channel from being placed into bypass with no bypass signal available (see Figure 5-1).

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 3-3 WCAP-18651-NP July 2021 Revision 0 3.4 HUMAN FACTORS/ADMINISTRATIVE CONTROL Human Factors and Administrative Controls have been designed into the PR NIS BTI for Prairie Island Units 1 and 2. The design features incorporated that address the Human Factors and Administrative Controls are:

A keylock switch (PR NIS bypass panel)

LEDs on the PR NIS bypass panels Control board annunciation of the channel in the bypassed condition Permanently installed PR NIS bypass test capability The PR NIS BTI is located inside the cabinets where the PR channels are located. There is a local LED indication on the PR NIS bypass panel that identifies the channel that is in bypass and the channels that are not in bypass.

[

]a,c

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 3-4 WCAP-18651-NP July 2021 Revision 0 3.5 RELIABILITY The reliability of the PR NIS BTI ensures that it functions as designed. The PR NIS BTI is designed with the reliability characteristics necessary to preserve the total integrity of the RTS. The PR NIS BTI is designed to reduce the frequency of failures by utilizing highly reliable components.

IEEE Standard 603-1991 delineates certain functional performance requirements regarding the aspects of system reliability for the protection systems. Because the PR NIS BTI will be implemented to support the RTS, it has been evaluated against those criteria that are applicable to its design.

All of the components of the PR NIS BTI are mechanical or electro-mechanical and will be reliable for at least 50,000 operations.

3.6 INDICATION AND ANNUNCIATION The PR NIS BTI is provided with the capability to provide timely and accurate information to the control room operator, as well as the personnel performing the bypass testing. In accordance with IEEE Standard 603-1991 and RG 1.47, control room annunciation must be provided for the status of any PR NIS channel that is enabled for bypass. An annunciator on the MCB ensures that the control room operator knows that a PR NIS protection set channel has been enabled for bypass.

The PR NIS bypass panel provides a local LED indication that identifies the status of the channels. The position of the keylock switch on the PR NIS bypass panel will identify if the channel is enabled for bypass, and an illuminated LED on the PR NIS bypass panel will indicate that power is available to the PR NIS bypass panel. The LEDs that are associated with the locking toggle switches identify that the channel has been placed in the bypass condition.

3.7 OPERATOR ACTIONS

[

]a,c 3.8 EQUIPMENT QUALIFICATION The equipment qualification for the PR NIS BTI addresses several aspects. Since the PR NIS bypass panels are installed in the Class 1E instrumentation racks, it must be demonstrated that: (1) the installation of the PR NIS BTI in these instrumentation racks will not adversely affect the seismic qualification of the Class 1E racks, and (2) the PR NIS BTI panels are capable of withstanding the required seismic levels associated with Prairie Island Units 1 and 2 and continue to maintain their structural integrity and electrical isolation. All components used in the PC cards and PR NIS bypass panels are acceptable for the environment conditions in the cabinets. The PR NIS BTI that will be installed in the Class 1E instrumentation cabinets was subjected to multi-axis, multi-frequency inputs in accordance with RG 1.100.

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 3-5 WCAP-18651-NP July 2021 Revision 0 The NIS cabinets were generically qualified to a floor response spectra that bounds the Prairie Island Units 1 and 2 floor response spectra where the NIS cabinets are located. The PR NIS bypass panels were generically qualified to the in-equipment response spectra based upon the test data of the NIS cabinet.

The generic qualification of the PR NIS bypass panels bounds the worst-case equipment response spectra of the NIS cabinet. Since the generic floor response spectra is greater than the Prairie Island Units 1 and 2 floor response spectra, the generic qualification for the NIS cabinet and PR NIS bypass panel is applicable to Prairie Island Units 1 and 2. The PR NIS BTI generic seismic qualification and environmental evaluation was performed in accordance with WCAP-8587 (Reference 6).

3.9 ELECTROMAGNETIC COMPATIBILITY The PR NIS bypass panels and associated wiring are completely contained inside a metal cabinet; therefore, the dominant entry of electromagnetic interference would be expected to be conducted through the field cabling. Additionally, the PR NIS bypass panels utilize high level signals (118 VAC) that are not susceptible to radiated or conducted interference. The ability of the PR NIS BTI panel to affect other equipment within the same cabinet is minimal due to the panel metal assembly and, more importantly, the very low duty cycle of the bypass relays. Additionally, the relays contain arc suppression circuits in order to minimize any interference issues.

3.10 DISCUSSION OF BTI PANEL The comparators that will be bypassed affect the PR NIS Functions that are identified in Table 5-1.

Each PR NIS BTI panel is operated by unit-specific keylock switches. The PR NIS bypass panel assemblies are part numbers 10173D82G01 thru G04 for Unit 1 and 10173D82G05 thru G08 for Unit 2.

The use of a unit specific keylock switch provides an administrative control to prevent two channels from being placed in bypass at one time in that unit. The base panel part number is 4D04921G02.

The PR NIS panels are individually numbered per channel per unit, as shown in Table 5-2.

