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| {{#Wiki_filter:*"""P Entergy GNRO-201 0-0001 0 February 8, 2010 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Entergy Operations, Inc.P.O.Box 756 Port Gibson, MS 39150 Michael A.Krupa Director, Extended Power Uprate Grand Gulf Nuclear Station Tel.(601)437-6684 | | {{#Wiki_filter:* Entergy |
| | " ""P Entergy Operations, Inc. |
| | P. O. Box 756 Port Gibson, MS 39150 Michael A. Krupa Director, Extended Power Uprate Grand Gulf Nuclear Station Tel. (601) 437-6684 GNRO-201 0-0001 0 February 8, 2010 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 |
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| ==SUBJECT:== | | ==SUBJECT:== |
| | Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531) |
| | Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29 |
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| ==REFERENCES:== | | ==REFERENCES:== |
| | : 1. Entergy Operations, Inc. letter to the NRC, License Amendment Request - Power Range Neutron Monitoring System Upgrade, dated November 3,2009 (ADAMS Accession No. ML093140463) |
| | : 2. NRC letter to Entergy Operations, Inc., Grand Gulf Nuclear Station, Unit 1 - Request for Additional Information Re: Power Range Neutron Monitoring System (TAG No. ME2531), dated January 15, 2010 |
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| ==Dear Sir or Madam:== | | ==Dear Sir or Madam:== |
| Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No.ME2531)Grand Gulf Nuclear Station, Unit 1 Docket No.50-416 License No.NPF-29 1.Entergy Operations, Inc.letter to the NRC, License Amendment Request-Power Range Neutron Monitoring System Upgrade, dated November 3,2009 (ADAMS Accession No.ML093140463) 2.NRC letter to Entergy Operations, Inc., Grand Gulf Nuclear Station, Unit1-Request for Additional Information Re: Power Range Neutron Monitoring System (TAG No.ME2531), dated January 15, 2010 In Reference 1, Entergy Operations, Inc.(Entergy)submitted to the NRC a license amendment request (LAR), which proposes to revise the Grand Gulf Nuclear Station (GGNS)Technical Specifications (TS)to reflect the installation of the digital General Electric-Hitachi (GEH)Nuclear Measurement Analysis and Control (NUMAC)Power Range Neutron Monitoring (PRNM)System.In Reference 2, the NRC staff requested additional information needed to support their review and approval of Reference 1.Responses to the staff's Requests for Additional Information (RAls)are provided in Attachment 1 of this letter.Associated revisions to the mark-ups of the proposed changes are provided in Attachment 2.In addition to the changes pertaining to the NRC RAls, Entergy discovered a typographical error in marked-up TS Table 3.3.1.1-1, provided on page 13 of Attachment 3 of Reference 1.The reference for Note (b)was inadvertently shown as being deleted.As discussed in Section 4.4.3.5.a of Reference 1, Entergy proposed to relocate the reference to align with the applicable function in the table.A corrected marked-up TS Table 3.3.1.1-1 is provided in Attachment 2.Please replace the current TS Table 3.3.1.1-1 with the corrected table.*"""P Entergy GNRO-201 0-0001 0 February 8, 2010 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Entergy Operations, Inc.P.O.Box 756 Port Gibson, MS 39150 Michael A.Krupa Director, Extended Power Uprate Grand Gulf Nuclear Station Tel.(601)437-6684
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| ==SUBJECT:==
| | In Reference 1, Entergy Operations, Inc. (Entergy) submitted to the NRC a license amendment request (LAR), which proposes to revise the Grand Gulf Nuclear Station (GGNS) |
| | | Technical Specifications (TS) to reflect the installation of the digital General Electric-Hitachi (GEH) Nuclear Measurement Analysis and Control (NUMAC) Power Range Neutron Monitoring (PRNM) System. |
| ==REFERENCES:==
| | In Reference 2, the NRC staff requested additional information needed to support their review and approval of Reference 1. |
| | | Responses to the staff's Requests for Additional Information (RAls) are provided in Attachment 1 of this letter. Associated revisions to the mark-ups of the proposed changes are provided in Attachment 2. |
| ==Dear Sir or Madam:==
| | In addition to the changes pertaining to the NRC RAls, Entergy discovered a typographical error in marked-up TS Table 3.3.1.1-1, provided on page 13 of Attachment 3 of Reference 1. |
| Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No.ME2531)Grand Gulf Nuclear Station, Unit 1 Docket No.50-416 License No.NPF-29 1.Entergy Operations, Inc.letter to the NRC, License Amendment Request-Power Range Neutron Monitoring System Upgrade, dated November 3,2009 (ADAMS Accession No.ML093140463) 2.NRC letter to Entergy Operations, Inc., Grand Gulf Nuclear Station, Unit1-Request for Additional Information Re: Power Range Neutron Monitoring System (TAG No.ME2531), dated January 15, 2010 In Reference 1, Entergy Operations, Inc.(Entergy)submitted to the NRC a license amendment request (LAR), which proposes to revise the Grand Gulf Nuclear Station (GGNS)Technical Specifications (TS)to reflect the installation of the digital General Electric-Hitachi (GEH)Nuclear Measurement Analysis and Control (NUMAC)Power Range Neutron Monitoring (PRNM)System.In Reference 2, the NRC staff requested additional information needed to support their review and approval of Reference 1.Responses to the staff's Requests for Additional Information (RAls)are provided in Attachment 1 of this letter.Associated revisions to the mark-ups of the proposed changes are provided in Attachment 2.In addition to the changes pertaining to the NRC RAls, Entergy discovered a typographical error in marked-up TS Table 3.3.1.1-1, provided on page 13 of Attachment 3 of Reference 1.The reference for Note (b)was inadvertently shown as being deleted.As discussed in Section 4.4.3.5.a of Reference 1, Entergy proposed to relocate the reference to align with the applicable function in the table.A corrected marked-up TS Table 3.3.1.1-1 is provided in Attachment 2.Please replace the current TS Table 3.3.1.1-1 with the corrected table.*"""P Entergy GNRO-201 0-0001 0 February 8, 2010 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Entergy Operations, Inc.P.O.Box 756 Port Gibson, MS 39150 Michael A.Krupa Director, Extended Power Uprate Grand Gulf Nuclear Station Tel.(601)437-6684
| | The reference for Note (b) was inadvertently shown as being deleted. As discussed in Section 4.4.3.5.a of Reference 1, Entergy proposed to relocate the reference to align with the applicable function in the table. A corrected marked-up TS Table 3.3.1.1-1 is provided in Attachment 2. Please replace the current TS Table 3.3.1.1-1 with the corrected table. |
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| ==SUBJECT:==
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| ==Dear Sir or Madam:==
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| Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No.ME2531)Grand Gulf Nuclear Station, Unit 1 Docket No.50-416 License No.NPF-29 1.Entergy Operations, Inc.letter to the NRC, License Amendment Request-Power Range Neutron Monitoring System Upgrade, dated November 3,2009 (ADAMS Accession No.ML093140463) 2.NRC letter to Entergy Operations, Inc., Grand Gulf Nuclear Station, Unit1-Request for Additional Information Re: Power Range Neutron Monitoring System (TAG No.ME2531), dated January 15, 2010 In Reference 1, Entergy Operations, Inc.(Entergy)submitted to the NRC a license amendment request (LAR), which proposes to revise the Grand Gulf Nuclear Station (GGNS)Technical Specifications (TS)to reflect the installation of the digital General Electric-Hitachi (GEH)Nuclear Measurement Analysis and Control (NUMAC)Power Range Neutron Monitoring (PRNM)System.In Reference 2, the NRC staff requested additional information needed to support their review and approval of Reference 1.Responses to the staff's Requests for Additional Information (RAls)are provided in Attachment 1 of this letter.Associated revisions to the mark-ups of the proposed changes are provided in Attachment 2.In addition to the changes pertaining to the NRC RAls, Entergy discovered a typographical error in marked-up TS Table 3.3.1.1-1, provided on page 13 of Attachment 3 of Reference 1.The reference for Note (b)was inadvertently shown as being deleted.As discussed in Section 4.4.3.5.a of Reference 1, Entergy proposed to relocate the reference to align with the applicable function in the table.A corrected marked-up TS Table 3.3.1.1-1 is provided in Attachment 2.Please replace the current TS Table 3.3.1.1-1 with the corrected table.*"""P Entergy GNRO-201 0-0001 0 February 8, 2010 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Entergy Operations, Inc.P.O.Box 756 Port Gibson, MS 39150 Michael A.Krupa Director, Extended Power Uprate Grand Gulf Nuclear Station Tel.(601)437-6684
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| ==Dear Sir or Madam:==
| | GNRO-201 0-0001 0 Page 2 The No Significance Hazards Determination and the Environmental Consideration provided in Reference 1 are not impacted by these responses. |
| Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No.ME2531)Grand Gulf Nuclear Station, Unit 1 Docket No.50-416 License No.NPF-29 1.Entergy Operations, Inc.letter to the NRC, License Amendment Request-Power Range Neutron Monitoring System Upgrade, dated November 3,2009 (ADAMS Accession No.ML093140463) 2.NRC letter to Entergy Operations, Inc., Grand Gulf Nuclear Station, Unit1-Request for Additional Information Re: Power Range Neutron Monitoring System (TAG No.ME2531), dated January 15, 2010 In Reference 1, Entergy Operations, Inc.(Entergy)submitted to the NRC a license amendment request (LAR), which proposes to revise the Grand Gulf Nuclear Station (GGNS)Technical Specifications (TS)to reflect the installation of the digital General Electric-Hitachi (GEH)Nuclear Measurement Analysis and Control (NUMAC)Power Range Neutron Monitoring (PRNM)System.In Reference 2, the NRC staff requested additional information needed to support their review and approval of Reference 1.Responses to the staff's Requests for Additional Information (RAls)are provided in Attachment 1 of this letter.Associated revisions to the mark-ups of the proposed changes are provided in Attachment 2.In addition to the changes pertaining to the NRC RAls, Entergy discovered a typographical error in marked-up TS Table 3.3.1.1-1, provided on page 13 of Attachment 3 of Reference 1.The reference for Note (b)was inadvertently shown as being deleted.As discussed in Section 4.4.3.5.a of Reference 1, Entergy proposed to relocate the reference to align with the applicable function in the table.A corrected marked-up TS Table 3.3.1.1-1 is provided in Attachment 2.Please replace the current TS Table 3.3.1.1-1 with the corrected table.
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| cc: GNRO-201 0-0001 0 Page 2 The No Significance Hazards Determination and the Environmental Consideration provided in Reference 1 are not impacted by these responses.
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| This letter contains no new commitments. | | This letter contains no new commitments. |
| If you have any questions or require additional information, please contact Mr.Guy Davant at (601)368-5756.I declare under penalty of perjury that the foregoing is true and correct.Executed on February 8, 2010.Sincerely,MAKlghd | | If you have any questions or require additional information, please contact Mr. Guy Davant at (601) 368-5756. |
| | I declare under penalty of perjury that the foregoing is true and correct. |
| | Executed on February 8, 2010. |
| | Sincerely, |
| | ~.A-. r~ |
| | MAKlghd |
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| ==Attachment:== | | ==Attachment:== |
| | : 1. Responses to NRC Requests for Additional Information Pertaining to License Amendment Request - Power Range Neutron Monitoring System Upgrade |
| | : 2. Revised Ol, TS, and TS Bases Pages cc: Mr. Elmo E. Collins, Jr. |
| | Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 612 East lamar Blvd., Suite 400 Arlington, TX 76011-4005 U. S. Nuclear Regulatory Commission ATTN: Mr. C. F. lyon, NRR/DORl (w/2) |
| | ATTN: ADDRESSEE ONLY ATTN: Courier Delivery Only Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378 State Health Officer Mississippi Department of Health P. O. Box 1700 Jackson, MS 39215-1700 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 |
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| 1.Responses to NRC Requests for Additional Information Pertaining to License Amendment Request-Power Range Neutron Monitoring System Upgrade 2.Revised Ol, TS, and TS Bases Pages Mr.Elmo E.Collins, Jr.Regional Administrator, Region IV U.S.Nuclear Regulatory Commission 612 East lamar Blvd., Suite 400 Arlington, TX 76011-4005 U.S.Nuclear Regulatory Commission ATTN: Mr.C.F.lyon, NRR/DORl (w/2)ATTN: ADDRESSEE ONLY ATTN: Courier Delivery Only Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378 State Health Officer Mississippi Department of Health P.O.Box 1700 Jackson, MS 39215-1700 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 cc: GNRO-201 0-0001 0 Page 2 The No Significance Hazards Determination and the Environmental Consideration provided in Reference 1 are not impacted by these responses. | | ATTACHMENT 1 GNRO-201 0-0001 0 RESPONSES TO NRC REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE to GNRO-201 0-0001 0 Page 1 of 4 RESPONSES TO NRC REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE Responses to the NRC staff's Requests for Additional Information (RAls) are provided in of this letter. Associated revisions to the mark-ups of the proposed changes are provided in Attachment 2. |
| This letter contains no new commitments.
| | NRC RAI No.1 Please explain how a unit restart is allowed by adding the note, "LCO 3.0.4.b is not applicable" to new Required Action J.2. , page 14 of the application letter states, "Entergy also proposes a note that states LCO 3.0.4.b is not applicable to new Required Action J.2. This note allows unit restart in the event of a shutdown during the 120-day completion time." However, Limiting Condition for Operation (LCO) 3.0.4.a and LCO 3.0.4.c remain applicable. LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability, when an LCO is not met, only when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Condition J is referenced in Table 3.3.1.1-1 and entered as required by Required Action 0.1. Condition J Required Action J.1 requires initiating an alternate method to detect and suppress thermal hydraulic instability oscillations within 12 hours and J.2 requires restoring the required channels to operable status within 120 days. Condition J does not permit continued operation for an unlimited period of time. LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability, when an LCO is not met, only when an allowance is stated in the individual value, parameter, or other Specification. LCO 3.0.4.c is not allowed in any condition in GGNS TS 3.3.1.1. |
| If you have any questions or require additional information, please contact Mr.Guy Davant at (601)368-5756.I declare under penalty of perjury that the foregoing is true and correct.Executed on February 8, 2010.Sincerely,MAKlghd
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| ==Attachment:== | | ===Response=== |
| | Entergy agrees with the NRC's comments and proposes to revise the wording of the proposed note applied to Required Action J.2 to read, "LCO 3.0.4 is not applicable." This revised wording addresses the NRC's comments and allows unit restart in the event of a shutdown during the 120-day completion time of Required Action J.2. |
| | As discussed in Section 4.4.1.2 of the LAR, this note is consistent with the original intent of the NUMAC PRNM Licensing Topical Report (LTR), which is to allow normal plant operations to continue during the recovery time from a hypothesized design problem with the Option III stability solution algorithms. This proposed note was approved by the NRC for Monticello Nuclear Generating Plant 1 and Peach Bottom Atomic Power Station, Units 2 and 32 . |
| | NRC letter to Northern States Power Company, Monticello Nuclear Generating Plant (MNGP)- |
| | Issuance of Amendment Regarding the Power Range Neutron Monitoring System (TA C No. |
| | MDB064) , dated January 30,2009 (ADAMS Ascension No. ML083440681) to GNRO-201 0-0001 0 Page 2 of 4 Entergy has revised TS Insert B and the discussion of Required Action J.2 in TS Bases Insert J (contained on page 9 of LAR Attachment 3 and page 27 of LAR Attachment 4, respectively) to reflect the wording change for the note, as specified above. |
| | NRC RAI No.2 Please provide revised proposed TS Bases changes that are consistent with Technical Specification Task Force (TSTF)-493, Revision 4, or justify deviations. |
| | The applicability section in Federal Register (74 FR 58065), "Notice of Opportunity for Public Comment on the Proposed Model Safety Evaluation for Plant-Specific Adoption of Technical Specification Task Force Traveler-493, Revision 4, "Clarify Application of Setpoint Methodology for LSSS Functions" stated, "The licensee must add footnotes to all the functions identified in TSTF Traveler-493, Revision 4, Appendix A, and must incorporate the related TS Bases changes." for any licensee wishing to adopt TS task force (TSTF) Traveler-493, option A without changes to setpoint values. The NRC staff considers the changes made by TSTF-493, Revision 4 to TS 3.3.1.1 Bases sections: (1) background; (2) applicable safety analyses, LCO, and applicability; (3) actions; and (4) surveillance requirements to be related to GGNS proposed amendment. |
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| 1.Responses to NRC Requests for Additional Information Pertaining to License Amendment Request-Power Range Neutron Monitoring System Upgrade 2.Revised Ol, TS, and TS Bases Pages Mr.Elmo E.Collins, Jr.Regional Administrator, Region IV U.S.Nuclear Regulatory Commission 612 East lamar Blvd., Suite 400 Arlington, TX 76011-4005 U.S.Nuclear Regulatory Commission ATTN: Mr.C.F.lyon, NRR/DORl (w/2)ATTN: ADDRESSEE ONLY ATTN: Courier Delivery Only Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378 State Health Officer Mississippi Department of Health P.O.Box 1700 Jackson, MS 39215-1700 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 cc: GNRO-201 0-0001 0 Page 2 The No Significance Hazards Determination and the Environmental Consideration provided in Reference 1 are not impacted by these responses. | | ===Response=== |
| This letter contains no new commitments. | | Entergy plans to revise the "BACKGROUND" and "APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY" sections of TS Bases 3.3.1.1 to reflect TSTF-493, Rev. 4 wording as applied to the APRM functions. Specifically, Entergy has added subsections entitled Application of TSTF-493, Rev. 4 (Ref. 17) to APRM Functions 2.a, 2.b, 2.d, and 2.f to TS Bases pages B 3.3-2 and B 3.3-4 as Inserts 1 and 2, respectively. |
| If you have any questions or require additional information, please contact Mr.Guy Davant at (601)368-5756.I declare under penalty of perjury that the foregoing is true and correct.Executed on February 8, 2010.Sincerely,MAKlghd
| | NRC RAI No.3 Please state which SRs verify trip setpoint settings for functions 2.a, 2.b, 2.c, 2.d, 2.e, and 2.f in TS Table 3.3.1.1-1, and provide a revised TS Table 3.3.1.1-1 with the addition of notes (d) and (e) for these functions as needed. |
| | The proposed change revises GGNS TSs to incorporate NRC-approved TSTF Traveler-493, Revision 4, to be consistent with Option A. Option A, without changes to setpoint values, adds two Notes to SRs in the Surveillance Requirement Column of TSs Instrumentation Function Tables. Specifically, Notes are added to TS 3.3.1.1 SRs that require verifying trip setpoint setting values, (i.e. Channel Calibration and Channel Functional Test SRs) for NUREG-1434. |
| | The first Surveillance Note requires evaluation of channel performance for the condition where the As-Found setting for the channel setpoint is outside its As-Found Tolerance but conservative with respect to the AV. This is proposed note (d) to TS Table 3.3.1.1-1. The second Surveillance Note requires that the As-Left setting for the channel be returned to 2 NRC letter to Exelon Nuclear, Peach Bottom Atomic Power Station, Units 2 and 3 -Issuance of Amendment Re: Activation of Oscillation Power Range Monitor Trip (TAG Nos. MC2219 and MC2220) , dated March 21, 2005 (page 4 of SE) (ADAMS Accession No. ML05270020) to GNRO-201 0-0001 0 Page 3 of 4 within the As-Left Tolerance of the Nominal Trip Setpoint (NTSP)]. This is proposed note (e) to TS Table 3.3.1.1-1. |
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| ==Attachment:== | | ===Response=== |
| | At GGNS, trip setpoints are typically verified via channel calibration procedures, only. APRM Functions 2.a, 2.b, 2.d, and 2.f will follow this practice with their trip setpoints being verified via channel calibration SR 3.3.1.1.10, only. The proposed Notes (d) and (e) have been applied in TS Table 3.3.1.1 to SR 3.3.1.1.10 for these functions, as discussed in Section 4.4.3.1 of the LAR. Notes (d) and (e) are not applicable to APRM Functions 2.c and 2.e, as discussed in Section 5.1.5 of the LAR. |
| | NRC RAI No.4 In its application, the licensee proposed the following new operating license condition (OLC): |
| | During Cycle 19, GGNS may conduct monitoring of the Oscillation Power Range Monitor (OPRM). During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) may be disabled and operated in an 'indicate only' mode at which time technical specification requirements would not apply. During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations. |
| | In the application, the licensee stated that it would review the operating data, setpoints, and margins at the end of the OPRM monitoring period. Once it determines that the results are acceptable, the licensee will enable the OPRM (with applicable SRs met) by connecting it to the reactor protection system trip relays, completing implementation of the hardware changes, and notifying the NRC. |
| | However, the proposed OLC wording does not restrict GGNS from returning the OPRM into "indicate only" mode, once the OPRM has been enabled during Cycle 19. Also, the proposed "may" wording in the OLC suggests that GGNS has the option to disable the OPRM and conduct monitoring of the OPRM. Please revise the proposed OLC to address these concerns or provide further justification for the proposed wording. |
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| 1.Responses to NRC Requests for Additional Information Pertaining to License Amendment Request-Power Range Neutron Monitoring System Upgrade 2.Revised Ol, TS, and TS Bases Pages Mr.Elmo E.Collins, Jr.Regional Administrator, Region IV U.S.Nuclear Regulatory Commission 612 East lamar Blvd., Suite 400 Arlington, TX 76011-4005 U.S.Nuclear Regulatory Commission ATTN: Mr.C.F.lyon, NRR/DORl (w/2)ATTN: ADDRESSEE ONLY ATTN: Courier Delivery Only Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378 State Health Officer Mississippi Department of Health P.O.Box 1700 Jackson, MS 39215-1700 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 cc: GNRO-201 0-0001 0 Page 2 The No Significance Hazards Determination and the Environmental Consideration provided in Reference 1 are not impacted by these responses.
