Text

0000-0102-0888-RI, Plant-Specific Responses Required by Numac Prnm Retrofit Plus Option III Stability Trip Function Topical Report, (NEDC-3241OP-A)
	ML101790437
Person / Time
Site:	Grand Gulf
Issue date:	06/30/2010
From:	Rudy S; GE-Hitachi Nuclear Energy Americas
To:	; Office of Nuclear Reactor Regulation
References
	GNRO-2010/00040, NEDC-3241OP-A, TAC ME2531 0000-0102-0888-RI, GEH DRF 0000-0098-4327
	Download: ML101790437 (65)
	v • d • e

ATTACHMENT 5 GNRO-2010/00040 RESPONSE TO RAI No. 5 GE HITACHI NUCLEAR ENERGY REPORT 0000-0102-0888-Rl GRAND GULF NUCLEAR STATION - PLANT-SPECIFIC RESPONSES REQUIRED BY NUMAC PRNM RETROFIT PLUS OPTION III STABILITY TRIP FUNCTION TOPICAL REPORT (NEDC-3241OP-A)

HITACHI GE Hitachi Nuclear Energy 0000-0102-0888-RI GEH DRF 0000-0098-4327 Class III June 2010 Grand Gulf Nuclear Station Plant-Specific Responses Required By NUMAC PRNM Retrofit Plus Option III Stability Trip Function Topical Report (NEDC-3241OP-A)

Prepared by: S. Rudy Verified by: L. Schichlein Approved by: E. Schrull

0000-0102-0888-RI Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Table of Contents Grand Gulf Specific Responses Required by NUMAC PRNM Pages 1-19 Retrofit Topical Report Appendix A, Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Pages AI-A7 i

0000-0102-0888-R1 Grand Gulf Specific ResponsesRequired by NUMAC PRNM Retrofit Topical Report The section numbers and Utility Actions Required listed below are from the NUMAC PRNM Retrofit Plus Option III Stability Trip Function Topical Report NEDC-3241 OP-A including Supplement 1.

Section No. Utility Action Required Response 2.3.2 Option III Stability Implementation Not a required specific LTR response Confirm that the actual plant Option IIl The GGNS Option II implementation is in configuration is included in the variations accordance with the LTR Requirements of covered in the Power Range Neutron Monitor section 2.3.2 with the exception of 2 deviations (PRNM) Licensing Topical Report (LTR) from the BWROG Option III Topical Report.

[NEDC-3241OP-A, Volumes I & 2 and . Justification for these deviations is provided Supplement

' " ... 1]. , ." ' . . .. ' . . .. *!iL5

. 't , separately R0, Septdnmb~r (GEH2009).ý document0000-0107-7607-P-2.3.4 Plant Unique or Plant-Specific Aspects The actual, current plant configuration and the Cohnfirmlithiit h'e'actual plah'tconfiguratiI6n'i s proposed replacement PRNM are included in injcluded initlhe variations covered in the Power the P.RNM,.LTR as follows: (Applicable LTR

... Range Neutron Monitor (PRNM) Licensing sections are listed.)

Topical Report (LTR) [NEDC-3241OP-A, Volumes f &:2 and Supplement I], and the Current Proposed configuration alternative(s)being applied for the APRM 2.3.3.1..1.3 2.3.3.1.2.2 replacementiPRNM are covered by the PRNM RBM 2.3.3.2.1.2 2.3.3.2.2.2 LTR. Document in tile plant-specific licensing Flow Unit 2.3.3.3.1.3 2.3.3.3.2.2 sNubittal for the PRNM 't" Rod Control 2.3.3.4.1.3 2.3.3.4.2.3 current plant configuration of.the replacement ARTS 2.3.3.5.1.5 2.3.3.5.2.3 PRNM , and documenit confinnmatioin that those Panel lnterface 2.3.3.6.1.2 2.3.3.6.2.1 are-cove'-e'd'y.the PRNM'LTR. Fo'afti,'

clian6es to the plant operator's panel, document in.the submittal the human"fadtors reviev Human Factors Engineering review will be a'c~ii~ tliaft'were taken to confirm conipatibility performed as part of the normal design process.

with existing'plant commitments and procedures.----.... .. ......

.. . "The actual PRNMS, System.to be installedat

, )1.,.. GGNS~contains;3 deviations from the system c...

. -,....... design as.deskribed in the LTR. Justification for 4 "* * , ,thesedeviations is.provided as Appendix A.

3.4 System Functions,*,- . . . ,

As 5art'of the plant-specificlicensing'submittal, the utility should document' the following:

1)" The pfemodification flow chiannel- I) T"ie' cuirent flow channel configuration

" '"&nf" i*i'tio"* aii configuration, add any an changes : planned p.a..n c'onsists of four flow channels, eight (fi~ormally changes will'be either addingtwo transmitters. Thus, the current 6..,hanhel s toreach four'or no chang6 configuration meets the requirements f;lanh

5) n itt. ..- . . .. "-,.'.I . described in LTR Section 3.2.3.2.2,

d. 'therefore no changes will be made.

NOTE: If transmitters areadded, the.

requirements on the addedtransmitters Nshould be:

Non-safety related, but qualified . .. ,. -

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0000-01 02-0888-RI Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 3.4 (cont.) environmentally and seismically to operate in the application environment.

Mounted with structures equivalent or better than those for the currently installed channels.

Cabling routed to achieve separation to the extent feasible using existing cableways and routes.

2) Document the APRM trips currently applied 2) The new and existing APRM trip functions at the plant. If different from those documented are listed below. The "post-modification" in the PRNM LTR, document plans to change to trips will be the same as those identified in those in theLTR. !,. the LTR.

The T Neutron Flux - High, Setdown

. function (APRM Function 2.a) has been retained as described in LTR paragraphs 3.2.4 and 8.3.1.4.

The Fixed Neutron Flux-High function (APRM Function 2.b) has been retained as described in LTR paragraph 3.2.5).

The lnop function (APRM Function 2.c) has been retained as described in LTR paragraph 3.2.10.

I i.

The Flow Biased Simulated Thermal Power- High function (APRM

Functi6n 2.d) has been retained as 1~-

described' in LTR paragraph 3:2.5.

The 2-Out-of-4 Voter function (APRM Function 2.e) has been added as described in as described in LTR parag iphs 3.212 and 8.3.2.4.

The OPRM Upscale function (APRM Functidn 2.0 has been added as described'in LTR paragraph 8.4.1.2.

3) Document the current status related to 3) ARTS is no't applicable to GGNS because ARTS and the planned post modification status Grandf Gulf is a BWR6.

as:

ARTS currently implemented, and retained in the PRNM

" ARTS will be implemented concurrently with the PRNM (reference ARTS submittal)

. ARTS not implemented and will not be implemented with the PRNM

ARTS not applicable I ____________________________________________

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0000-0102-0888-Ri Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 4.4.1.1 1 Regulatory Requirements of the Replacement A review of the GGNS requirements confirms System - System Design that the regulatory requirements addressed in the LTR encompass the related GGNS This section identifies requirements that are requirements. Part of the normal design process expected to encompass most specific plant confirms that the detailed PRNM design meets commitments relative to the PRNM replacemeiit the applicable detailed GGNS technical and project, but may not be complete and some may licensing requirements.

not apply to all plants. Therefore, the utility must confirm that the requirements identified here address all of those identified in the plant commitments. The plant-specific licensing submittal should identify the specific requirements applicable for the plant, confirm that any clarifications included, here apply to the

,plant, and.document the specific requirements that the replacement PRNM is intended, to meet for.the plant. .....

4.4.212.A,.4 Regulatory.Requirements for the Replacement The PRNM cOntrol room electronics are; System -Equipment. Qualification - Temperature qualified for'continuous operation Under the-and Humidity following temperature conditions: 5 to 50 'C

, .' . ,*I; [41. to 122 'F]. i'The GGNS control room Plant'specific"actionwill confirm that the temperature range is 60'F to 90'F. This is maximinm:c6ntrol room temp5eratures prus , within'th rianige'for which PRNM equipment is mounting~panel temperature rise, allowing~for qualified.; The'design process includes actions heat'lad of the PRNM equipment, doesnot to confirm that the PRNM equipment, as exceed thWe temperatures presented-in thePRNM installed in the plant, is qualified for the LTRI.and that control room humlidity is,. environmental limits, including temperature rise maintainedwithin the~limits-stated in the PRNM measurements. /

LTR.ýlThis'evaluation wvillý:normally be accotmplished, by determining the. operating The PRNM control room electronics are temperature 6f the currentle'quipment which;will qualified for continuous operation under the be'usedas(a:bounding~value because~the heat following relative humidity conditions: 10 to lad 6f thee-eplacement-system4is less than the 90% (non-condensing). The GGNS control cureitosystbm while the panel structure, and room humidity range is 20% to 50%. This is thus cooling, remains essentially the same. within the range for which PRNM equipment is Documentation of the above adtionjincluding qualifie& Thequalification results will be the specificimethod used for.the required , docuumented in a plant unique "Qualification confiihmation.should be included in plant- Summary'!.. .- .

specific licensing submittals.

4.4.2.2.2.4 Regulatory Requirements'for the Replacement ThePRNM control room electronics are Systemd v!Euipment Qualification - Pressure, qualified for continuous operation under the Plant-',spe i cac~tio nwf;ll cdnfnin that the ' following.pressure conditions: 13 - 16 psia. The maxin*.i um.. tr~l room. pressure does 'int '. GGNS control room pressure range is 0.1 to xce'ed thelimits presented in*the "1.0 PRM LTR. in..wg. This is within the range for which Ary l ... '"differetal 6i.. i'side t". outside PRNM equipment is qualified. The ihe'mouhtingIpan'1el sincehd assumed to b1 nergligible qualification results will be documented in a eand'thetel. are flot sealed isno plant unique "Qualification Summary..

fdrced' 6bbfihg or ventilati6i. -Do~utiihtatiOn 6f this'ctioii arnt'dthe rieqdired corifitiatidn should beifncluded" i6 plant-specific licensgng " . , . -'

__________ szibm itttalsj'." * .. . ... ". .' " ,. .

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0000-0102-0888-RI Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 4.4.2.2.3.4 Regulatory Requirements for the Replacement The PRNM control room electronics are System -Equipment Qualification -Radiation qualified for continuous operation under the Plant-specific action will confirm that the following conditions: Dose Rate < 0.001 Rads maximum control room radiation levels do not (carbon)/hr and Total Integrated Dose exceed the limits presented in the PRNM LTR. (TID) < 1000 Rads (carbon). The GGNS Documentation of this action and the required control room dose rate is 0.5 mRad/hr gamma.

confirmation should be included in plant- The control room Total Integrated Dose is 1.8 x specific licensing submittals. 102 Rads gamma. This is within the range for which PRNM equipment is qualified. The qualification results will be documented in a plant unique "Qualification Summary.

4.4.2.3.4 Regulatory Requirements for the Replacement Evaluations to confirm that the maximum System -Seismic Qualification . se~ismic accelerations at the mounting locations Polantspecific action or analysis will confirmm of the equipment do not exceed qualification that the maximum seismic accelerations at the Iimitshof te equipment is completed as part of

.-mounting locationsof the equipment-(control the normal design change process. The seismic roomzfloor.a.ccelefation-plus panle: ... qualification results'Will be documented in amhlification)y'for bbthýOBE an"d SSE spectrums '!Qualification Summary".

do ,tf ex~ceed the lit-hits stated in the PRNM LTR-.-Dbo'umentation of this action and. the required[confirmation should be.included in ,

plant~specific licensing submittaIls.

