GNRO-2009/00062, License Amendment Request to Revise Minimum Critical Power Ratio Safety Limits

License Amendment Request to Revise Minimum Critical Power Ratio Safety Limits

ML093060261
Person / Time
Site:	Grand Gulf
Issue date:	10/27/2009
From:	Jeremy G. Browning Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2009/00062
Download: ML093060261 (44)

Text

Attachment 4 Contains PROPRIETARY Information GNRO-2009/00062 October 2009 u.s. Nuclear Regulatory Commission A N: Document Control Desk Washington, DC 20555

SUBJECT:

License Amendment Request to Revise Minimum Critical Power Ratio Safety Limits Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

Dear Sir or Madam:

Pursuant to 10CFR50.90, Entergy Operations, Inc. (Entergy) proposes to revise the Grand Gulf Nuclear Station (GGNS) Technical Specifications (TS). This proposed amendment requests a change to the minimum critical power ratio (MCPR) safety limit.

This change is required to support the GGNS upcoming Cycle 18 operation. Cycle 18 will be the first cycle of operation with a mixed core of Global Nuclear Fuels (GNF) GNF2, GE14, and AREVA ATRIUM-10 reload fuel.

The proposed amendment reflects an increase of the two recirculation loop MCPR limit from 1.08 to 1.09 and the single recirculation loop MCPR safety limit from 1.10 to 1.12.

The proposed change has been evaluated in accordance with 10CFR50.91(a)(1) using the criteria in 10CFR50.92(c), and it has been determined that the changes do not involve a significant hazards consideration. The bases for these determinations are included in the attached submittal.

The proposed change does not include any new commitments. is requested to be withheld from public disclosure in accordance with 10CFR 9.17(a)(4) 10CFR2.390(a)(4) and is PROPRIETARY to Global Nuclear Fuels Americas (GNF-A). An affidavit attesting to the proprie ry nature of the information is provided in . A non-proprietary version of Attachment 4 is included in Attachment 5. is the GGNS Power/Flow map for both Cycles 17 and 18 operation as referenced in Attachment 4 and 5 section Entergy v"" ..... v .... '.. ~ approval the proposed amendment by March 30, 201 to support the Spring o refueling outage. Once the amendment shall implemented after the current (Cycle 17) is completed and prior to the operation of Cycle 18.

When Attachment 4 is Removed From Letter Entire Document is then NON-PROPRIETARY

GNRO-2009/00062 2 3 questions or information, nln'lCn contact Michael at perjury that the 1"_"..",_,...". _ _ is true and correct

....,,\oJ"''"" on October 2009.

JGB/MJL Attachments: 1. License Amendment Request Safety Limit Technical Specification Change

2. Proposed Technical Specification Changes (mark-up and final typed page)

3. GNF Affidavit Supporting Request to Withhold from Public Disclosure Under 10CFR2.390

4. GNF Additional Information Regarding the Requested Changes to REMOVED the Technical Specification SLMCPR Grand Gulf Cycle 18-Proprietary Version

5. GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR Grand Gulf Cycle 18 Non-Proprietary Version

6. GGNS Power/Flow Map - Cycle 17 and Cycle 18

GNRO-2009/00062 Page 3 of 3 cc: u. S. Nuclear Regulatory Commission ATTN: Mr. Elmo E. Collins, Jr. (w/2)

Regional Administrator, Region IV 612 East Lamar Blvd., Suite 400 Arlington,TX 76011-4005 U. S. Nuclear Regulatory Commission ATTN: Mr. C. F. Lyon, NRR/DORL (w/2)

Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

ATTACHMENT 1 GNRO-2009/00062 LICENSE AMENDMENT REQUEST SAFETY LIMIT TECHNICAL SPECIFICATION CHANGE to GNRO-2009/00062 1 of 5

1.0 DESCRIPTION

The changes would revise the Grand Gulf Nuclear Station (GGNS) Unit 1 Technical Specifications (TS) Section 2.1.1.2 Minimum Critical Power Ratio Safety Limits (MCPRSLs) for two-loop and single-loop operation. The changes to Section 2.1.1.2 are necessary as a result of Unit 1 Cycle 18 cycle specific calculations.

The calculations performed to support the proposed MCPRSLs utilize NRC approved methodology.