| | ===Response=== |
| This letter contains no new commitments.
| | Entergy proposes to revise the wording of the OLC as follows (changes denoted in bold, italicized text): |
| If you have any questions or require additional information, please contact Mr.Guy Davant at (601)368-5756.I declare under penalty of perjury that the foregoing is true and correct.Executed on February 8, 2010.Sincerely,MAKlghd
| | During Cycle 19, GGNS will conduct monitoring of the Oscillation Power Range Monitor (OPRM). During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) will be disabled and operated in an 'indicate only' mode and technical specification requirements will not apply to this function. During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations. Once monitoring has been successfully completed, the OPRM Upscale function will be enabled and technical specification requirements will be to GNRO-201 0-0001 0 Page 4 of 4 applied to the function; no further operating with this function in an Ilindicate only" mode will be conducted. |
| | Entergy has revised OL Insert A (contained on page 2 of LAR Attachment 3) to reflect the above wording. The OL page associated with this insert was provided on page 1 of LAR ; it reflected OL Amendment 182. The current OL Amendment is now 183. |
| | Therefore, Entergy is providing the revised OL Amendment 183 page along with Insert A to reflect the current OL amendment. |
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| ==Attachment:==
| | ATTACHMENT 2 GNRO-201 0-0001 0 REVISED OL, TS, TS BASES, AND INSERT PAGES to GNRO-2010-00010 Page 1 of 10 INSERT B - New Conditions J and K with Required Actions J. As required by Required Action J.1 Initiate alternate method to 12 hours 0.1 and referenced in detect and suppress thermal Table 3.3.1.1-1. hydraulic instability oscillations. |
| | AND J.2 - - - - - - - - - NOTE - - - - - - - - |
| | LCO 3.0.4 is not applicable. |
| | ---------------------- |
| | Restore required channels to 120 days OPERABLE. |
| | K. Required Action and associated K.1 Reduce THERMAL POWER 4 hours Completion Time of Condition J to < 24% RTP. |
| | not met. |
| | to GNRO-201 0-0001 0 Page 2 of 10 INSERT J - New Required Actions J.1 and J.2 If OPRM Upscale trip capability is not maintained, Condition J exists. Reference 15 justified use of alternate methods to detect and suppress oscillations for a limited period of time. The alternate methods are procedurally established consistent with the guidelines identified in Reference 16 requiring manual operator action to scram the plant if certain predefined events occur. The 12-hour allowed action time is based on engineering judgment to allow orderly transition to the alternate methods while limiting the period of time during which no automatic or alternate detect and suppress trip capability is formally in place. Based on the small probability of an instability event occurring at all, the 12 hours is judged to be reasonable. |
| | The alternate method to detect and suppress oscillations implemented in accordance with J.1 was evaluated (Reference 15) based on use up to 120 days only. The evaluation, based on engineering judgment, concluded that the likelihood of an instability event that could not be adequately handled by the alternate methods during this 120-day period was negligibly small. |
| | The 120-day period is intended to be an outside limit to allow for the case where design changes or extensive analysis might be required to understand or correct some unanticipated characteristic of the instability detection algorithms or equipment. This action is not intended and was not evaluated as a routine alternative to returning failed or inoperable equipment to OPERABLE status. Correction of routine equipment failure or inoperability is expected to normally be accomplished within the completion times allowed for Actions for Conditions A and B. |
| | LCO 3.0.4 is not applicable to J.2 to allow unit restart in the event of a shutdown during the 120-day completion time. |
| | to GNRO-201 0-0001 0 RPS Instrumentation Page 3 of 10 B 3.3.1.1 BASES BACKGROUND The RPS is comprised of two independent trip systems (A (continued) and B), with two logic channels in each trip system (logic channels Al and A2, 81 and 82), as shown in Reference 1. |
| | The outputs of the logic channels in a trip system are combined in a one-out-of-two logic so either channel can trip the associated trip system. The tripping of both trip systems will produce a reactor scram. This logic arrangement is referred to as one-out-of-two taken twice logic. Each trip system can be reset by use of a reset switch. If a full scram occurs (both trip systems trip), a relay prevents reset of the trip systems for 10 seconds after the full scram signal is received. This 10 second delay on reset ensures that the scram function will be completed. |
| | Two scram pilot valves are located in the hydraulic control unit (HCU) for each control rod drive (eRO). Each scram pilot valve is solenoid operated, with the solenoids normally energized. The scram pilot valves control the air supply to the scram inlet and outlet valves for the associated CRo. When either scram pilot valve solenoid is energized, air pressure holds the scram valves closed and, therefore, both scram pilot valve solenoids must be de-energized to cause a control rod to scram. The scram valves control the supply and discharge paths for the CRD water during a scram. One of the scram pilot valve solenoids for each CRD is controlled by trip system A, and the other solenoid is controlled by trip system B. Any trip of trip system A in conjunction with any trip in trip system B results in de-energizing both solenoids, air bleeding off, scram valves opening, and control rod scram. |
| | The backup scram valves, which energize on a scram signal to depressurize the scram air header, are also controlled by the RPS. Additionally, the RPS System controls the Sov vent and drain valves such that when both trip systems trip, the SOV vent and drain valves close to isolate the SOV. |
| | APPLICABLE The actions of the RPS are assumed in the safety analyses SAFETY ANALYSES, of References 2, 3, and 4. The RPS initiates a reactor LCO and t scram when monitored parameter values exceed the Allowable APPLICABILITY Values specified by the setpoint methodology and listed in Table 3.3.1.1-1 to preserve the integrity of the fuel cladding, the reactor coolant pressure boundary (RepS), and (continued) |
| | GRAND GULF B 3.3-2 Revision No. 0 to GNRO-201 0-0001 0 Page 4 of 10 INSERT 1 Application of TSTF-493. Rev. 4 (Ref. 17) to APRM Functions 2.a. 2.b. 2.d, and 2.f 10 CFR 50.36(c)(1 )(ii)(A) requires that Technical Specifications include LSSS for variables that have significant safety functions. LSSS are defined by the regulation as "...settings for automatic protective devices...so chosen that automatic protective actions will correct the abnormal situation before a safety limit is exceeded." The Analytical Limit is the limit of the process variable at which a protective action is initiated, as established by the safety analysis, to ensure that a SL is not exceeded. Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protective channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur. |
| | The trip setpoint is a predetermined setting for a protection channel chosen to ensure automatic actuation prior to the process variable reaching the Analytical Limit and thus ensuring that the SL would not be exceeded. As such, the trip setpoint accounts for uncertainties in setting the channel (e.g., calibration), uncertainties in how the channel might actually perform (e.g., repeatability), changes in the point of action of the channel over time (e.g., drift during surveillance intervals), and any other factors which may influence its actual performance (e.g., harsh accident environments). In this manner, the trip setpoint ensures that SLs are not exceeded. |
| | Technical Specifications contain values related to the OPERABILITY of equipment required for safe operation of the facility. OPERABLE is defined in Technical Specifications as |
| | "... being capable of performing its specified safety function(s)." Relying solely on the trip setpoint to define OPERABILITY in Technical Specifications would be an overly restrictive requirement if it were applied as an OPERABILITY limit for the "as found" value of a protection channel setting during a Surveillance. This would result in Technical Specification compliance problems, as well as reports and corrective actions required by the rule which are not necessary to ensure safety. For example, an automatic protection channel with a setting that has been found to be different from the trip setpoint due to some drift of the setting may still be OPERABLE because drift is to be expected. This expected drift would have been specifically accounted for in the setpoint methodology for calculating the trip setpoint and thus the automatic protective action would still have ensured that the SL would not be exceeded with the "as found" setting of the protection channel. Therefore, the channel would still be OPERABLE because it would have performed its safety function and the only corrective action required would be to reset the channel within the established as-left tolerance around the trip setpoint to account for further drift during the next surveillance interval. |
| | Note that, although the channel is OPERABLE under these circumstances, the trip setpoint must be left adjusted to a value within the as-left tolerance, in accordance with uncertainty assumptions stated in the referenced setpoint methodology (as-left criteria), and confirmed to be operating within the statistical allowances of the uncertainty terms assigned (as-found criteria). |
| | to GNRO-201 0-0001 0 Page 5 of 10 However, there is also some point beyond which the channel may not be able to perform its function due to, for example, greater than expected drift. This value needs to be specified in the Technical Specifications in order to define OPERABILITY of the channels and is designated as the Allowable Value. |
| | If the actual setting (as-found setpoint) of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance, the channel is OPERABLE but degraded. The degraded condition will be further evaluated during performance of the SR. |
| | This evaluation will consist of resetting the channel setpoint to the trip setpoint (within the allowed tolerance), and evaluating the channel response. If the channel is functioning as required and expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation. |
| | to GNRO-201 0-0001 0 RPS Instrumentation Page 6 of 10 B 3.3.1.1 BASES APPLICABLE environment errors (for channels that must function in fiarsh SAFETY ANALYSES, environments as defined by 10 CFR 50.49) are accounted for. |
| | LCO, and APPLICABILITY The OPERABILITY of scram pilot valves and associated |
| | {continued} solenoids, backup scram valves, and SOV valves, described in the Background section, are not addressed by this LCO. |
| | The individual Functions are required to be OPERABLE in the MODES specified in the Table that may require an RPS trip to mitigate the consequences of a design basis accident or transient. To ensure a reliable scram function, a combination of Functions is required in each MODE to provide primary and diverse initiation signals. |
| | RPS is required to be OPERABLE in MODE 5 with any, control rod withdrawn from a core cell containing one or more fuel assemblies. Control rods withdrawn from a core cell containing no fuel assemblies do not affect the reactivity of the core and therefore are not required to have the capability to scram. Provided all other control rods remain inserted, the RPS function is not required. In this condition, the required SCM (LCO 3.1.1, "SHUTDOWN MARGIN (SOM)") and refuel position one-rod-out interlock (lCO 3.9.2, "Refuel Position One-Rod-Out Interlock") ensure that no event requiring RPS will occur. During normal operation in MODES 3 and 4, all control rods are fully inserted and the Reactor Mode Switch-Shutdown Position control rod withdrawal block (LCO 3.3.2.1, "Control Rod Block Instrumentation") does not allow any control rod to be withdrawn. Under these conditions, the RPS function ;s not required to be OPERABLE. |
| | The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis. |
| | ~l.a. Intermediate Range Monitor fIRM) Neutron Flux--High The IRMs monitor neutron flux levels from the upper range of the source range monitors (SRMs) to the lower range of the average power range monitors (APRMs). The IRMs are capable of generating trip signals that can be used to prevent fuel damage resulting from abnormal operating transients in the intermediate power range. In this power range, the most significant source of reactivity change is due to control (continued) |
| | GRAND GULF B 3.3-4 Revision No. 0 to GNRO-201 0-0001 0 Page 7 of 10 INSERT 2 Application of TSTF-493, Rev. 4 (Ref. 17) to APRM Functions 2.a, 2.b, 2.d, and 2.f Permissive and interlock setpoints allow the blocking of trips during plant startups, and restoration of trips when the permissive conditions are not satisfied, but they are not explicitly modeled in the Safety Analyses. These permissives and interlocks ensure that the starting conditions are consistent with the safety analysis, before preventive or mitigating actions occur. Because these permissives or interlocks are only one of multiple conservative starting assumptions for the accident analysis, they are generally considered as nominal values without regard to measurement accuracy. |
| | Allowable Values for RPS Instrumentation Functions are specified for each RPS Function specified in Table 3.3.1.1-1. Trip setpoints and the methodologies for calculating the as-left and as-found tolerances are described in the Technical Requirements Manual. The nominal setpoints are selected to ensure that the actual setpoints remain conservative with respect to the as-found tolerance between successive CHANNEL CALIBRATIONS. After each calibration, the trip setpoint shall be left within the as-left band around the setpoint. |
| | to GNRO-201 0-0001 0 GGNS OPERATING LICENSE Page 8 of 10 (b) SERI is required to notify the NRC in writing prior to any change in (i) the terms or conditions of any new or existing sale or lease agreements executed as part of the above authorized financial transactions, (ii) the GGNS Unit 1 operating agreement, (iii) the existing property insurance coverage for GGNS Unit 1 that would materially alter the representations and conditions set forth in the Staff's Safety Evaluation Report dated December 19, 1988 attached to Amendment No. 54. |
| | In addition, SERI is required to notify the NRC of any action by a lessor or other successor in interest to SERI that may have an effect on the operation of the facility. |
| | C. The license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: |
| | (1) Maximum Power Level Entergy Operations, Inc. is authorized to operate the facility at reactor core power levels not in excess of 3898 megawatts thermal (100 percent power) in accordance with the conditions specified herein. |
| | (2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix a, as revised through Amendment No. 183 are hereby incorporated into this license. Entergy Operations, Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. |
| | ) |
| | TaB S~rvBillaRee Re~Hiremeft~3 (SR~) for Diesel GQRSrater Id eORtaiRea ift tfte Technical Specifications aae listed selow, are ROt: re'1t1ired to be peLfoLliled immBeiat:ely HpOR implemeftto6tion of Amendment Uo. l.2.1. |
| | TaQ iRs listed se10',J shall ee !Hleee~~ft111y delttonstLated a~ tao ROKt re~Hlar1} sefted~le~ ~er£ormal~e. |
| | SR 3.8.1.9, SR 3.8.1.1Q, afta SR 3.8.1.14 Amendment No. 11t'j-4 to GNRO-201 0-0001 0 Page 9 of 10 INSERT A - Exception During Cycle 19, GGNS will conduct monitoring of the Oscillation Power Range Monitor (OPRM). During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) will be disabled and operated in an 'indicate only' mode and technical specification requirements will not apply to this function. During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations. |
| | Once monitoring has been successfully completed, the OPRM Upscale function will be enabled and technical specification requirements will be applied to the function; no further operating with this function in an "indicate only" mode will be conducted. |
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| 1.Responses to NRC Requests for Additional Information Pertaining to License Amendment Request-Power Range Neutron Monitoring System Upgrade 2.Revised Ol, TS, and TS Bases Pages Mr.Elmo E.Collins, Jr.Regional Administrator, Region IV U.S.Nuclear Regulatory Commission 612 East lamar Blvd., Suite 400 Arlington, TX 76011-4005 U.S.Nuclear Regulatory Commission ATTN: Mr.C.F.lyon, NRR/DORl (w/2)ATTN: ADDRESSEE ONLY ATTN: Courier Delivery Only Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378 State Health Officer Mississippi Department of Health P.O.Box 1700 Jackson, MS 39215-1700 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 ATTACHMENT 1 GNRO-201 0-0001 0 RESPONSES TO NRC REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE ATTACHMENT 1 GNRO-201 0-0001 0 RESPONSES TO NRC REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE ATTACHMENT 1 GNRO-201 0-0001 0 RESPONSES TO NRC REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE ATTACHMENT 1 GNRO-201 0-0001 0 RESPONSES TO NRC REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE Attachment 1 to GNRO-201 0-0001 0 Page 1 of 4 RESPONSES TO NRC REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE Responses to the NRC staff's Requests for Additional Information (RAls)are provided in Attachment 1 of this letter.Associated revisions to the mark-ups of the proposed changes are provided in Attachment 2.NRC RAI No.1 Please explain how a unit restart is allowed by adding the note,"LCO 3.0.4.b is not applicable" to new Required Action J.2.Attachment 1, page 14 of the application letter states,"Entergy also proposes a note that states LCO 3.0.4.b is not applicable to new Required Action J.2.This note allows unit restart in the event of a shutdown during the 120-day completion time." However, Limiting Condition for Operation (LCO)3.0.4.a and LCO 3.0.4.c remain applicable.
| | Attachment 2 to RPS Instrumentation GNRO-201 0-0001 0 3.3.1.1 Page 10 of 10 Table 3.3.1.1-1 (page 1 of 3) |
| LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability, when an LCO is not met, only when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time.Condition J is referenced in Table 3.3.1.1-1 and entered as required by Required Action 0.1.Condition J Required Action J.1 requires initiating an alternate method to detect and suppress thermal hydraulic instability oscillations within 12 hours and J.2 requires restoring the required channels to operable status within 120 days.Condition J does not permit continued operation for an unlimited period of time.LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability, when an LCO is not met, only when an allowance is stated in the individual value, parameter, or other Specification.
| | Reactor Protection System Instrumentation APPLICABLE CONDIT IONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTI ON COND ITI ONS SYSTEM ACTION 0.1 REQUIREMENTS VALUE |
| LCO 3.0.4.c is not allowed in any condition in GGNS TS 3.3.1.1.Response Entergy agrees with the NRC's comments and proposes to revise the wording of the proposed note applied to Required Action J.2 to read,"LCO 3.0.4 is not applicable." This revised wording addresses the NRC's comments and allows unit restart in the event of a shutdown during the 120-day completion time of Required Action J.2.As discussed in Section 4.4.1.2 of the LAR, this note is consistent with the original intent of the NUMAC PRNM Licensing Topical Report (L TR), which is to allow normal plant operations to continue during the recovery time from a hypothesized design problem with the Option III stability solution algorithms.
| | : 1. Intermediate Range Monitors |
| This proposed note was approved by the NRC for Monticello Nuclear Generating Plant 1 and Peach Bottom Atomic Power Station, Units 2 and 3 2.NRC letter to Northern States Power Company, Monticello Nuclear Generating PlantIssuance of Amendment Regarding the Power Range Neutron Monitoring System (TA C No.MDB064), dated January 30,2009 (ADAMS Ascension No.ML083440681)
| | : a. Neutron Flux-High 2 3 H SR 3.3.1.1.1 :s; 122/125 SR 3.3.1.1.3 divisions of SR 3.3.1.1.12 full scale SR 3.3.1.1.13 5 (a) 3 SR 3.3.1.1.1 :s; 122/125 SR 3.3.1.1.4 divisions of SR 3.3.1.1.12 full scale SR 3.3.1.1.13 |
| Attachment 1 to GNRO-201 0-0001 0 Page 1 of 4 RESPONSES TO NRC REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE Responses to the NRC staff's Requests for Additional Information (RAls)are provided in Attachment 1 of this letter.Associated revisions to the mark-ups of the proposed changes are provided in Attachment 2.NRC RAI No.1 Please explain how a unit restart is allowed by adding the note,"LCO 3.0.4.b is not applicable" to new Required Action J.2.Attachment 1, page 14 of the application letter states,"Entergy also proposes a note that states LCO 3.0.4.b is not applicable to new Required Action J.2.This note allows unit restart in the event of a shutdown during the 120-day completion time." However, Limiting Condition for Operation (LCO)3.0.4.a and LCO 3.0.4.c remain applicable.
| | : b. Inop 2 3 H SR 3.3.1.1.3 NA SR 3.3.1.1.13 5 (a) SR 3.3.1.1.4 NA SR 3.3.1.1.13 |
| LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability, when an LCO is not met, only when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time.Condition J is referenced in Table 3.3.1.1-1 and entered as required by Required Action 0.1.Condition J Required Action J.1 requires initiating an alternate method to detect and suppress thermal hydraulic instability oscillations within 12 hours and J.2 requires restoring the required channels to operable status within 120 days.Condition J does not permit continued operation for an unlimited period of time.LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability, when an LCO is not met, only when an allowance is stated in the individual value, parameter, or other Specification.