4.4.2.4.4 Reguilatory.'Requirements for the Replacement Systeri ,EM;I'Qualification ,.

Thi uhitiliy s~h6uld 'estabhish or document practices to control emission sources, maintain good grounding practices and maintain equipment and cable separation.

l).Conirolliiiig Emissiozis.

I. 1) Controlling Emissions a)Portable Transceivers (walkie-talkies): .a) The qualificatJon levels used for the Estabhsh practices to in portbe transceivers prevent operattoh of close proximhty of NUMAC expected to PRNM result system exceed those from portable equipment sensitive tb-ouch emissioiis'* transceivers, even if such transceivers are (NOTE: Thlequalifhafiaon levels used for . operated immediately adjacent to NUMAC Sthe'NUMACPPRNM'exceed those equipment. GGNS generally prohibits expected to result froim portable , operation of portable transceivers near transceivers, even if ýuch transceivers are sensitive equipment, and if warranted, operated itmmediately' adjacent to the requires positioning of warning signs at

.NUMC eqiipme'ntt.)- critical locations throughout the plant.

"".".... .Placement of warning signs is evaluated as part of the modification process. (NOTE:

S:,' 1J .- . , ; The GGNS control'room is a radio exclusion area.)

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0000-0102-0888-RI Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 4.4.2.4.4 b) ARC Welding: b) The qualification levels used for the (cont.) Establish practices to assure that ARC NUMAC PRNM system minimize the welding'activities do not occur in the likelihood of detrimental effects due to ARC vicinity of equipment sensitive to such welding as long as reasonable ARC welding emissions, particularly during times when control and shielding practices are used.

the potentially sensitive equipment is ARC welding is only performed at GGNS required to be operational for plant safety. with specific work orders and directions, (NOTE: The qualification levels used for and is known to have the potential to affect NUMAC PRNM minimize the likelihood: operation of I&C equipment at a number of of detrimental effects due to ARC welding locations in the plant, Therefore, ARC .

as long as reasonable ARC welding control welding activity is only performed when any and shielding practices are used.) potential effect on I&C equipment is tolerable relative to plant operation.

c) Limit Emissions from-New Equipment: c) EMI emissions from new equipment Establish

. .., 1 CAC* practices

. I . ' '. for new

. equipment

- . and installed at GGNS are evaluated as part.of plantmt odifications to assure that they the'no~n:nfl design modification process

.either do not produce unacceptable levels . described in GGNS procedures.

.. femisions, or ifistallation shielding, .

filters', grounding-or other methods prevent I~ such '6"missions from reaching othe.r-potentially sensitive equipment. ,These practides 4hould address.both radiated emissions and conducted emissions,'-

liarticiilarly conducted emissionson power lines: andpower, distribution-systems,;.

Related to power distribution, both, the.

effeciso6f newequipmentinjecting: noise on the-power, system and-the poWer system cdibducting noise tothe 6d0ntected. - 'A eqtipment should be-addressed' *(NOTE:

For the, qualification ofthe.PRNM.

equipment includes; 6missions~testing4) .

2) Gr6unding Practices - 2) Grounding.. Practices Existihg.Grdcunding;System:ý The',pecific. The PRNM system equipment is being installed details' indeffectiveness ofthe original ., ` ' in place of existing Power Range Monitor grounding'system in BWRs varhed significantly. (PRM) system electronics. The replacement As patof-the Imodificationprocess, idditify any system interfaces with the same cables and known or likely'problem 'areas based o66' wiring at the panel interfaces as the current previous; experiencetand'inclulde in ,the 1' system, including ground bus connections. No modification programleither an evaluation 'step problems have been identified with the current to determ'ineif problems actually exist;'or PRM system related to grounding or grounding include'corrective action as:part of the*'. practices. The original installation included modificatioh. (NOTE: The PRNM equipment is specific grounding practices designed to being, installed in plfc6 of existing PRM * %- minimize performance problems. The electronic's Which is' generally;more sensitive to replacement PRNM system is less sensitive to EMI than'the NUMAC equipnment;, As l'6n'g, as grounding issues than is the current system and the plant Has experienced no significant includes specific actions in the wiring inside the problems With the PRM, no problems-are, panel to maximize shielding and grounding anticipate.dLwith tile PRNM provided grounding effectiveness.,

i' done in a.comparable manner.)

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0000-0102-0888-R1 Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 4.4.2.4.4 Grounding Practices for New Modifications:

(cont.) New plant modifications process should include a specific evaluation of grounding methods to be used to assure both that the new equipment is installed in a way equivalent to the conditions used in the qualification. (NOTE: NUMAC PRNM equipment qualification is performed in a panel assembly comparable to that used in the plant.)

,3,)s' rEquipment.and.Cable Separation-.,: 3) Eauinment and Cable Senaration

"Clling:, Establish.ficbling practices to

... The original.PRM system cable installation iassiu .rethatsigfialcabe_ with te requirements met this objective. The pote* n tial to. be "r eeiivers"- are,keP replacement PRNM system uses the same

., ;spnarate from cables that are sources of, cable routes and paths at comparable energy o1,:se'. (N.OTE:The, original PRM cable levels where feasible., Because no specific problem has been identified in the current

.,, .. i,nsgtalationrequirements met.this.

.I i,. Abjerctive. Thy reptaqement PRNM system, no special action is necessary for the S.,uses the same cableroutes d so PRNM modification. The existing system

,,unless some specific problem, has been cabling complies with applicable GGNS

.*.:. identified in the current system, no cable routing and separation requirements.

special action should be necessary for Additionally, the modification process is the PRNM modification.) performed in accordance with the existing

Equipment: Establish equipment separation criteria.

separation and shielding practices for the installation of new equipment to s.ISii nulate that equipment's qualification

'condition, both relatiV6 to susceptibility and emissions. (NOTE: The original PRM. cabinet-desi6ri ffiet thisbbjedti'e.

The.replacement'PRNM uses the same

1 mdibfiting cibin'et,.and'used an.

equivalefitmounting 'assembly-for.

qualification. 'No special acti6nishould.

belnecessary, for thePRNM modification.) , .

The plani-specfic li~ensin*.*ub'mittalA shoiduld identify the 'ptactices that are in place'orvill be applied f6rt te PRNM modification to"addlress each of thýe&ove' I>et*. *a,items.: , " , L odp

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0000-0102-0888-RI Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 6.6 System Failure Analysis The .utility must confirm applicability of the failure analysis conclusions contained in the PRNM LTR by the following actions:

1. Confirm that the events defined in EPRI 1. The GGNS Technical Specification Report No. NP-2230 or in Appendices F and G Surveillance Requirements for the Reactor of Reference 11 of the PRNM LTR, encompass Protection System (RPS) are based on Reference the events that are analyzed for the plant; II of the PRNM LTR as discussed in the GGNS Technical Specification Bases (Section 3.3.1.1, Reactor Protection System Instrumentation, Reference 9 in GGNS TS Bases). Therefore, the Reference 11 failure analysis is applicable to GGNS. The overall redundancy and diversity of a; sensors;available to provide trip signals in the RPS meets NRC-approved licensing basis requirements.

2. Confirm that the configuration implemented 2. The proposed PRNM configuration is byIthe plant is with inthe limitsdescribed in the included among the configurations described in LTR; and:."' " the PRNM LTR, as itemized under Section 2.3.4 above. The proposed configuration is being designed by GEH and is within the limits described in the LTR...

3. "Prepare a-plant-'specific '10CFR50:59' *' 3. The requirements of IOCFR50.59 applies to evaluaYion'6f 'the nmodi fication p'erthe applicable the PRNMS nmidification in accordance with plant procedures. applicable plant procedures.

These confirmations and conclusions should be documented in the plant-specific licensing submittals for the PRNM modification.

[Reference II of the LTR is NEDC-30851P-A, , I'; , ' t * , ;

"Technical Specification Improvement Analysis

" '1.'

, *. c , . . .

for BWR Reactor Protection System", Licensing Topical Report, GE Nuclear Energy, Class III (proprietary), dated March 1988.

7.6 lrnpa'ct~n UFSAR Applicable sections of the FSAR are reviewed The plant-specific action required for FSAR and appropriate' revisions of those sections are updates Will vary between plants. In all cases, prepared and approved as part of the normal however, existing FSAR documents should be design process. Following implementation of reviewed-to identify areas that have descriptions the design modification, and closure of the specific to the cuirenrt PRNM using the general design pac age,,the FSAR revisions are guidance of:Sections 7.2 through 7 5 of the included in the updated FSAR as part of the PRNM LTR to identify potential areas impacted. periodic 10 CFR 50.71 (e) FSAR update The utility should include in the plant-specific submittal.

lidesing i ', -

sbin*mittl'a statement of the plans f6r W A .*

w uddating the plant FSAR f6r the PRNM project.

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0000-0102-0888-Rl Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 8.3.1.4 APRM-Related RPS Trip Functions - Functions Covered by Tech Specs I. Delete the APRM Downscale function, if 1. GGNS does not have an "APRM currently used, from the RPS Instrumentation Downscale" RPS Trip Function Tech Spec.

"function" table, the related surveillance requirements, and, if applicable, the related setpoint, and related descriptions in the bases sections.

2. Delete the APRM Flow-biased Neutron 2. APRM Flow Biased Simulated Thermal Flux Upscale function, if currently used, from Power - High and the APRM Fixed Neutron the RPS Instrumentation "function" table, the Flux - High functions have been retained.

related surveillance requirements, and, if applicable, the related setpoint, and related descriptions in the bases sections. Replace these with the corresponding entries for the APRM Simulated Thermal Power - High and the APRM Neutron Flux - High functions. Perform analysis necessary to establish setpoints for added trips.

3. Add the APRM Neutron Flux - High 3. The current APRM Neutron Flux- High, (Setdown) function, if not currently used, to the Setdown function has been retained.

RPS Instrumentation "function" table, add the related surveillance requirements, and, if applicable, the related setpoints, and related descriptions in the bases sections. Perform analysis necessary to-establish setpoints for added trips.

8.3.2.4 APRM-Related RPS Trip Functions - Minimum Number of Operable APRM Channels I. For the 4-APRM channel replacement I. The PRNM modification and the proposed configuration, revise the RPS Instrumentation Tech Spec and Bases change implement the "function" table to show 3 APRM channels, changes as described in the PRNM LTR for a shared by both trip systems for each APRM BWR6 plant. GGNS Tech Specs do not include function shown (after any additions or deletions notes related to APRMs that call for removal of per PRNM LTR Paragraph 8.3.1.4). Add a "2- shorting links or references to special conditions out-of-4 Voter" function with two channels related to loss of all LPRMs from the "other" under the "minimum operable channels". For APRM. Therefore, no related note changes are plants with Tech Specs that include a footnote required.

calling for removing shorting links, remove the references to the footnote related to APRM A "2-out-of-4 Voter" function with two channels (retain references for SRM and IRM) and delete under the "minimum operable channels" have any references to APRM channels in the been added as Function 2.e.

footnote. For smaller core plants, delete the notes for and references to special conditions related to loss of all LPRMs from the "other" APRM.

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0000-0102-0888-Ri Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 8.3.2.4 2. Review action statements to see if changes 2. Action statement changes in the proposed (cont.) are required. If the improvements documented Tech Spec change are consistent with the'PRNM in Reference II have not been implemented, LTR described changes for plants with then changes will likely be required to Improved Tech Specs. GGNS has previously implement the 12-hour and 6-hour operation switched to the ISTS format.

times discussed above for fewer than the minimum required channels. If Improved Tech Specs are applied to the plant, action statements remain unchanged.