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 4-1 WCAP-18651-NP July 2021 Revision 0 4

COMPLIANCE WITH THE APPLICABLE REGULATIONS, REGULATORY GUIDES, AND INDUSTRY STANDARDS As with any modifications to the RTS, compliance with the applicable regulations, Regulatory Guidance and Industry Standards must be addressed. This section addresses the design of the PR NIS BTI to the current applicable:

GDCs RGs IEEE Standards 4.1 GDCs The following GDCs are applicable to the PR NIS BTI and are discussed in Subsections 4.1.1 through 4.1.7:

GDC 2 - Design Bases for Protection Against Natural Phenomena GDC 19 - Control Room GDC 20 - Protection System Functions GDC 21 - Protection System Reliability and Testability GDC 22 - Protection System Independence GDC 23 - Protection System Failure Modes GDC 24 - Separation of Protection and Control Systems 4.1.1 GDC 2 - Design Bases for Protection from Natural Phenomena GDC 2 states: Systems and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions. This criterion is applicable to the installation of the PR NIS BTI at Prairie Island Units 1 and 2 because it is being added to the Class 1E NIS cabinets. The PR NIS BTI cannot adversely affect the current seismic qualification of the cabinets, nor can it become a missile in a seismic event and thus adversely affect any safety-related equipment.

The PR NIS BTI must maintain its required functionality during and after a seismic event. Equipment qualification reports have been prepared to address all seismic qualification concerns. Section 3.8 discusses the equipment qualification and seismic qualification associated with the PR NIS BTI.

4.1.2 GDC 19 - Control Room GDC 19 states: A control room shall be provided from which actions can be taken to operate the nuclear power plant safely under normal conditions and to maintain it in a safe condition under accident conditions. This criterion is applicable to the installation of the PR NIS BTI at Prairie Island Units 1 and 2 because adequate indication and annunciation of the status of the PR protection system channels (i.e.,

normal, bypasses, or tripped) must be available to the operators. The PR NIS BTI has been designed to meet this criterion by providing the operator with accurate information concerning the status of the

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 4-2 WCAP-18651-NP July 2021 Revision 0 channels being tested on the main control board. Section 3.6 discusses the indication and annunciation design features of the PR NIS BTI and its conformance to this criterion.

4.1.3 GDC 20 - Protection System Functions GDC 20 states: The protection system shall be designed to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded... This criterion is applicable to the installation of the PR NIS BTI because the protection system must still be able to perform its function after the installation of the PR NIS BTI. When the PR NIS BTI does not have power applied, it is not within the protection system circuitry (i.e., no protection system signals pass through the PR NIS BTI). Isolation devices are used as isolators between Class 1E and non-Class 1E circuits. A complete discussion of the administrative control and operator actions to ensure conformance to this criterion are discussed in Sections 3.4 and 3.7, respectively.

4.1.4 GDC 21 - Protection System Reliability and Testability GDC 21 states: The protection system shall be designed for high functional reliability and in-service testability commensurate with the safety function to be performed. Redundancy and independence designed into the protection system shall be sufficient to assure that no single failure results in loss of the protection function... This criterion is applicable to the installation of the PR NIS BTI because the PR NIS BTI design must have sufficient reliability to ensure that a single failure will not cause the protection system to be unable to perform its function. A complete discussion of the conformance of the installation of the PR NIS BTI to the single failure criterion is contained in Subsection 4.2.2.

4.1.5 GDC 22 - Protection System Independence GDC 22 states: The protection system shall be designed to assure that the effects of natural phenomena and of normal operating, maintenance, testing, and postulated accident conditions on redundant channels do not result in the loss of the protection function, or shall be demonstrated to be acceptable on some other defined basis. This criterion is applicable to the installation of the PR NIS BTI because the capability exists, without the proper administrative controls, for the simultaneous bypassing of more than one protection set channel at a time. Section 3.4 discusses the administrative controls that prevent the bypassing of more than one protection set channel at a time and thus conformance to this criterion.

4.1.6 GDC 23 - Protection System Failure Modes GDC states: The protection system shall be designed to fail into a safe state... if conditions such as disconnection of the system, loss of energy (e.g., electric power, instrument air) or postulated adverse environments are experienced. This criterion is applicable to the installation of the PR NIS BTI because a failure mode of the PR NIS BTI is the loss of power to it. Loss of power, due to either a circuit breaker opening or loss of power to the cabinet, will cause the PR NIS BTI to terminate any bypassing that was being performed. The PR NIS BTI will return to their normal operating mode, which is no bypass of the channel. This demonstrates conformance to this criterion.

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 4-3 WCAP-18651-NP July 2021 Revision 0 4.1.7 GDC 24 - Separation of Protection and Control Systems GDC 24 states: The protection system shall be separated from control systems to the extent that failure of any single control system component or channel, or failure or removal from service of any single protection system component or channel which is common to the control and protection system leaves intact a system satisfying all the reliability, redundancy, and independence requirements of the protection system. This criterion is applicable to the installation of the PR NIS BTI because the indication and annunciation of the status of the channel in bypass are part of the control system. Subsection 4.2.3 and Section 5.6 (within Subsection 4.3.1) discuss the PR NIS BTI conformance to RG 1.75 and IEEE Standard 603-1991, respectively, with respect to separation and isolation requirements.