| | : 2. Average Power Range Monitors |
| LCO 3.0.4.c is not allowed in any condition in GGNS TS 3.3.1.1.Response Entergy agrees with the NRC's comments and proposes to revise the wording of the proposed note applied to Required Action J.2 to read,"LCO 3.0.4 is not applicable." This revised wording addresses the NRC's comments and allows unit restart in the event of a shutdown during the 120-day completion time of Required Action J.2.As discussed in Section 4.4.1.2 of the LAR, this note is consistent with the original intent of the NUMAC PRNM Licensing Topical Report (L TR), which is to allow normal plant operations to continue during the recovery time from a hypothesized design problem with the Option III stability solution algorithms.
| | : a. Neutron Fl ux - Hi gh , 2 SR Setdown S~ |
| This proposed note was approved by the NRC for Monticello Nuclear Generating Plant 1 and Peach Bottom Atomic Power Station, Units 2 and 3 2.NRC letter to Northern States Power Company, Monticello Nuclear Generating PlantIssuance of Amendment Regarding the Power Range Neutron Monitoring System (TA C No.MDB064), dated January 30,2009 (ADAMS Ascension No.ML083440681)
| | SR SR |
| Attachment 1 to GNRO-201 0-0001 0 Page 1 of 4 RESPONSES TO NRC REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE Responses to the NRC staff's Requests for Additional Information (RAls)are provided in Attachment 1 of this letter.Associated revisions to the mark-ups of the proposed changes are provided in Attachment 2.NRC RAI No.1 Please explain how a unit restart is allowed by adding the note,"LCO 3.0.4.b is not applicable" to new Required Action J.2.Attachment 1, page 14 of the application letter states,"Entergy also proposes a note that states LCO 3.0.4.b is not applicable to new Required Action J.2.This note allows unit restart in the event of a shutdown during the 120-day completion time." However, Limiting Condition for Operation (LCO)3.0.4.a and LCO 3.0.4.c remain applicable.
| | : b. Fixed Neutro~ |
| LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability, when an LCO is not met, only when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time.Condition J is referenced in Table 3.3.1.1-1 and entered as required by Required Action 0.1.Condition J Required Action J.1 requires initiating an alternate method to detect and suppress thermal hydraulic instability oscillations within 12 hours and J.2 requires restoring the required channels to operable status within 120 days.Condition J does not permit continued operation for an unlimited period of time.LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability, when an LCO is not met, only when an allowance is stated in the individual value, parameter, or other Specification.
| | Flux-High |
| LCO 3.0.4.c is not allowed in any condition in GGNS TS 3.3.1.1.Response Entergy agrees with the NRC's comments and proposes to revise the wording of the proposed note applied to Required Action J.2 to read,"LCO 3.0.4 is not applicable." This revised wording addresses the NRC's comments and allows unit restart in the event of a shutdown during the 120-day completion time of Required Action J.2.As discussed in Section 4.4.1.2 of the LAR, this note is consistent with the original intent of the NUMAC PRNM Licensing Topical Report (L TR), which is to allow normal plant operations to continue during the recovery time from a hypothesized design problem with the Option III stability solution algorithms.
| | : c. Inop 1,2 |
| This proposed note was approved by the NRC for Monticello Nuclear Generating Plant 1 and Peach Bottom Atomic Power Station, Units 2 and 3 2.NRC letter to Northern States Power Company, Monticello Nuclear Generating PlantIssuance of Amendment Regarding the Power Range Neutron Monitoring System (TA C No.MDB064), dated January 30,2009 (ADAMS Ascension No.ML083440681)
| | : d. Flow Biased Simulated 3 G SR 3.3.1.1.1 Therma 1 Power - Hi gh SR 3.3.1.1.2 SR 3.3.1.1.7 SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.13 SR 3.3.1.1.15 SR 3.3.1.1.16 SR 3.3.1.1.17 SR 3.3.1.1.18 (continued) |
| Attachment 1 to GNRO-201 0-0001 0 Page 1 of 4 RESPONSES TO NRC REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE Responses to the NRC staff's Requests for Additional Information (RAls)are provided in Attachment 1 of this letter.Associated revisions to the mark-ups of the proposed changes are provided in Attachment 2.NRC RAI No.1 Please explain how a unit restart is allowed by adding the note,"LCO 3.0.4.b is not applicable" to new Required Action J.2.Attachment 1, page 14 of the application letter states,"Entergy also proposes a note that states LCO 3.0.4.b is not applicable to new Required Action J.2.This note allows unit restart in the event of a shutdown during the 120-day completion time." However, Limiting Condition for Operation (LCO)3.0.4.a and LCO 3.0.4.c remain applicable.
| | (a) With any control rod withdrawn from a core cell containing one or more fuel assemblies. |
| LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability, when an LCO is not met, only when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time.Condition J is referenced in Table 3.3.1.1-1 and entered as required by Required Action 0.1.Condition J Required Action J.1 requires initiating an alternate method to detect and suppress thermal hydraulic instability oscillations within 12 hours and J.2 requires restoring the required channels to operable status within 120 days.Condition J does not permit continued operation for an unlimited period of time.LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability, when an LCO is not met, only when an allowance is stated in the individual value, parameter, or other Specification.
| | (b) All0 ** al:Jle Vallics sl'eeifieEi il'l tAC COLR. Al1o'hasle Vall:fe A1sEiifieatiol'l I"CEll:f;pcEi 8) tRe (QlP: Ellie to reEil:lctioAS iA fceEihatcr teA1I'Cratl:lre ffia) Be EielayeEi fop l:ll' to 12 ~ol:lrs. |
| LCO 3.0.4.c is not allowed in any condition in GGNS TS 3.3.1.1.Response Entergy agrees with the NRC's comments and proposes to revise the wording of the proposed note applied to Required Action J.2 to read,"LCO 3.0.4 is not applicable." This revised wording addresses the NRC's comments and allows unit restart in the event of a shutdown during the 120-day completion time of Required Action J.2.As discussed in Section 4.4.1.2 of the LAR, this note is consistent with the original intent of the NUMAC PRNM Licensing Topical Report (L TR), which is to allow normal plant operations to continue during the recovery time from a hypothesized design problem with the Option III stability solution algorithms.
| | GRAND GULF 3.3-6 Amendment No. +4+/-, 169}} |
| This proposed note was approved by the NRC for Monticello Nuclear Generating Plant 1 and Peach Bottom Atomic Power Station, Units 2 and 3 2.NRC letter to Northern States Power Company, Monticello Nuclear Generating PlantIssuance of Amendment Regarding the Power Range Neutron Monitoring System (TA C No.MDB064), dated January 30,2009 (ADAMS Ascension No.ML083440681)
| |
| Attachment 1 to GNRO-201 0-0001 0 Page 2 of 4 Entergy has revised TS Insert B and the discussion of Required Action J.2 in TS Bases Insert J (contained on page 9 of LAR Attachment 3 and page 27 of LAR Attachment 4, respectively) to reflect the wording change for the note, as specified above.NRC RAI No.2 Please provide revised proposed TS Bases changes that are consistent with Technical Specification Task Force (TSTF)-493, Revision 4, or justify deviations.
| |
| The applicability section in Federal Register (74 FR 58065),"Notice of Opportunity for Public Comment on the Proposed Model Safety Evaluation for Plant-Specific Adoption of Technical Specification Task Force Traveler-493, Revision 4,"Clarify Application of Setpoint Methodology for LSSS Functions" stated,"The licensee must add footnotes to all the functions identified in TSTF Traveler-493, Revision 4, Appendix A, and must incorporate the related TS Bases changes." for any licensee wishing to adopt TS task force (TSTF)493, option A without changes to setpoint values.The NRC staff considers the changes made by TSTF-493, Revision 4 to TS 3.3.1.1 Bases sections: (1)background; (2)applicable safety analyses, LCO, and applicability; (3)actions;and (4)surveillance requirements to be related to GGNS proposed amendment.
| |
| Response Entergy plans to revise the"BACKGROUND" and"APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY" sections of TS Bases 3.3.1.1 to reflect TSTF-493, Rev.4 wording as applied to the APRM functions.
| |
| Specifically, Entergy has added subsections entitled Application of TSTF-493, Rev.4 (Ref.17)to APRM Functions 2.a, 2.b, 2.d, and 2.f to TS Bases pages B 3.3-2 and B 3.3-4 as Inserts 1 and 2, respectively.
| |
| NRC RAI No.3 Please state which SRs verify trip setpoint settings for functions 2.a, 2.b, 2.c, 2.d, 2.e, and 2.f in TS Table 3.3.1.1-1, and provide a revised TS Table 3.3.1.1-1 with the addition of notes (d)and (e)for these functions as needed.The proposed change revises GGNS TSs to incorporate NRC-approved TSTF Traveler-493, Revision 4, to be consistent with Option A.Option A, without changes to setpoint values, adds two Notes to SRs in the Surveillance Requirement Column of TSs Instrumentation Function Tables.Specifically, Notes are added to TS 3.3.1.1 SRs that require verifying trip setpoint setting values, (i.e.Channel Calibration and Channel Functional Test SRs)for NUREG-1434.
| |
| The first Surveillance Note requires evaluation of channel performance for the condition where the As-Found setting for the channel setpoint is outside its As-Found Tolerance but conservative with respect to the AV.This is proposed note (d)to TS Table 3.3.1.1-1.
| |
| The second Surveillance Note requires that the As-Left setting for the channel be returned to 2 NRC letter to Exelon Nuclear, Peach Bottom Atomic Power Station, Units 2 and 3-Issuance of Amendment Re: Activation of Oscillation Power Range Monitor Trip (TAG Nos.MC2219 and MC2220), dated March 21, 2005 (page 4 of SE)(ADAMS Accession No.ML05270020)
| |
| Attachment 1 to GNRO-201 0-0001 0 Page 2 of 4 Entergy has revised TS Insert B and the discussion of Required Action J.2 in TS Bases Insert J (contained on page 9 of LAR Attachment 3 and page 27 of LAR Attachment 4, respectively) to reflect the wording change for the note, as specified above.NRC RAI No.2 Please provide revised proposed TS Bases changes that are consistent with Technical Specification Task Force (TSTF)-493, Revision 4, or justify deviations.
| |
| The applicability section in Federal Register (74 FR 58065),"Notice of Opportunity for Public Comment on the Proposed Model Safety Evaluation for Plant-Specific Adoption of Technical Specification Task Force Traveler-493, Revision 4,"Clarify Application of Setpoint Methodology for LSSS Functions" stated,"The licensee must add footnotes to all the functions identified in TSTF Traveler-493, Revision 4, Appendix A, and must incorporate the related TS Bases changes." for any licensee wishing to adopt TS task force (TSTF)493, option A without changes to setpoint values.The NRC staff considers the changes made by TSTF-493, Revision 4 to TS 3.3.1.1 Bases sections: (1)background; (2)applicable safety analyses, LCO, and applicability; (3)actions;and (4)surveillance requirements to be related to GGNS proposed amendment.
| |
| Response Entergy plans to revise the"BACKGROUND" and"APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY" sections of TS Bases 3.3.1.1 to reflect TSTF-493, Rev.4 wording as applied to the APRM functions.
| |
| Specifically, Entergy has added subsections entitled Application of TSTF-493, Rev.4 (Ref.17)to APRM Functions 2.a, 2.b, 2.d, and 2.f to TS Bases pages B 3.3-2 and B 3.3-4 as Inserts 1 and 2, respectively.
| |
| NRC RAI No.3 Please state which SRs verify trip setpoint settings for functions 2.a, 2.b, 2.c, 2.d, 2.e, and 2.f in TS Table 3.3.1.1-1, and provide a revised TS Table 3.3.1.1-1 with the addition of notes (d)and (e)for these functions as needed.The proposed change revises GGNS TSs to incorporate NRC-approved TSTF Traveler-493, Revision 4, to be consistent with Option A.Option A, without changes to setpoint values, adds two Notes to SRs in the Surveillance Requirement Column of TSs Instrumentation Function Tables.Specifically, Notes are added to TS 3.3.1.1 SRs that require verifying trip setpoint setting values, (i.e.Channel Calibration and Channel Functional Test SRs)for NUREG-1434.
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| The first Surveillance Note requires evaluation of channel performance for the condition where the As-Found setting for the channel setpoint is outside its As-Found Tolerance but conservative with respect to the AV.This is proposed note (d)to TS Table 3.3.1.1-1.
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| The second Surveillance Note requires that the As-Left setting for the channel be returned to 2 NRC letter to Exelon Nuclear, Peach Bottom Atomic Power Station, Units 2 and 3-Issuance of Amendment Re: Activation of Oscillation Power Range Monitor Trip (TAG Nos.MC2219 and MC2220), dated March 21, 2005 (page 4 of SE)(ADAMS Accession No.ML05270020)
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| Attachment 1 to GNRO-201 0-0001 0 Page 2 of 4 Entergy has revised TS Insert B and the discussion of Required Action J.2 in TS Bases Insert J (contained on page 9 of LAR Attachment 3 and page 27 of LAR Attachment 4, respectively) to reflect the wording change for the note, as specified above.NRC RAI No.2 Please provide revised proposed TS Bases changes that are consistent with Technical Specification Task Force (TSTF)-493, Revision 4, or justify deviations.
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| The applicability section in Federal Register (74 FR 58065),"Notice of Opportunity for Public Comment on the Proposed Model Safety Evaluation for Plant-Specific Adoption of Technical Specification Task Force Traveler-493, Revision 4,"Clarify Application of Setpoint Methodology for LSSS Functions" stated,"The licensee must add footnotes to all the functions identified in TSTF Traveler-493, Revision 4, Appendix A, and must incorporate the related TS Bases changes." for any licensee wishing to adopt TS task force (TSTF)493, option A without changes to setpoint values.The NRC staff considers the changes made by TSTF-493, Revision 4 to TS 3.3.1.1 Bases sections: (1)background; (2)applicable safety analyses, LCO, and applicability; (3)actions;and (4)surveillance requirements to be related to GGNS proposed amendment.
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| Response Entergy plans to revise the"BACKGROUND" and"APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY" sections of TS Bases 3.3.1.1 to reflect TSTF-493, Rev.4 wording as applied to the APRM functions.
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| Specifically, Entergy has added subsections entitled Application of TSTF-493, Rev.4 (Ref.17)to APRM Functions 2.a, 2.b, 2.d, and 2.f to TS Bases pages B 3.3-2 and B 3.3-4 as Inserts 1 and 2, respectively.
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| NRC RAI No.3 Please state which SRs verify trip setpoint settings for functions 2.a, 2.b, 2.c, 2.d, 2.e, and 2.f in TS Table 3.3.1.1-1, and provide a revised TS Table 3.3.1.1-1 with the addition of notes (d)and (e)for these functions as needed.The proposed change revises GGNS TSs to incorporate NRC-approved TSTF Traveler-493, Revision 4, to be consistent with Option A.Option A, without changes to setpoint values, adds two Notes to SRs in the Surveillance Requirement Column of TSs Instrumentation Function Tables.Specifically, Notes are added to TS 3.3.1.1 SRs that require verifying trip setpoint setting values, (i.e.Channel Calibration and Channel Functional Test SRs)for NUREG-1434.
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| The first Surveillance Note requires evaluation of channel performance for the condition where the As-Found setting for the channel setpoint is outside its As-Found Tolerance but conservative with respect to the AV.This is proposed note (d)to TS Table 3.3.1.1-1.
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| The second Surveillance Note requires that the As-Left setting for the channel be returned to 2 NRC letter to Exelon Nuclear, Peach Bottom Atomic Power Station, Units 2 and 3-Issuance of Amendment Re: Activation of Oscillation Power Range Monitor Trip (TAG Nos.MC2219 and MC2220), dated March 21, 2005 (page 4 of SE)(ADAMS Accession No.ML05270020)
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| Attachment 1 to GNRO-201 0-0001 0 Page 2 of 4 Entergy has revised TS Insert B and the discussion of Required Action J.2 in TS Bases Insert J (contained on page 9 of LAR Attachment 3 and page 27 of LAR Attachment 4, respectively) to reflect the wording change for the note, as specified above.NRC RAI No.2 Please provide revised proposed TS Bases changes that are consistent with Technical Specification Task Force (TSTF)-493, Revision 4, or justify deviations.
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| The applicability section in Federal Register (74 FR 58065),"Notice of Opportunity for Public Comment on the Proposed Model Safety Evaluation for Plant-Specific Adoption of Technical Specification Task Force Traveler-493, Revision 4,"Clarify Application of Setpoint Methodology for LSSS Functions" stated,"The licensee must add footnotes to all the functions identified in TSTF Traveler-493, Revision 4, Appendix A, and must incorporate the related TS Bases changes." for any licensee wishing to adopt TS task force (TSTF)493, option A without changes to setpoint values.The NRC staff considers the changes made by TSTF-493, Revision 4 to TS 3.3.1.1 Bases sections: (1)background; (2)applicable safety analyses, LCO, and applicability; (3)actions;and (4)surveillance requirements to be related to GGNS proposed amendment.
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| Response Entergy plans to revise the"BACKGROUND" and"APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY" sections of TS Bases 3.3.1.1 to reflect TSTF-493, Rev.4 wording as applied to the APRM functions.
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| Specifically, Entergy has added subsections entitled Application of TSTF-493, Rev.4 (Ref.17)to APRM Functions 2.a, 2.b, 2.d, and 2.f to TS Bases pages B 3.3-2 and B 3.3-4 as Inserts 1 and 2, respectively.
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| NRC RAI No.3 Please state which SRs verify trip setpoint settings for functions 2.a, 2.b, 2.c, 2.d, 2.e, and 2.f in TS Table 3.3.1.1-1, and provide a revised TS Table 3.3.1.1-1 with the addition of notes (d)and (e)for these functions as needed.The proposed change revises GGNS TSs to incorporate NRC-approved TSTF Traveler-493, Revision 4, to be consistent with Option A.Option A, without changes to setpoint values, adds two Notes to SRs in the Surveillance Requirement Column of TSs Instrumentation Function Tables.Specifically, Notes are added to TS 3.3.1.1 SRs that require verifying trip setpoint setting values, (i.e.Channel Calibration and Channel Functional Test SRs)for NUREG-1434.
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| The first Surveillance Note requires evaluation of channel performance for the condition where the As-Found setting for the channel setpoint is outside its As-Found Tolerance but conservative with respect to the AV.This is proposed note (d)to TS Table 3.3.1.1-1.
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| The second Surveillance Note requires that the As-Left setting for the channel be returned to 2 NRC letter to Exelon Nuclear, Peach Bottom Atomic Power Station, Units 2 and 3-Issuance of Amendment Re: Activation of Oscillation Power Range Monitor Trip (TAG Nos.MC2219 and MC2220), dated March 21, 2005 (page 4 of SE)(ADAMS Accession No.ML05270020)
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| Attachment 1 to GNRO-201 0-0001 0 Page 3 of 4 within the As-Left Tolerance of the Nominal Trip Setpoint (NTSP)].This is proposed note (e)to TS Table 3.3.1.1-1.
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| Response At GGNS, trip setpoints are typically verified via channel calibration procedures, only.APRM Functions 2.a, 2.b, 2.d, and 2.f will follow this practice with their trip setpoints being verified via channel calibration SR 3.3.1.1.10, only.The proposed Notes (d)and (e)have been applied in TS Table 3.3.1.1 to SR 3.3.1.1.10 for these functions, as discussed in Section 4.4.3.1 of the LAR.Notes (d)and (e)are not applicable to APRM Functions 2.c and 2.e, as discussed in Section 5.1.5 of the LAR.NRC RAI No.4 In its application, thelicenseeproposed the following new operating license condition (OLC): During Cycle 19, GGNS may conduct monitoring of the Oscillation Power Range Monitor (OPRM).During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) may be disabled and operated in an'indicate only'mode at which time technical specification requirements would not apply.During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations.
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| In the application, the licensee stated that it would review the operating data, setpoints, and marginsatthe end of the OPRM monitoring period.Once it determines that the results are acceptable, the licensee will enable the OPRM (with applicable SRs met)by connecting it to the reactor protection system trip relays, completing implementation of the hardware changes, and notifying the NRC.However, the proposed OLC wording does not restrict GGNS from returning the OPRM into"indicate only" mode, once the OPRM has been enabled during Cycle 19.Also, the proposed"may" wording in the OLC suggests that GGNS has the option to disable the OPRM and conduct monitoring of the OPRM.Please revise the proposed OLC to address these concerns or provide further justification for the proposed wording.Response Entergy proposes to revise the wording of the OLC as follows (changes denoted in bold, italicized text): During Cycle 19, GGNS will conduct monitoring of the Oscillation Power Range Monitor (OPRM).During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) will be disabled and operated in an'indicate only'mode and technical specification requirements will not apply to this function.During such time, BackupStabilityProtection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations.