The proposed changes are described in detail in Section 2.0.

The requested approval date of March 30, 2010 will allow time for the Core Operating Limits Report (COLR) to be prepared prior to the Spring 2010 Unit 1 refueling outage.

2.0 PROPOSED CHANGE

S Specifically, the proposed changes would revise the following:

2.1 TS 2.1.1.2 - Reactor Core Safety Limits The proposed amendment reflects an increase of the two recirculation loop MCPRSL from 1.08 to 1.09 and the single recirculation loop MCPRSL limit from 1.10 to 1.12.

3.0 BACKGROUND

Grand Gulf Cycle 18 is the first cycle of operation with Global Nuclear Fuel (GNF) GNF2 reload fuel. The current Cycle 18 core design consists of 308 fresh GNF2 bundles, 244 reload ATRIUM-10 bundles, and 248 reload GE14 bundles. While we do not expect this to change, any final core design changes will be evaluated to confirm that the proposed Technical Specification changes remain valid.

The proposed Minimum Critical Power Ratio Safety Limit values for the upcoming operating cycle were developed with Global Nuclear Fuel's MCPRSL methodology. The methodology used is found in NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel (GESTAR-II)" and NEDC-33383P, "GEXL97 Correlation Applicable to ATRIUM-10 FueL" to GNRO-2009/00062 2 of 5 4.0 TECHNICAL ANALYSES Operations, Inc. is proposing that Grand Gulf Nuclear Station Operating be amended to modify the Minimum Critical Power Ratio (MCPR) Safety Limits reported in Technical Specification 2.1 1.2. The proposed changes are in order to reflect the safety limit changes for the Cycle 18 mixed core.

The MCPR Safety Limit (SL) is developed to assure compliance with General Design Criterion 10 of 10CFR50 Appendix A. The Bases to Technical Specification 1.1.2 states that "The MCPR SL ensures sufficient conservatism in the operating MCPR limit that, in the event of an AOO [(Anticipated Operational Occurrence)] from the limiting condition of operation, at least 99.9% of the fuel rods in the core would be expected to avoid boiling transition".

Information to support the cycle specific MCPRSL is included in Attachment 4. This attachment summarizes the MCPR Safety Limit Analysis, methodology, inputs, results, and the reasons for the increase in the MCPR Safety Limit. The GGNS Cycle 18 core will consist of GNF2, GE14, and ATRIUM-10 fuel types. The COLR references in TS section 5.6.5 reflect the methods and codes that apply to fuel types in the Cycle 18 core.

For two-loop operation, a MCPR SL of 1.09 was demonstrated to be adequate to ensure that 99.9 percent of the rods in the core avoid a boiling transition during the most limiting AOO.

For single-loop operation, this assurance is provided by a MCPR SL of 1.12.

5.0 REGULATORY ANALYSIS

5.1 Applicable Regulatory Requirements/Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met.

10CFR50.36, Technical Specifications, defines a safety limit as a limit upon important process variables that are found to be necessary to reasonably protect the integrity of certain physical barriers that guard against the uncontrolled release of radioactivity.

5.2 No Significant Hazards Consideration Energy Operations, Inc. is proposing that the Grand Gulf Nuclear Station (GGNS) Operating License be amended to modify the Minimum Critical Power Ratio (MCPR) safety limits reported in Technical Specification 2.1.1.2. The proposed changes are necessary in order to reflect the safety limit changes for the Cycle 18 mixed core.

Entergy has evaluated the proposed license amendment request in accordance with 10CFR50.91 against the standards in 10CFR50.92 and has determined that the operation of GGNS in accordance with the proposed amendment presents no significant hazards.

Entergy's evaluation against of the criteria in 10CFR50.92 follows.

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

LJ,...,t"'Io_,."_,....,...* No.

The Minimum Critical Power Ratio (MCPR) limit is defined in the Bases to Technical Specification 1.1.2 as that "that, in the event of an AOO [(Anticipated Operational Occurrence)] from the limiting condition of operation, at least 99.9% of the fuel rods in the core would be expected to avoid boiling transition. The MCPR safety limit satisfies the requirements of General Design Criterion 10 of Appendix A to 10CFR50 regarding acceptable fuel design limits. The MCPR safety limit is re-evaluated for each reload using NRC-approved methodologies. The analyses for GGNS Cycle 18 have concluded that a two-loop MCPR safety limit of 1.09, based on the application of Global Nuclear Fuels' NRC approved MCPR safety limit methodology, will ensure that this acceptance criterion is met. For single-loop operation, a MCPR safety limit of 1.12, also ensures that this acceptance criterion is met. The MCPR operating limits are presented and controlled in accordance with the GGNS Core Operating Limits Report (COLR).