4.2 RGs The following RGs are applicable to the installation of the PR NIS BTI:

RG 1.47, Rev. 1 - Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety Systems RG 1.53, Rev. 2 - Application of Single Failure Criterion to Nuclear Power Plant Protection Systems RG 1.75, Rev. 3 - Physical Independence of Electric Systems RG 1.89, Rev. 1 - Qualification of Class 1E Equipment for Nuclear Power Plants RG 1.100, Rev. 3 - Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants RG 1.118, Rev. 3 - Periodic Testing of Electric Power and Protection Systems RG 1.22, Rev. 0 - Periodic Testing of Protection System Actuation Functions RG 1.30, Rev. 0 - Quality Assurance Requirements for the Installation Inspection, and Testing Instrumentation and Electric Equipment 4.2.1 RG 1.47, Rev. 1 - Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety Systems RG 1.47 discusses an acceptable method of complying with the requirements of IEEE Standard 279-1971and IEEE Standard 603-1991, and states that automatic indication should be provided in the control room for each bypass or deliberately induced inoperable status that meets all of the following conditions:

a. Renders inoperable any redundant portion of the protection system, systems actuated or controlled by the protection system, and auxiliary or supporting systems that must be operable for the protection system and the system it actuates to perform their safety-related functions.

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b. Expected to occur more frequently than once per year.

c. Expected to occur when the affected system is normally required to be operable.

The PR NIS BTI meets all of these conditions. By placing a protection system channel in the bypass mode, that channel in the protection system is rendered inoperable. For any channel that is placed in the bypass mode, an automatic annunciation is initiated in the main control room. Section 3.6 discusses how the PR NIS BTI conforms to this RG along with the detailed responses to each of the regulatory positions listed below.

Regulatory positions:

1. Administrative procedures should be supplemented by an indication system that automatically indicates, for each affected safety system or subsystem, the bypass or deliberately induced inoperability of a safety function and the systems actuated or controlled by the safety function.

Provisions should also be made to allow the operations staff to confirm that a bypassed safety function has been properly returned to service.

The PR NIS BTI hardware automatically indicates through the annunciator signals that the channel has been placed in bypass. In addition, Xcel Energy will have administrative procedures in place to identify to the operator that a channel is in bypass.

2. The indicating system of Position 1 above should also be activated automatically by the bypassing or the deliberately induced inoperability of any auxiliary or supporting system that effectively bypasses or renders inoperable a safety function and the systems actuated or controlled by the safety function.

Annunciator signals are provided by the PR NIS BTI. Signals to the main control board (MCB) annunciator panel will be provided by the PR NIS BTI. These annunciator signals are provided automatically once the PR NIS BTI panel is switched to bypass mode.

3. Annunciating functions for system failure and automatic actions based on the self-test or self-diagnostic capabilities of digital computer-based I&C safety systems should be consistent with Positions 1 and 2 above.

The PR NIS BTI panel does not contain any self-test or self-diagnostic capabilities or any digital computer-based components.

4. The bypass and inoperable status indication system should include a capability for ensuring its operable status during normal plant operation to the extent that the indicating and annunciating functions can be verified.

Indication is provided locally by the LEDs on the front of the PR NIS bypass panel and on the MCB annunciator panel.

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5. Bypass and inoperable status indicators should be arranged such that the operator can determine whether continued reactor operation is permissible. The control room of all affected units should receive an indication of the bypass of shared system safety functions.

The bypass status of a channel will be indicated on the MCB annunciator panel that will identify to the operator the status of any channel that is bypassed. Separate MCB annunciators will be provided for Units 1 and 2. There are no shared safety system functions. Also see the discussions regarding regulatory positions 2 and 4 above.

6. Bypass and inoperable status indicators should be designed and installed in a manner that precludes the possibility of adverse effects on plant safety systems. The indication system should not be used to perform functions that are essential to safety, unless it is designed in conformance with criteria established for safety systems.

The PR NIS BTI front panel LED indication and MCB annunciator panel indication are only used for indication purposes and do not perform any safety function.

4.2.2 RG 1.53, Rev. 2 - Application of Single Failure Criterion to Nuclear Power Plant Protection Systems RG 1.53 endorses IEEE Standard 379-2000 with some clarification. IEEE Standard 379-2000 addresses the single failure criterion in nuclear power plant protection systems. A discussion of the PR NIS BTI compliance with IEEE Standard 379-2000, RG 1.53 and the single failure criterion in general is discussed in Section 4.3.

A single hardware failure of the PR NIS BTI hardware cannot cause a channel to inadvertently go into bypass. The PR NIS BTI design only includes analog and passive components and does not include any microprocessors or digital hardware.

Channel bypass using the PR NIS BTI panel is accomplished by these four steps:

1. The main breaker is switched on.

2. The unit specific key is obtained.

3. The unit specific key is inserted and turned on the PR NIS BTI front panel.

4. The PR NIS BTI front panel switch is enabled.

For a channel to inadvertently stay in the bypass mode, the main breaker, the key switch, and the toggle switch would all have to fail at the same time for a channel to inadvertently go into bypass. Additionally, the MCB annunciator panel indication would also have to fail such that the operators would not be able to identify that all three of those failures had occurred.

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 4-6 WCAP-18651-NP July 2021 Revision 0 4.2.3 RG 1.75, Rev. 3 - Physical Independence of Electric Systems RG 1.75 endorses and delineates acceptable methods for complying with the requirements of IEEE Standard 279-1971 with respect to physical independence of electric systems.

RG 1.75 discusses requirements for physical separation between Class 1E and non-Class 1E circuits, electrical isolation between Class 1E and non-Class 1E circuits, and requirements for associated circuits.

The PR NIS BTI is a safety-related assembly. Furthermore, the cabinet that contains the PR NIS BTI panel and the NIS drawers is considered a safety-related cabinet with only safety-related power applied to the PR NIS panels and drawers. It should be noted that there are non-safety-related signals (MCB annunciator) that are routed from the PR NIS BTI panel, which are isolated from the safety-related signals and hardware by safety-related hardware e.g., relays. Section 5.6 (within Subsection 4.3.1) discusses the PR NIS BTI conformance to IEEE Standard 603-1991, with respect to separation and isolation requirements.