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| Once monitoring has been successfully completed, the OPRM Upscale function will be enabled and technical specification requirements will be Attachment 1 to GNRO-201 0-0001 0 Page 3 of 4 within the As-Left Tolerance of the Nominal Trip Setpoint (NTSP)].This is proposed note (e)to TS Table 3.3.1.1-1.
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| Response At GGNS, trip setpoints are typically verified via channel calibration procedures, only.APRM Functions 2.a, 2.b, 2.d, and 2.f will follow this practice with their trip setpoints being verified via channel calibration SR 3.3.1.1.10, only.The proposed Notes (d)and (e)have been applied in TS Table 3.3.1.1 to SR 3.3.1.1.10 for these functions, as discussed in Section 4.4.3.1 of the LAR.Notes (d)and (e)are not applicable to APRM Functions 2.c and 2.e, as discussed in Section 5.1.5 of the LAR.NRC RAI No.4 In its application, thelicenseeproposed the following new operating license condition (OLC): During Cycle 19, GGNS may conduct monitoring of the Oscillation Power Range Monitor (OPRM).During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) may be disabled and operated in an'indicate only'mode at which time technical specification requirements would not apply.During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations.
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| In the application, the licensee stated that it would review the operating data, setpoints, and marginsatthe end of the OPRM monitoring period.Once it determines that the results are acceptable, the licensee will enable the OPRM (with applicable SRs met)by connecting it to the reactor protection system trip relays, completing implementation of the hardware changes, and notifying the NRC.However, the proposed OLC wording does not restrict GGNS from returning the OPRM into"indicate only" mode, once the OPRM has been enabled during Cycle 19.Also, the proposed"may" wording in the OLC suggests that GGNS has the option to disable the OPRM and conduct monitoring of the OPRM.Please revise the proposed OLC to address these concerns or provide further justification for the proposed wording.Response Entergy proposes to revise the wording of the OLC as follows (changes denoted in bold, italicized text): During Cycle 19, GGNS will conduct monitoring of the Oscillation Power Range Monitor (OPRM).During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) will be disabled and operated in an'indicate only'mode and technical specification requirements will not apply to this function.During such time, BackupStabilityProtection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations.
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| Once monitoring has been successfully completed, the OPRM Upscale function will be enabled and technical specification requirements will be Attachment 1 to GNRO-201 0-0001 0 Page 3 of 4 within the As-Left Tolerance of the Nominal Trip Setpoint (NTSP)].This is proposed note (e)to TS Table 3.3.1.1-1.
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| Response At GGNS, trip setpoints are typically verified via channel calibration procedures, only.APRM Functions 2.a, 2.b, 2.d, and 2.f will follow this practice with their trip setpoints being verified via channel calibration SR 3.3.1.1.10, only.The proposed Notes (d)and (e)have been applied in TS Table 3.3.1.1 to SR 3.3.1.1.10 for these functions, as discussed in Section 4.4.3.1 of the LAR.Notes (d)and (e)are not applicable to APRM Functions 2.c and 2.e, as discussed in Section 5.1.5 of the LAR.NRC RAI No.4 In its application, thelicenseeproposed the following new operating license condition (OLC): During Cycle 19, GGNS may conduct monitoring of the Oscillation Power Range Monitor (OPRM).During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) may be disabled and operated in an'indicate only'mode at which time technical specification requirements would not apply.During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations.
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| In the application, the licensee stated that it would review the operating data, setpoints, and marginsatthe end of the OPRM monitoring period.Once it determines that the results are acceptable, the licensee will enable the OPRM (with applicable SRs met)by connecting it to the reactor protection system trip relays, completing implementation of the hardware changes, and notifying the NRC.However, the proposed OLC wording does not restrict GGNS from returning the OPRM into"indicate only" mode, once the OPRM has been enabled during Cycle 19.Also, the proposed"may" wording in the OLC suggests that GGNS has the option to disable the OPRM and conduct monitoring of the OPRM.Please revise the proposed OLC to address these concerns or provide further justification for the proposed wording.Response Entergy proposes to revise the wording of the OLC as follows (changes denoted in bold, italicized text): During Cycle 19, GGNS will conduct monitoring of the Oscillation Power Range Monitor (OPRM).During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) will be disabled and operated in an'indicate only'mode and technical specification requirements will not apply to this function.During such time, BackupStabilityProtection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations.
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| Once monitoring has been successfully completed, the OPRM Upscale function will be enabled and technical specification requirements will be Attachment 1 to GNRO-201 0-0001 0 Page 3 of 4 within the As-Left Tolerance of the Nominal Trip Setpoint (NTSP)].This is proposed note (e)to TS Table 3.3.1.1-1.
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| Response At GGNS, trip setpoints are typically verified via channel calibration procedures, only.APRM Functions 2.a, 2.b, 2.d, and 2.f will follow this practice with their trip setpoints being verified via channel calibration SR 3.3.1.1.10, only.The proposed Notes (d)and (e)have been applied in TS Table 3.3.1.1 to SR 3.3.1.1.10 for these functions, as discussed in Section 4.4.3.1 of the LAR.Notes (d)and (e)are not applicable to APRM Functions 2.c and 2.e, as discussed in Section 5.1.5 of the LAR.NRC RAI No.4 In its application, thelicenseeproposed the following new operating license condition (OLC): During Cycle 19, GGNS may conduct monitoring of the Oscillation Power Range Monitor (OPRM).During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) may be disabled and operated in an'indicate only'mode at which time technical specification requirements would not apply.During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations.
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| In the application, the licensee stated that it would review the operating data, setpoints, and marginsatthe end of the OPRM monitoring period.Once it determines that the results are acceptable, the licensee will enable the OPRM (with applicable SRs met)by connecting it to the reactor protection system trip relays, completing implementation of the hardware changes, and notifying the NRC.However, the proposed OLC wording does not restrict GGNS from returning the OPRM into"indicate only" mode, once the OPRM has been enabled during Cycle 19.Also, the proposed"may" wording in the OLC suggests that GGNS has the option to disable the OPRM and conduct monitoring of the OPRM.Please revise the proposed OLC to address these concerns or provide further justification for the proposed wording.Response Entergy proposes to revise the wording of the OLC as follows (changes denoted in bold, italicized text): During Cycle 19, GGNS will conduct monitoring of the Oscillation Power Range Monitor (OPRM).During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) will be disabled and operated in an'indicate only'mode and technical specification requirements will not apply to this function.During such time, BackupStabilityProtection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations.
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| Once monitoring has been successfully completed, the OPRM Upscale function will be enabled and technical specification requirements will be Attachment 1 to GNRO-201 0-0001 0 Page 4 of 4 applied to the function;no further operating with this function in an Ilindicate only" mode will be conducted.
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| Entergy has revised OL Insert A (contained on page 2 of LAR Attachment 3)to reflect the above wording.The OL page associated with this insert was provided on page 1 of LAR Attachment 3;it reflected OL Amendment 182.The current OL Amendment is now 183.Therefore, Entergy is providing the revised OL Amendment 183 page along with Insert A to reflect the current OL amendment.
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| Attachment 1 to GNRO-201 0-0001 0 Page 4 of 4 applied to the function;no further operating with this function in an Ilindicate only" mode will be conducted.
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| Entergy has revised OL Insert A (contained on page 2 of LAR Attachment 3)to reflect the above wording.The OL page associated with this insert was provided on page 1 of LAR Attachment 3;it reflected OL Amendment 182.The current OL Amendment is now 183.Therefore, Entergy is providing the revised OL Amendment 183 page along with Insert A to reflect the current OL amendment.
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| Attachment 1 to GNRO-201 0-0001 0 Page 4 of 4 applied to the function;no further operating with this function in an Ilindicate only" mode will be conducted.
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| Entergy has revised OL Insert A (contained on page 2 of LAR Attachment 3)to reflect the above wording.The OL page associated with this insert was provided on page 1 of LAR Attachment 3;it reflected OL Amendment 182.The current OL Amendment is now 183.Therefore, Entergy is providing the revised OL Amendment 183 page along with Insert A to reflect the current OL amendment.
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| Attachment 1 to GNRO-201 0-0001 0 Page 4 of 4 applied to the function;no further operating with this function in an Ilindicate only" mode will be conducted.
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| Entergy has revised OL Insert A (contained on page 2 of LAR Attachment 3)to reflect the above wording.The OL page associated with this insert was provided on page 1 of LAR Attachment 3;it reflected OL Amendment 182.The current OL Amendment is now 183.Therefore, Entergy is providing the revised OL Amendment 183 page along with Insert A to reflect the current OL amendment.
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| ATTACHMENT 2 GNRO-201 0-0001 0 REVISED OL, TS, TS BASES, AND INSERT PAGES ATTACHMENT 2 GNRO-201 0-0001 0 REVISED OL, TS, TS BASES, AND INSERT PAGES ATTACHMENT 2 GNRO-201 0-0001 0 REVISED OL, TS, TS BASES, AND INSERT PAGES ATTACHMENT 2 GNRO-201 0-0001 0 REVISED OL, TS, TS BASES, AND INSERT PAGES Attachment 2 to GNRO-2010-00010 Page 1 of 10 INSERTB-New Conditions J and K with Required Actions J.As required by Required Action J.1 I nitiate alternate method to 12 hours 0.1 and referenced in detect and suppress thermal Table 3.3.1.1-1.
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| hydraulic instability oscillations.
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| AND J.2---------NOTE--------LCO 3.0.4 is not applicable.
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| ----------------------
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| Restore required channels to 120 days OPERABLE.K.Required Action and associated K.1 Reduce THERMAL POWER 4 hours Completion Time of Condition J to<24%RTP.not met.Attachment 2 to GNRO-2010-00010 Page 1 of 10 INSERTB-New Conditions J and K with Required Actions J.As required by Required Action J.1 I nitiate alternate method to 12 hours 0.1 and referenced in detect and suppress thermal Table 3.3.1.1-1.
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| hydraulic instability oscillations.
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| AND J.2---------NOTE--------LCO 3.0.4 is not applicable.
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| ----------------------
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| Restore required channels to 120 days OPERABLE.K.Required Action and associated K.1 Reduce THERMAL POWER 4 hours Completion Time of Condition J to<24%RTP.not met.Attachment 2 to GNRO-2010-00010 Page 1 of 10 INSERTB-New Conditions J and K with Required Actions J.As required by Required Action J.1 I nitiate alternate method to 12 hours 0.1 and referenced in detect and suppress thermal Table 3.3.1.1-1.
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| hydraulic instability oscillations.
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| AND J.2---------NOTE--------LCO 3.0.4 is not applicable.
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| ----------------------
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| Restore required channels to 120 days OPERABLE.K.Required Action and associated K.1 Reduce THERMAL POWER 4 hours Completion Time of Condition J to<24%RTP.not met.Attachment 2 to GNRO-2010-00010 Page 1 of 10 INSERTB-New Conditions J and K with Required Actions J.As required by Required Action J.1 I nitiate alternate method to 12 hours 0.1 and referenced in detect and suppress thermal Table 3.3.1.1-1.
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| hydraulic instability oscillations.
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| AND J.2---------NOTE--------LCO 3.0.4 is not applicable.
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| ----------------------
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| Restore required channels to 120 days OPERABLE.K.Required Action and associated K.1 Reduce THERMAL POWER 4 hours Completion Time of Condition J to<24%RTP.not met.
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| Attachment 2 to GNRO-201 0-0001 0 Page 2 of 10 INSERTJ-New Required Actions J.1 and J.2 If OPRM Upscale trip capability is not maintained, Condition J exists.Reference 15 justified use of alternate methods to detect andsuppressoscillations for a limited period of time.The alternate methods are procedurally established consistent with the guidelines identified in Reference 16 requiring manual operator action to scram the plant if certain predefined events occur.The 12-hour allowed action time is based on engineering judgment to allow orderly transition to the alternate methods while limiting the period of time during which no automatic or alternate detect and suppress trip capability is formally in place.Based on the small probability of an instability event occurring at all, the 12 hours is judged to be reasonable.
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| The alternate method to detect and suppress oscillations implemented in accordance with J.1 was evaluated (Reference 15)based on use up to 120 days only.The evaluation, based on engineering judgment, concluded that the likelihood of an instability event that could not be adequately handled by the alternate methods during this 120-day period was negligibly small.The 120-day period is intended to be an outside limit to allow for the case where design changes or extensive analysis might be required to understand or correct some unanticipated characteristic of the instability detection algorithms or equipment.
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| This action is not intended and was not evaluated as a routine alternative to returning failed or inoperable equipment to OPERABLE status.Correction of routine equipment failure or inoperability is expected to normally be accomplished within the completion times allowed for Actions for Conditions A and B.LCO 3.0.4 is not applicable to J.2 to allow unit restart in the event of a shutdown during the 120-day completion time.Attachment 2 to GNRO-201 0-0001 0 Page 2 of 10 INSERTJ-New Required Actions J.1 and J.2 If OPRM Upscale trip capability is not maintained, Condition J exists.Reference 15 justified use of alternate methods to detect andsuppressoscillations for a limited period of time.The alternate methods are procedurally established consistent with the guidelines identified in Reference 16 requiring manual operator action to scram the plant if certain predefined events occur.The 12-hour allowed action time is based on engineering judgment to allow orderly transition to the alternate methods while limiting the period of time during which no automatic or alternate detect and suppress trip capability is formally in place.Based on the small probability of an instability event occurring at all, the 12 hours is judged to be reasonable.
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| The alternate method to detect and suppress oscillations implemented in accordance with J.1 was evaluated (Reference 15)based on use up to 120 days only.The evaluation, based on engineering judgment, concluded that the likelihood of an instability event that could not be adequately handled by the alternate methods during this 120-day period was negligibly small.The 120-day period is intended to be an outside limit to allow for the case where design changes or extensive analysis might be required to understand or correct some unanticipated characteristic of the instability detection algorithms or equipment.
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| This action is not intended and was not evaluated as a routine alternative to returning failed or inoperable equipment to OPERABLE status.Correction of routine equipment failure or inoperability is expected to normally be accomplished within the completion times allowed for Actions for Conditions A and B.LCO 3.0.4 is not applicable to J.2 to allow unit restart in the event of a shutdown during the 120-day completion time.Attachment 2 to GNRO-201 0-0001 0 Page 2 of 10 INSERTJ-New Required Actions J.1 and J.2 If OPRM Upscale trip capability is not maintained, Condition J exists.Reference 15 justified use of alternate methods to detect andsuppressoscillations for a limited period of time.The alternate methods are procedurally established consistent with the guidelines identified in Reference 16 requiring manual operator action to scram the plant if certain predefined events occur.The 12-hour allowed action time is based on engineering judgment to allow orderly transition to the alternate methods while limiting the period of time during which no automatic or alternate detect and suppress trip capability is formally in place.Based on the small probability of an instability event occurring at all, the 12 hours is judged to be reasonable.
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| The alternate method to detect and suppress oscillations implemented in accordance with J.1 was evaluated (Reference 15)based on use up to 120 days only.The evaluation, based on engineering judgment, concluded that the likelihood of an instability event that could not be adequately handled by the alternate methods during this 120-day period was negligibly small.The 120-day period is intended to be an outside limit to allow for the case where design changes or extensive analysis might be required to understand or correct some unanticipated characteristic of the instability detection algorithms or equipment.
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| This action is not intended and was not evaluated as a routine alternative to returning failed or inoperable equipment to OPERABLE status.Correction of routine equipment failure or inoperability is expected to normally be accomplished within the completion times allowed for Actions for Conditions A and B.LCO 3.0.4 is not applicable to J.2 to allow unit restart in the event of a shutdown during the 120-day completion time.Attachment 2 to GNRO-201 0-0001 0 Page 2 of 10 INSERTJ-New Required Actions J.1 and J.2 If OPRM Upscale trip capability is not maintained, Condition J exists.Reference 15 justified use of alternate methods to detect andsuppressoscillations for a limited period of time.The alternate methods are procedurally established consistent with the guidelines identified in Reference 16 requiring manual operator action to scram the plant if certain predefined events occur.The 12-hour allowed action time is based on engineering judgment to allow orderly transition to the alternate methods while limiting the period of time during which no automatic or alternate detect and suppress trip capability is formally in place.Based on the small probability of an instability event occurring at all, the 12 hours is judged to be reasonable.
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| The alternate method to detect and suppress oscillations implemented in accordance with J.1 was evaluated (Reference 15)based on use up to 120 days only.The evaluation, based on engineering judgment, concluded that the likelihood of an instability event that could not be adequately handled by the alternate methods during this 120-day period was negligibly small.The 120-day period is intended to be an outside limit to allow for the case where design changes or extensive analysis might be required to understand or correct some unanticipated characteristic of the instability detection algorithms or equipment.
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| This action is not intended and was not evaluated as a routine alternative to returning failed or inoperable equipment to OPERABLE status.Correction of routine equipment failure or inoperability is expected to normally be accomplished within the completion times allowed for Actions for Conditions A and B.LCO 3.0.4 is not applicable to J.2 to allow unit restart in the event of a shutdown during the 120-day completion time.
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| Attachment 2 to GNRO-201 0-0001 0 Page 3 of 10 BASES BACKGROUND (continued)
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| APPLICABLE SAFETY ANALYSES, LCO t and APPLICABILITY RPS Instrumentation B 3.3.1.1 The RPS is comprised of two independent trip systems (A and B), with two logic channels in each trip system (logic channels Al and A2, 81 and 82), as shown in Reference 1.The outputs of the logic channels in a trip system are combined in a one-out-of-two logic so either channel can trip the associated trip system.The tripping of both trip systems will produce a reactor scram.This logic arrangement is referred to as one-out-of-two taken twice logic.Each trip system can be reset by use of a reset switch.If a full scram occurs (both trip systems trip), a relay prevents reset of the trip systems for 10 seconds after the full scram signal is received.This 10 second delay on reset ensures that the scram function will be completed.
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| Two scram pilot valves are located in thehydrauliccontrol unit (HCU)for each control rod drive (eRO).Each scram pilot valve is solenoid operated, with the solenoids normally energized.
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| The scram pilot valves control the air supply to the scram inlet and outlet valves for the associated CRo.When either scram pilot valve solenoid is energized, air pressure holds the scram valves closed and, therefore, both scram pilot valve solenoids must be de-energized to cause a control rod to scram.The scram valves control the supply and discharge paths for the CRD water during a scram.One of the scram pilot valve solenoids for each CRD is controlled by trip system A, and the other solenoid is controlled by trip system B.Any trip of trip system A in conjunction with any trip in trip system B results in de-energizing both solenoids, air bleeding off, scram valves opening, and control rod scram.The backup scram valves, which energize on a scram signal to depressurize the scram air header, are also controlled by the RPS.Additionally, the RPS System controls the Sov vent and drain valves such that when both trip systems trip, the SOV vent and drain valves close to isolate the SOV.The actions of the RPS are assumed in the safety analyses of References 2, 3, and 4.The RPS initiates a reactor scram when monitored parameter values exceed the Allowable Values specified by the setpoint methodology and listed in Table 3.3.1.1-1 to preserve the integrity of the fuel cladding, the reactor coolant pressure boundary (RepS), and (continued)
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| GRAND GULF B 3.3-2 Revision No.0 Attachment 2 to GNRO-201 0-0001 0 Page 3 of 10 BASES BACKGROUND (continued)
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| APPLICABLE SAFETY ANALYSES, LCO t and APPLICABILITY RPS Instrumentation B 3.3.1.1 The RPS is comprised of two independent trip systems (A and B), with two logic channels in each trip system (logic channels Al and A2, 81 and 82), as shown in Reference 1.The outputs of the logic channels in a trip system are combined in a one-out-of-two logic so either channel can trip the associated trip system.The tripping of both trip systems will produce a reactor scram.This logic arrangement is referred to as one-out-of-two taken twice logic.Each trip system can be reset by use of a reset switch.If a full scram occurs (both trip systems trip), a relay prevents reset of the trip systems for 10 seconds after the full scram signal is received.This 10 second delay on reset ensures that the scram function will be completed.
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| Two scram pilot valves are located in thehydrauliccontrol unit (HCU)for each control rod drive (eRO).Each scram pilot valve is solenoid operated, with the solenoids normally energized.