The requested Technical Specification changes do not involve any plant modifications or operational changes that could affect system reliability or performance or that could affect the probability of operator error. The requested changes do not affect any postulated accident precursors, do not affect any accident mitigating systems, and do not introduce any new accident initiation mechanisms.

Therefore, the changes to the Minimum Critical Power Ratio safety limit do not involve a significant increase in the probability or consequences of any accident previously evaluated.

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

Response: No.

The GNF2 fuel to be used in Cycle 18 is of a design compatible with the co-resident GE14 and ATRIUM-10 fuel. Therefore, the introduction of GNF2 fuel into the Cycle 18 core will not create the possibility of a new or different kind of accident. The proposed changes do not involve any new modes of operation, any changes to setpoints, or any plant modifications. The proposed revised MCPR safety limits have accounted for the mixed fuel core and have been shown to be acceptable for Cycle 18 operation.

Compliance with the criterion for incipient boiling transition continues to be ensured.

The core operating limits will continue to be developed using NRC approved methods which also account for the mixed fuel core design. The proposed MCPR safety limits or methods for establishing the core operating limits do not result in the creation of any new precursors to an accident.

Therefore, this change does not create the possibility of a new or different kind of accident from any previously evaluated.

",,,,,,,,,,.\t"'l-..., __,,, 1 to GNRO-2009/00062 5

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

MCPR safety limits have evaluated in with Global Nuclear Fuels NRC-approved cycle-specific limit methodology to ensure that during normal operation and during AOO's at least 99.90/0 of the fuel rods in the core are not expected to experience transition boiling. The proposed revised MCPR safety limits have accounted for the mixed fuel core and have been shown to be acceptable for Cycle 18 operation. Compliance with the criterion for incipient boiling transition continues to be ensured. On this basis, the implementation of the change to the MCPR safety limits does not involve a significant reduction in a margin of safety.

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

Based on the above, Entergy has determined that operation of the facility in accordance with the proposed change does not involve a significant hazards consideration as defined in 10CFR50.92(c), in that it:

(1) Does not involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Does not create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Does not involve a significant reduction in a margin of safety.

5.3 Environmental Consideration Entergy has evaluated the proposed amendment to determine if it meets the eligibility criterion for a categorical exclusion set forth in 10CFR51.22(c)(9) as follows:

(i) Does the proposed change involve a significant hazards consideration?

Response: No.

As discussed in Section 5.2, the proposed amendment does not involve a significant hazards consideration.

(ii) Does the propose change involve a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite?

Response: No.

There is no significant change in the types or significant increase in the amounts of any effluents offsite. The proposed change does not involve any physical alteration of the plant (no new or different type of equipment will installed) or change in methods governing normal plant operation.

to GNRO-2009/00062 Page 5 of 5 (iii) Does the proposed change involve a significant increase in individual or cumulative occupational radiation exposure?

Response: No.

There is no significant increase in individual or cumulative occupational radiation involve any physical alteration of the plant (no new or different type of equipment will be installed) or change in methods governing normal plant operation .

Based on the above, and pursuant to 10CFR51.22(b), Entergy concludes no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 PRECEDENCE None

7.0 REFERENCES

1. NEDE-33383-P, Revision 1, June 2008, GEXL97 Correlation Applicable to ATRIUM-10 Fuel

2. NEDE-24011-P-A, GESTAR-II, General Electric Standard Application for Reactor Fuel

ATTACHMENT 2 GNRO-2009/00062 Proposed Technical Specification Changes (mark-up and final typed page)

SLs 2.0 2.0 SAFETY LIMITS CSLs) 2.1 SLs 2.1.1 Reactor Core SLs 2.1.1.1 With the reactor steam dome pressure < 785 ps;g or core flow < 10% rated core flow:

THERMAL POWER shall be s 25% RTP.