3. Revise the Bases section as needed to 3. The proposed Tech Spec Bases changes replace the descriptions of the current 6- or 8- include revisions to the descriptions of the APRM channel systems and bypass capability architecture, consistent with the PRNM LTR.

with a corresponding description of the 4-APRM system, 2-out-of-4 Voter channels (2 per RPS system), and allowed one APRM bypass total.

8.3.3.4 APRM-Related RPS Trip Functions -

Applicable Modes of Operation

1) APRM Neutron Flux - High (Setdown) 1) Tech Spec and Bases changes are Change Tech Spec "applicable modes" entry, if consistent with the PRNM LTR.

required, to be Mode 2 (startup). Delete references to actions and surveillance requirements associated with other modes.

Delete any references to notes associated with "non-coincidence" mode and correct notes as required. Revise Bases descriptions as required.

2) APRM Simulated Thermal Power - High 2) The APRM Flow Biased Simulated Retain as is unless this function is being added Thermal Power - High function has been to replace the APRM Flow-biased Neutron Flux retained and is consistent with the PRNM LTR.

Trip. In that case, add requirement for operation in Mode I (RUN) and add or modify Bases descriptions as required.

3) APRM Neutron Flux - High 3) The APRM Fixed Neutron Flux - High Retain as is unless this function is being added function has been retained and is consistent with to replace the APRM Flow-biased Neutron Flux the PRNM LTR.

Trip. In that case, add requirement for operation in Mode I (RUN) and add or modify Bases descriptions as required.

4) APRM Inop Trip 4) The current GGNS TS require this function Delete any requirements for operation in modes only in Modes I and 2.

other than Mode I and Mode 2 (RUN and STARTUP). Revise the Bases descriptions as needed.

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" 0000-0102-0888-RI Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 8.3.4.1.4 APRM-Related RPS Trip Functions - Channel Checks/ Instrument Checks a) For plants without Channel Check a) The GGNS Technical Specifications requirements, add once per 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or once per currently include a once-per-shift Channel day Channel Check or Instrument Check Check requirement for the APRM Functions requirement for the three APRM flux based (except for Inop). The APRM Function Channel functions. No Channel Check requirements are Check requirement has been changed from once added for APRM Inop function. Plants with per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to once per day (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ). The once per 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or once per shift requirements new Channel Check SR 3.3.1.1.19 with a may change them to once per day. frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months has been added to TS 3.3.1.1 and applies to Functions 2.a, 2.b, 2.d, 2.e, and 2.f.

b) For plants with 4 full recirculation flow b) GGNS currently uses 8 recirculation flow channels and with Tech Specs that call for daily transmitters. Associated surveillances have been or other channel check requirements for flow included in those for the APRM Flow Biased comparisons under APRM Flow Biased. Simulated Thermal Power - High and the OPRM Simulated Thermal Power Trip, delete those Upscale functions (the latter because of the requirements. Move any note reference related OPRM trip enable function). The proposed to verification of flow signals to Channel Technical Specification and Bases changes for Functional Test entry. the recirculation flow related SRs are consistent with the PRNM LTR but with some expansion to clarify that the recirculation flow functionsalso support the OPRM Upscale. function trip enable.

8.3.4.2.4 APRM-Related RPS Trip Functions - Channel Functional Tests a) Delete existing channel functional test a) .The proposed Technical Specification and requirements and replace with a requirement for Bases changes related to Channel Functional a Channel Functional Test frequency of each Tests are consistent with the PRNM LTR.

184 days (6 months) [delete any specific requirement related to startup or shutdown except for the APRM Neutron Flux - High (Setdown) function as noted in Paragraph 8.3.4.2.2(1) of the PRNM LTR. Add a notation that both the APRM channels and the 2-out-of-4 Voter channels are to be included in the Channel Functional Test.

b) Add a notation for the APRM Simulated b) The proposed Technical Specification and Thermal Power - High function that the test shall Bases changes to Ch~annel Functional Test for include the recirculation flow input processing, the APRM functions include a notation, excluding the flow transmitters, applicable to the Flow Biased Simulated Thermal Power - High (Function 2.d) and the CAUTION: Plants that have not implemented OPRM Upscale (Function 2.0, consistent with the APRM surveillance improvements of the PRNM LTR requirements, that the SR Reference II of the PRNM LTR, or those that includes the recirculation flow input processing, have continued to use a weekly surveillance of excluding the flow transmitters. However, the scram contactors, may need to implement or PRNM LTR includes this notation only in the modify surveillance actions to continue to Bases. For the GGNS Technical Specification, I the Channel Functional Test has been added as 10 of 19

0000-0102-0888-RI Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 8.3.4.2.4 provide a once per week functional test of scram SR 3.3.1.1.20, and has been expanded to also (cont.) contactors. (Prior to changes defined in apply to the OPRM Upscale function (to cover Reference 11, the weekly APRM functional test OPRM Upscale trip enable).

also scramprovides a weekly test of all automatic contactors.) The functional test procedure will be established to test all of the hardware required to produce the trip functions, but not to directly re-test software-only (firmware-only) logic. The APRM automatic self-test function monitors the integrity of the EPROMs storing all of the firmware so that if a hardware fault results in a "change" to the firmware (software), that fault will be detected by the self-test logic. The continued operation of the self-test procedures is monitored by the built-in "watch-dog timer" function, so if for some unforeseen reason the self-test function (lowest priority in the instrument logic) stops running, that failure also will be detected automatically. To provide further assurance that the self-test function continues to operate, a step will be included in the APRM Channel Check surveillance to confirm that self-test is still running.

8.3.4.3.4 APRM-Related RPS Trip Functions - Channel Calibrations a) Replace current calibration interval with a) The proposed Technical Specification and either 18 or 24 months except for APRM Inop. Bases changes related to Channel Calibration Retain Inop requirement as is (i.e., no has been changed to 24-month interval, with no requirement for calibration). calibration required for the lnop Function, consistent with the PRNM LTR.

b) Delete any requirements for flow calibration b) Consistent with the PRNM LTR and calibration of the 6 second time constant requirements, the proposed Tedhnical separate from overall calibration of the APRM Specification and Bases changes add a notation Simulated Thermal Power - High function, applicable to the Channel Calibration for the APRM Flow Biased Simulated Thermal Power -

High function to exclude requirements to calibrate the recirculation flow transmitters.

However, the PRNM LTR includes this notation only in the Bases. For the GGNS Technical Specification, the notation has been included in Channel Calibration SR 3.3.1.1.10. In addition, current SRs 3.3.1.1.16, which verifies the simulated thermal power time constant, and 3.3.1.1.18, which adjusts the flow control reference card, have been deleted.

11 of 19

0000-0102-0888-RI Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 8.3.4.3.4 c) Replace every 3 day frequency for c) The current GGNS Technical (cont.) calibration of APRM power against thermal Specifications include a "weekly" frequency for power with a 7 day frequency if applicable. the verification of APRM power versus calculated plant thermal power so no change in that frequency is required to be consistent with the PRNM LTR.

d) Revise Bases text as required. d) The proposed Technical Specification Bases changes related to Channel Calibrations are consistent with the PRNM LTR.

8.3.4.4.4 APRM-Related RPS Trin Functions - Resnonse The proposed Technical Specification and Bases Time Testing changes related to Response Time Testing (new SR 3.3.1.1.22 and Table 3.3. 1. 1- 1) are consistent Delete response time testing requirement from with the justification in the PRNM LTR Tech Specs or plant procedures, as applicable, Supplement 1. "

for the APRM functions. Replace it with a Consistent with the PRNM LTRs, the only response time testing requirement for the 2-out- APRM Function to which the SR applies is of-4 Voter "pseudo" function, to include the Function 2.e (voter). However, while the output solid-state relays of the voter channel PRNM LTRs justified reduced response time through the final RPS trip channel contactors. testing frequency for Function 2.e, no TS markups were includedto implement an 4W" Frequency of response time testing shall be greater than 4 (the total number of voter determined using four 2-out-of-4 Voter channels). Therefore, a note has been added to channels, but tests may alternate use of 2-out-of- the GGNS SR Table 3.3.1.1-1 to define that 4 Voter outputs provided each APRM/RPS "n=8" for Function 2.e.

interfacing relay is tested at least once per eight refueling cycles (based on a maximum 24 month The PRNM LTR Supplement 1justified cycle), and each RPS scram contactor is tested at response time testing at a rate that tested one least once per four refueling cycles. Each 2-out- RPS Interface relay every plant operating cycle, of-4 Voter output shall be tested at no less than with tests using the APRM output for one cycle half the frequency of the tests of the APRM/RPS and the OPRM output for the next cycle. This interface relays. Tests shall alternate such that yields a testing rate once per 8 operating cycles one logic train for each RPS trip system is tested for each RPS interface relay and once per every every two cycles. 16 operating cycles for the APRM or OPRM output.

The PRNM modification includes redundant APRM trip and redundant OPRM trip outputs from each 2-Out-Of-4 Voter channel. One of the OPRM outputs and one of the APRM outputs are connected in series to the coil of one RPS interface relay. The second OPRMoutput and the second APRM output from the 2-Out-Of-4 Voter channel are connected in series with the coil to a second RPS interface relay. There are 8 total RPS interface relays.,

8.3.5.4 APRM-Related RPS Trip Functions - Logic System Functional Testing (LSFT) The GGNS Technical Specifications have been Revise Tech Specs to change the interval for changed to delete the LSFT requirement from LSFT from 18 months to 24 months unless the the existing APRM Functions 2.a, 2.b, 2.c, and utility elects to retain the 18-month interval for 2.d. New SR 3.3.1.1.21 with a 24-month plant scheduling purposes. Delete any LSFT interval, has been added to TS 3.3.1.1 and requirements associated with the APRM applied to the new 2-Out-of-4 Voter function, 12 of 19

0000-0102-0888-RI Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 8.3.5.4 channels and move it to the 2-out-of-4 Voter APRM Function 2.e.

(cont.) channel. Include testing of the 2-out-of-4 voting logic and any existing LSFTs covering RPS relays.

8.3.6.1 APRM-Related RPS Trip Functions - Setpoints Add to or delete from the appropriate document ARTS is not applicable at GGNS. PRNM any changed RPS setpoint information. If setpoints and Allowable Values are re-calculated ARTS is being implemented concurrently with or confirmed using approved setpoint the PRNM modification, either include the methodology. The Allowable Values for the related Tech Spec submittal information with APRM RPS Functions are included in the the PRNM information in the plant-specific Technical Specifications or the COLR, submittal, or reference the ARTS submittal in comparable to what is currently in the GGNS the PRNM submittal. In the plant-specific Technical Specifications an'd consistent with the licensing submittal, identify what changes, if PRNM LTR.

any, are being implemented and identify the basis or method used for the calculation of setpoints and where the setpoint information or changes will be recorded.

8.4.1.4 OPRM-Related RPS Trip Functions - Functions An OPRM Upscale Function has been added to Covered by Tech Specs the GGNS Technical Specification as an "APRM Function" (Function 2.0 consistent with Add the OPRM Upscale function as an "APRM PRNM LTR Supplement 1, Appendix H.

function" in the RPS Instrumentation "function" Additions to the Technical Specification Bases table. Also add the related surveillance for Function 2.f have also been incorporated requirements and, if applicable, the related consistent with the PRNM LTR.

setpoint, and the related descriptions in the bases The'PRNM LTR Supplement I included some sections. Perform analysis necessary to establish setpoints for the OPRM Upscale trip. additional wording for Function 2.e (voter) to Add discussions related to the OPRM function address independent voting of the OPRM and in the'Bases for the APRM Inop and 2-out-of-4 APRM signals.