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| The scram pilot valves control the air supply to the scram inlet and outlet valves for the associated CRo.When either scram pilot valve solenoid is energized, air pressure holds the scram valves closed and, therefore, both scram pilot valve solenoids must be de-energized to cause a control rod to scram.The scram valves control the supply and discharge paths for the CRD water during a scram.One of the scram pilot valve solenoids for each CRD is controlled by trip system A, and the other solenoid is controlled by trip system B.Any trip of trip system A in conjunction with any trip in trip system B results in de-energizing both solenoids, air bleeding off, scram valves opening, and control rod scram.The backup scram valves, which energize on a scram signal to depressurize the scram air header, are also controlled by the RPS.Additionally, the RPS System controls the Sov vent and drain valves such that when both trip systems trip, the SOV vent and drain valves close to isolate the SOV.The actions of the RPS are assumed in the safety analyses of References 2, 3, and 4.The RPS initiates a reactor scram when monitored parameter values exceed the Allowable Values specified by the setpoint methodology and listed in Table 3.3.1.1-1 to preserve the integrity of the fuel cladding, the reactor coolant pressure boundary (RepS), and (continued)
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| GRAND GULF B 3.3-2 Revision No.0 Attachment 2 to GNRO-201 0-0001 0 Page 3 of 10 BASES BACKGROUND (continued)
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| APPLICABLE SAFETY ANALYSES, LCO t and APPLICABILITY RPS Instrumentation B 3.3.1.1 The RPS is comprised of two independent trip systems (A and B), with two logic channels in each trip system (logic channels Al and A2, 81 and 82), as shown in Reference 1.The outputs of the logic channels in a trip system are combined in a one-out-of-two logic so either channel can trip the associated trip system.The tripping of both trip systems will produce a reactor scram.This logic arrangement is referred to as one-out-of-two taken twice logic.Each trip system can be reset by use of a reset switch.If a full scram occurs (both trip systems trip), a relay prevents reset of the trip systems for 10 seconds after the full scram signal is received.This 10 second delay on reset ensures that the scram function will be completed.
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| Two scram pilot valves are located in thehydrauliccontrol unit (HCU)for each control rod drive (eRO).Each scram pilot valve is solenoid operated, with the solenoids normally energized.
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| The scram pilot valves control the air supply to the scram inlet and outlet valves for the associated CRo.When either scram pilot valve solenoid is energized, air pressure holds the scram valves closed and, therefore, both scram pilot valve solenoids must be de-energized to cause a control rod to scram.The scram valves control the supply and discharge paths for the CRD water during a scram.One of the scram pilot valve solenoids for each CRD is controlled by trip system A, and the other solenoid is controlled by trip system B.Any trip of trip system A in conjunction with any trip in trip system B results in de-energizing both solenoids, air bleeding off, scram valves opening, and control rod scram.The backup scram valves, which energize on a scram signal to depressurize the scram air header, are also controlled by the RPS.Additionally, the RPS System controls the Sov vent and drain valves such that when both trip systems trip, the SOV vent and drain valves close to isolate the SOV.The actions of the RPS are assumed in the safety analyses of References 2, 3, and 4.The RPS initiates a reactor scram when monitored parameter values exceed the Allowable Values specified by the setpoint methodology and listed in Table 3.3.1.1-1 to preserve the integrity of the fuel cladding, the reactor coolant pressure boundary (RepS), and (continued)
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| GRAND GULF B 3.3-2 Revision No.0 Attachment 2 to GNRO-201 0-0001 0 Page 3 of 10 BASES BACKGROUND (continued)
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| APPLICABLE SAFETY ANALYSES, LCO t and APPLICABILITY RPS Instrumentation B 3.3.1.1 The RPS is comprised of two independent trip systems (A and B), with two logic channels in each trip system (logic channels Al and A2, 81 and 82), as shown in Reference 1.The outputs of the logic channels in a trip system are combined in a one-out-of-two logic so either channel can trip the associated trip system.The tripping of both trip systems will produce a reactor scram.This logic arrangement is referred to as one-out-of-two taken twice logic.Each trip system can be reset by use of a reset switch.If a full scram occurs (both trip systems trip), a relay prevents reset of the trip systems for 10 seconds after the full scram signal is received.This 10 second delay on reset ensures that the scram function will be completed.
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| Two scram pilot valves are located in thehydrauliccontrol unit (HCU)for each control rod drive (eRO).Each scram pilot valve is solenoid operated, with the solenoids normally energized.
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| The scram pilot valves control the air supply to the scram inlet and outlet valves for the associated CRo.When either scram pilot valve solenoid is energized, air pressure holds the scram valves closed and, therefore, both scram pilot valve solenoids must be de-energized to cause a control rod to scram.The scram valves control the supply and discharge paths for the CRD water during a scram.One of the scram pilot valve solenoids for each CRD is controlled by trip system A, and the other solenoid is controlled by trip system B.Any trip of trip system A in conjunction with any trip in trip system B results in de-energizing both solenoids, air bleeding off, scram valves opening, and control rod scram.The backup scram valves, which energize on a scram signal to depressurize the scram air header, are also controlled by the RPS.Additionally, the RPS System controls the Sov vent and drain valves such that when both trip systems trip, the SOV vent and drain valves close to isolate the SOV.The actions of the RPS are assumed in the safety analyses of References 2, 3, and 4.The RPS initiates a reactor scram when monitored parameter values exceed the Allowable Values specified by the setpoint methodology and listed in Table 3.3.1.1-1 to preserve the integrity of the fuel cladding, the reactor coolant pressure boundary (RepS), and (continued)
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| GRAND GULF B 3.3-2 Revision No.0 Attachment 2 to GNRO-201 0-0001 0 Page 4 of 10 INSERT 1 Application of TSTF-493.Rev.4 (Ref.17)to APRM Functions2.a.2.b.2.d, and 2.f 10 CFR 50.36(c)(1)(ii)(A)requires that Technical Specifications include LSSS for variables that have significant safety functions.
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| LSSS are defined by the regulation as"...settings for automatic protective devices...so chosen that automatic protective actions will correct the abnormal situation before a safety limit is exceeded." The Analytical Limit is the limit of the process variable at which a protective action is initiated, as established by the safety analysis, to ensure that a SL is not exceeded.Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded.However, in practice, the actual settings for automatic protective channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur.The trip setpoint is a predetermined setting for a protection channel chosen to ensure automatic actuation prior to the process variable reaching the Analytical Limit and thus ensuring that the SL would not be exceeded.As such, the trip setpoint accounts for uncertainties in setting the channel (e.g., calibration), uncertainties in how the channel might actually perform (e.g., repeatability), changes in the point of action of the channel over time (e.g., drift during surveillance intervals), and any other factors which may influence its actual performance (e.g., harsh accident environments).
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| In this manner, the trip setpoint ensures that SLs are not exceeded.Technical Specifications contain values related to the OPERABILITY of equipment required for safe operation of the facility.OPERABLE is defined in Technical Specifications as"...being capable of performing its specified safety function(s)." Relying solely on the trip setpoint to define OPERABILITY in Technical Specifications would be an overly restrictive requirement if it were applied as an OPERABILITY limit for the"as found" value of a protection channel setting during a Surveillance.
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| This would result in Technical Specification compliance problems, as well as reports and corrective actions required by the rule which are not necessary to ensure safety.For example, an automatic protection channel with a setting that has been found to be different from the trip setpoint due to some drift of the setting may still be OPERABLE because drift is to be expected.This expected drift would have been specifically accounted for in the setpoint methodology for calculating the trip setpoint and thus the automatic protective action would still have ensured that the SL would not be exceeded with the"as found" setting of the protection channel.Therefore, the channel would still be OPERABLE because it would have performed its safety function and the only corrective action required would be to reset the channel within the established as-left tolerance around the trip setpoint to account for further drift during the next surveillance interval.Note that, although the channel is OPERABLE under these circumstances, the trip setpoint must be left adjusted to a value within the as-left tolerance, in accordance with uncertainty assumptions stated in the referenced setpoint methodology (as-left criteria), and confirmed to be operating within the statistical allowances of the uncertainty terms assigned (as-found criteria).
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| Attachment 2 to GNRO-201 0-0001 0 Page 4 of 10 INSERT 1 Application of TSTF-493.Rev.4 (Ref.17)to APRM Functions2.a.2.b.2.d, and 2.f 10 CFR 50.36(c)(1)(ii)(A)requires that Technical Specifications include LSSS for variables that have significant safety functions.
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| LSSS are defined by the regulation as"...settings for automatic protective devices...so chosen that automatic protective actions will correct the abnormal situation before a safety limit is exceeded." The Analytical Limit is the limit of the process variable at which a protective action is initiated, as established by the safety analysis, to ensure that a SL is not exceeded.Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded.However, in practice, the actual settings for automatic protective channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur.The trip setpoint is a predetermined setting for a protection channel chosen to ensure automatic actuation prior to the process variable reaching the Analytical Limit and thus ensuring that the SL would not be exceeded.As such, the trip setpoint accounts for uncertainties in setting the channel (e.g., calibration), uncertainties in how the channel might actually perform (e.g., repeatability), changes in the point of action of the channel over time (e.g., drift during surveillance intervals), and any other factors which may influence its actual performance (e.g., harsh accident environments).
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| In this manner, the trip setpoint ensures that SLs are not exceeded.Technical Specifications contain values related to the OPERABILITY of equipment required for safe operation of the facility.OPERABLE is defined in Technical Specifications as"...being capable of performing its specified safety function(s)." Relying solely on the trip setpoint to define OPERABILITY in Technical Specifications would be an overly restrictive requirement if it were applied as an OPERABILITY limit for the"as found" value of a protection channel setting during a Surveillance.
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| This would result in Technical Specification compliance problems, as well as reports and corrective actions required by the rule which are not necessary to ensure safety.For example, an automatic protection channel with a setting that has been found to be different from the trip setpoint due to some drift of the setting may still be OPERABLE because drift is to be expected.This expected drift would have been specifically accounted for in the setpoint methodology for calculating the trip setpoint and thus the automatic protective action would still have ensured that the SL would not be exceeded with the"as found" setting of the protection channel.Therefore, the channel would still be OPERABLE because it would have performed its safety function and the only corrective action required would be to reset the channel within the established as-left tolerance around the trip setpoint to account for further drift during the next surveillance interval.Note that, although the channel is OPERABLE under these circumstances, the trip setpoint must be left adjusted to a value within the as-left tolerance, in accordance with uncertainty assumptions stated in the referenced setpoint methodology (as-left criteria), and confirmed to be operating within the statistical allowances of the uncertainty terms assigned (as-found criteria).
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| Attachment 2 to GNRO-201 0-0001 0 Page 4 of 10 INSERT 1 Application of TSTF-493.Rev.4 (Ref.17)to APRM Functions2.a.2.b.2.d, and 2.f 10 CFR 50.36(c)(1)(ii)(A)requires that Technical Specifications include LSSS for variables that have significant safety functions.
| |
| LSSS are defined by the regulation as"...settings for automatic protective devices...so chosen that automatic protective actions will correct the abnormal situation before a safety limit is exceeded." The Analytical Limit is the limit of the process variable at which a protective action is initiated, as established by the safety analysis, to ensure that a SL is not exceeded.Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded.However, in practice, the actual settings for automatic protective channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur.The trip setpoint is a predetermined setting for a protection channel chosen to ensure automatic actuation prior to the process variable reaching the Analytical Limit and thus ensuring that the SL would not be exceeded.As such, the trip setpoint accounts for uncertainties in setting the channel (e.g., calibration), uncertainties in how the channel might actually perform (e.g., repeatability), changes in the point of action of the channel over time (e.g., drift during surveillance intervals), and any other factors which may influence its actual performance (e.g., harsh accident environments).
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| In this manner, the trip setpoint ensures that SLs are not exceeded.Technical Specifications contain values related to the OPERABILITY of equipment required for safe operation of the facility.OPERABLE is defined in Technical Specifications as"...being capable of performing its specified safety function(s)." Relying solely on the trip setpoint to define OPERABILITY in Technical Specifications would be an overly restrictive requirement if it were applied as an OPERABILITY limit for the"as found" value of a protection channel setting during a Surveillance.
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| This would result in Technical Specification compliance problems, as well as reports and corrective actions required by the rule which are not necessary to ensure safety.For example, an automatic protection channel with a setting that has been found to be different from the trip setpoint due to some drift of the setting may still be OPERABLE because drift is to be expected.This expected drift would have been specifically accounted for in the setpoint methodology for calculating the trip setpoint and thus the automatic protective action would still have ensured that the SL would not be exceeded with the"as found" setting of the protection channel.Therefore, the channel would still be OPERABLE because it would have performed its safety function and the only corrective action required would be to reset the channel within the established as-left tolerance around the trip setpoint to account for further drift during the next surveillance interval.Note that, although the channel is OPERABLE under these circumstances, the trip setpoint must be left adjusted to a value within the as-left tolerance, in accordance with uncertainty assumptions stated in the referenced setpoint methodology (as-left criteria), and confirmed to be operating within the statistical allowances of the uncertainty terms assigned (as-found criteria).
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| Attachment 2 to GNRO-201 0-0001 0 Page 4 of 10 INSERT 1 Application of TSTF-493.Rev.4 (Ref.17)to APRM Functions2.a.2.b.2.d, and 2.f 10 CFR 50.36(c)(1)(ii)(A)requires that Technical Specifications include LSSS for variables that have significant safety functions.
| |
| LSSS are defined by the regulation as"...settings for automatic protective devices...so chosen that automatic protective actions will correct the abnormal situation before a safety limit is exceeded." The Analytical Limit is the limit of the process variable at which a protective action is initiated, as established by the safety analysis, to ensure that a SL is not exceeded.Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded.However, in practice, the actual settings for automatic protective channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur.The trip setpoint is a predetermined setting for a protection channel chosen to ensure automatic actuation prior to the process variable reaching the Analytical Limit and thus ensuring that the SL would not be exceeded.As such, the trip setpoint accounts for uncertainties in setting the channel (e.g., calibration), uncertainties in how the channel might actually perform (e.g., repeatability), changes in the point of action of the channel over time (e.g., drift during surveillance intervals), and any other factors which may influence its actual performance (e.g., harsh accident environments).
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| In this manner, the trip setpoint ensures that SLs are not exceeded.Technical Specifications contain values related to the OPERABILITY of equipment required for safe operation of the facility.OPERABLE is defined in Technical Specifications as"...being capable of performing its specified safety function(s)." Relying solely on the trip setpoint to define OPERABILITY in Technical Specifications would be an overly restrictive requirement if it were applied as an OPERABILITY limit for the"as found" value of a protection channel setting during a Surveillance.
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| This would result in Technical Specification compliance problems, as well as reports and corrective actions required by the rule which are not necessary to ensure safety.For example, an automatic protection channel with a setting that has been found to be different from the trip setpoint due to some drift of the setting may still be OPERABLE because drift is to be expected.This expected drift would have been specifically accounted for in the setpoint methodology for calculating the trip setpoint and thus the automatic protective action would still have ensured that the SL would not be exceeded with the"as found" setting of the protection channel.Therefore, the channel would still be OPERABLE because it would have performed its safety function and the only corrective action required would be to reset the channel within the established as-left tolerance around the trip setpoint to account for further drift during the next surveillance interval.Note that, although the channel is OPERABLE under these circumstances, the trip setpoint must be left adjusted to a value within the as-left tolerance, in accordance with uncertainty assumptions stated in the referenced setpoint methodology (as-left criteria), and confirmed to be operating within the statistical allowances of the uncertainty terms assigned (as-found criteria).
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| Attachment 2 to GNRO-201 0-0001 0 Page 5 of 10 However, there is also some point beyond which the channel may not be able to perform its function due to, for example, greater than expected drift.This value needs to be specified in the Technical Specifications in order to define OPERABILITY of the channels and is designated as the Allowable Value.If the actual setting (as-found setpoint)of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance, the channel is OPERABLE but degraded.The degraded condition will be further evaluated during performance of the SR.This evaluation will consist of resetting the channel setpoint to the trip setpoint (within the allowed tolerance), and evaluating the channel response.If the channel is functioning as required and expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance.
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| After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.
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| Attachment 2 to GNRO-201 0-0001 0 Page 5 of 10 However, there is also some point beyond which the channel may not be able to perform its function due to, for example, greater than expected drift.This value needs to be specified in the Technical Specifications in order to define OPERABILITY of the channels and is designated as the Allowable Value.If the actual setting (as-found setpoint)of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance, the channel is OPERABLE but degraded.The degraded condition will be further evaluated during performance of the SR.This evaluation will consist of resetting the channel setpoint to the trip setpoint (within the allowed tolerance), and evaluating the channel response.If the channel is functioning as required and expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance.
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| After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.
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| Attachment 2 to GNRO-201 0-0001 0 Page 5 of 10 However, there is also some point beyond which the channel may not be able to perform its function due to, for example, greater than expected drift.This value needs to be specified in the Technical Specifications in order to define OPERABILITY of the channels and is designated as the Allowable Value.If the actual setting (as-found setpoint)of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance, the channel is OPERABLE but degraded.The degraded condition will be further evaluated during performance of the SR.This evaluation will consist of resetting the channel setpoint to the trip setpoint (within the allowed tolerance), and evaluating the channel response.If the channel is functioning as required and expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance.
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| After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.
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| Attachment 2 to GNRO-201 0-0001 0 Page 5 of 10 However, there is also some point beyond which the channel may not be able to perform its function due to, for example, greater than expected drift.This value needs to be specified in the Technical Specifications in order to define OPERABILITY of the channels and is designated as the Allowable Value.If the actual setting (as-found setpoint)of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance, the channel is OPERABLE but degraded.The degraded condition will be further evaluated during performance of the SR.This evaluation will consist of resetting the channel setpoint to the trip setpoint (within the allowed tolerance), and evaluating the channel response.If the channel is functioning as required and expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance.
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| After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.
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| Attachment 2 to GNRO-201 0-0001 0 Page 6 of 10 BASES RPS Instrumentation B 3.3.1.1 The OPERABILITY of scram pilot valves and associated solenoids, backup scram valves, and SOV valves, described in the Background section, are not addressed by this LCO.APPLICABLE environment errors (for channels that must function in fiarsh SAFETY ANALYSES, environments as defined by 10 CFR 50.49)are accounted for.LCO, and APPLICABILITY
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| {continued}
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| The individual Functions are required to be OPERABLE in the MODES specified in the Table that may require an RPS trip to mitigate the consequences of a design basis accident or transient.
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| To ensure a reliable scram function, a combination of Functions is required in each MODE to provide primary and diverse initiation signals.RPS is required to be OPERABLE in MODE 5 with any, control rod withdrawn from a core cell containing one or more fuel assemblies.
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| Control rods withdrawn from a core cell containing no fuel assemblies do not affect the reactivity of the core and therefore are not required to have the capability to scram.Provided all other control rods remain inserted, the RPS function is not required.In this condition, the required SCM (LCO 3.1.1,"SHUTDOWN MARGIN (SOM)")and refuel position one-rod-out interlock (lCO 3.9.2,"Refuel Position One-Rod-Out Interlock")
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| ensure that no event requiring RPS will occur.During normal operation in MODES 3 and 4, all control rods are fully inserted and the Reactor Mode Switch-Shutdown Position control rod withdrawal block (LCO 3.3.2.1,"Control Rod Block Instrumentation")
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| does not allow any control rod to be withdrawn.
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| Under these conditions, the RPS function;s not required to be OPERABLE.The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.l.a.Intermediate Range Monitor fIRM)Neutron Flux--High The IRMs monitor neutron flux levels from the upper range of the source range monitors (SRMs)to the lower range of the average power range monitors (APRMs).The IRMs are capable of generating trip signals that can be used to prevent fuel damage resulting from abnormal operating transients in the intermediate power range.In this power range, the most significant source of reactivity change is due to control (continued)
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| GRAND GULF B 3.3-4 Revision No.0 Attachment 2 to GNRO-201 0-0001 0 Page 6 of 10 BASES RPS Instrumentation B 3.3.1.1 The OPERABILITY of scram pilot valves and associated solenoids, backup scram valves, and SOV valves, described in the Background section, are not addressed by this LCO.APPLICABLE environment errors (for channels that must function in fiarsh SAFETY ANALYSES, environments as defined by 10 CFR 50.49)are accounted for.LCO, and APPLICABILITY
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| {continued}
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| The individual Functions are required to be OPERABLE in the MODES specified in the Table that may require an RPS trip to mitigate the consequences of a design basis accident or transient.
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| To ensure a reliable scram function, a combination of Functions is required in each MODE to provide primary and diverse initiation signals.RPS is required to be OPERABLE in MODE 5 with any, control rod withdrawn from a core cell containing one or more fuel assemblies.
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| Control rods withdrawn from a core cell containing no fuel assemblies do not affect the reactivity of the core and therefore are not required to have the capability to scram.Provided all other control rods remain inserted, the RPS function is not required.In this condition, the required SCM (LCO 3.1.1,"SHUTDOWN MARGIN (SOM)")and refuel position one-rod-out interlock (lCO 3.9.2,"Refuel Position One-Rod-Out Interlock")
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| ensure that no event requiring RPS will occur.During normal operation in MODES 3 and 4, all control rods are fully inserted and the Reactor Mode Switch-Shutdown Position control rod withdrawal block (LCO 3.3.2.1,"Control Rod Block Instrumentation")
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| does not allow any control rod to be withdrawn.