2.1.1.2 With the reactor steam dome pressure ~ 785 ps;g and core flow L 10% rate~or. flow:

(1.0, MCPR shall be ~ . for two recirculation loop operat~on or z~\for single recirculation loop operatl on. ~. ~

2.1.1.3 Reactor vessel water level shall be greater than the top of active irradiated fuel.

2.1.2 Reactor Coolant System Pressure SL Reactor steam dome pressure shall be ~ 1325 psig.

2.2 SL Violations With any SL violation, the following actions shall be completed within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s:

2.2.1 Restore compliance with all SLs; and 2.2.2 Insert all insertable control rods.

GRAND GULF 2.0-1 Amendment No. +4r 146

SLs 2.0 2.0 SAFETY LIMITS 2.1 SLs 2.1.1 2.1.1.1 With the reactor steam dome pressure < 785 g or core flow < 10% rated core flow:

THERMAL POWER shall be ~ 25% RTP.

2.1.1.2 With the reactor steam dome pressure ~ 785 psig and core flow ~ 10% rated core flow:

MCPR shall be ~ 1.09 for two recirculation loop operation or ~ 1.12 for single recirculation loop operation.

2.1.1.3 Reactor vessel water level shall be greater than the top of active irradiated fuel.

2.1.2 Reactor Coolant System Pressure SL Reactor steam dome pressure shall be ~ 1325 psig.

2.2 SL Violations With any SL violation, the following actions shall be completed within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s:

2.2.1 Restore compliance with all SLs; and 2.2.2 Insert all insertable control rods.

GRAND GULF 2.0-1 Amendment No. +/-46 __

ATTACHMENT 3 GNRO-2009/00062 GNF Affidavit Supporting Request to Withhold from Public Disclosure Under 10CFR2.390

Global Nuclear Fuel Rich Augi Customer Project Manager P.O. Box 780 M/C J32 Wilmington, NC 28402-0780 RA-ENO-JB1-09-101 October 21,2009 Mr. Jim Head ecc: Jim Lee Entergy Operations, Inc. Ed Gibbs (GNF) 1340 Echelon Parkway Mitch Lindquist (GNF)

Jackson, MS 39213

Subject:

Grand Gulf Cycle 18 Safety Limit, Revision 01

References:

1. Entergy Operations, Inc. Fixed Services Agreement for the Supply of Fuel and Fuel Related Work to GGNS with Global Nuclear Fuel-Americas, LLC, Agreement Number 10134077, as amended

2. RA-ENO-JB1-09-082, "Grand Gulf Cycle 18 Safety Limit", dated September 18,2009 Attachments:

1. "Grand Gulf Cycle 18 SLMCPR Results", eDRF 0000-0014-0496, filename "JB1_C18._TS_Change_Letter_Non-Proprietary_lmage_R1.pdf"

2. "Grand Gulf Cycle 18 SLMCPR Results", eDRF 0000-0014-0496, filename "JB1_C18_TS_Change_Letter_Proprietary_R1.pdf"

3. Signed Affidavit, filename "JB1 C18_TS__R1_Letter_Affidavit_signed.pdf"

Dear Jim:

Attached, please find the revised Grand Gulf Safety Limit results letter documenting the results for Cycle 18. This revision was issued for the following items:

Section 2.2.1 was clarified Incorrect reference in Table 2 was corrected Table 3 errors were corrected The signed affidavit will be transmitted with a copy of this letter via FEDEX.

Regards, Rich Augi Customer Project Manager

Global Nuclear Fuel- Americas AFFIDAVIT I, Russell E. Stachowski, state as follows:

(1) I am Consulting Engineer-Nuclear and Reactor Physics, Nuclear Fuel-Americas, LLC ("GNF-A"), 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 infonnation sought to be withheld is contained in the GNF proprietary report, GNF-OOOO-0107-2614-RI-P, GNF Additional Information Regarding the Requested Changes to the Technical Specijicatiol1 SLMCPR, Grand Gulf Cycle 18, Class III, (GNF Proprietary Information), dated I 1/2009. The GNF proprietary information in GNF-OOOO-OI07.. 2614-RI-P is identified a dotted underline inside double square brackets. A "((" marking at the beginning of a table, figure, or paragraph closed with. a "))" marking at the end of the table, figure or paragraph is used to indicate that the entire content between the double brackets is proprietary. In each case, the superscript notation* ~3t refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for* withholding of proprietary information of which it is the owner or licensee, GNF-A relies upon the exemption from disclosure set forth in the Freedom of Infonnation Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.1 7(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify 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, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group

v. FDA, 704F2d1280 (DC Cir. 1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