Voter functions.

NOTE: The markups in Appendix H of Supplement I to the PRNM LTR show the OPRM Upscale as an APRM sub-function.

However, individual plants may determine that for their particular situation, addition of the OPRM to the RPS Instrumentation table separate from the APRM, or as a separate Tech Spec, better meets their needs. In those cases, the basis elements of the Tech Spec as shown in this Supplement would remain, but the specific implementation would be different.

8.4.2.4 OPRM-Related RPS Trip Functions - Minimum A minimum operable channels requirement of Number of Operable OPRM Channels three, shared by both trip systems has been For the OPRM functions added (Section 8.4. 1), included in the Technical Specification for the includ in the OPRM Tech Spec a "minimum OPRM Upscale Function (Function 2.0. This operable channels" requirement for three OPRM addition, as well as addition of Required Action statements and Bases descriptions, is consistent channels, shared by both trip systems. with the PRNM LTR and LTR Supplement 1.

13 of19

0000-0102-0888-Rl Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 8.4.2.4 (cont.) Add the same action statements as for the However, to make the Required Action APRM Neutron Flux - High function for OPRM statements more consistent with the intent of the Upscale function. In addition, add a new action LTR, a note has been added to Required Action OPRM Upscale statement forstatmen forOPRfunction Upsalefuncion3.0.4 J.2 stating that LCO was revised 3.0.4(c)Technical in GGNS is applicable. LCO unavailable per Paragraph 8.4.2.2 of the PRNM Specificatisedmen Tefl 175 LTR. Specifications Amendment 175 to reflect NRC-approved changes regarding Mode change Revise the Bases section as needed to add limitations via BWROG TSTF-359, "Increased descriptions of the 4-OPRM system with 2-out- Flexibility in Mode Restraints."

of-4 output Voter channels (2 per RPS Trip System), and allowed one OPRM bypass total. Although applying LCO 3.0.4(c) is not included in the NUMAC PRNM LTR Supplement 1, it is consistent with the intent of Required Action J.2. Inclusion of Action J.2 is intended to allow orderly identification and Implementation of a resolution plan for an unanticipated design problem with the OPRM system without undue impact on normal plant operation. The LCO 3.0.4(c) application does not eliminate the requirement to restore the OPRM Upscale function to OPERABLE status within a 120-day period. Applying LCO 3.0.4(c) does, however, allow the plant to start up with the alternate detect and suppress provision of Action J.2 in effect during the 120-day period.

8.4.3.4 OPRM-Related RPS Trip Functions - A GGNS-specific Modes of Operation Applicable Modes of Operation requirement of> 24% RTP, consistent with the PRNM LTR Supplement I has been included in Add the requirement for operation of the OPRM the Technical Specification along with Upscale function in Mode I (RUN) when associated Bases descriptions.

Thermal Power is > 25% RTP, and add Bases descriptions as required.

8.4.4.1.4 OPRM-Related RPS Trip Functions - Channel Check A new Channel Check requirement of once per Add once per 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or once per day Channel day (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ), SR 3.3.1.1.19, has been added. It Check or Instrument Check requirements for the is applied to the OPRM Upscale function, OPRM Upscale function, consistent with the PRNM LTR.

8.4.4.2.4 OPRM-Related RPS Trip Functions - Channel Functional Test Add Channel Functional Test requirements with A new Channel Functional Test requirement a requirement for a test frequency of every 184 with a test frequency of every 184 days (Table days (6 months), including the 2-out-of-4 Voter 3.3.1.1-1) has been added toTS 3.3.1.1 as SR function. 3.3.1.1.20 for the OPRM Upscale and 2-Out-Of 4 Voter Functions consistent with the PRNM LTR, Supplement i. The third note to SR 3.3.1.1.20 (not included in the PRNM LTR) 14 of 19

0000-0102-0888-RI Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 8.4.4.2.4 clarifies that the SR also applies to the flow (cont.) input function, except the flow transmitters.

8.4.4.2.4 Add a "confirm auto-enable region" surveillance New "confirm auto-enable region" surveillance (cont.) on a once perroutage basis up to 24 month requirement, SR 3.3.1.1.23, has been added to TS 3.3.1.1 to require confirmation that the OPRM Upscale trip output auto-enable (not bypassed) setpoints remain correct. The SR Bases wording is consistent with the LTR.

8.4.4.3.4 OPRM-Related RPS Trip Functions - Channel Calibration Add calibration interval requirement of every 24 Channel Calibration SR 3.3.1.1.10 has'been months for the OPRM Upscale function, applied to the OPRM Upscale function to be consistent with the PRNM LTR Supplement 1.

Revise Bases text as required. The frequency of SR 3.3.1.1.10 has been changed from 184 days to 24 months, consistent with the LTR.

8.4.4.4.4 OPRM-Related RPS Trip Functions - Response Time Testing Modify as necessary the response time testing See response to 8.3.4.4.4. That response also procedure for the 2-out-of-4 Voter function to addresses OPRM.

include the Voter OPRM output solid-state relays as part of the response time tests, alternating testing of the Voter OPRM output with the Voter APRM output.

8.4.5.4 OPRM-Related RPS Trip Functions - Logic The LSFT surveillance (new SR 3.3.1.1.21) for System Functional Testing (LSFT) the OPRM Upscale Function is a test of the 2-Out-Of-4 Voter only, consistent with the PRNM Add requirement for LSFT every refueling LTR. Consistent with the PRNM LTR cycle, 18 or 24 months at the utility's option Supplement 1, revision of the related plant based on which best fits plant scheduling, procedures to include testing of the OPRM Upscale trip outputs from the 2-Out-Of-4 Voter is required. The procedure changes are made as part of the normal modification process.

8.4.6.1 OPRM-Related RPS Trip Functions - Setpoints There are four "sets" of OPRM related setpoints and adjustable parameters: a) OPRM trip auto-Add setpoint information to the appropriate enable (not bypassed) setpoints for STP and document and identify in the plant-specific drive flow; b) period based detection algorithm submittal the basis or method used for the (PBDA) confirmation count and amplitude calculation and where the setpoint information setpoints; c) PBDA tuning parameters; and d) will-be recorded. growth rate algorithm (GRA) and amplitude based algorithm (ABA) setpoints.

The first set, the setpoints for the "auto-enable" region for OPRM, as discussed in the Bases for Function 2.1, will be treated as nominal setpoints with no additional margins added. The 15 of 19

0000-0102-0888-RI Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 8.4.6.1 deadband for these setpoints is established so (cont.) that it increases the enabled region once the enabled region is entered. The settings are defined plant procedures.

The second set, the PBDA trip setpoints, will be established in accordance with the BWROG LTR 32465-A methodology, previously reviewed and approved by the NRC, and will be documented in the COLR.

The third set, the PBDA "tuning" parameter values, will be established in accordance with and controlled by GGNS procedures, within the limits established in the BWROG LTRs, or as documented in this submittal, and documented in the GGNS Core Operating Limits Report.

The fourth set, the GRA and ABA setpoints, consistent with the BWROG submittals, will be established as nominal values only, and controlled by GGNS procedures.

8.5.1.4 APRM-Related Control Rod Block Functions - ARTS is not applicable at GGNS.

Functions Covered by Tech Specs GGNS Technical Specifications currently do not If ARTS will be implemented concurrently with contain any APRM rod block functions.

the PRNM modification, include or reference those changes in the plant-specific PRNM submittal. Implement the applicable portion of the above described changes via modifications to the Tech Specs and related procedures and documents. In the plant-specific submittal, identify functions currently in the plant Tech Specs and which, if any, changes are being implemented. For any functions deleted from Tech Specs, identify where setpoint and surveillance requirements will be documented.

NOTE: A utility may choose not to delete some or all of the items identified in the PRNM LTR from the plant Tech Specs.

8.5.2.4 APRM-Related Control Rod Block Functions - See 8.5.1.4 above. No additional confirmation Minimum Number of Operable Control Rod of action required relative to minimum operable Block Channels channels as shown in the Technical Change the minimum number of APRM Specifications beyond that required by 8.5.1.4 channels to three, if APRM functions are above.

retained in Tech Specs. No additional action is required relative to minimum operable channels' beyond that required by Paragraph 8.5.1.4 of the PRNM LTR.

16 of 19

0000-0102-0888-RI Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 8.5.3.4 APRM-Related Control Rod Block Functions - See 8.5.1.4 above. No additional confirmation Applicable Modes of Operation of action required relative to applicable modes No action required relative to modes during of operation as shown in the Technical which the function must be available beyond Specifications beyond that required by 8.5.1.4 that required by Paragraph 8.5.1.4 of the PRNM above.

LTR unless APRM functions are retained in Tech Specs and include operability requirements for Mode 5. In that case, delete such requirements.

8.5.4.1.4 APRM-Related Control Rod Block Functions - GGNS Technical Specifications currently do not Required Surveillances and Calibration - contain any APRM rod block functions, or any Channel Check Channel Check requirements for the RBM rod Delete any requirements for instrument or block functions. Therefore, no change to GGNS channel checks related to RBM and, where Technical Specifications is required to applicable, recirculation flow rod block implement the PRNM LTR requirements. The functions (non-ARTS plants), and APRM RBM is not applicable to GGNS.

functions. Identify in the plant-specific PRNM submittals if any checks are currently included in Tech Specs, and confirm that they are being deleted.

8.5.4.2.4 APRM-Related Control Rod Block Functions - GGNS Technical Specifications currently do not Required Surveillances and Calibration - contain any APRM rod block functions.

Channel Functional Test Change Channel Functional Test requirements to identify a frequency of every 184-days (6 months).

In the plantrspecific licensing submittal, identify current Tech Spec test frequencies that will be changed to 184 days (6 months).

8.5.4.3.4 APRM-Related Control Rod Block Functions - GGNS Technical Specifications currently do not Required Surveillances and Calibration - contain any APRM rod block functions Channel Calibrations Change channel calibration requirements to identify a frequency of every 24 months. In the plant-specific licensingsubmittal, identify current Tech Spec test frequencies that will be changed to 24 months.

8.5.4.4.4 APRM-Related Control Rod Block Functions - GGNS Technical Specifications currently do not Required Surveillances and Calibration - contain any APRM rod block functions.

Response Time Testing None.

8.5.5.4 APRM-Related'Control Rod Block Functions - GGNS Technical Specifications currently do not Required Surveillances and Calibration - Logic contain any APRM rod block functions.

System Functional Testing (LSFT)

None.

17 of 19.

0000-0102-0888-RI Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 8.5.6.1 APRM-Related Control Rod Block Functions - ARTS is not applicable to GGNS.

Required Surveillances and Calibration -

Setpoints Add to or delete from the appropriate document any changed control rod block setpoint information. If ARTS is being implemented concurrently with the PRNM modification, either include the related Tech Spec submittal information with the PRNM information in the plant-specificsubmittal, or reference the ARTS submittal in the PRNM submittal. In the plant-specific submittal, identify what changes, if any, are being implemented and identify the basis or method used for calculation of setpoints and where the setpoint information or changes will be recorded.