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| Under these conditions, the RPS function;s not required to be OPERABLE.The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.l.a.Intermediate Range Monitor fIRM)Neutron Flux--High The IRMs monitor neutron flux levels from the upper range of the source range monitors (SRMs)to the lower range of the average power range monitors (APRMs).The IRMs are capable of generating trip signals that can be used to prevent fuel damage resulting from abnormal operating transients in the intermediate power range.In this power range, the most significant source of reactivity change is due to control (continued)
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| GRAND GULF B 3.3-4 Revision No.0 Attachment 2 to GNRO-201 0-0001 0 Page 6 of 10 BASES RPS Instrumentation B 3.3.1.1 The OPERABILITY of scram pilot valves and associated solenoids, backup scram valves, and SOV valves, described in the Background section, are not addressed by this LCO.APPLICABLE environment errors (for channels that must function in fiarsh SAFETY ANALYSES, environments as defined by 10 CFR 50.49)are accounted for.LCO, and APPLICABILITY
| |
| {continued}
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| The individual Functions are required to be OPERABLE in the MODES specified in the Table that may require an RPS trip to mitigate the consequences of a design basis accident or transient.
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| To ensure a reliable scram function, a combination of Functions is required in each MODE to provide primary and diverse initiation signals.RPS is required to be OPERABLE in MODE 5 with any, control rod withdrawn from a core cell containing one or more fuel assemblies.
| |
| Control rods withdrawn from a core cell containing no fuel assemblies do not affect the reactivity of the core and therefore are not required to have the capability to scram.Provided all other control rods remain inserted, the RPS function is not required.In this condition, the required SCM (LCO 3.1.1,"SHUTDOWN MARGIN (SOM)")and refuel position one-rod-out interlock (lCO 3.9.2,"Refuel Position One-Rod-Out Interlock")
| |
| ensure that no event requiring RPS will occur.During normal operation in MODES 3 and 4, all control rods are fully inserted and the Reactor Mode Switch-Shutdown Position control rod withdrawal block (LCO 3.3.2.1,"Control Rod Block Instrumentation")
| |
| does not allow any control rod to be withdrawn.
| |
| Under these conditions, the RPS function;s not required to be OPERABLE.The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.l.a.Intermediate Range Monitor fIRM)Neutron Flux--High The IRMs monitor neutron flux levels from the upper range of the source range monitors (SRMs)to the lower range of the average power range monitors (APRMs).The IRMs are capable of generating trip signals that can be used to prevent fuel damage resulting from abnormal operating transients in the intermediate power range.In this power range, the most significant source of reactivity change is due to control (continued)
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| GRAND GULF B 3.3-4 Revision No.0 Attachment 2 to GNRO-201 0-0001 0 Page 6 of 10 BASES RPS Instrumentation B 3.3.1.1 The OPERABILITY of scram pilot valves and associated solenoids, backup scram valves, and SOV valves, described in the Background section, are not addressed by this LCO.APPLICABLE environment errors (for channels that must function in fiarsh SAFETY ANALYSES, environments as defined by 10 CFR 50.49)are accounted for.LCO, and APPLICABILITY
| |
| {continued}
| |
| The individual Functions are required to be OPERABLE in the MODES specified in the Table that may require an RPS trip to mitigate the consequences of a design basis accident or transient.
| |
| To ensure a reliable scram function, a combination of Functions is required in each MODE to provide primary and diverse initiation signals.RPS is required to be OPERABLE in MODE 5 with any, control rod withdrawn from a core cell containing one or more fuel assemblies.
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| Control rods withdrawn from a core cell containing no fuel assemblies do not affect the reactivity of the core and therefore are not required to have the capability to scram.Provided all other control rods remain inserted, the RPS function is not required.In this condition, the required SCM (LCO 3.1.1,"SHUTDOWN MARGIN (SOM)")and refuel position one-rod-out interlock (lCO 3.9.2,"Refuel Position One-Rod-Out Interlock")
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| ensure that no event requiring RPS will occur.During normal operation in MODES 3 and 4, all control rods are fully inserted and the Reactor Mode Switch-Shutdown Position control rod withdrawal block (LCO 3.3.2.1,"Control Rod Block Instrumentation")
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| does not allow any control rod to be withdrawn.
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| Under these conditions, the RPS function;s not required to be OPERABLE.The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.l.a.Intermediate Range Monitor fIRM)Neutron Flux--High The IRMs monitor neutron flux levels from the upper range of the source range monitors (SRMs)to the lower range of the average power range monitors (APRMs).The IRMs are capable of generating trip signals that can be used to prevent fuel damage resulting from abnormal operating transients in the intermediate power range.In this power range, the most significant source of reactivity change is due to control (continued)
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| GRAND GULF B 3.3-4 Revision No.0 Attachment 2 to GNRO-201 0-0001 0 Page 7 of 10 INSERT 2 Application of TSTF-493, Rev.4 (Ref.17)to APRM Functions2.a,2.b, 2.d, and 2.f Permissive and interlock setpoints allow the blocking of trips during plant startups, and restoration of trips when the permissive conditions are not satisfied, but they are not explicitly modeled in the Safety Analyses.These permissives and interlocks ensure that the starting conditions are consistent with the safety analysis, before preventive or mitigating actions occur.Because these permissives or interlocks are only one of multiple conservative starting assumptions for the accident analysis, they are generally considered as nominal values without regard to measurement accuracy.Allowable Values for RPS Instrumentation Functions are specified for each RPS Function specified in Table 3.3.1.1-1.
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| Trip setpoints and the methodologies for calculating the as-left and as-found tolerances are described in the Technical Requirements Manual.The nominal setpoints are selected to ensure that the actual setpoints remain conservative with respect to the as-found tolerance between successive CHANNEL CALIBRATIONS.
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| After each calibration, the trip setpoint shall be left within the as-left band around the setpoint.Attachment 2 to GNRO-201 0-0001 0 Page 7 of 10 INSERT 2 Application of TSTF-493, Rev.4 (Ref.17)to APRM Functions2.a,2.b, 2.d, and 2.f Permissive and interlock setpoints allow the blocking of trips during plant startups, and restoration of trips when the permissive conditions are not satisfied, but they are not explicitly modeled in the Safety Analyses.These permissives and interlocks ensure that the starting conditions are consistent with the safety analysis, before preventive or mitigating actions occur.Because these permissives or interlocks are only one of multiple conservative starting assumptions for the accident analysis, they are generally considered as nominal values without regard to measurement accuracy.Allowable Values for RPS Instrumentation Functions are specified for each RPS Function specified in Table 3.3.1.1-1.
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| Trip setpoints and the methodologies for calculating the as-left and as-found tolerances are described in the Technical Requirements Manual.The nominal setpoints are selected to ensure that the actual setpoints remain conservative with respect to the as-found tolerance between successive CHANNEL CALIBRATIONS.
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| After each calibration, the trip setpoint shall be left within the as-left band around the setpoint.Attachment 2 to GNRO-201 0-0001 0 Page 7 of 10 INSERT 2 Application of TSTF-493, Rev.4 (Ref.17)to APRM Functions2.a,2.b, 2.d, and 2.f Permissive and interlock setpoints allow the blocking of trips during plant startups, and restoration of trips when the permissive conditions are not satisfied, but they are not explicitly modeled in the Safety Analyses.These permissives and interlocks ensure that the starting conditions are consistent with the safety analysis, before preventive or mitigating actions occur.Because these permissives or interlocks are only one of multiple conservative starting assumptions for the accident analysis, they are generally considered as nominal values without regard to measurement accuracy.Allowable Values for RPS Instrumentation Functions are specified for each RPS Function specified in Table 3.3.1.1-1.
| |
| Trip setpoints and the methodologies for calculating the as-left and as-found tolerances are described in the Technical Requirements Manual.The nominal setpoints are selected to ensure that the actual setpoints remain conservative with respect to the as-found tolerance between successive CHANNEL CALIBRATIONS.
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| After each calibration, the trip setpoint shall be left within the as-left band around the setpoint.Attachment 2 to GNRO-201 0-0001 0 Page 7 of 10 INSERT 2 Application of TSTF-493, Rev.4 (Ref.17)to APRM Functions2.a,2.b, 2.d, and 2.f Permissive and interlock setpoints allow the blocking of trips during plant startups, and restoration of trips when the permissive conditions are not satisfied, but they are not explicitly modeled in the Safety Analyses.These permissives and interlocks ensure that the starting conditions are consistent with the safety analysis, before preventive or mitigating actions occur.Because these permissives or interlocks are only one of multiple conservative starting assumptions for the accident analysis, they are generally considered as nominal values without regard to measurement accuracy.Allowable Values for RPS Instrumentation Functions are specified for each RPS Function specified in Table 3.3.1.1-1.
| |
| Trip setpoints and the methodologies for calculating the as-left and as-found tolerances are described in the Technical Requirements Manual.The nominal setpoints are selected to ensure that the actual setpoints remain conservative with respect to the as-found tolerance between successive CHANNEL CALIBRATIONS.
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| After each calibration, the trip setpoint shall be left within the as-left band around the setpoint.
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| Attachment 2 to GNRO-201 0-0001 0 Page 8 of 10 (b)GGNS OPERATING LICENSE SERI is required to notify the NRC in writing prior to any change in (i)the terms or conditions of any new or existing sale or lease agreements executed as part of the above authorized financial transactions, (ii)the GGNS Unit 1 operating agreement, (iii)the existing property insurance coverage for GGNS Unit 1 that would materially alter the representations and conditions set forth in the Staff's Safety Evaluation Report dated December 19, 1988 attached to Amendment No.54.In addition, SERI is required to notify the NRC of any action by a lessor or other successor in interest to SERI that may have an effect on the operation of the facility.C.The license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect;and is subject to the additional conditions specified or incorporated below: (1)Maximum Power Level Entergy Operations, Inc.is authorized to operate the facility at reactor core power levels not in excess of 3898 megawatts thermal (100 percent power)in accordance with the conditions specified herein.(2)Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix a, as revised through Amendment No.183 are hereby incorporated into this license.Entergy Operations, Inc.shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.)TaB for Diesel GQRSrater Id eORtaiRea ift tfte Technical Specifications aae listed selow, are ROt: re'1t1ired to be peLfoLliled immBeiat:ely HpOR implemeftto6tion of Amendment Uo.l.2.1.TaQ iRs listed se10',J shall ee delttonstLatedtao ROKt SR 3.8.1.9, SR 3.8.1.1Q, afta SR 3.8.1.14 Amendment No.11t'j-4 Attachment 2 to GNRO-201 0-0001 0 Page 8 of 10 (b)GGNS OPERATING LICENSE SERI is required to notify the NRC in writing prior to any change in (i)the terms or conditions of any new or existing sale or lease agreements executed as part of the above authorized financial transactions, (ii)the GGNS Unit 1 operating agreement, (iii)the existing property insurance coverage for GGNS Unit 1 that would materially alter the representations and conditions set forth in the Staff's Safety Evaluation Report dated December 19, 1988 attached to Amendment No.54.In addition, SERI is required to notify the NRC of any action by a lessor or other successor in interest to SERI that may have an effect on the operation of the facility.C.The license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect;and is subject to the additional conditions specified or incorporated below: (1)Maximum Power Level Entergy Operations, Inc.is authorized to operate the facility at reactor core power levels not in excess of 3898 megawatts thermal (100 percent power)in accordance with the conditions specified herein.(2)Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix a, as revised through Amendment No.183 are hereby incorporated into this license.Entergy Operations, Inc.shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.)TaB for Diesel GQRSrater Id eORtaiRea ift tfte Technical Specifications aae listed selow, are ROt: re'1t1ired to be peLfoLliled immBeiat:ely HpOR implemeftto6tion of Amendment Uo.l.2.1.TaQ iRs listed se10',J shall ee delttonstLatedtao ROKt SR 3.8.1.9, SR 3.8.1.1Q, afta SR 3.8.1.14 Amendment No.11t'j-4 Attachment 2 to GNRO-201 0-0001 0 Page 8 of 10 (b)GGNS OPERATING LICENSE SERI is required to notify the NRC in writing prior to any change in (i)the terms or conditions of any new or existing sale or lease agreements executed as part of the above authorized financial transactions, (ii)the GGNS Unit 1 operating agreement, (iii)the existing property insurance coverage for GGNS Unit 1 that would materially alter the representations and conditions set forth in the Staff's Safety Evaluation Report dated December 19, 1988 attached to Amendment No.54.In addition, SERI is required to notify the NRC of any action by a lessor or other successor in interest to SERI that may have an effect on the operation of the facility.C.The license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect;and is subject to the additional conditions specified or incorporated below: (1)Maximum Power Level Entergy Operations, Inc.is authorized to operate the facility at reactor core power levels not in excess of 3898 megawatts thermal (100 percent power)in accordance with the conditions specified herein.(2)Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix a, as revised through Amendment No.183 are hereby incorporated into this license.Entergy Operations, Inc.shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.)TaB for Diesel GQRSrater Id eORtaiRea ift tfte Technical Specifications aae listed selow, are ROt: re'1t1ired to be peLfoLliled immBeiat:ely HpOR implemeftto6tion of Amendment Uo.l.2.1.TaQ iRs listed se10',J shall ee delttonstLatedtao ROKt SR 3.8.1.9, SR 3.8.1.1Q, afta SR 3.8.1.14 Amendment No.11t'j-4 Attachment 2 to GNRO-201 0-0001 0 Page 8 of 10 (b)GGNS OPERATING LICENSE SERI is required to notify the NRC in writing prior to any change in (i)the terms or conditions of any new or existing sale or lease agreements executed as part of the above authorized financial transactions, (ii)the GGNS Unit 1 operating agreement, (iii)the existing property insurance coverage for GGNS Unit 1 that would materially alter the representations and conditions set forth in the Staff's Safety Evaluation Report dated December 19, 1988 attached to Amendment No.54.In addition, SERI is required to notify the NRC of any action by a lessor or other successor in interest to SERI that may have an effect on the operation of the facility.C.The license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect;and is subject to the additional conditions specified or incorporated below: (1)Maximum Power Level Entergy Operations, Inc.is authorized to operate the facility at reactor core power levels not in excess of 3898 megawatts thermal (100 percent power)in accordance with the conditions specified herein.(2)Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix a, as revised through Amendment No.183 are hereby incorporated into this license.Entergy Operations, Inc.shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.)TaB for Diesel GQRSrater Id eORtaiRea ift tfte Technical Specifications aae listed selow, are ROt: re'1t1ired to be peLfoLliled immBeiat:ely HpOR implemeftto6tion of Amendment Uo.l.2.1.TaQ iRs listed se10',J shall ee delttonstLatedtao ROKt SR 3.8.1.9, SR 3.8.1.1Q, afta SR 3.8.1.14 Amendment No.11t'j-4 Attachment 2 to GNRO-201 0-0001 0 Page 9 of 10 INSERTA-Exception During Cycle 19, GGNS will conduct monitoring of the Oscillation Power Range Monitor (OPRM).During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) will be disabled and operated in an'indicate only'mode and technical specification requirements will not apply to this function.During such time, BackupStabilityProtection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations.
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| Once monitoring has been successfully completed, the OPRM Upscale function will be enabled and technical specification requirements will be applied to the function;no further operating with this function in an"indicate only" mode will be conducted.
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| Attachment 2 to GNRO-201 0-0001 0 Page 9 of 10 INSERTA-Exception During Cycle 19, GGNS will conduct monitoring of the Oscillation Power Range Monitor (OPRM).During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) will be disabled and operated in an'indicate only'mode and technical specification requirements will not apply to this function.During such time, BackupStabilityProtection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations.
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| Once monitoring has been successfully completed, the OPRM Upscale function will be enabled and technical specification requirements will be applied to the function;no further operating with this function in an"indicate only" mode will be conducted.
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| Attachment 2 to GNRO-201 0-0001 0 Page 9 of 10 INSERTA-Exception During Cycle 19, GGNS will conduct monitoring of the Oscillation Power Range Monitor (OPRM).During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) will be disabled and operated in an'indicate only'mode and technical specification requirements will not apply to this function.During such time, BackupStabilityProtection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations.
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| Once monitoring has been successfully completed, the OPRM Upscale function will be enabled and technical specification requirements will be applied to the function;no further operating with this function in an"indicate only" mode will be conducted.
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| Attachment 2 to GNRO-201 0-0001 0 Page 9 of 10 INSERTA-Exception During Cycle 19, GGNS will conduct monitoring of the Oscillation Power Range Monitor (OPRM).During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) will be disabled and operated in an'indicate only'mode and technical specification requirements will not apply to this function.During such time, BackupStabilityProtection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations.
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| Once monitoring has been successfully completed, the OPRM Upscale function will be enabled and technical specification requirements will be applied to the function;no further operating with this function in an"indicate only" mode will be conducted.