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

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product; GNF-OOOO-O I07-2614-R I-P Affidavit Page 1 of3

c. Information which rpui:::ll~I~ as[)eci[S Infonnation Dresell~t" or future GNF-A customer-funded development IJ... V ....l""'I ... .l~ .. resulting in potential products to

d. Information which discloses patentable subject matter for which it may be desirable to obtain patent v~~.....

lJ.. V l l ....

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. above.

(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GNF-A, 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 GNF-A, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary infonnation, and the subsequent steps taken *to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GNF-A. Access to such documents within GNF-A is limited on 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, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF-A 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 agreements.

(8) The infonnation identified in paragraph (2) is classified as proprietary because it contains details ofGNF-A's fuel design and licensing methodology.

The development of the methods used in analyses, along with the testing, development and approval of the supporting methodology was achieved at a significant cost to GNF-A or its licensor.

GNF-OOOO-O I07-2614-R J.p Affidavit 20f3

(9) Public disclosure of the information sought to be withlleJd is likely to cause substantial harm to GNF-Ats competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GNF-A'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.

The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A.

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.

GNF-Ats competitive advantage will be lost if its competitors are able to use the results of the GNF-A 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 infonnation to GNF-A 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 GNF-A 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.

st Executed on this 21 day of October 2009.

Russell E. Stachowski Chief Consulting Engineer-Nuclear and Reactor Physics Global Nuclear Fuel - Americas, LLC GNF-OOOO-o 107-2614..R J.. p Affidavit Page 3 of 3

ATTACHMENT 5 GNRO-2009/00062 GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR Grand Gulf Cycle 18 (NON-PROPRIETARY VERSION)

GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR Grand Gulf Cycle 18 1

Proprietary Information Notice Import~lntNotice Rega."{ling Contents of this Report

PJease Read Carefull)'

2

GNF NON-PROPRIETARY INFORMATION Class I GNF Attachment Table of Contents 1.4) MET:OODOLOGY _ "' *4 2.0DJ:SC*USSION******************.**********.*_**.***********************_*.*****.*.***.*************.***********************.**************.*****.************.* 4 2..1 MAJOR C()NTRIBlJTORS T() SLI\4CPR. CHA.NGE , , 4 2.2.. DEVL'\.TI()NS IN NRC-ApPROVED UNCERTA1N11ES , ,.. 5 2.2../. R-.Ftl(.:l()} 5 2.2.2. C'ore P10w .Rate and !?aruloll11i:!Jective TI}) ]<e,(ltlll1J! ,.., , ,"',

2.3. DEPAR:nJR.E l~*R()~,INRC-Aj>PR()VED METHt){X)L()GY 6 2.4. FUEL AXIALP(}\VER SrV\.PE PEN.ALTY 6 2.5. tvl:ETH()IX)L()GYRESTRICTl()NS 8 2.6. M'INl?\,nnvt CORE FL()W C()NDITl(}N , 8 2.7. Llt\!f1TlNG CONTR()J" ROD PATTERNS 8 2..8. C()RI~ *f\.1()Nfl*(}RINCJ S'~{S'l'IE~l , , 8 2.9.. P()\VI~I~.!Fl ..()\)l:Mi\I* 8 2.. 1(). C()R.f~ :U:>f\J)IN (:JDJ/\(lRJ\tv1 8 2*.11. *Fl(.Jt.JI<l~ :R..r{I:f::l~J~*NC{~S 8 2.12. .AD1)rn()NAL* SLMCPRLICENSING C()NJ)lTl()NS ............................................................*...*..............*....,.. 9

.2.13. SlJ)"l!Vf!\J.{*~{ " ,....*.. , 9 3.0 RE:FE'RENC'ES **..****************..********.'.********.*****.*****.*.***.*.***.****..****.************.**************.*********..********.**************.*** .J.()