8.6.2 Shutdown Margin Testing - Refueling Technical Specification and Technical As applicable, revise the Shutdown Margin Specification Bases changes to Specification Testing - Refueling (or equivalent Tech Spec) 3.10.8, Shutdown Margin (SDM) Test -

LCO(s), action statements, surveillance Refueling have been made by adding APRM requirements and Bases as required to be Function 2.e to LCO 3.10.8 and SR 3. 10.8.1..

consistent with the APRM Tech Spec changes implemented for PRNM.

None Specification 3.4.1, Recirculation Loops Changes are included in the proposed Tech Spec Operating Bases for LCO 3.4.1. Deleted statements related No action identified in the PRNM'LTR. to Fraction of Core Boiling Boundary and PBDS and Reference 4 (NEDO 32339-A).

These changes, although not directly addressed in the PRNM LTR, are consistent with the remainder of the PRNM modification and implementation of the Option III Stability Solution.

None Core Operating Limits Report Specification 5.6.5 has been modified to require the setpoints for APRM Function 2.f(OPRM Reporting requirements Section 5.6.5 does not Upscale) to be included in the COLR.

currently address the OPRM.

9.1.3 Utility Quality Assurance Program Quality assurance requirements for work performed at GGNS are, defined and described As part of the plant-specificlicensing submittal, in GGNS Quality Assurance Program Manual.

the utility should document the established program that is applicable to the project For the PRNM modification, GGNS has modification. The submittal should also contracted with GEH to include the following document for the project what scope is being PRNM scope: 1) design, 2) hardware/ software, 1 performed by the utility and what scope is being 3) licensing support, 4) training, 5) O&M 18 of 19

0000-0102-0888-RI Grand Gulf Specific Responses Required by NUMAC PRNM Retrofit Topical Report Section No. Utility Action Required Response 9.1.3 (cont.) supplied by others. For scope supplied by manuals and design documentation, 6) EMI/RFI others, document the utility actions taken or qualification of equipment, and 7) PRNMS planned to define or establish requirements for setpoint calculations.

the project, to assure those requirements are compatible with the plant-specific configuration. On-site engineering work to incorporate the Actions taken or planned by the utility to assure GEH provided design information into an compatibility of the GEH quality program with Engineering Change (EC) or to provide any the utility program should also be documented. supporting, interface design changes will be performed per requirements of applicable GGNS Utility planned level of participation in the procedures. Modification work to implement overall V&V process for the project should be the design change will be performed per GGNS documented, along with utility plans for procedures or GGNS-approved contractor software configuration management and procedures. GGNS participates in appropriate provision to support any required changes after reviews of GEH's design and V&V program for delivery should be documented. the PRNM modification.

For software delivered in the form of hardware (EPROMs), GGNS intends to have GEH maintain post delivery configuration control of

(

the actual source code and handle any changes.

GGNS handles any changes in the EPROMs as hardware changes under its applicable hardware modification procedures.

19 of 19

GE HitachiNuclear Energy I 0000-0103-7166-RO I

Title:

Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator: F.G. Novak Verified I IGEH External Date: 9/4/09 1Sheet I of 7 Appendix A Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations A-I

GE Hitachi Nuclear Energy I 0000-0103-7166-RO I

Title:

Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator: F.G. Novak Verified I I GEH External Date: 9/4/09 1Sheet 2 of 7 Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Grand Gulf Nuclear Station (GGNS) will be submitting a license application for the implementation of Power Range Neutron Monitor (PRNM). The bases for the license application are the referenced documents in the relevant licensing topical reports (Reference 1-3).

The PRNM developed for GGNS has three deviations from the referenced documents. These are summarized in Table I and discussed in detail below. The licensing topical reports explicitly allow for plant-to-plant variation of some features. These are not addressed herein.

Table 1. GGNS NUMAC PRNM LTR Deviations Function! PRNM LicensingBasis:: GGNS Design , Justificatin - .

Equipment

a. APRM Upscale / OPRM Upscale function OPRM Upscale Improved operating OPRM Upscale / voted separately from the function yoted with flexibility APRM Inop Function APRM Inop function the APRM Inop Logic function

b. OPRM Pre-Trip Alarm if any instability Alarm if the period Delete function that Alarm algorithm exceeds defined based algorithm does not afford timely alarm setpoints. exceeds defined operator action.

alarm setpoints.

c. Recirculation Flow The PCI uses 2 Total The PCI uses 4 Total Safety functions are not Processing Flow signals for the Flow Flow signals for the affected; design was Comparison. Flow Comparison. reviewed and 'approved for all plants in original report.

A-2

GE HitachiNuclear Energy I 0000-0103-7166-RO I

Title:

Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator: F.G. Novak Verified, T[GEH External Date: 9/4/09 Sheet 3 of 7 Technical Justifications

a. APRM Upscale / OPRM Upscale / APRM Inop Function Logic Licensing Topical Report NEDC-3241 OP-A Supplement I (Reference 3) Section 8.4.1.3 describes the logic wherein the OPRM Upscale function is voted separately from the APRM Inop function. That is, an APRM Inop in one APRM channel and an OPRM Upscale in another will result in two half-trips in each of the 2-out-of-4 voter channels, but no RPS trips.

Designed this way, when an APRM chassis keylock switch is placed in the "INOP" position, the APRM upscale trip signal sent to the 2-out-of-4 voter channels is set to trip. However, the OPRM trip output from that chassis continues to be processed normally. Typically this logic is of no consequence because if an APRM chassis (affecting both the APRM and OPRM channels) is declared inoperable, the APRM bypass can be used to bypass both the APRM and OPRM trips from that channel, which in turn modifies the logic in the 2-out-of-4 voter to be a 2-out-of-3 vote of both the APRM and OPRM trips from the remaining 3 channels. However, if the need to declare a second APRM/OPRM channel inoperable arises when another APRM/OPRM channel is already bypassed (and cannot be returned to service within the allowed out of service time), it is necessary to place the APRM and OPRM outputs from the second channel in the tripped condition to satisfy Technical Specification requirements. If the APRM channel is still sufficiently functional to process trip outputs, placing the keylock switch in the [NOP position will force a trip for the APRM channel, but not for the OPRM channel. Other action, such as disconnecting a fiber-optic cable to the 2-out-of-4 voters or removing power from the APRM chassis, is necessary to satisfy the requirement to place the OPRM channel in the tripped condition.

The automatic APRM Inop trip is intended to provide a trip when the APRM channel is known to be incapable of providing a trip based on normal functions. This trip occurs immediately even though the Technical Specification requirements allow a period of time for action. The automatic trip is provided to assure that conditions that may disable the APRM trip function do not go undetected. Since the OPRM trip function is implemented in the same equipment as the APRM trip function, conditions that could disable the APRM trip function would likely disable the OPRM trip function as well.

For the Grand Gulf PRNM, the OPRM Upscale function is combined with the APRM Inop function as the OPRM channel input to be voted. That is, an APRM Inop in one APRM channel and an OPRM Upscale in another will result in RPS trip outputs from all four 2-out-of-4 voter channels. Again this logic is typically of no consequence because if an APRM chassis (affecting both the APRM and OPRM channels) is declared inoperable, the APRM bypass can be used to bypass both the APRM and OPRM trips from that channel, which in turn modifies the logic in the 2-out-of-4 voter to be a 2-out-of-3 vote of both the APRM and OPRM trips from the A-3

GE HitachiNuclear Energy I 0000-0103-7166-RO l

Title:

Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator: F.G. Novak Verified [GEH External Date: 9/4/09 Sheet 4 of 7 remaining 3 channels. This design allows using the APRM chassis keylock switch to place APRM and OPRM outputs from a second channel in the tripped condition when another APRM/OPRM channel is already bypassed (and cannot be returned to service within the allowed out of service time) without having to resort to other actions such as disconnecting a fiber-optic cable to the 2-out-of-4 voters or removing power from the APRM chassis.

For the GGNS PRNM, the Supplement I (Reference 3) Bases are changed as follows.

1. Page H-12: change the second paragraph as shown below.

The APRM System is divided into four APRM channels and four 2-out-of-4 voter channels. Each APRM channel provides inputs to each of the four voter channels. The four voter channels are divided into two groups of two each, with each group of two providing inputs to one RPS trip system. The system is designed to allow one APRM channel, but no voter channels, to be bypassed.. A trip from any one unbypassed APRM will result in a "half-trip" in all four of the voter channels, but no trip inputs to either RPS trip system. APR. . tr...p-a.uitns_ 2.n, 2.b, 2.a, and. 2.. .. .....-. in dependscly .Ctl - .f..

GPR. Upsele

n. ...

2.f.. Thzzfcc,

.R. any @.ay 2.;, 2.e, . 2.4-fi.. trip in ..... t...

.f. fu *etae hannezl, ....... in t...

..... lt. in t.. tr.ip inputs . to .... RP tR.i.. . syatz !;ie eizHnnnl (Al, A2, P!, afti 92) 9.

£i§Ialnly, apuntiRnt6 2. f; triýp g anyn1 ssed AYRfl ehannels will "esalt in afitil cm i.. fr.O . the' .8-6^*..

tor ohonnols. Three of the four APRM channels and all four of the voter channels are required to be OPERABLE to ensure that no single failure will preclude a scram on a valid signal. In addition, to provide adequate coverage of the entire core, consistent with the design bases for the APRM Functions 2.a, 2.b, and 2.d, at least [20] LPRM inputs, with at least [three] LPRM inputs from each of the four axial levels at which the"LPRMs are located, must be operable for each APRM channel. For the OPRM Upscale, Function 2.f, LPRMs are assigned to "cells" of [4]' detectors. A minimum of

[later] cells, each with a minimum of [2] LPRMs, must be OPERABLE for the OPRM Upscale Function 2.f to be OPERABLE.

Replaced deleted text with the following:

Since APRM trip Functions 2.a, 2.b, 2.d and 2.f are implemented in the same hardware, these trip Functions are combined with APRM Inop trip Function 2.c. Any Function 2.a, 2.b, 2.c or 2.d trip from any two unbypassed APRM channels will result in a full trip in each of the four voter channels, which in turn results in two trip inputs into each RPS trip system logic channel (Al, A2, BI, and B2). Similarly, any Function 2.c or 2.f trip from any two unbypassed APRM channels will result in a full trip from-each of the four voter channels.

A-4

GE HitachiNuclearEnergy I 0000-0103-7166-RO I

Title:

Grand Gulf Nuclear Station NUMACPRNM LTR Deviations Originator: F.G. Novak Verified GEH External Date: 9/4/09 Sheet 5 of 7

2. Page 1-113: For Function 2.e, change the 1st sentence of the 3rd paragraph to the following. "The 2-Out-Of-4 Voter Function votes APRM Functions 2.a, 2.b, and 2.d independently of Function 2.f."

b. OPRM Pre-Trip Alarms Licensing Topical Report NEDC-3241 OP-A (Reference 1) paragraph 3.3.3.1.2 states that the OPRM provides an oscillation pre-trip alarm when one of the instability algorithms (period based, amplitude based, or growth based) for an operable OPRM cell has exceeded user defined setpoints. The GGNS PRNM design will provide the OPRM pre-trip alarm when the Period Based Algorithm for an operable OPRM cell has exceeded user defined setpoints.

The pre-trip Alarms are intended to alert the operator of a developing instability event so that manual actions to avoid a reactor scram can be attempted. The OPRM LicensingTopical Reports (References 4-6) do not require pre-trip alarms.