4.2.4 RG 1.89, Rev. 1 - Qualification of Class 1E Equipment for Nuclear Power Plants RG 1.89 endorses IEEE Standard 323-1974. A discussion of the PR NIS BTI conformance to the requirements of IEEE Standard 323-1974 and RG 1.89 is contained in Section 4.3.

Regulatory positions:

1. Section 50.49, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants, of 10 CFR Part 50 requires that safety related electric equipment (Class lE) as defined in paragraph 50.49(b)(1) be qualified to perform its intended safety functions.

The PR NIS BTI generic seismic qualification and environmental evaluation was performed in accordance with WCAP-8587 (Reference 6).

2. Paragraph 50.49(d) and Section 6.2 of IEEE Std 323-1974 require equipment specifications to include performance and environmental conditions. For the requirements called for in item (7) of Section 6.2 of IEEE 323-1974 and paragraph 50.49(d)(3), the following should be included:

a. Temperature and Pressure Conditions Inside Containment for Loss-of-Coolant Accident (LOCA) and Main Steam Line Break (MSLB).

b. Effects of Sprays and Chemicals

c. Radiation Conditions Inside and Outside Containment.

d. Environmental Conditions for Equipment Outside Containment.

Items 2a, 2b and 2c are not applicable to the PR NIS BTI equipment due the location of the hardware in the main control room. Item 2d is applicable because the PR NIS BTI panels are

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Westinghouse Non-Proprietary Class 3 4-7 WCAP-18651-NP July 2021 Revision 0 located in the control room environment, which is considered to be a mild environment as described in WCAP-8687 (Reference 5). The design of the PR NIS BTI addresses the mild environment.

3. Section 6.3, Type Test Procedures, of IEEE Std. 323-1974 should be supplemented with the following:

a. Electric equipment that could be submerged should be identified and qualified by testing in a submerged condition to demonstrate operability for the duration required.

b. Electric equipment located in an area where rapid pressure changes are postulated simultaneously with the most adverse relative humidity should be qualified to demonstrate that the equipment seals and vapor barriers will prevent moisture from penetrating into the equipment to the degree necessary to maintain equipment functionability.

c. The parameters to which electric equipment is being qualified (e.g., temperature, pressure, radiation) by exposure to a simulated environment in a test chamber should be measured sufficiently close to the equipment to ensure that actual test conditions accurately represent the environment characterized by the test.

d. Performance characteristics that demonstrate the operability of equipment should be verified before, after, and periodically during testing throughout its range of required operability.

e. Chemical spray or demineralized water spray that is representative of service conditions should be incorporated during simulated event testing at pressure and temperature conditions that would occur when the spray systems actuate.

f.

Cobalt-60 or cesium-137 would be acceptable gamma radiation sources for environmental qualification.

These regulatory positions are not applicable because the PR NIS BTI panel is located in the control room environment, which is considered to be a mild environment as discussed in Reference 5. The PR NIS BTI panel does not have any requirements associated with a harsh environment that is discussed in position 3.

4. The suggested values in Section 6.3.1.5, Margin, of IEEE Std. 323-1974, except time margins, are acceptable for meeting the requirements of paragraph 50.49(e)(8). Alternatively, quantified margins should be applied to the environmental parameters discussed in Regulatory Position C.2 to ensure that the postulated accident conditions have been enveloped during testing.

The PR NIS BTI generic seismic qualification and environmental evaluation bounds the Prairie Island Units 1 and 2 current licensing basis and was performed in accordance with WCAP-8587 (Reference 6).

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5. Section 6.3.3, Aging, of IEEE Std 323-1974 and paragraph 50.49(e)(5) should be supplemented with the following:

a. If synergistic effects have been identified prior to the initiation of qualification, they should be accounted for in the qualification program. Synergistic effects known at this time are dose rate effects and effects resulting from the different sequence of applying radiation and (elevated) temperature.

b. The expected operating temperature of the equipment under service conditions should be accounted for in thermal aging. The Arrhenius methodology is considered an acceptable method of addressing accelerated thermal aging within the limitation of state-of-the-art technology. Other aging methods will be evaluated on a case-by-case basis.

c. The aging acceleration rate and activation energies used during qualification testing and the basis upon which the rate and activation energy were established should be defined, justified, and documented.

d. Periodic surveillance and testing programs are acceptable to account for uncertainties regarding age related degradation that could affect the functional capability of equipment. Results of such programs will be acceptable as ongoing qualification to modify designated life (or qualified life) of equipment and should be incorporated into the maintenance and refurbishment/ replacement schedules.

Aging testing was not performed for the PR NIS BTI panel because it is not part of the RTS, and is only used for the testing of a channel in bypass. During normal system operation, the PR NIS BTI hardware is de-energized. Additionally, a failure of the PR NIS BTI panel will not prevent a reactor trip from occurring.

6. Replacement electric equipment installed subsequent to February 22, 1983, must be qualified in accordance with the provisions of § 50.49 unless there are sound reasons to the contrary.

Future replacement components for the PR NIS BTI panel will be commercially dedicated in accordance with the original qualification requirements. The commercial dedications will address the critical characteristics required to maintain the qualification of the equipment.