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| Attachment 2 to GNRO-201 0-0001 0 Page 10 of 10 RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 (page 1 of 3)Reactor Protection System Instrumentation FUNCTI ON APPLICABLE MODES OR OTHER SPECIFIED COND ITI ONS REQUIRED CHANNELS PER TRIP SYSTEM CONDIT IONS REFERENCED FROM REQUIRED ACTION 0.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 1.Intermediate Range Monitors SR 3.3.1.1.1:s;122/125 SR 3.3.1.1.3 divisions of SR 3.3.1.1.12 full scale SR 3.3.1.1.13 SR 3.3.1.1.1:s;122/125 SR 3.3.1.1.4 divisions of SR 3.3.1.1.12 full scale SR 3.3.1.1.13 SR 3.3.1.1.3 NA SR 3.3.1.1.13 SR 3.3.1.1.4 NA SR 3.3.1.1.13 SRSR SR SR 3.3.1.1.1 SR 3.3.1.1.2 SR 3.3.1.1.7 SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.13 SR 3.3.1.1.15 SR 3.3.1.1.16 SR 3.3.1.1.17 SR 3.3.1.1.18 H G 3 3 1,2 5 (a)3 2 c.Inop b.Fixed Flux-High d.Flow Biased Simulated Therma 1 Power-Hi gh a.Neutron Flux-High b.Inop 2 3 H 5 (a)2.Average Power Range Monitors a.Neutron Fl ux-Hi gh , 2 Setdown (continued)(a)With any control rod withdrawn from a core cell containing one or more fuel assemblies.(b)All0**al:Jle Vallics sl'eeifieEi il'l tAC COLR.Al1o'hasle Vall:fe A1sEiifieatiol'l I"CEll:f;pcEi 8)tRe (QlP: Ellie to reEil:lctioAS iA fceEihatcr teA1I'Cratl:lre ffia)Be EielayeEi fop l:ll'to 12 GRAND GULF 3.3-6 Amendment No.+4+/-, 169 Attachment 2 to GNRO-201 0-0001 0 Page 10 of 10 RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 (page 1 of 3)Reactor Protection System Instrumentation FUNCTI ON APPLICABLE MODES OR OTHER SPECIFIED COND ITI ONS REQUIRED CHANNELS PER TRIP SYSTEM CONDIT IONS REFERENCED FROM REQUIRED ACTION 0.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 1.Intermediate Range Monitors SR 3.3.1.1.1:s;122/125 SR 3.3.1.1.3 divisions of SR 3.3.1.1.12 full scale SR 3.3.1.1.13 SR 3.3.1.1.1:s;122/125 SR 3.3.1.1.4 divisions of SR 3.3.1.1.12 full scale SR 3.3.1.1.13 SR 3.3.1.1.3 NA SR 3.3.1.1.13 SR 3.3.1.1.4 NA SR 3.3.1.1.13 SRSR SR SR 3.3.1.1.1 SR 3.3.1.1.2 SR 3.3.1.1.7 SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.13 SR 3.3.1.1.15 SR 3.3.1.1.16 SR 3.3.1.1.17 SR 3.3.1.1.18 H G 3 3 1,2 5 (a)3 2 c.Inop b.Fixed Flux-High d.Flow Biased Simulated Therma 1 Power-Hi gh a.Neutron Flux-High b.Inop 2 3 H 5 (a)2.Average Power Range Monitors a.Neutron Fl ux-Hi gh , 2 Setdown (continued)(a)With any control rod withdrawn from a core cell containing one or more fuel assemblies.(b)All0**al:Jle Vallics sl'eeifieEi il'l tAC COLR.Al1o'hasle Vall:fe A1sEiifieatiol'l I"CEll:f;pcEi 8)tRe (QlP: Ellie to reEil:lctioAS iA fceEihatcr teA1I'Cratl:lre ffia)Be EielayeEi fop l:ll'to 12 GRAND GULF 3.3-6 Amendment No.+4+/-, 169 Attachment 2 to GNRO-201 0-0001 0 Page 10 of 10 RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 (page 1 of 3)Reactor Protection System Instrumentation FUNCTI ON APPLICABLE MODES OR OTHER SPECIFIED COND ITI ONS REQUIRED CHANNELS PER TRIP SYSTEM CONDIT IONS REFERENCED FROM REQUIRED ACTION 0.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 1.Intermediate Range Monitors SR 3.3.1.1.1:s;122/125 SR 3.3.1.1.3 divisions of SR 3.3.1.1.12 full scale SR 3.3.1.1.13 SR 3.3.1.1.1:s;122/125 SR 3.3.1.1.4 divisions of SR 3.3.1.1.12 full scale SR 3.3.1.1.13 SR 3.3.1.1.3 NA SR 3.3.1.1.13 SR 3.3.1.1.4 NA SR 3.3.1.1.13 SRSR SR SR 3.3.1.1.1 SR 3.3.1.1.2 SR 3.3.1.1.7 SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.13 SR 3.3.1.1.15 SR 3.3.1.1.16 SR 3.3.1.1.17 SR 3.3.1.1.18 H G 3 3 1,2 5 (a)3 2 c.Inop b.Fixed Flux-High d.Flow Biased Simulated Therma 1 Power-Hi gh a.Neutron Flux-High b.Inop 2 3 H 5 (a)2.Average Power Range Monitors a.Neutron Fl ux-Hi gh , 2 Setdown (continued)(a)With any control rod withdrawn from a core cell containing one or more fuel assemblies.(b)All0**al:Jle Vallics sl'eeifieEi il'l tAC COLR.Al1o'hasle Vall:fe A1sEiifieatiol'l I"CEll:f;pcEi 8)tRe (QlP: Ellie to reEil:lctioAS iA fceEihatcr teA1I'Cratl:lre ffia)Be EielayeEi fop l:ll'to 12 GRAND GULF 3.3-6 Amendment No.+4+/-, 169 Attachment 2 to GNRO-201 0-0001 0 Page 10 of 10 RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 (page 1 of 3)Reactor Protection System Instrumentation FUNCTI ON APPLICABLE MODES OR OTHER SPECIFIED COND ITI ONS REQUIRED CHANNELS PER TRIP SYSTEM CONDIT IONS REFERENCED FROM REQUIRED ACTION 0.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 1.Intermediate Range Monitors SR 3.3.1.1.1:s;122/125 SR 3.3.1.1.3 divisions of SR 3.3.1.1.12 full scale SR 3.3.1.1.13 SR 3.3.1.1.1:s;122/125 SR 3.3.1.1.4 divisions of SR 3.3.1.1.12 full scale SR 3.3.1.1.13 SR 3.3.1.1.3 NA SR 3.3.1.1.13 SR 3.3.1.1.4 NA SR 3.3.1.1.13 SRSR SR SR 3.3.1.1.1 SR 3.3.1.1.2 SR 3.3.1.1.7 SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.13 SR 3.3.1.1.15 SR 3.3.1.1.16 SR 3.3.1.1.17 SR 3.3.1.1.18 H G 3 3 1,2 5 (a)3 2 c.Inop b.Fixed Flux-High d.Flow Biased Simulated Therma 1 Power-Hi gh a.Neutron Flux-High b.Inop 2 3 H 5 (a)2.Average Power Range Monitors a.Neutron Fl ux-Hi gh , 2 Setdown (continued)(a)With any control rod withdrawn from a core cell containing one or more fuel assemblies.(b)All0**al:Jle Vallics sl'eeifieEi il'l tAC COLR.Al1o'hasle Vall:fe A1sEiifieatiol'l I"CEll:f;pcEi 8)tRe (QlP: Ellie to reEil:lctioAS iA fceEihatcr teA1I'Cratl:lre ffia)Be EielayeEi fop l:ll'to 12 GRAND GULF 3.3-6 Amendment No.+4+/-, 169}}
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Letter Sequence Response to RAI |
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TAC:ME2531, Clarify Application of Setpoint Methodology for LSSS Functions (Approved, Closed) |
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MONTHYEARML0931404632009-11-0303 November 2009 License Amendment Request Regarding Power Range Neutron Monitoring System Upgrade Project stage: Request ML0934100662009-12-10010 December 2009 Acceptance Review of License Amendment Request for Power Range Neutron Monitoring System - Includes Revised Schedule for Completion Based on Late Submittal Project stage: Acceptance Review ML1004308252010-02-0808 February 2010 Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI ML1010902452010-04-22022 April 2010 Request for Additional Information Power Range Neutron Monitoring System Project stage: RAI ML1014100942010-05-18018 May 2010 Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI ML1014704032010-05-25025 May 2010 Affidavit for 5/25/10 NRC Meeting to Discuss Response to Requests for Additional Information on License Amendment Request for Digital Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2010/00040, Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2010-06-0303 June 2010 Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI ML1018001492010-06-18018 June 2010 Schedule for Responding to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Request ML1017904372010-06-30030 June 2010 0000-0102-0888-RI, Plant-Specific Responses Required by Numac Prnm Retrofit Plus Option III Stability Trip Function Topical Report, (NEDC-3241OP-A) Project stage: Other ML1021500292010-07-29029 July 2010 Responses to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2010/00064, Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2010-09-29029 September 2010 Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2010/00075, Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2010-12-13013 December 2010 Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2010/00070, Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2010-12-14014 December 2010 Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI ML1111704322011-04-27027 April 2011 Request for Additional Information, Round 4, License Amendment Request for Power Range Neutron Monitoring System Project stage: RAI ML1111704242011-04-27027 April 2011 E-mail, Request for Additional Information, Round 4, License Amendment Request for Power Range Neutron Monitoring System Project stage: RAI GNRO-2011/00032, Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2011-05-0303 May 2011 Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI ML1113204932011-05-12012 May 2011 E-mail, Request for Additional Information, Round 5, License Amendment Request for Power Range Neutron Monitoring System Project stage: RAI GNRO-2011/00038, Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2011-05-16016 May 2011 Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2011/00039, Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2011-05-26026 May 2011 Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2011/00042, Responses to NRC Requests for Additional Information Re License Amendment Request for Power Range Neutron Monitoring System2011-05-31031 May 2011 Responses to NRC Requests for Additional Information Re License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI ML1113906562011-06-0202 June 2011 Request for Withholding Information from Public Disclosure, 5/11/2011 Affidavit Executed by J. Harrison, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00038 Project stage: Withholding Request Acceptance ML1113905962011-06-0202 June 2011 Request for Withholding Information from Public Disclosure, 4/28/2011 Affidavit Executed by E. Schrull, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00032 Project stage: Withholding Request Acceptance GNRO-2011/00044, Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2011-06-13013 June 2011 Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI ML1117402132011-06-23023 June 2011 Email, Request for Additional Information, Round 6, License Amendment Request for Power Range Neutron Monitoring System Project stage: RAI GNRO-2011/00045, Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2011-06-28028 June 2011 Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Supplement GNRO-2011/00057, Response to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2011-07-22022 July 2011 Response to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2011/00066, Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2011-09-28028 September 2011 Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2011/00089, Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2011-10-18018 October 2011 Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2011/00090, Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531) - Software Evaluation Report2011-10-26026 October 2011 Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531) - Software Evaluation Report Project stage: Supplement GNRO-2011/00091, Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531) V&V Summary Test Report2011-11-0808 November 2011 Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531) V&V Summary Test Report Project stage: Supplement GNRO-2011/00110, Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531) V&V Summary Test Report2011-12-0101 December 2011 Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531) V&V Summary Test Report Project stage: Supplement ML1204406602012-02-27027 February 2012 Request for Withholding Information from Public Disclosure, 11/29/2011 Affidavit Executed by J. Harrison, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00110 Project stage: Withholding Request Acceptance ML1204406382012-02-27027 February 2012 Request for Withholding Information from Public Disclosure, 9/22/2011 Affidavit Executed by J. Harrison, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00066 Project stage: Withholding Request Acceptance ML1204406532012-02-27027 February 2012 Request for Withholding Information from Public Disclosure, 11/3/2011 Affidavit Executed by E. Schrull, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00091 Project stage: Withholding Request Acceptance ML1204406022012-02-27027 February 2012 Request for Withholding Information from Public Disclosure, 5/19/2011 Affidavit Executed by J. Harrison, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00039 Project stage: Withholding Request Acceptance ML1204406162012-02-27027 February 2012 Request for Withholding Information from Public Disclosure, 5/25/2011 Affidavit Executed by E. Schrull, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00042 Project stage: Withholding Request Acceptance ML1204406232012-02-27027 February 2012 Request for Withholding Information from Public Disclosure, 6/23/2011 Affidavit Executed by E. Schrull, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00045 Project stage: Withholding Request Acceptance ML1204406272012-02-27027 February 2012 Request for Withholding Information from Public Disclosure, 7/21/2011 Affidavit Executed by E. Schrull, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00057 Project stage: Withholding Request Acceptance ML1204406462012-02-27027 February 2012 Request for Withholding Information from Public Disclosure, 10/20/2011 Affidavit Executed by E. Schrull, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00090 Project stage: Withholding Request Acceptance ML1210701392012-04-0202 April 2012 Email Correction to Technical Specification Table 3.3.1-1 Project stage: Other ML1209403902012-04-16016 April 2012 Correction to Technical Specification (TS) Page 3.3-6 for Amendment No. 188, Revise TSs to Reflect Installation of Digital GE-Hitachi Nuclear Measurement Analysis and Control Power Range Neutron Monitoring System Project stage: Other GNRO-2012/00031, Supplemental Information - License Conditions, Extended Power Uprate2012-04-26026 April 2012 Supplemental Information - License Conditions, Extended Power Uprate Project stage: Supplement GNRO-2013/00031, Corrected Response to NRC Request for Additional Information Regarding License Amendment Request for Power Range Neutron Monitoring System2013-05-22022 May 2013 Corrected Response to NRC Request for Additional Information Regarding License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI ML13149A2252013-06-24024 June 2013 Correction to Safety Evaluation Page 60 (Redacted) for Amendment No. 188, Revise TSs to Reflect Installation of Digital GE-Hitachi Nuclear Measurement Analysis and Control Power Range Neutron Monitoring System Project stage: Approval 2011-04-27
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Category:Letter
MONTHYEARML24263A2712024-09-19019 September 2024 Application to Revise Technical Specifications to Adopt TSTF-592, Revise Automatic Depressurization System (ADS) Instrumentation Requirements ML24257A0172024-09-17017 September 2024 Request for Withholding Information from Public Disclosure Unit 1 IR 05000416/20240122024-09-17017 September 2024 License Renewal Post Approval Phase 2 Inspection Report 05000416/2024012 ML24254A3602024-09-10010 September 2024 Pre-Submittal Slides for License Amendment Request, Criticality Safety Analysis, Technical Specification 4.3.1, Criticality and Technical Specification 5.5.14, Spent Fuel Storage Rack Neutron Absorber Monitoring Program IR 05000416/20244022024-09-0909 September 2024 Security Baseline Inspection Report 05000416/2024402 05000416/LER-2024-003, Feedwater Inlet Check Valve Incorrectly Determined Operable2024-08-26026 August 2024 Feedwater Inlet Check Valve Incorrectly Determined Operable ML24235A0832024-08-22022 August 2024 Evaluations Performed in Accordance with 10 CFR 50.54(q) for Changes to Emergency Planning Documents IR 05000416/20240052024-08-21021 August 2024 Updated Inspection Plan for Grand Gulf Nuclear Station (Report 05000416/2024005) ML24220A2642024-08-20020 August 2024 Entergy Operations, Inc. - Entergy Fleet Project Manager Assignment ML24185A1522024-08-13013 August 2024 Issuance of Amendment Nos. 334, 235, and 215, Respectively, to Revise TSs to Adopt TSTF-205 ML24176A1202024-07-29029 July 2024 Issuance of Amendment 234 Revision to Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times – RITSTF Initiative 4b IR 05000416/20240022024-07-29029 July 2024 Integrated Inspection Report 05000416/2024002 ML24172A2502024-07-29029 July 2024 – Issuance of Amendment No. 233 Adoption of 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors ML24204A2432024-07-23023 July 2024 Notification of Cyber Security Baseline Inspection and Request for Information (05000416/2024403) ML24191A2432024-07-0909 July 2024 Completion of License Renewal Activities Prior to Entering the Period of Extended Operations IR 05000416/20240102024-06-27027 June 2024 Biennial Problem Identification and Resolution Inspection Report 05000416/2024010 ML24156A1762024-06-24024 June 2024 Regulatory Audit Summary in Support of License Amendment Requests to Adopt TSTF-505, Revision 2 and 10 CFR 50.69 (Epids L-2023-LLA-0081 and L-2023-LLA-0080) ML24165A1512024-06-13013 June 2024 Second Supplement to License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times – RITSTF Initiative 4b and Application to Adopt 10 CFR 50.69, Risk-Informe ML24163A2652024-06-11011 June 2024 Inservice Inspection Summary Report ML24060A2192024-05-30030 May 2024 Authorization of Alternative to Use EN-RR-01 Concerning Proposed Alternative to Adopt Code Case N-752 ML24149A1592024-05-28028 May 2024 Automatic Actuation of Reactor Protection System ML24130A0912024-05-0909 May 2024 Request for Information Letter License Renewal Phase 2 Inspection ML24128A1512024-05-0909 May 2024 Project Manager Assignment ML24128A0422024-05-0707 May 2024 License Amendment Request to Remove Obsolete License Conditions IR 05000416/20240012024-05-0202 May 2024 Integrated Inspection Report 05000416 2024001 ML24122C6112024-05-0101 May 2024 Supplement to License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - Ritstf. ML24116A0372024-04-25025 April 2024 Report of Technical Specification Bases Changes ML24113A0972024-04-22022 April 2024 Annual Report of Individual Monitoring - NRC Form 5 for 2023 Per 1 0 CFR 20.2206 ML24113A0952024-04-22022 April 2024 Annual Radioactive Effluent Release Report for 2023 ML24107A8872024-04-16016 April 2024 2023 Annual Radiological Environmental Operating Report (AREOR) ML24107B0402024-04-16016 April 2024 Notification by Entergy Operations, Inc., of Proposed Economic Performance Incentive and Reliance on Post-Event Improvements in Plant Procedures And/Or Methods of Operation in FERC ML24101A3882024-04-10010 April 2024 Response to Request for Confirmation of Information by the Office of Nuclear Reactor Regulation Proposed Alternative Request EN-RR-22-001 Risk-Informed Categorization and Treatment for Repair ML24100A0692024-04-0909 April 2024 Report of Changes or Errors to 10 CFR 50.46 Analysis ML24094A0992024-04-0303 April 2024 (GGNS) Core Operating Limits Report (COLR) Cycle 25, Revision O ML24089A2262024-03-29029 March 2024 Entergy Response to Regulatory Issue Summary 2024-01, Preparation and Scheduling of Operator Licensing Exams ML24087A1962024-03-27027 March 2024 High Pressure Core Spray Inoperable Due to Minimum Flow Valve Failure to Close IR 05000416/20220042024-03-19019 March 2024 – Amended Integrated Inspection Report 05000416/2022004 and Exercise of Enforcement Discretion ML24075A1712024-03-15015 March 2024 Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3)) ML24074A2892024-03-14014 March 2024 Proof of Financial Protection (10 CFR 140.15) ML24058A3512024-02-28028 February 2024 Notification of Biennial Problem Identification and Resolution Inspection and Request for Information IR 05000416/20230062024-02-28028 February 2024 Annual Assessment Letter for Grand Gulf Nuclear Station - Report 05000416/2023006 IR 05000416/20233012024-02-26026 February 2024 NRC Examination Report 05000416-2023301 ML24043A1892024-02-12012 February 2024 Spent Fuel Storage Radioactive Effluent Release Report for 2023 ML24012A1422024-01-31031 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0051 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML24043A0732024-01-29029 January 2024 2024-01 Post Examination Comments IR 05000416/20230042024-01-25025 January 2024 Integrated Inspection Report 5000416/2023004 IR 05000416/20234012024-01-18018 January 2024 Cyber Security Inspection Report 05000416/2023401 (Public) ML24018A0222024-01-18018 January 2024 Core Operating Limits Report (COLR) Cycle 24, Revision 2 IR 05000416/20243012024-01-16016 January 2024 NRC Initial Operator Licensing Examination Approval 05000416/2024301 ML24012A1962024-01-12012 January 2024 Response to 2nd Round Request for Additional Information Concerning Relief Request Number EN-RR-22-001 – Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and 2024-09-09
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Text
" ""P Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150 Michael A. Krupa Director, Extended Power Uprate Grand Gulf Nuclear Station Tel. (601) 437-6684 GNRO-201 0-0001 0 February 8, 2010 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531)
Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29
REFERENCES:
- 1. Entergy Operations, Inc. letter to the NRC, License Amendment Request - Power Range Neutron Monitoring System Upgrade, dated November 3,2009 (ADAMS Accession No. ML093140463)
- 2. NRC letter to Entergy Operations, Inc., Grand Gulf Nuclear Station, Unit 1 - Request for Additional Information Re: Power Range Neutron Monitoring System (TAG No. ME2531), dated January 15, 2010
Dear Sir or Madam:
In Reference 1, Entergy Operations, Inc. (Entergy) submitted to the NRC a license amendment request (LAR), which proposes to revise the Grand Gulf Nuclear Station (GGNS)
Technical Specifications (TS) to reflect the installation of the digital General Electric-Hitachi (GEH) Nuclear Measurement Analysis and Control (NUMAC) Power Range Neutron Monitoring (PRNM) System.
In Reference 2, the NRC staff requested additional information needed to support their review and approval of Reference 1.
Responses to the staff's Requests for Additional Information (RAls) are provided in Attachment 1 of this letter. Associated revisions to the mark-ups of the proposed changes are provided in Attachment 2.
In addition to the changes pertaining to the NRC RAls, Entergy discovered a typographical error in marked-up TS Table 3.3.1.1-1, provided on page 13 of Attachment 3 of Reference 1.
The reference for Note (b) was inadvertently shown as being deleted. As discussed in Section 4.4.3.5.a of Reference 1, Entergy proposed to relocate the reference to align with the applicable function in the table. A corrected marked-up TS Table 3.3.1.1-1 is provided in Attachment 2. Please replace the current TS Table 3.3.1.1-1 with the corrected table.
GNRO-201 0-0001 0 Page 2 The No Significance Hazards Determination and the Environmental Consideration provided in Reference 1 are not impacted by these responses.
This letter contains no new commitments.
If you have any questions or require additional information, please contact Mr. Guy Davant at (601) 368-5756.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on February 8, 2010.
Sincerely,
~.A-. r~
MAKlghd
Attachment:
- 1. Responses to NRC Requests for Additional Information Pertaining to License Amendment Request - Power Range Neutron Monitoring System Upgrade
- 2. Revised Ol, TS, and TS Bases Pages cc: Mr. Elmo E. Collins, Jr.
Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 612 East lamar Blvd., Suite 400 Arlington, TX 76011-4005 U. S. Nuclear Regulatory Commission ATTN: Mr. C. F. lyon, NRR/DORl (w/2)
ATTN: ADDRESSEE ONLY ATTN: Courier Delivery Only Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378 State Health Officer Mississippi Department of Health P. O. Box 1700 Jackson, MS 39215-1700 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150
ATTACHMENT 1 GNRO-201 0-0001 0 RESPONSES TO NRC REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE to GNRO-201 0-0001 0 Page 1 of 4 RESPONSES TO NRC REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE Responses to the NRC staff's Requests for Additional Information (RAls) are provided in of this letter. Associated revisions to the mark-ups of the proposed changes are provided in Attachment 2.
NRC RAI No.1 Please explain how a unit restart is allowed by adding the note, "LCO 3.0.4.b is not applicable" to new Required Action J.2. , page 14 of the application letter states, "Entergy also proposes a note that states LCO 3.0.4.b is not applicable to new Required Action J.2. This note allows unit restart in the event of a shutdown during the 120-day completion time." However, Limiting Condition for Operation (LCO) 3.0.4.a and LCO 3.0.4.c remain applicable. LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability, when an LCO is not met, only when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Condition J is referenced in Table 3.3.1.1-1 and entered as required by Required Action 0.1. Condition J Required Action J.1 requires initiating an alternate method to detect and suppress thermal hydraulic instability oscillations within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and J.2 requires restoring the required channels to operable status within 120 days. Condition J does not permit continued operation for an unlimited period of time. LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability, when an LCO is not met, only when an allowance is stated in the individual value, parameter, or other Specification. LCO 3.0.4.c is not allowed in any condition in GGNS TS 3.3.1.1.