For Option III, the OPRM cell signals are analyzed by the Period Based Algorithm (PBA), the Amplitude Based Algorithm (ABA), and the Growth Rate Algorithm (GRA). Automatic protection is actuated if any one of the three algorithms meets its trip conditions. However, only the PBA is required to provide protection of the Safety Limit Minimum Critical Power Ratio

(.LMCPR) for anticipated reactor instabilities. The other two algorithms (ABA and GRA) are included as defense-in-depth.

The PBA amplitude trip setpoint is the relative power level, or peak over average (P/A), at which the OPRM cell generates a trip signal,' provided the required number of Successive Confirmation Counts (SCCs) has been reached. The following two conditions must both be met for at least one cell in an OPRM channel to result in a PBA-based channeltrip.

1. The Successive Confirmation Count (SCC) reaches or exceeds the SCC trip setpoint.

2. The cell relative power level, or peak over average (P/A), signal reaches or exceeds the amplitude trip setpoint.

The GRA and ABA are designed to detect large, fast growing oscillations. Unlike the PBA, the ABA and GRA trips do not require a minimum number of SCCs to generate a trip signal.

During fast growing oscillation events, the trips will occur very early in the event with little time for effective operator action. Consequently, GRA and ABA pre-trip alarms are not provided in the GGNS PRNM design.

A-5

GE Hitachi Nuclear Energy I 0000-0103-7166-RO I

Title:

Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator: F.G. Novak Verified ]I GEH External Date: 9/4/09 1Sheet 6 of 7

c. Recirculation Flow Processing Licensing Topical Report NEDC-32410P-A Volume 1 (Reference 1) and Supplement I (Reference 3) Section 3.2.3.2.2 provide a Description of (flow processing) Logic in the PRNM System for plants with 4 Flow Channels and 8 Transmitters. Statement (c) explains that each APRM sends its total flow signal to two PRNM Communication Interface (PCI) chassis for the BWR6. Statement (d) explains that the PCI chassis compares two total flows, one from each of two APRMs, and that alarms are issued if the flow differs by more than a user-entered value.

In the replacement system at GGNS, each PCI will compare all four total flows. One total flow signal is from the APRM chassis in the same channel and one is from the LPRM in the other channel belonging to the same RPS trip system. The other two flow signals are provided by the other PCI chassis When the PCI determines that the flow differs by more than the user-entered value, it will transmit this status to its associated APRM, which will issue the alarm as described.

In order to make all four total flow signals available at each PCI chassis, fiber optic communication between all four PCI chassis will be established. Licensing Topical Report NEDC-3241 OP-A Supplement 1 (Reference 3) Figure E. 1.7 (BWR 6, Larger Core), which illustrates the APRM/PCI configuration block diagram, is amended to include a dotted line (fiber-optic) network between the PCI chassis. Additionally, Figure E.1.7 is also amended to show that each APRM chassis communicates with the PCI in the same channel, and each LPRM chassis communicates with the PCI belonging to the other channel in the same RPS trip system.

There is no effect on any APRM hardware.

By using all four total flow signals, the logic is the same as that described in Reference 1 for all plants with a similar configuration (4 Flow Channels and 8 Transmitters), and in Reference 3 for non-BWR6 plants with a similar configuration. The communication network between the PCI chassis agrees conceptually with Figure E.3.6 of Reference 3. Additionally, by providing all four flow signals for comparison, the logic satisfies what is discussed in Licensing Topical Report NEDC-32410P-A (Reference 1) Section 8.3.4.1.2, where it.is explained that any requirement for a daily flow comparison check is deleted from surveillances and replaced by the automatic comparison of all four total recirculation flow values. It is noted that the justification (Section 8.3.4.1.3) explicitly calls out comparison logic that includes all four channels.

Incorporating this logic has no affect on any safety functions.

A-6

GE Hitachi Nuclear Energy I 0000-0103-7166-RO

Title:

Grand Gulf Nuclear Station NUMAC PRNM LTR Deviations Originator: F.G. Novak Verified GEH External Date: 9/4/09 Sheet 7 of 7

\

References

1. NEDC-3241 OP-A Volume 1, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function,"

October, 1995.

2. NEDC-3241 OP-A Volume 2 -- Appendices, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," October, 1995.

3. NEDC-3241 OP-A Supplement 1, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function,"

November, 1997.

A-7

ATTACHMENT 7 GNRO-2010/00040 RESPONSE TO RAI No. 6 This is a non-proprietary version from which the proprietary information has been removed.

Portions of the enclosure that have been removed are indicated by an open and closed bracket as shown here (( I].

to GNRO-2010/00040 Page 1 of 20 Response to RAI No. 6 The response to RAI #1 provides the information necessary to evaluate the equipment configuration (e.g., identify the revisions/version of hardware, programmable devices, software) for the Grand Gulf PRNM system. The remainder of this response provides information that reconciles differences between the specific plant design, which is a BWR6 for Grand Gulf, and the topical report design description, whose supporting analysis is largely non-BWR6 based. Reconciliation of the differences between the plant specific and topical report designs is provided by showing additions to or deletions from the descriptions of References 6-1 and 6-2.

2.1.2 Hardware Impact Amend the first paragraph of the base report as follows to clarify the plant computer and AC power source interface for GGNS (additions shown in italics):

I]

Amend the third paragraph of the base report as follows to discuss the addition of "PCI" chassis for GGNS (additions shown in italics):

((I Modify the sixth paragraph of the base report as follows to clarify the AC power source interface for GGNS (additions shown in italics and deletions shown as sPrkethreugh):

I]

Amend the last paragraph of the base report as follows to discuss the addition of "PCI" chassis for GGNS (additions shown in italics and deletions shown as strikethm&gh):

to GNRO-2010/00040 Page 2 of 20 11 2.3.3 Plant-Specific Configuration Variations Modify the list of configurations in the base report after the first paragraph to reflect the GGNS configuration (additions shown in italics and deletions shown as st*iketh~auq4):

1]

3.2.3.2.2 PRNM System- 4 Flow Channels Modify the text of the base report as follows to reflect the GGNS configuration (additions shown in italics and deletions shown as stikethreh):

[1 1]

5.3.1 Major System Level Hardware Modify the text of the base report as follows to reflect the GGNS configuration (additions shown in italics and deletions shown as striket4reuq):

((

1]

to GNRO-2010/00040 Page 3 of 20 5.3.2.1 Average Power Range Monitor (APRM) Chassis Modify the second paragraph of the base report as follows to reflect the GGNS configuration (additions shown in italics and deletions shown as stFikethie6§.h):

((]

5.3.2.2 Power Range Neutron Monitor (PRNM) Communication Interface (GGNS)

Rod Bloc-k Monito (RBM) Chassis (not applicable to BWR-)

Replace Section 5.3.2.2 of the base report with the following to reflect the GGNS configuration (additions shown .in italics and deletions shown as str4kethg4h):

to GNRO-2010/00040 Page 4 of 20 5]

5.3.2.3 Two-Out-Of-Four Logic Module (1) 2-Out-Of-4 Voting Logic and Interface for APRM/OPRM Outputs to the RPS Clarify the GGNS BWVR& voting logic for Inop conditions of the base report by adding a new 7th paragraph (ahead of the last paragraph) under subheading (1) as follows:

))

5.3.2.6 Quad Low Voltage Power Supply Chassis Modify the second, third and fourth paragraphs of the base report as follows to reflect the GGNS configuration (additions shown in italics and deletions shown as 6tFikethFeugh):

((

to GNRO-2010/00040 Page 5 of 20 5.3.2.7 Fiber-Optic Network Modify the second paragraph of the base report as follows to reflect the GGNS configuration (additions shown in italics and deletions shown as st4kethr6hig4):

5.3.2.8 Electrical Connections Clarify the GGNS configuration of the base report by replacing all occurrences of "RBM" with "PCI".

5.3.3 Modules Used in PRNM Clarify the GGNS configuration of the base report by deleting the 11 h bullet (Remote I/O),

replacing all other occurrences of "RBM" with "PCI" and adding a 1 6 th bullet "Low Voltage Power Supplies (PCI only)".

5.3.3.1 386SX Computer Modules Clarify the GGNS configuration of the base report by replacing all occurrences of "RBM" with "PCI".

5.3.3.2 Display Controller Module Clarify the GGNS configuration of the base report by replacing all occurrences of "RBM" with "PCIr.

5.3.3.5 Open Drain IO Module Modify the first sentence of the first paragraph of the base report as follows to reflect the GGNS configuration (additions shown in italics and deletions shown as .t.i..et~.g.,):

1]

Amend the third paragraph of the base report as follows to reflect the GGNS configuration (additions shown in italics):

to GNRO-2010/00040 Page 6 of 20 1]

5.3.3.7 16-Channel Analog Output Module Replace Section 5.3.3.7 of the base report with the following to reflect the GGNS configuration:

11 5.3.3.8 Analog Module Clarify the first paragraph of the base report as follows to reflect the GGNS configuration by replacing all occurrences of "RBM" with "PCI".

5.3.3.9 FDDI Comm Module Replace Section 5.3.3.9 of the base report with the following to reflect the GGNS configuration (additions shown in italics and deletions shown as s6tikethF96iq):

to GNRO-2010/00040 Page 7 of 20 i]

5.3.3.10 GE I/O Communication Module Replace Section 5.3.3.10 of the base report with the following to reflect the GGNS configuration (additions shown in italics and deletions shown as stiketFh9ig4):

((I 5.3.3.12 GEDAC Module Clarify the GGNS configuration of the base report by replacing all occurrences of "RBM" with "PCI" 5.3.3.13 Broadcaster Module Clarify the GGNS configuration of the base report by replacing all occurrences of "RBM" with "PCI".

5.3.3.14 Display Module Clarify the GGNS configuration of the base report by replacing all occurrences of "RBM" with "PCI".

5.3.3.15 Front Panel Clarify the GGNS configuration of the base report by replacing all occurrences of "RBM" with "PCI".

5.3.3.16 Low Voltage Power Supply (LVPS) Modules Replace Section 5.3.3.16 of the base report with the following to reflect the GGNS configuration (additions shown in italics and deletions shown as st*kethprou):

6!

to GNRO-2010/00040 Page 8 of 20 5C 5.3.5,1 APRM/OPRMIPCl R-BM/Plant Computer Replace Section 5.3.5.1 of the base report with the following to reflect the GGNS configuration (additions shown in italics and deletions shown as strekethFrcgh):

((

to GNRO-2010/00040 Page 9 of 20

] D 5.3.5.2 LPRM Detectors to APRM Clarify the GGNS configuration of the base report by deleting the third sentence ("The detectors typically...") and all following text.

5.3.5.3 Flow Transmitters to APRM Clarify the GGNS configuration of the base report by deleting the fourth sentence ("In some cases...") and all following text.

5.3.7 Equipment Interchangeability Clarify the GGNS configuration of the base report by replacing "Both RBM" with "All PCI" in the second paragraph, and by replacing the remaining occurrence of "RBM" with "PCI."

5.3.8.1 Loss of Input Power Clarify the treatment of AC power input for GGNS of the base report by adding a new second paragraph and modifying the first, third and fourth paragraphs as follows (additions shown in italics and deletions shown as St*4kethFOUgh):

to GNRO-2010/00040 Page 10 of 20 I]

5.3.8.2 Abnormal Conditions Leading to Inoperative Status Clarify the GGNS configuration of the base report by deleting "and RBM" in the first sentence and modifying a note at the end of the section as follows:

((]

5.3.8.3 Abnormal Conditions Leading to Alarms Clarify the GGNS configuration of the base report by replacing "RBM" with "PCI" in the fourth bullet, and deleting the seventh and eighth bullets.