7. In addition to the requirements of paragraph 50.49(j) of 10 CFR Part 50 and Section 8, Documentation, of IEEE Std. 323-1974, documentation should address the information identified in Appendix E to this guide. A record of the qualification should be maintained in an auditable file to permit verification that each item of electric equipment is qualified to perform its safety function under its postulated environmental conditions throughout its installed life.

This equipment has been qualified in accordance with WCAP-8587 (Reference 6), and the test results are documented in WCAP-8687 (Reference 5) which have been approved by the NRC (Reference 6).

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 4-9 WCAP-18651-NP July 2021 Revision 0 4.2.5 RG 1.100, Rev. 3 - Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants RG 1.100 endorses IEEE Standard 344-2004 and previous revisions of the Standard. A discussion of the conformance of the PR NIS BTI to IEEE Standard 344-1975 and this RG 1.100 are discussed in Section 4.3. The PR NIS BTI panel was seismically qualified in accordance with IEEE Standard 344-1975; therefore, the differences with the current IEEE Standard 344-2004 were evaluated for compliance. The two differences between IEEE Standard 344-1975 and IEEE Standard 344-2004 listed below do not impact the seismic qualification.

1. Use of experience data - This is not applicable because experience data was not used since the PR NIS BTI panel was seismically tested.

2. High frequency ground motion for hard-rock-based plants - Prairie Island Units 1 and 2 is not considered to be a hard-rock-based plant.

4.2.6 RG 1.118, Rev. 3 - Periodic Testing of Electric Power and Protection Systems RG 1.118 endorses IEEE Standard 338-1987 for periodic testing of protection systems subject to providing a method of preventing the expansion of any bypass condition to redundant channels. This is accomplished by administrative control of access to the bypass capability. The latest version of the RG 1.118 was compared to the previous version and the following changes were evaluated.

Position on 2.3 and 3 2.3 Test procedures or administrative controls shall provide for verifying the open circuit or verifying that temporary connections are restored after testing.

Xcel Energy will have administrative controls in place to perform periodic surveillance testing when using the PR NIS BTI Panel.

3. The description for a logic system functional test, as noted in Section 6.3.5 of IEEE Std. 338-1987, implies that the sensor is included. A logic system functional test is to be a test of all logic components (i.e., all relays and contacts, trip units, solid state logic elements, etc.) of a logic circuit, from as close to the sensor as practicable up to but not including the actuated device, to verify operability.

The in-containment sensors (PR ex-core detectors) are not directly connected to the PR NIS BTI panel. Within a protection channel, the PR NIS BTI panel is located between the NIS drawers and RTS; therefore, sensor testing is not applicable to the PR NIS BTI panel. The PR NIS BTI panel does not impact that RTS actuation logic test of any components. The PR NIS BTI panel only provides a means of testing the instrument channel in the bypass mode.

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 4-10 WCAP-18651-NP July 2021 Revision 0 4.2.7 RG 1.22, Rev. 0 - Periodic Testing of Protection System Actuation Functions The following section discusses how the PR NIS BTI panel complies with RG 1.22.

1. The protection system should be designed to permit periodic testing to extend to and include the actuation devices and actuated equipment.

a. The periodic tests should duplicate, as closely as practicable, the performance that is required of the actuation devices in the event of an accident.

The PR NIS BTI panel provides a preferred means for periodic testing because it allows testing a channel in bypass versus trip and reduces the potential for a spurious reactor trip during testing. When the protection channel is being tested, the trip signal passes through the PR NIS BTI panel.

b. The protection system and the systems whose operation it initiates should be designed to permit testing of the actuation devices during reactor operation.

The PR NIS BTI panel provides a means of verifying that the 120V signal on the terminal blocks is present. If the 120V signal is not present on the terminal blocks, the PR channel would be in the tripped state and an annunciator on the MCB would identify it. Within a protection channel, the PR NIS BTI panel is located between the NIS drawers and the RTS; therefore, the PR NIS BTI panels do not directly interface with the actuation device.

Therefore, the PR NIS BTI panel does not impact the testing of the actuation devices, and the testing of the actuation devices is not affected by the PR NIS BTI panel.

2. Acceptable methods of including the actuation devices in the periodic tests of the protection system.

This is not applicable to the PR NIS BTI panel, since the actuation device (such as the reactor trip breaker) is not connected to the PR NIS BTI panel. Therefore, the PR NIS BTI panel does not impact the testing of the actuation devices, and the testing of the actuation devices is not affected by the PR NIS BTI panel.

3. Where the ability of a system to respond to a bona fide accident signal is intentionally bypassed for the purpose of performing a test during reactor operation:

a. Positive means should be provided to prevent expansion of the bypass condition to redundant or diverse systems, and

b. Each bypass condition should be individually and automatically indicated to the reactor operator in the main control room.

Each PR channel is isolated from each other; therefore, placing one channel in bypass cannot result in placing any other PR channel in bypass. The PR NIS BTI panels have individual LEDs that indicate when a channel is bypassed. Refer to Section 3.4.

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4. Where actuated equipment is not tested during reactor operation, it should be shown that:

a. There is no practicable system design that would permit operation of the actuated equipment without adversely affecting the safety or operability of the plant;

b. The probability that the protection system will fail to initiate the operation of the actuated equipment is, and can be maintained, acceptably low without testing the actuated equipment during reactor operation, and

c. The actuated equipment can be routinely tested when the reactor is shut down.