Response
Entergy agrees with the NRC's comments and proposes to revise the wording of the proposed note applied to Required Action J.2 to read, "LCO 3.0.4 is not applicable." This revised wording addresses the NRC's comments and allows unit restart in the event of a shutdown during the 120-day completion time of Required Action J.2.
As discussed in Section 4.4.1.2 of the LAR, this note is consistent with the original intent of the NUMAC PRNM Licensing Topical Report (LTR), which is to allow normal plant operations to continue during the recovery time from a hypothesized design problem with the Option III stability solution algorithms. This proposed note was approved by the NRC for Monticello Nuclear Generating Plant 1 and Peach Bottom Atomic Power Station, Units 2 and 32 .
NRC letter to Northern States Power Company, Monticello Nuclear Generating Plant (MNGP)-
Issuance of Amendment Regarding the Power Range Neutron Monitoring System (TA C No.
MDB064) , dated January 30,2009 (ADAMS Ascension No. ML083440681) to GNRO-201 0-0001 0 Page 2 of 4 Entergy has revised TS Insert B and the discussion of Required Action J.2 in TS Bases Insert J (contained on page 9 of LAR Attachment 3 and page 27 of LAR Attachment 4, respectively) to reflect the wording change for the note, as specified above.
NRC RAI No.2 Please provide revised proposed TS Bases changes that are consistent with Technical Specification Task Force (TSTF)-493, Revision 4, or justify deviations.
The applicability section in Federal Register (74 FR 58065), "Notice of Opportunity for Public Comment on the Proposed Model Safety Evaluation for Plant-Specific Adoption of Technical Specification Task Force Traveler-493, Revision 4, "Clarify Application of Setpoint Methodology for LSSS Functions" stated, "The licensee must add footnotes to all the functions identified in TSTF Traveler-493, Revision 4, Appendix A, and must incorporate the related TS Bases changes." for any licensee wishing to adopt TS task force (TSTF) Traveler-493, option A without changes to setpoint values. The NRC staff considers the changes made by TSTF-493, Revision 4 to TS 3.3.1.1 Bases sections: (1) background; (2) applicable safety analyses, LCO, and applicability; (3) actions; and (4) surveillance requirements to be related to GGNS proposed amendment.
Response
Entergy plans to revise the "BACKGROUND" and "APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY" sections of TS Bases 3.3.1.1 to reflect TSTF-493, Rev. 4 wording as applied to the APRM functions. Specifically, Entergy has added subsections entitled Application of TSTF-493, Rev. 4 (Ref. 17) to APRM Functions 2.a, 2.b, 2.d, and 2.f to TS Bases pages B 3.3-2 and B 3.3-4 as Inserts 1 and 2, respectively.
NRC RAI No.3 Please state which SRs verify trip setpoint settings for functions 2.a, 2.b, 2.c, 2.d, 2.e, and 2.f in TS Table 3.3.1.1-1, and provide a revised TS Table 3.3.1.1-1 with the addition of notes (d) and (e) for these functions as needed.
The proposed change revises GGNS TSs to incorporate NRC-approved TSTF Traveler-493, Revision 4, to be consistent with Option A. Option A, without changes to setpoint values, adds two Notes to SRs in the Surveillance Requirement Column of TSs Instrumentation Function Tables. Specifically, Notes are added to TS 3.3.1.1 SRs that require verifying trip setpoint setting values, (i.e. Channel Calibration and Channel Functional Test SRs) for NUREG-1434.
The first Surveillance Note requires evaluation of channel performance for the condition where the As-Found setting for the channel setpoint is outside its As-Found Tolerance but conservative with respect to the AV. This is proposed note (d) to TS Table 3.3.1.1-1. The second Surveillance Note requires that the As-Left setting for the channel be returned to 2 NRC letter to Exelon Nuclear, Peach Bottom Atomic Power Station, Units 2 and 3 -Issuance of Amendment Re: Activation of Oscillation Power Range Monitor Trip (TAG Nos. MC2219 and MC2220) , dated March 21, 2005 (page 4 of SE) (ADAMS Accession No. ML05270020) to GNRO-201 0-0001 0 Page 3 of 4 within the As-Left Tolerance of the Nominal Trip Setpoint (NTSP)]. This is proposed note (e) to TS Table 3.3.1.1-1.
Response
At GGNS, trip setpoints are typically verified via channel calibration procedures, only. APRM Functions 2.a, 2.b, 2.d, and 2.f will follow this practice with their trip setpoints being verified via channel calibration SR 3.3.1.1.10, only. The proposed Notes (d) and (e) have been applied in TS Table 3.3.1.1 to SR 3.3.1.1.10 for these functions, as discussed in Section 4.4.3.1 of the LAR. Notes (d) and (e) are not applicable to APRM Functions 2.c and 2.e, as discussed in Section 5.1.5 of the LAR.
NRC RAI No.4 In its application, the licensee proposed the following new operating license condition (OLC):
During Cycle 19, GGNS may conduct monitoring of the Oscillation Power Range Monitor (OPRM). During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) may be disabled and operated in an 'indicate only' mode at which time technical specification requirements would not apply. During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations.
In the application, the licensee stated that it would review the operating data, setpoints, and margins at the end of the OPRM monitoring period. Once it determines that the results are acceptable, the licensee will enable the OPRM (with applicable SRs met) by connecting it to the reactor protection system trip relays, completing implementation of the hardware changes, and notifying the NRC.
However, the proposed OLC wording does not restrict GGNS from returning the OPRM into "indicate only" mode, once the OPRM has been enabled during Cycle 19. Also, the proposed "may" wording in the OLC suggests that GGNS has the option to disable the OPRM and conduct monitoring of the OPRM. Please revise the proposed OLC to address these concerns or provide further justification for the proposed wording.
Response
Entergy proposes to revise the wording of the OLC as follows (changes denoted in bold, italicized text):
During Cycle 19, GGNS will conduct monitoring of the Oscillation Power Range Monitor (OPRM). During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) will be disabled and operated in an 'indicate only' mode and technical specification requirements will not apply to this function. During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations. Once monitoring has been successfully completed, the OPRM Upscale function will be enabled and technical specification requirements will be to GNRO-201 0-0001 0 Page 4 of 4 applied to the function; no further operating with this function in an Ilindicate only" mode will be conducted.
Entergy has revised OL Insert A (contained on page 2 of LAR Attachment 3) to reflect the above wording. The OL page associated with this insert was provided on page 1 of LAR ; it reflected OL Amendment 182. The current OL Amendment is now 183.
Therefore, Entergy is providing the revised OL Amendment 183 page along with Insert A to reflect the current OL amendment.
ATTACHMENT 2 GNRO-201 0-0001 0 REVISED OL, TS, TS BASES, AND INSERT PAGES to GNRO-2010-00010 Page 1 of 10 INSERT B - New Conditions J and K with Required Actions J. As required by Required Action J.1 Initiate alternate method to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 0.1 and referenced in detect and suppress thermal Table 3.3.1.1-1. hydraulic instability oscillations.
AND J.2 - - - - - - - - - NOTE - - - - - - - -
LCO 3.0.4 is not applicable.
Restore required channels to 120 days OPERABLE.
K. Required Action and associated K.1 Reduce THERMAL POWER 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time of Condition J to < 24% RTP.
not met.
to GNRO-201 0-0001 0 Page 2 of 10 INSERT J - New Required Actions J.1 and J.2 If OPRM Upscale trip capability is not maintained, Condition J exists. Reference 15 justified use of alternate methods to detect and suppress oscillations for a limited period of time. The alternate methods are procedurally established consistent with the guidelines identified in Reference 16 requiring manual operator action to scram the plant if certain predefined events occur. The 12-hour allowed action time is based on engineering judgment to allow orderly transition to the alternate methods while limiting the period of time during which no automatic or alternate detect and suppress trip capability is formally in place. Based on the small probability of an instability event occurring at all, the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is judged to be reasonable.
The alternate method to detect and suppress oscillations implemented in accordance with J.1 was evaluated (Reference 15) based on use up to 120 days only. The evaluation, based on engineering judgment, concluded that the likelihood of an instability event that could not be adequately handled by the alternate methods during this 120-day period was negligibly small.
The 120-day period is intended to be an outside limit to allow for the case where design changes or extensive analysis might be required to understand or correct some unanticipated characteristic of the instability detection algorithms or equipment. This action is not intended and was not evaluated as a routine alternative to returning failed or inoperable equipment to OPERABLE status. Correction of routine equipment failure or inoperability is expected to normally be accomplished within the completion times allowed for Actions for Conditions A and B.
LCO 3.0.4 is not applicable to J.2 to allow unit restart in the event of a shutdown during the 120-day completion time.
to GNRO-201 0-0001 0 RPS Instrumentation Page 3 of 10 B 3.3.1.1 BASES BACKGROUND The RPS is comprised of two independent trip systems (A (continued) and B), with two logic channels in each trip system (logic channels Al and A2, 81 and 82), as shown in Reference 1.
The outputs of the logic channels in a trip system are combined in a one-out-of-two logic so either channel can trip the associated trip system. The tripping of both trip systems will produce a reactor scram. This logic arrangement is referred to as one-out-of-two taken twice logic. Each trip system can be reset by use of a reset switch. If a full scram occurs (both trip systems trip), a relay prevents reset of the trip systems for 10 seconds after the full scram signal is received. This 10 second delay on reset ensures that the scram function will be completed.
Two scram pilot valves are located in the hydraulic control unit (HCU) for each control rod drive (eRO). Each scram pilot valve is solenoid operated, with the solenoids normally energized. The scram pilot valves control the air supply to the scram inlet and outlet valves for the associated CRo. When either scram pilot valve solenoid is energized, air pressure holds the scram valves closed and, therefore, both scram pilot valve solenoids must be de-energized to cause a control rod to scram. The scram valves control the supply and discharge paths for the CRD water during a scram. One of the scram pilot valve solenoids for each CRD is controlled by trip system A, and the other solenoid is controlled by trip system B. Any trip of trip system A in conjunction with any trip in trip system B results in de-energizing both solenoids, air bleeding off, scram valves opening, and control rod scram.
The backup scram valves, which energize on a scram signal to depressurize the scram air header, are also controlled by the RPS. Additionally, the RPS System controls the Sov vent and drain valves such that when both trip systems trip, the SOV vent and drain valves close to isolate the SOV.
APPLICABLE The actions of the RPS are assumed in the safety analyses SAFETY ANALYSES, of References 2, 3, and 4. The RPS initiates a reactor LCO and t scram when monitored parameter values exceed the Allowable APPLICABILITY Values specified by the setpoint methodology and listed in Table 3.3.1.1-1 to preserve the integrity of the fuel cladding, the reactor coolant pressure boundary (RepS), and (continued)
GRAND GULF B 3.3-2 Revision No. 0 to GNRO-201 0-0001 0 Page 4 of 10 INSERT 1 Application of TSTF-493. Rev. 4 (Ref. 17) to APRM Functions 2.a. 2.b. 2.d, and 2.f 10 CFR 50.36(c)(1 )(ii)(A) requires that Technical Specifications include LSSS for variables that have significant safety functions. LSSS are defined by the regulation as "...settings for automatic protective devices...so chosen that automatic protective actions will correct the abnormal situation before a safety limit is exceeded." The Analytical Limit is the limit of the process variable at which a protective action is initiated, as established by the safety analysis, to ensure that a SL is not exceeded. Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protective channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur.
The trip setpoint is a predetermined setting for a protection channel chosen to ensure automatic actuation prior to the process variable reaching the Analytical Limit and thus ensuring that the SL would not be exceeded. As such, the trip setpoint accounts for uncertainties in setting the channel (e.g., calibration), uncertainties in how the channel might actually perform (e.g., repeatability), changes in the point of action of the channel over time (e.g., drift during surveillance intervals), and any other factors which may influence its actual performance (e.g., harsh accident environments). In this manner, the trip setpoint ensures that SLs are not exceeded.
Technical Specifications contain values related to the OPERABILITY of equipment required for safe operation of the facility. OPERABLE is defined in Technical Specifications as
"... being capable of performing its specified safety function(s)." Relying solely on the trip setpoint to define OPERABILITY in Technical Specifications would be an overly restrictive requirement if it were applied as an OPERABILITY limit for the "as found" value of a protection channel setting during a Surveillance. This would result in Technical Specification compliance problems, as well as reports and corrective actions required by the rule which are not necessary to ensure safety. For example, an automatic protection channel with a setting that has been found to be different from the trip setpoint due to some drift of the setting may still be OPERABLE because drift is to be expected. This expected drift would have been specifically accounted for in the setpoint methodology for calculating the trip setpoint and thus the automatic protective action would still have ensured that the SL would not be exceeded with the "as found" setting of the protection channel. Therefore, the channel would still be OPERABLE because it would have performed its safety function and the only corrective action required would be to reset the channel within the established as-left tolerance around the trip setpoint to account for further drift during the next surveillance interval.
Note that, although the channel is OPERABLE under these circumstances, the trip setpoint must be left adjusted to a value within the as-left tolerance, in accordance with uncertainty assumptions stated in the referenced setpoint methodology (as-left criteria), and confirmed to be operating within the statistical allowances of the uncertainty terms assigned (as-found criteria).
to GNRO-201 0-0001 0 Page 5 of 10 However, there is also some point beyond which the channel may not be able to perform its function due to, for example, greater than expected drift. This value needs to be specified in the Technical Specifications in order to define OPERABILITY of the channels and is designated as the Allowable Value.
If the actual setting (as-found setpoint) of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance, the channel is OPERABLE but degraded. The degraded condition will be further evaluated during performance of the SR.
This evaluation will consist of resetting the channel setpoint to the trip setpoint (within the allowed tolerance), and evaluating the channel response. If the channel is functioning as required and expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.
to GNRO-201 0-0001 0 RPS Instrumentation Page 6 of 10 B 3.3.1.1 BASES APPLICABLE environment errors (for channels that must function in fiarsh SAFETY ANALYSES, environments as defined by 10 CFR 50.49) are accounted for.
LCO, and APPLICABILITY The OPERABILITY of scram pilot valves and associated
{continued} solenoids, backup scram valves, and SOV valves, described in the Background section, are not addressed by this LCO.
The individual Functions are required to be OPERABLE in the MODES specified in the Table that may require an RPS trip to mitigate the consequences of a design basis accident or transient. To ensure a reliable scram function, a combination of Functions is required in each MODE to provide primary and diverse initiation signals.
RPS is required to be OPERABLE in MODE 5 with any, control rod withdrawn from a core cell containing one or more fuel assemblies. Control rods withdrawn from a core cell containing no fuel assemblies do not affect the reactivity of the core and therefore are not required to have the capability to scram. Provided all other control rods remain inserted, the RPS function is not required. In this condition, the required SCM (LCO 3.1.1, "SHUTDOWN MARGIN (SOM)") and refuel position one-rod-out interlock (lCO 3.9.2, "Refuel Position One-Rod-Out Interlock") ensure that no event requiring RPS will occur. During normal operation in MODES 3 and 4, all control rods are fully inserted and the Reactor Mode Switch-Shutdown Position control rod withdrawal block (LCO 3.3.2.1, "Control Rod Block Instrumentation") does not allow any control rod to be withdrawn. Under these conditions, the RPS function ;s not required to be OPERABLE.
The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.
~l.a. Intermediate Range Monitor fIRM) Neutron Flux--High The IRMs monitor neutron flux levels from the upper range of the source range monitors (SRMs) to the lower range of the average power range monitors (APRMs). The IRMs are capable of generating trip signals that can be used to prevent fuel damage resulting from abnormal operating transients in the intermediate power range. In this power range, the most significant source of reactivity change is due to control (continued)
GRAND GULF B 3.3-4 Revision No. 0 to GNRO-201 0-0001 0 Page 7 of 10 INSERT 2 Application of TSTF-493, Rev. 4 (Ref. 17) to APRM Functions 2.a, 2.b, 2.d, and 2.f Permissive and interlock setpoints allow the blocking of trips during plant startups, and restoration of trips when the permissive conditions are not satisfied, but they are not explicitly modeled in the Safety Analyses. These permissives and interlocks ensure that the starting conditions are consistent with the safety analysis, before preventive or mitigating actions occur. Because these permissives or interlocks are only one of multiple conservative starting assumptions for the accident analysis, they are generally considered as nominal values without regard to measurement accuracy.
Allowable Values for RPS Instrumentation Functions are specified for each RPS Function specified in Table 3.3.1.1-1. Trip setpoints and the methodologies for calculating the as-left and as-found tolerances are described in the Technical Requirements Manual. The nominal setpoints are selected to ensure that the actual setpoints remain conservative with respect to the as-found tolerance between successive CHANNEL CALIBRATIONS. After each calibration, the trip setpoint shall be left within the as-left band around the setpoint.
to GNRO-201 0-0001 0 GGNS OPERATING LICENSE Page 8 of 10 (b) SERI is required to notify the NRC in writing prior to any change in (i) the terms or conditions of any new or existing sale or lease agreements executed as part of the above authorized financial transactions, (ii) the GGNS Unit 1 operating agreement, (iii) the existing property insurance coverage for GGNS Unit 1 that would materially alter the representations and conditions set forth in the Staff's Safety Evaluation Report dated December 19, 1988 attached to Amendment No. 54.
In addition, SERI is required to notify the NRC of any action by a lessor or other successor in interest to SERI that may have an effect on the operation of the facility.
C. The license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1) Maximum Power Level Entergy Operations, Inc. is authorized to operate the facility at reactor core power levels not in excess of 3898 megawatts thermal (100 percent power) in accordance with the conditions specified herein.
(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix a, as revised through Amendment No. 183 are hereby incorporated into this license. Entergy Operations, Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
)
TaB S~rvBillaRee Re~Hiremeft~3 (SR~) for Diesel GQRSrater Id eORtaiRea ift tfte Technical Specifications aae listed selow, are ROt: re'1t1ired to be peLfoLliled immBeiat:ely HpOR implemeftto6tion of Amendment Uo. l.2.1.
TaQ iRs listed se10',J shall ee !Hleee~~ft111y delttonstLated a~ tao ROKt re~Hlar1} sefted~le~ ~er£ormal~e.
SR 3.8.1.9, SR 3.8.1.1Q, afta SR 3.8.1.14 Amendment No. 11t'j-4 to GNRO-201 0-0001 0 Page 9 of 10 INSERT A - Exception During Cycle 19, GGNS will conduct monitoring of the Oscillation Power Range Monitor (OPRM). During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) will be disabled and operated in an 'indicate only' mode and technical specification requirements will not apply to this function. During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations.
Once monitoring has been successfully completed, the OPRM Upscale function will be enabled and technical specification requirements will be applied to the function; no further operating with this function in an "indicate only" mode will be conducted.
Attachment 2 to RPS Instrumentation GNRO-201 0-0001 0 3.3.1.1 Page 10 of 10 Table 3.3.1.1-1 (page 1 of 3)
Reactor Protection System Instrumentation APPLICABLE CONDIT IONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTI ON COND ITI ONS SYSTEM ACTION 0.1 REQUIREMENTS VALUE
- 1. Intermediate Range Monitors
- a. Neutron Flux-High 2 3 H SR 3.3.1.1.1 :s; 122/125 SR 3.3.1.1.3 divisions of SR 3.3.1.1.12 full scale SR 3.3.1.1.13 5 (a) 3 SR 3.3.1.1.1 :s; 122/125 SR 3.3.1.1.4 divisions of SR 3.3.1.1.12 full scale SR 3.3.1.1.13
- b. Inop 2 3 H SR 3.3.1.1.3 NA SR 3.3.1.1.13 5 (a) SR 3.3.1.1.4 NA SR 3.3.1.1.13
- 2. Average Power Range Monitors
- a. Neutron Fl ux - Hi gh , 2 SR Setdown S~
SR SR
- b. Fixed Neutro~
Flux-High
- c. Inop 1,2
- d. Flow Biased Simulated 3 G SR 3.3.1.1.1 Therma 1 Power - Hi gh SR 3.3.1.1.2 SR 3.3.1.1.7 SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.13 SR 3.3.1.1.15 SR 3.3.1.1.16 SR 3.3.1.1.17 SR 3.3.1.1.18 (continued)
(a) With any control rod withdrawn from a core cell containing one or more fuel assemblies.
(b) All0 ** al:Jle Vallics sl'eeifieEi il'l tAC COLR. Al1o'hasle Vall:fe A1sEiifieatiol'l I"CEll:f;pcEi 8) tRe (QlP: Ellie to reEil:lctioAS iA fceEihatcr teA1I'Cratl:lre ffia) Be EielayeEi fop l:ll' to 12 ~ol:lrs.
GRAND GULF 3.3-6 Amendment No. +4+/-, 169