ML101190125
| ML101190125 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 05/04/2010 |
| From: | Lyon C Plant Licensing Branch IV |
| To: | Entergy Operations |
| Lyon C Fred, NRR/DORL/LPL4, 301-415-2296 | |
| References | |
| TAC ME2531 | |
| Download: ML101190125 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 4, 2010 Vice President, Operations Entergy Operations, Inc.
Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150
SUBJECT:
GRAND GULF NUCLEAR STATION, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION RE: POWER RANGE NEUTRON MONITORING SYSTEM (TAC NO. ME2531)
Dear Sir or Madam:
By application dated November 3, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML093140430), Entergy Operations. Inc. (Entergy, the licensee), requested U.S. Nuclear Regulatory Commission (NRC) staff approval of an amendment to the Grand Gulf Nuclear Station, Unit 1, technical specifications to reflect installation of the digital General Electric - Hitachi Nuclear Measurement Analysis and Control Power Range Neutron Monitoring System.
The NRC staff reviewed the information provided in your application and determined that additional information is required in order to complete its review. The enclosed questions were provided to Mr. G. Davant of your staff on April 28. 2010. Please provide a response to the enclosed questions within 30 days of the date of this letter.
The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for NRC staff review and contribute toward the NRC's goal of efficient and effective use of NRC staff resources. If circumstances result in the need to revise the requested response date, please contact me at 301-415-2296 or via e-mail at fred.lyon@nrc.gov.
Sincerely, Carl. F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416
Enclosure:
Request for Additional Information cc w/encl: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION POWER RANGE NUCLEAR MONITORING SYSTEM UPGRADE ENTERGY OPERATIONS, INC.
GRAND GULF NUCLEAR STATION, UNIT 1 DOCKET NO. 50-416 By letter dated November 3, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML093140463), Entergy Operations, Inc. (Entergy, the licensee) submitted a license amendment request (LAR) "Power Range Neutron Monitoring System Upgrade" for the installation of the digital General Electric - Hitachi (GEH) Nuclear Measurement Analysis and Control (NUMAC) Power Range Neutron Monitoring (PRNM) System for Grand Gulf Nuclear Station, Unit 1 (GGNS). Entergy plans to replace the existing analog Average Power Range Monitor (APRM) subsystem of the existing Neutron Monitoring System with the digital GEH NUMAC PRNM System during the spring 2012 refueling outage. This upgrade is based upon prior U.S. Nuclear Regulatory Commission (NRC) approvals of a licensing topical report (LTR) and its Supplement 1. By letter dated September 5, 1995, the NRC approved the GE Nuclear Energy (GE) LTR, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function,"
NEDC-32410P-A, dated October 1995. By letter and safety evaluation dated August 15, 1997 (ADAMS Legacy Accession Nos. 9708210236 and 9708210245, respectively), the NRC approved Supplement 1 to the LTR. Each safety evaluation is included in the approved version of the LTR and its supplement (ADAMS Legacy Accession Nos. 9605290009 and 9806120242, respectively, non-publicly available).
The NRC staff has reviewed the instrumentation and controls aspects of the licensee's submittal and determined that the following additional information is needed to complete its review:
- 1.
Please identify the changes to the GEH NUMAC PRNM System platform from that defined and approved within GE LTR NEDC-3241 OP-A. For example, the identified changes should include those to hardware, programmable devices. software, applicable development processes, and the like, that will be reflected within the GGNS PRNM System upgrade. When considering the software development processes for the platform, the response should address changes (from that previously approved for the GE LTR NEDC-3241 OP-A) to the applicable documentation that is identified under Section B.2 of Standard Review Plan (SRP), NUREG-0800, Branch Technical Position 7-14, "Guidance on Software Reviews for Digital Computer-Based Instrumentation and Control Systems," Revision 5, March 2007 (ADAMS Accession No. ML070670183).
- 2.
NUMAC PRNM LTR section 4.4.1.11 requires the Utility Action to "identity the specific requirements applicable to the plant, confirm that any clarifications included in NEDC-32410P-A apply to the plant, and document the specific requirements that the Enclosure
- 2 replacement PRNM is intended to meet for the plant." However, the entry for 4.4.1.11 in of the license amendment does not document specific GGNS PRNM requirements. For example, no discussion of response time requirements could be identified. Therefore, to support the NRC staff's review using current criteria, please identify the GGNS specific requirements applicable to the GEH NUMAC PRNM System application (e.g., application software). When considering the requirements documentation, please address the related documentation that is identified under Section B.2 of SRP, NUREG-0800, Branch Technical Position 7-14, Revision 5.