This is not applicable to the PR NIS BTI panel because the actuated equipment is not directly connected to it. The PR NIS BTI panel does not impact the testing of the actuation devices and the testing of the actuation devices is not affected by the PR NIS BTI panel.

4.2.8 RG 1.30, Rev. 0 - Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment Xcel Energy will comply with RG 1.30 for the installation, inspection, and testing. The factory acceptance test (FAT) will be performed at a 10CFR Part 21, Appendix B facility before shipping the hardware to the site.

4.3 IEEE STANDARDS The following IEEE Standards are applicable to the PR NIS BTI panel and are discussed in Subsections 4.3.1 through 4.3.6:

IEEE 603-1991 - IEEE Standard: Criteria for Protection Systems for Nuclear Power Generating Stations IEEE 379-2000 - Trial Use Guide for the Application of the Single Failure Criteria to Nuclear Power Generating Station Protection Systems IEEE 384-1974 - Trial Use Standard for Separation of Class 1E Equipment and Circuits IEEE 344-2004 - IEEE Recommended Practices for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations IEEE 338-1987 - IEEE Standard Criteria for the Periodic Testing of Nuclear Power Generating Station Class 1E Power and Protection Systems IEEE 323-1974 - IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 4-12 WCAP-18651-NP July 2021 Revision 0 4.3.1 IEEE Standard 603-1991 IEEE Standard 603-1991 has several sections which are applicable to the PR NIS BTI. The sections that are applicable are:

Section 5.1 - Single Failure Criterion This section requires that any single failure in the protection system shall not prevent proper protective action at the system level when required. A discussion of the potential fault conditions and failure detection of the PR NIS BTI are discussed in Sections 3.2 and 3.3, respectively.

Any postulated failure in the PR NIS BTI that would inadvertently cause the channel in bypass to trip are failures in a safe direction, i.e., a tripped condition and will not be discussed. Failures in the PR NIS BTI that need to be addressed are those that could potentially:

1. Cause a channel to go into the bypass condition inadvertently.

2. Cause a channel to fail to exit the bypass condition when indications show otherwise.

All of these types of failures could cause the same result. That is, the possibility could exist for more than one redundant protection set channels to be in bypass at the same time such that a reactor trip may not be generated. Several contacts on the PR NIS BTI would have to close to cause the inadvertent bypass of a channel. For a channel to fail to come out of bypass while indicating that it has returned to normal, one contact would have to stick closed in the associated relay. These failures would all be identified by the local bypass status lights on the PR NIS bypass panel. Thus, there is no credible single failure of the PR NIS BTI that could result in the protection system being degraded to the point of being unable to perform its intended safety function.

Section 5.3 - Quality of Components This section requires that components and modules be of a high quality. The components used in the PR NIS BTI are of a quality consistent with minimum maintenance requirements and low failure rates. The quality of the components that are used in the PR NIS BTI is consistent with components that are used in the RTS. All of the components are mechanical or electro-mechanical and are reliable for at least 50,000 operations under normal environmental conditions.

Section 5.4 - Equipment Qualification This section requires that type test data, or reasonable engineering extrapolation based on test data, be available to verify that the protection system equipment meets the performance requirements. Generic tests were performed to verify that the PR NIS BTI panels that are located in Class 1E instrument cabinets, will not result in any of the failure modes identified above, during a seismic event. The tests were performed to demonstrate structural integrity and electrical isolation where applicable. A complete discussion of the equipment qualification of the PR NIS BTI is contained in Section 3.8.

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 4-13 WCAP-18651-NP July 2021 Revision 0 Section 5.6 - Control and Protection System Interaction Each PR NIS BTI panel is located within its own protection set; therefore, a single fault in a channel would not impact other redundant channels. The components in the PR NIS BTI panels that are non-Class 1E are isolated from the Class 1E circuits by qualified isolators. Therefore, there is no possibility that a control system fault could propagate to all of the PR NIS bypass panels and simultaneously adversely affect all protection sets. Separation requirements are maintained in the PR NIS BTI panels by physical separation on the bottom lid of the PR NIS bypass panel of 6 inches between the safety-related and non-safety-related 118 VAC power supply. The circuit board maintains this required separation by placing a ground layer between the safety-related and non-safety-related 118 VAC circuits.

Section 5.7 - Capability for Test and Calibration The PR NIS BTI panel complies with this section by providing the capability to functionally test its operation, and it does not require any calibration.

Section 5.8 - Information Displays 5.8.3.1: The annunciator signal is not part of the RTS.

5.8.3.2: The annunciator signal is provided automatically once the PR NIS BTI keylock is engaged.

5.8.3.3: The keylock switch is located on the PR NIS BTI front panel, which is located in the control room.

Section 5.8.3 - Indication of Bypasses This section requires that for a protective function that has been deliberately bypassed, indication/annunciation of the bypass must be continuously displayed in the control room. The PR NIS BTI includes both a local alarm/status light on the PR NIS BTI panel, and annunciators in the control room when a channel is bypassed.

Section 5.9 - Control of Access This section requires that the PR NIS BTI design use administrative control as a means for bypassing protective functions channels. The design of the PR NIS BTI requires the use of the keylock switches for placing a channel in bypass. Administrative control can be implemented by the proper control of the distribution of the keys for the PR NIS BTI panels.

Section 6.6 - Channel Bypass or Removal from Operation The PR NIS BTI panel will not affect the compliance of the protection system to this section. When one channel is bypassed for testing, a two-out-of-three coincidence logic is maintained to trip the reactor. The protection system will continue to conform to this section.