5.3.12 Testability and Self-Test Capability Clarify the GGNS configuration of the base report by replacing "RBM" with "PCI" in the title of Section 5.3.11.1 as follows (additions shown in italics and deletions shown as St*kethmugl4):

5.3.11.1 APRM AND PCIRRBM CHASSIS TESTING Clarify the GGNS configuration of the base report by replacing all occurrences of "RBM" with "PCI".

5.3.11.3 Interface and Overlap Testing Clarify the GGNS configuration of the base report by replacing "RBM" with "PCI" in the first paragraph.

Clarify the last paragraph of the base report as follows to reflect the GGNS configuration (additions shown in italics and deletions shown as s6tFkethreugh):

to GNRO-2010/00040 Page 11 of 20 I))

5.3.12 Calibration Clarify the GGNS configuration of the base report by replacing "RBM" with "PCIr.

Clarify the GGNS configuration of the base report by replacing all occurrences of "RBM" with "PCI" in the title of Section 5.3.12.1 and following text.

5.3.12.3 APRM Power Calibration Clarify the GGNS configuration of the base report by replacing all occurrences of "RBM" with "PCI".

5.3.13 Security Considerations Clarify the GGNS configuration of the base report by replacing all occurrences of "RBM" with "PCI".

5.3.16.1 Mechanical Design Aspects/Packaging Clarify the GGNS configuration of the base report by replacing "Each APRM, RBM" with "Each APRM, PCI " in the first sentence.

5.3.16.2 Weight Clarify the GGNS configuration of the base report by replacing "Each APRM, RBM" with "Each APRM, PCI" in the first sentence.

5.3.16.3 Mounting Clarify the GGNS configuration of the base report by replacing "Each APRM, RBM" with "Each APRM, PCI" in the first sentence.

5.3.16.4 Front Panel Clarify the GGNS configuration of the base report by replacing "Each APRM, RBM" with "Each APRM, PCI," in the first sentence.

5.3.17.1 Input Power Supplies Clarify the GGNS configuration of the base report by amending the subsection as follows (additions shown in italics, deletions shown as strikethre.gh):

to GNRO-2010/00040 Page 12 of 20 5]

5.3.17.3.2 Digital Output Signals Clarify the GGNS configuration of the base report by amending the 9th bullet as follows (additions shown in italics, deletions shown as str*kethFer9h):

Clarify the GGNS configuration of the base report by amending the 1 1th bullet as follows (additions shown in italics, deletions shown as strikethr,'gh):

to GNRO-2010/00040 Page 13 of 20 5.3.17.3.3 Digital Multiplexed Signals (Fiber-Optic)

Clarify the GGNS configuration of the base report by amending the text as follows (additions shown in italics, deletions shown as .tFiket.. .ug,,):

to GNRO-2010/00040 Page 14 of 20 1))

5.3.17.3.4 Digital Multiplexed Signals (non-Fiber-Optic)

Clarify the GGNS configuration of the base report by replacing the entire section with the following:

((I 5.3.17.6 Analog Input Signals, Electrical Characteristics Clarify the GGNS configuration of the base report by replacing "RBM" with "PCI" in item 2.

5.3.17.7 Analog Output Signals, Electrical Characteristics Clarify the GGNS configuration of the base report by replacing "RBM" with "PCI" in item 2.

5.3.18 User Interface and Controls Clarify the GGNS configuration of the base report by replacing "RBM" with "PCI" in the first paragraph.

5.3.19 Single Failure Considerations Clarify the GGNS configuration of the base report by replacing "RBM" with "PCI".

5.3.20 Replacement PRNM Installation Clarify the GGNS configuration by amending the first sentence of the second paragraph of the base report as follows (additions shown in italics, deletions shown as strikethFOUgh):

1]

to GNRO-2010/00040 Page 15 of 20 APPENDIX E PRNM BLOCK DIAGRAMS Replace Figures E.1.7, E.2.1, E.2.2, E.3.6 and E.5.6 of the base report with the following:

to GNRO-2010/00040 Page 16 of 20 E.1 APRM/PCI Configuration Block Diagrams Figure E.1.7 - Replacement 4 APRM Configuration, Grand Gulf to GNRO-2010/00040 Page 17 of 20 E.2 Replacement 2-Out-Of-4 Output Logic Interface Block Diagrams

((3 Figure E.2.1 - Replacement PRNM General Block Diagram, Grand Gulf to GNRO-2010/00040 Page 18 of 20 E.2 Replacement 2-Out-Of-4 Output Logic Interface Block Diagrams (Continued)

((

Figure E.2.2 - Replacement APRM / RPS Interface Block Diagram, Grand Gulf to GNRO-2010/00040 Page 19 of 20 E.3 APRM/Flow Interface Block Diagrams Figure E.3.6 - 4 APRM Replacement Configuration, Grand Gulf (See Figure E.1.7 for PCI Connections) to GNRO-2010/00040 Page 20 of 20 E.5 Power Distribution/interface Interface Block Diagrams

((

(31))

Figure E.5.6 - Replacement Configuration, Grand Gulf References 6-2. GE Nuclear Energy, Licensing Topical Report (LTR) NEDC-3241OP-A Volume 1 and NEDC-32410P-A Volume 2 -- Appendices, Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option Ill Stability Trip Function, October 1995 (ADAMS Ascension No. ML9605290009 includes NRC SE).

6-2. GE Nuclear Energy, LTR NEDC-3241OP-A Supplement 1, Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option Ill Stability Trip Function, November 1997 (ADAMS Ascension No.

ML9806120242 includes NRC SE).

ATTACHMENT 9 GNRO-2010/00040 RESPONSE TO RAI No. 10 (NON-PROPRIETARY VERSION)

This is a non-proprietary version from which the proprietary information has been removed.

Portions of the enclosure that have been removed are indicated by an open and closed bracket as shown here (( I

'A to GNRO-2010/00040 Page 1 of 7 Response to RAI No. 10 Setpoint Methodology -- non-OPRM GEH setpoints are calculated using the NRC approved methodology contained in NEDC-31336P-A (Reference 10-1). Conceptually, the GEH method is based on ISA Method 2, but leads to more conservative setpoints and is referred to as "Method 2 plus". According to this NRC approved methodology, the setpoints are calculated from the Analytic Limit (AL) using a top down approach, and margin is calculated by methodology:

Between the AL and the Allowable Value (AV),

Between the AL and the Nominal Trip Setpoint (NTSP), and

Between the AV and the NTSP.

The margin between the AL and the final NTSP is at least equal to, and generally greater than required.

GEH's setpoint methodology for operating plants uses single-sided distributions in the development of AVs and NTSPs for instrument channels that provide trips when the process variable being measured approaches the setpoint in one direction, as described in ISA Standard 67.04 Part II. Each of the setpoint functions for the GGNS PRNMS provide trips where the setpoint is approached in only one direction. Per the Safety Evaluation (SE) from the NRC for Reference 10-1:

"The GE methodology utilizes single-sided distributions in the development of trip setpoints and allowable values. ... The staff has stated that this methodology is acceptable provided that a channel approaches a trip in only one direction."

GEH's setpoint methodology for operating plants uses vendor instrument error specifications conservatively to provide setpoints that meet margin requirements to a high degree of

-confidence. This was demonstrated by actual data analysis during licensing of the GEH methodology (Reference 10-1). GEH's Instrument Setpoint Methodology was approved by the NRC in November 1995 while Regulatory Guide (RG) 1.105, Revision 2 was in use. RG 1.105 Revision 3 was introduced in December 1999, but the revised content, that quantified the confidence level to be 95%, did not invalidate or affect the approved GEH Setpoint Methodology. Per the SE from the NRC for Reference 10-1:

the BWROG presented data to show that although the GE setpoint methodology does not produce results with a defined confidence level, it was shown that the data analysis can produce results that have a high degree of confidence (95 percent confidence limits). ... By establishing that the 95 percent confidence intervals are bounded by the design allowances developed per NEDC-31336, GE has shown that the results produced by the GE setpoint methodology can be established with high confidence."

to GNRO-2010/00040 Page 2 of 7 The AL is a process parameter value used in the safety analysis and represents a limiting value for the automatic initiation of protective actions., From the AL, an AV is first calculated which has margin to the AL based on all measurement errors except drift. ((

)) All random errors are combined using Square Root of the Sum of the Squares (SRSS) method, and non-conservative bias errors are added algebraically. The AV represents the limiting value to which a setpoint can drift (as determined from surveillance) and still assure that the AL is protected. ((

)) The AV is the value specified in the Technical Specifications, and is an AL surrogate that assures the AL is protected if the setpoint does not exceed it.

Figure 10-1

'A to GNRO-2010/00040 Page 3 of 7 The approved GEH setpoint methodology basically results in two calculated NTSPs as shown in Figure 10-1. ((

)) This setpoint is called "NTSPI" and the AL/NTSP1 margin is based on all errors (PMA, PEA, AT, C, and Drift (D)), where AT is the instrument accuracy under Trip conditions. NTSP1 is the Limiting Trip Setpoint (LTSP), as the instrument setting can be no closer to the AL than NTSP1. However NTSP1 generally does not have the margin to the AV required by GEH methodology, and so is seldom the final adjusted NTSP, called NTSP(Adj), the second NTSP. ((

)) Relevant equations are shown below. [Notes: 91 refers to the random component for each error. The subscript L refers to the error for the whole instrument loop, and the errors are based on a one-sided approach to the setpoints.]

A]

AV = AL - AVMARGIN (for an increasing setpoint)

((I))

NTSP1 = AL - NTSPMARGIN (for an increasing setpoint)

= Limiting Trip Setpoint (LTSP)

Per NEDC-31336P-A (Reference 10-1), the errors used in the AV and NTSP calculations include errors for the Calibration Tools, the Standards used to calibrate the Calibration Tools, and the calibration procedure error tolerances (i.e., As Left Tolerances; ALTs). As shown in Figure 10-1, the Calibration Errors are included in the AV and NTSP1 calculations, and are also considered in the AV to NTSP(Adj) margin. All setpoints are reset to the NTSP, within the ALT, after calibration. The AV/NTSP margin additionally considers the Leave Alone Tolerances (LATs) (the tolerance within which calibration need not be performed), along with the Calibration errors discussed above (also see the equation below). All LATs are equal to their associated ALTs. Relevant equations are shown below.

(( )) (calculated for each instrument in the instrument loop)

LAT = ALT

'A to GNRO-2010/00040 Page 4 of 7 If the margin is not sufficient, the NTSP is adjusted to provide added margin.

If the NTSP has sufficient margin to meet these requirements for LAT, no adjustment to NTSP is required. However, if margin is not sufficient, the NTSP adjusted to provide added margin.

This adjusted NTSP is "NTSP(Adj)", and it is also checked for LER avoidance.

Setpoints -- non-OPRM - GGNS Specific Two sets of Average Power Range Monitor (APRM) setpoint calculations were performed to support installation of PRNMS at GGNS. The first set of calculations was based on the implementation of PRNM at the current licensed thermal power. In this set of calculations, the APRM Flow Biased Simulated Thermal Power-High setpoint was calculated because the function of this setpoint changed from supporting a stability solution to power excursion mitigation with the implementation of the Oscillation Power Range Monitor (OPRM) subsystem of Power Range Neutron Monitoring System (PRNMS) (discussed in the next section). A second set of calculations was performed to support Extended Power Uprate (EPU). In this set of calculations, the Neutron Flux-High (Setdown), Fixed Neutron Flux-High, Flow Biased Simulated Thermal Power-High, and APRM Downscale were calculated. Both sets of calculations included scrams and rod blocks. All calculations were based on the error terms associated with the upgraded PRNMS equipment. As Left Tolerances (ALTs) (the tolerance within which the device calibration reading is left after calibration) were considered in the calculations; these tolerances were based on the existing Recirculation Loop flow transmitters, and PRNMS flow and power electronics. The AV/NTSP margin includes instrument loop accuracy under calibration conditions, instrument calibration errors, and instrument drift errors. ((

Table 10-1 summarizes the ALs (AVs if no ALs) associated with the PRNMS setpoint calculations for GGNS. Columns for both CLTP and EPU values are shown. If a setpoint is not credited in a safety evaluation, there is no applicable AL, per GEH setpoint methodology.