- 3.
Please describe how a software common-cause failure of the GGNS PRNM System upgrade application is addressed or coped with, such that upon its failure GGNS remains within its design basis for all design-basis accidents and anticipated operational occurrences.
- 4.
For the GGNS application of the GEH NUMAC PRNM System, please clearly identify and define all safety to non-safety data communications, including the data communications between the PRNM System and the Plant Computer and between independent/redundant PRNM channels. For the data communications among the four PRNM channels of the GGNS PRNM System, please include a demonstration of compliance with NRC's "Digital Instrumentation and Controls, DI&C-ISG-04, Task Working Group #4: Highly-Integrated Control Rooms-Communications Issues (HICRc), Interim Staff Guidance, Revision 1," dated March 6,2009 (ADAMS Accession No. ML083310185) (DI&C-ISG-04), for intra-channel communications. For the plant specific data communications between the GGNS PRNM System and the Plant Computer, please include a demonstration of compliance with DI&C-ISG-04 for safety to non-safety communications.
- 5.
In accordance with the NUMAC PRNM LTR, both the documentation of the qualification activities and the licensee's confirmation "should be included in the plant-specific licensing submittal"; however, this information was not addressed in the LAR. Please provide the analyses or reference documents (such as the referenced "Qualification Summary") that demonstrate the environmental conditions for the GGNS PRNM System configuration are enveloped by the conditions to which GEH NUMAC PRNM System equipment has been environmentally qualified (for example, NRC Regulatory Guide (RG) 1.89, "Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants"; Institute of Electrical and Electronics Engineers (IEEE) 323-1974; IEEE 323-1983; NRC RG 1.100 "Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants"; IEEE 344-1975, etc.) as discussed in section 4.4.2 of GE LTR NEDC-32410P-A. Paragraph 5.0, Item 4) in the original Safety Evaluation Report (SER) for the LTR requires plant-specific action to confirm appropriate qualification has been completed. However, as indicated in the following table, the LAR does not identify the applicable GGNS environmental conditions nor confirm that they have been enveloped by equipment qualification or analysis.
- 3 Qualification SER Item Paragraph Temperature 3.4.1 Humidity 3.4.1 Pressure 3.4.2 Radiation 3.4.2 Seismic 3.4.3 EMI 3.4.4 Compatibility LAR Entry RAI Issue to be Resolved 4.4.2.2.1.4 The LAR identifies the normal control room temperature. Please indicate if the identified temperature applies to the worst-case conditions in which the equipment is required to remain operable.
4.4.2.2.1.4 The LAR identifies the normal control room relative humidity. Please indicate if the identified relative humidity applies to the worst-case conditions in which the equipment is required to remain operable.
4.4.2.2.2.4 The LAR identifies the normal control room pressure. Please indicate if the identified pressure applies to the worst-case conditions in which the equipment is required to remain operable.
4.4.2.2.3.4 The LAR identifies the normal control room dose rates. Please indicate if the identified dose rates apply to the worst-I case conditions in which the equipment is required to remain operable.
4.4.2.3.4 Please provide documentation of the qualification action and that the licensee's confirmation has taken place.
4.4.2.4.4 Please provide direct testing references to the EMI requirements under 4.4.2.4.2 or compliance per 4.4.2.4.3 of the NUMAC PRNM LTR. Please provide documentation of the qualification action and that the licensee's confirmation has taken place
- 6.
Please provide the information necessary to evaluate the equipment configuration (for example, identify the revisions/version of hardware, programmable devices, software, etc.) for the GGNS PRNM System. Item 1) of paragraph 5.0 in the original SER for the LTR, requires the applicant to provide information that reconciles differences between the specific plant design, which is a BWR6 for GGNS, and the topical report design description, whose supporting analysis is largely non-BWR6 based. While Attachment 2 of the LAR defines changes to the plant configuration, it does not define the upgraded equipment's configuration. The entry for Section 2.3.4 in Attachment 2 of the LAR
- 4 identifies GGNS's options, but the information provided does not define the equipment configuration specific to its BWR6 application in sufficient detail to support the safety evaluation. For example, BWR6 application incorporates replacement of the Rod Block Monitor with the Computer Interface Units, which is not described within the GE LTR NEDC-32410P-A. Furthermore, GE LTR NEDC-32410P-A recognizes the Plant Computer and its data communications as plant-specific items.