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 4-14 WCAP-18651-NP July 2021 Revision 0 Section 6.3 - Interaction Between the Sense and Command Features and Other Systems As shown on Figure 5 (Interpretation of 6.3.1 of IEEE Standard 603-1991) from Subsection 6.3.1 of IEEE Standard 603-1991, the response with respect to Does event by itself result in condition requiring safety function and Does event cause action by a non-safety system, is No, therefore the criteria of 6.3.1 (1) and 6.3.2 (2) are not applicable. Furthermore, the PR NIS BTI panel is not directly connected to a field sensor. None of the actions listed in Subsection 6.3.1 can impact the PR NIS BTI hardware. The PR NIS BTI panel does not have the capability to receive an input from a field sensor or a process variable nor does it have the capability to generate a command signal.

Section 6.6 - Operating Bypasses If one channel is in bypass, the protection system can still perform its function, since a two-out-of-three coincidence logic is maintained.

Section 6.7 - Maintenance Bypass As discussed in IEEE 603 Section 6.3 above, the PR NIS BTI panel does not interface with field sensors or process variables and it does not generate a command signal.

Section 4.20 - Information Read-out This section requires that the protection system be designed to provide the operator with information pertaining to its own status and the status of the plant. Section 3.6 discusses the annunciation features of the PR NIS BTI and conformance to this section.

4.3.2 IEEE Standard 379-2000 IEEE Standard 379-2000 discusses the application of the single failure criterion to the protection system.

The most limiting single failure would be one that would cause a channel to remain in bypass and the control room annunciator indicates that the channel has been removed from bypass. Another redundant channel could then be placed in bypass and there would be two redundant channels in bypass simultaneously. However, if that were to occur, a reactor trip would still occur because a two-out-of-two coincidence logic would be maintained. A failure of any component in the PR NIS BTI that inadvertently causes a channel to trip is a failure in the conservative direction and would not prevent that channel from performing its function. There is no credible single failure that could inadvertently place a channel of the protection system into the bypass condition. Power is provided to the PR NIS BTI panel only when the circuit breaker is closed and the keylock switch is turned from NORMAL to BYPASS ENABLE, and the individual bypass toggle switch is placed in bypass. No single failure could inadvertently provide power to the PR NIS bypass panel.

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 4-15 WCAP-18651-NP July 2021 Revision 0 4.3.3 IEEE Standard 384-1974 IEEE Standard 384-1974 discusses the separation requirements for Class 1E circuits and equipment.

These separation requirements are required when Class 1E and non-Class 1E equipment is located within close proximity to one another. The information provided in this standard and in Regulatory Guide 1.75 is similar and also supports the separation requirements contained in IEEE Standard 603-1991, Section 5.6.

4.3.4 IEEE Standard 344-2004 IEEE Standard 344-2004 discusses the recommended practices for performing seismic qualification of Class 1E equipment. The PR NIS BTI, since it is being installed in Class 1E instrument racks, must be seismically qualified. Section 3.8 discusses the generic seismic qualification of the PR NIS BTI.

The PR NIS BTI panel was seismically qualified in accordance with IEEE Standard 344-1975, therefore the differences with the current IEEE Standard 344-2004 were evaluated for compliance. The following two differences between IEEE Standard 344-1975 and IEEE Standard 344-2004 do not invalidate the seismic qualification:

1. Use of experience data - This is not applicable because experience data was not used since, the PR NIS BTI panel was seismically tested.

2. High frequency ground motion for hard-rock-based plants - Prairie Island Units 1 and 2 is not considered to be a hard-rock-based plant.

4.3.5 IEEE Standard 338-1987 IEEE Standard 338-1987 discusses the criteria for performing periodic testing of safety systems.

Installation of the PR NIS BTI does not impact the capability for performing periodic tests that was originally designed into the equipment. The PR NIS BTI panel provides an alternative means of testing in bypass rather than in a tripped condition.

This IEEE Standard applies to the NIS detectors and drawers. This standard provides guidance for the periodic testing of safety-related systems. The PR NIS BTI panel does not perform a safety function when installed in the NIS cabinet. The PR NIS BTI panel does not have any impact on the capability to perform any testing as discussed in the IEEE Standard. The PR NIS BTI panel only allows the drawers to be tested in bypass. It does not change or influence the method of surveillance testing of the drawers. Therefore, the installation of the PR NIS BTI panels has no effect on the NIS system compliance with this IEEE Standard.

4.3.6 IEEE Standard 323-1974 IEEE Standard 323-1974 discusses the requirements for qualifying Class 1E equipment for nuclear power plants. Section 3.8 discusses the equipment qualification and conformance of the PR NIS BTI.

The PR NIS BTI generic seismic qualification and environmental evaluation bounds the Prairie Island Units 1 and 2 current licensing basis, and was performed in accordance with WCAP-8587 (Reference 6).

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 5-1 WCAP-18651-NP July 2021 Revision 0 5

CONCLUSION Various aspects of the PR NIS BTI are addressed in this TR. These aspects include a demonstration of the functionality of the PR NIS BTI hardware, and the design features of the PR NIS BTI panel to demonstrate compliance with the applicable GDCs, RGs and IEEE Standards associated with testing in bypass.

The PR NIS BTI will reduce the potential for spurious reactor trips, which reduces the potential transients associated with them, and ensures that the RTS PR functions remain capable of performing their specified safety function.