A to GNRO-2010/00040 Page 5 of 7 Table 10-1 PRNMS-CLTP PRNMS-EPU Setpoint Function (% RTP) (% RTP) Source / Basis APRM Neutron 122 122 Protects against fast reactivity Flux Scram transients (EPU: Reference 10-2)

AL APRM Flow TLO: 0.65 Wd + 62.9 TLO: 0.58 Wd + 59.1 Protects against slow reactivity Biased Simulated transients (EPU: Reference Thermal Power SLO: 0.65 Wd+ 42.3 SLO: 0.58 Wd+ 37.4 10-2)

Scram t AVs APRM Flow TLO: 0.65 Wd + 59.9 TLO: 0.58 Wd + 56.1 Prevents rod withdrawal and Biased Simulated alerts the operator if the power is Thermal Power SLO: 0.65 Wd + 39.3 SLO: 0.58 Wd + 34.4 significantly above licensed Rod Block t power level; the rod block function precedes a flow-biased AVs Scram (EPU: Reference 10-2)

APRM Setdown 20 20 Provides a redundant Scram (in Scram t addition to IRM High Flux) for reactivity transients in the AV Startup mode. (EPU:

Reference1 0-2)

APRM Setdown 14 14 Prevents rod withdrawal and Rod Block t alerts the operator for reactivity transients in the startup mode; AV the rod block function precedes a Scram. (EPU: Reference 10-2) t An AL is not applicable because this setpoint function is not used in any safety or transient analyses.

As an example, the following table provides a comparison of the calculated results in units of percent Rated Thermal Power (RTP) for the GGNS APRM Neutron Flux Scram, per GEH Instrument Setpoint Methodology. Note as stated earlier, the NTSP(Adj) is further away from the AL than NTSP1, the Limiting Trip Setpoint (LTSP).

'A to GNRO-2010/00040 Page 6 of 7 Parameter % RTP.

AL 122 AV 119.3 NTSP1 (LTSP) 118.9 NTSP(Adj) 117.3 References 10-3 and 10-4 provide calculation summaries and are available for NRC review.

Setpoints -- OPRM As described in Sections 4.4.2.8 and 4.4.3.7 of the License Amendment Request (LAR), the Oscillation Power Range Monitor (OPRM) setpoints are the nominal setpoints which are established using a comprehensive BWR Owners' Group (BWROG) methodology for stability analysis approved by the NRC (Reference 10-5). There is no Analytical Limit (AL) or Allowable Value (AV) with defined instrument error margins to the Nominal Trip Setpoint (NTSP) for the OPRM setpoints. Note that OPRM setpoints are not considered to be Limiting Safety System Settings (LSSSs) since stability is a special event and not an Anticipated Operational Occurrence (AOO) which define LSSSs.

The OPRM Period Based Detection Algorithm setpoints (Oscillation Amplitude and Successive Confirmation Counts setpoints) are not in the Technical Specifications, consistent with the sample Technical Specification approved in Reference 10-6. These setpoints are established as nominal values based on cycle specific reload stability analysis in accordance with Reference 10-5 and included in the Core Operating Limits Report (COLR).

The OPRM Upscale function auto-enable (not bypassed) region is established generically to correspond to reactor power greater than or equal to 30% of rated, and core flow (implemented as Recirculation drive flow) less than or equal to 60% of rated per Reference 10-5. Note that it is conservative to use Recirculation drive flow in place of core flow for the OPRM Upscale function auto-enable region boundary. The Current Licensed Thermal Power (CLTP) at Grand Gulf is 1.7% higher than the Original Licensed Thermal Power (OLTP). The OPRM Upscale function auto-enable region boundary is scaled such that the setpoint at the CLTP conditions is at the same absolute power as in the OLTP conditions (i.e., at 29% of CLTP).

OPRM Upscale function auto-enable (not bypassed) power and core flow setpoints are permissive setpoints. These setpoints are not explicitly modeled in stability analyses.

Because 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.

A to GNRO-2010/00040 Page 7 of 7 Use of nominal setpoints for the OPRM Upscale function has been addressed during the licensing of the PRNMS at Browns Ferry Unit 1 (Reference 10-7) and at Monticello (Reference 10-8) previously. Note also that the OPRM trip setpoints are not listed in the BWR/6 Standard Technical Specifications (STS, Reference 10-9).

Demonstration calculations for the nominal setpoints of the OPRM Upscale function are available for review.

REFERENCES 10-1. NEDC-31336P-A, "General Electric Instrument Setpoint Methodology," September 1996.

10-2. NEDC-33004P-A, "Constant Pressure Power Uprate," Revision 4, July 2003.

10-3 GEH Report, 0000-0102-8815-R1, "Instruments Limits Calculation, Entergy Operations, Inc., Grand Gulf Nuclear Station, Average Power Range Monitor, Power Range Neutron Monitoring System (NUMAC)-CLTP Operation," Revision 1, May 2010.

10-4. GEH Report, 0000-0109-0169-RO-Draft A, "Instruments Limits Calculation, Entergy Operations, Inc., Grand Gulf Nuclear Station, Average Power Range Monitor, Power Range Neutron Monitoring System (NUMAC)-EPU Operation," Revision 0, January 2010.

10-5. NEDO-32465-A, "Licensing Topical Report, Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications, Licensing Topical Report," August 1996..

10-6. NEDC-32410P-A Supplement 1, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," Class III, November 1997.

10-7. TVA to NRC, "Browns Ferry Nuclear Plant (BFN) - Unit 1, Technical Specifications (TS) Change TS Request for Additional Information (RAI) Regarding Oscillation Power Range Monitor (OPRM) - (TAC No. MC9565)," NA-BFN-TS-443, October 2, 2006.

10-8. MNGP to NRC, "Response to Requests for Additional Information for License Amendment Request for Power Range Neutron Monitoring System Upgrade (TAC No.

MD8064)," September 16, 2008.

10-9. "BWR/6 Standard Technical Specifications and Bases," NUREG 1434, Revision 3.1 Volumes 1 and 2.

A

ATTACHMENT 10 GNRO-2010/00040 AFFIDAVIT SUPPORTING REQUEST TO WITHHOLD INFORMATION FROM PUBLIC DISCLOSURE PROVIDED BY GE-HITACHI NUCLEAR ENERGY AMERICAS, LLC 3901 CASTLE HAYNE ROAD WILMINGTON, NC 28401

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GE-Hitachi Nuclear'Energy Americas LLC AFFIDAVIT I, Edward Schrull, state as follows:

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

(2) The information sought to be withheld is contained in Enclosure I of GEH letter, GG-PRNM-168777-EC066, Edward Cooper (GEH) to Jon Langberg (Entergy), "Responses to Request for Additional Information - 4, 6, and 10," dated June 2, 2010. The, GEH proprietary information in Enclosure 1, which is entitled "Responses to Request for Additional Information 4, 6, and 10," is enclosed by double square brackets. ((This sentence is an examp.le.*3.)) Figures containing GEH proprietary information are identified with double square brackets before and after the object. In each case, the superscript notation {3) refers to Paragraph (3) of this affidavit that provides the basis for the proprietary determination.

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

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

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

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

c. Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, that may include potential products of GEH.

GG-PRNM- 168777-EC066, 6/2/2010 Affidavit Page 1 of 3

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

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

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

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

(8) The information identified in paragraph (2) above is classified as proprietary because it contains details developed by GEH from NEDC-3241OP-A, "Nuclear Measurement Analysis and Control Power Range Neutron (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," dated October .1995. Development of the NUMAC PRNM, and information related to the design, modification, analyses methodologies and processes related to the NUMAC PRNM was achieved at a significant cost to GEH. The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a. major GEH asset.

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

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

GG-PRNM- I68777-EC066, 6/2/2010 Affidavit Page 2 of 3

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

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

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

Executed on this 2 nd day of June 2010.

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

Wilmington, NC 28401 edward.schrull@ge. com GG-PRNM- I 68777-EC066, 6/2/2010 Affidavit Page 3 of 3

ATTACHMENT 11 GNRO-2010/00040 LICENSEE-IDENTIFIED COMMITMENTS 1 to GNRO-2010/00040 Page 1 of 2 LICENSEE-IDENTIFIED COMMITMENTS The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE SCHEDULED COMMITMENT (Check one) COMPLETION ONE-TIME CONTINUING DATE ACTION COMPLIANCE (If Required)

Entergy will provide a schedule to the NRC for 4 6/18/2010 responding to RAI Nos. 1, 2, and 3 by June 18, 2010.

RAI No.5 1/17/2011 Entergy will:

(1) Confirm the worst-case environmental conditions in which the PRNM System equipment is required to remain operable for temperature, humidity, pressure, and radiation have been enveloped by equipment qualification or analysis.

(2) Provide documentation to the NRC that confirms qualification actions for seismic conditions and EMI compatibility have taken

place.

RAI No.7 4 6/30/2011 Entergy will provide the requested human factors evaluation information to the NRC on or before June 30, 2011.

RAI No.8 4 9/30/2010 Entergy will provide a table reflecting failure rate data for a BWR/6 PRNM System design to the NRC on or before September 30, 2010.

RAI No. 9 Prior to startup from the 2012 The key for the APRM OPERATE-INOP keylock refueling outage switch will be controlled by Operations in accordance with plant procedures.

1 to GNRO-2010/00040 Page 2 of 2 TYPE SCHEDULED COMMITMENT (Check one) COMPLETION ONE-TIME CONTINUING DATE ACTION COMPLIANCE (If Required)

RAI No. 9 Prior to startup from the 2012 The password that is used to access the refueling outage OPERATE-SET mode of the APRM channels for gain adjustments will be con/trolled by Operations in accordance with plant procedures.

RAI No. 10 Prior to startup from the 2012 Per the guidance provided in TSTF-493, Rev. 4, refueling outage Entergy will set the as-found tolerance equal to the Square Root Sum of the Squares (SRSS) combination of as-left tolerance and the projected drift. The as-found and as-left tolerances will be reflected in the associated surveillance test procedures.

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v t e Letter Sequence Other
TAC:ME2531, Clarify Application of Setpoint Methodology for LSSS Functions (Approved, Closed)
Initiation Request, Request Acceptance Supplement, Supplement, Supplement, Supplement, Supplement Administration Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance Questions 22 April 2010 27 April 2011 27 April 2011 12 May 2011 23 June 2011 Answers 3 June 2010 29 September 2010 14 December 2010 13 December 2010 3 May 2011 16 May 2011 26 May 2011 31 May 2011 13 June 2011 22 July 2011 28 September 2011 18 October 2011 22 May 2013 8 February 2010 18 May 2010 25 May 2010 29 July 2010 Results Approval Other: ML101790437, ML120940390, ML121070139
MONTHYEAR2011-04-27 [Table View]

ML101790437

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