- 7.
As required by Item 6) of paragraph 5.0 in the original SER for the LTR, please provide the information necessary to demonstrate that any changes to GGNS's operator's panel have received human factors reviews per plant-specific procedures. Contrary to the SER, Section 2.3.4 in Attachment 2 does not contain the results of the human factors engineering (HFE) review. Please provide the HFE information that is representative of the statement made in 2.3.3.6.2.1 that the GGNS operator panel will "maintain the current interface feel."
- 8.
Please identify how the failure rate data for the identified hardware items, as provided in NEDC-32410P-A Table F.2, is affected by the GGNS BWR6 equipment configuration.
- 9.
The original SER for the LTR requires a plant-specific action to confirm administrative controls for channel bypass or removal for operation, as well as access to the PRNM operating panel and the Average Power Range Monitor/Oscillation Power Range Monitor (APRM/OPRM) channel bypass switch will be provided (see paragraphs 3.10, 3.17 and 5.0, Item 5). Please describe the administrative controls that GGNS will provide for the GEH NUMAC PRNM System upgrade. Please demonstrate in your response that the administrative controls are provided for manually bypassing APRM/OPRM channels, or protective function, and for controlling access to the GGNS PRNM System panel and the APRM/OPRM channel bypass switch. Also, please identify and describe any administrative controls requiring operator involvement in the generation, review, and use of new Local Power Range Monitor gain and calculated core thermal power values, which can affect APRM and OPRM setpoints.
- 10.
To support NRC assessment of the acceptability of the LAR for the GGNS PRNM System setpoints, please provide documentation (including representative calculations) of the setpoint methodology used for establishing the limiting setpoint (or NSP) and the limiting acceptable values for the As-Found and As-Left setpoints. Please indicate the related Analytical Limits and other limiting design values (and the sources of these values) for each setpoint. In addition to demonstration of acceptable values for the new OPRM Upscale setpoint, the representative calculations should reflect the upgraded equipment to confirm values for existing setpoints, such as Neutron Flux-High (Setdown), Fixed Neutron Flux-High, and Flow Biased Simulated Thermal Power-High.
May 4,2010 Vice President, Operations Entergy Operations, Inc.
Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150 SUB..IECT:
GRAND GULF NUCLEAR STATION, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION RE: POWER RANGE NEUTRON MONITORING SYSTEM (TAC NO. ME2531)
Dear Sir or Madam:
By application dated November 3, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML093140430), Entergy Operations, Inc. (Entergy, the licensee), requested U.S. Nuclear Regulatory Commission (NRC) staff approval of an amendment to the Grand Gulf Nuclear Station, Unit 1, technical specifications to reflect installation of the digital General Electric - Hitachi Nuclear Measurement Analysis and Control Power Range Neutron Monitoring System.
The NRC staff reviewed the information provided in your application and determined that additional information is required in order to complete its review. The enclosed questions were provided to Mr. G. Davant of your staff on April 28, 2010. Please provide a response to the enclosed questions within 30 days of the date of this letter.
The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for NRC staff review and contribute toward the NRC's goal of efficient and effective use of NRC staff resources. If circumstances result in the need to revise the requested response date, please contact me at 301-415-2296 or via e-mail at fred.lyon@nrc.gov.
Sincerely, IRA!
Carl. F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416
Enclosure:
Request for Additional Information cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC RidsNrrLAJBurkhardt Resource RidsNrrDeEicb Resource LPLIV r/f RidsNrrPMGrandGulf Resource BDitlman, NRR RidsAcrsAcnw_MailCTR Resource RidsOgcRp Resource BMarcus, NRR RidsNrrDorlLpl4 Resource RidsRgn4MailCenter Resource ADAMS Accession No' ML101190125
- memo dated OFFICE NRRlLPL4/PM NRRlLPL4/LA NRRlDE/EICB/BC NRR/LPL4/BC NRRlLPL4/PM NAME FLyon JBurkhardt WKemper*
MMarkley CFLyon for FLyon BSingal for DATE 5/4/10 4/30/10 4/28/10 5/4/10 5/4/10 OFFICIAL AGENCY RECORD