The following tables and figure provide additional details of the PR NIS BTI. Table 5-1 lists the comparators that will be bypassed, and Table 5-2 identifies the PR NIS BTI panel part numbers. Figure 5-1 provides a basic functional diagram to illustrate the operation of a PR NIS BTI.

Table 5-1: NIS Comparators to by Bypassed Function Protection Set I

II III IV Power Range - High Flux Reactor Trip (Low Setpoint) 1 1

1 1

Power Range - High Flux Reactor Trip (High Setpoint) 1 1

1 1

Power Range - High Positive Rate 1

1 1

1 Power Range - High Negative Rate 1

1 1

1 Power Range - Overpower Rod Stop 1

1 1

1 Power Range - P-10 Permissive 1

1 1

1 Power Range - P-8 Permissive 1

1 1

1 Power Range - P-9 Permissive 1

1 1

1 Table 5-2: NIS BTI Panel Part Numbers Panel Part Number Description 10173D82G01 NIS Bypass Panel Assembly (Channel 1) Unit 1 10173D82G02 NIS Bypass Panel Assembly (Channel 2) Unit 1 10173D82G03 NIS Bypass Panel Assembly (Channel 3) Unit 1 10173D82G04 NIS Bypass Panel Assembly (Channel 4) Unit 1 10173D82G05 NIS Bypass Panel Assembly (Channel 1) Unit 2 10173D82G06 NIS Bypass Panel Assembly (Channel 2) Unit 2 10173D82G07 NIS Bypass Panel Assembly (Channel 3) Unit 2 10173D82G08 NIS Bypass Panel Assembly (Channel 4) Unit 2

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 Figure 5-1: NIS Bypass Panel Diagram WCAP-18651-NP 5-2 July 2021 Revision 0 a,c

Westinghouse Non-Proprietary Class 3 6-1 WCAP-18651-NP July2021 Revision 0 6

REFERENCES

1. WCAP-10271-P-A, Rev. 0, Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System, May 1986.

2. WCAP-10271, Supplement 1-P-A, Rev. 0, Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System Supplement 1, May 1986.

3. WCAP-10271-P-A, Supplement 2, Rev. 1, Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System, June 1990.

4. WCAP-14333-P-A, Rev. 1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times, October 1998.

5. WCAP-8687, Supplement 2, EQTR-E47G, Rev. 1, Equipment Qualification Test Report Nuclear Instrumentation System (NIS) Bypass Test Instrumentation Panel (Seismic Testing), March 1996.

6. WCAP-8587, Rev. 6-A, Methodology for Qualifying Westinghouse WRD Supplied NSSS Safety Related Electrical Equipment, March 1983.

- - This record was final approved on 7/13/2021 5:28:24 PM. (This statement was added by the PRIME system upon its validation)

L-PI-21-006 ENCLOSURE 3 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 Affidavit for Withholding of Proprietary Information (3 pages follow)

Westinghouse Non-Proprietary Class 3 CAW-21-5203 Page 1 of 3 COMMONWEALTH OF PENNSYLVANIA:

COUNTY OF BUTLER:

(1)

I, Anthony J. Schoedel, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).

(2)

I am requesting the proprietary portions of WCAP-18651-P, Revision 0 be withheld from public disclosure under 10 CFR 2.390.

(3)

I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged, or as confidential commercial or financial information.

(4)

Pursuant to 10 CFR 2.390, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i)

The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse and is not customarily disclosed to the public.

(ii)

The information sought to be withheld is being transmitted to the Commission in confidence and, to Westinghouses knowledge, is not available in public sources.

(iii)

Westinghouse notes that a showing of substantial harm is no longer an applicable criterion for analyzing whether a document should be withheld from public disclosure. Nevertheless, public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable

Westinghouse Non-Proprietary Class 3 CAW-21-5203 Page 2 of 3 others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

(5)

Westinghouse has policies in place to identify proprietary information. Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a)

The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b)

It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage (e.g., by optimization or improved marketability).

(c)

Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d)

It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e)

It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f)

It contains patentable ideas, for which patent protection may be desirable.

Westinghouse Non-Proprietary Clac;s 3 CAW-21-5203 Page3of3 (6)

The attached documents are bracketed and marked to indicate the bases for withholding. The justification for withholding is indicated in both versions hy means of lower-case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower-case letters refer to the types of information Westinghouse customarily bolds in confidence identified in Sections (5Xa) through (f) of this Affidavit.

I declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: 7// Lf /J.oJ, /

d4£J!~

Anthony J. Schocdel, Manager eVinci Licensing & Configuration Management

v t e Letter Sequence Request
EPID:L-2021-LLA-0180, License Amendment Request to Revise Technical Specification 3.3.1, Reactor Trip System (RTS) Instrumentation, to Incorporate Installed Bypass Test Capability for the Power Range RTS Functions (Approved, Closed)
Initiation Request Acceptance Administration Withholding Request Acceptance Questions Answers Results Approval Other:
MONTHYEAR2021-10-29 [Table View]

L-PI-21-006, License Amendment Request to Revise Technical Specification 3.3.1, Reactor Trip System (RTS) Instrumentation, to Incorporate Installed Bypass Test Capability for the Power Range RTS Functions

Text

SUMMARY

3.0 ASSESSMENT

4.0 REGULATORY ANALYSIS

6.0 REFERENCES

SUMMARY

2.1 Background

3.0 ASSESSMENT

4.0 REGULATORY ANALYSIS

6.0 REFERENCES

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