List of Figures FKRJRE 1. CtfRREN1' C'lCLE C()REL()ADING 'DIAGRA~1 11 FlfllrRE 2,PREVI()US C'YctJ~ CC)RE :L()ADIN(iDli\.(jRA~i , , , 12 FIG1JRE 3. FI(jURE 4.1 FRfl\l NEDC 32601 P A , , , 13 FIGIJRE 4. FIGURE III.5 1FR()t\:f NEDC 32601P A , H 14 FIGURE 5. FI(JUREIJI.5 2 FR()NI N:EDC 32601p*..A , , 1.5

~*List of Tables TABl..E 1. DESCRIPTI()N ()F 16 T.ABLE 2. SLMCPR C,ALctJl~ATf()N I\llETHOIX)LO(HES 17 TABLE 3. M<JN'TE CARLO Ci\LCULATED SLNfCPR VS.ESTHvlATE 18 l"ABI..'E 4. 'N()N-P()\VER DISTRIBlTfl(}N UNcl~R'rAIN'IIES 20

5. P()\VER DISTRIBUTIONUNCERT/\INTIES ~ 22 T'j\BLE 6. CRrncAL PO\\'ER UNCERTAINTIES 24 Table of Contents Page 3 of24

INFORMATION 1.0 Met.hodology

• MCPR

• and 17 the current cycle 8 S*LM.C.PR. calculations.

2.0 Discussion In this rtfC">iIIC>C~'1'''':I'\ nonnenClalure is n,vo recirculation loops in '''L *.., and SL*O flOfnellCUiIUJ"'e IS one recirculation loop in operation.

2.1. Major Contributors to SLMCPR Change 1.

2.2. Deviations in NRC-Approved Uncertainties R*Factor 2.2.2. Core Flow Rate and Random Effective TIP Reading

3 At'l",(>,/""1'HdA TIP reading uncertainties is "L.><Z~T'" """O.'ZL.><I.' as core flo\v is rOI'1III'"t-£tor1 I U~"',J .l.'''~':~

,*, ""'Jl that original core flow and rand0111 SL~1CPR !lnQlhr(!i(,;rp~ln~'ln 2.3. Departure from NRC.Approved Methodology the Grand 2.4. Fuel Axial Power Shape Penalty

~3f I]

((

7

2.5. Methodology Restrictions 2.6. Minimum Core Flow Condition n'11fllmunl core ] core T"f'n*nIT't#"'tn \vas not IlmlllnR at 2.7. Limiting Control Rod Patterns 2.8. Core Monitoring System Grand Gulf 18, MONICORE CtlC'*t.arn will as the core tU*V'I.I.I"*'.Jt.l..IJI_

2.9. Power/Flow Map 2.10. Core Loading Diagram 2.11. Figure References 4

8

GNF NON-PROPRIETARY INFORMATION Class 1 GN'F Attachnlcnt 2.12. Additional SLMCPR Licensing Conditions For Grand Gulf C:ycle 18, no additional SLM(~PR licensing conditions are included in the analysis.

2.13. Summary The requested changes to the Technical Specification SLMCPR values are 1.09 for TLO and 1 12 for S,LO for Grand CiulfC:ycle 18~

Figure 1. Current Cycle Core ,Loading Diagraln Page 9 of24

GNF NON-PROPRIETARY INFORMATION Class I GNF Attachment 3.0 References 1.Letter~ Glen Watford (GN'F-A) to 'U.S. Nuclear Regu)atory ComluissionDocument Control Desk \vith attention toR, Pulsifer (N~RC)') "Confimlation of lOxlOFuelDesign

~Applicability to lnlproved SLMCPR.,Po\\ter Distribution andR-FactorMethodologies"',

F'LN-200 1-0 I6, Septenlber 24 ~ 200 '}

2. Letter, Glen l\. Watford (GNF-A) to U.S. Nuclear Regulatory COlnmission DocUDlent C:ontrolDesk \\lith attention to J.Donoghue (N'RC), "Confirmation of the Applicability of the GEXL14 Correlation and AssociatedR-FactorlV1ethodology for Calculating SLMCPR Values in Cores Containing GE14 F'uer", FLN-2001-0'l7, October 1) 2001.

3. Letter, Glen i\. Watford (G'NF-i\) to U.S. Nuclear ,Regulatory C:ommissionDocunlent

(:ontrol Desk with attention to JosephE. Donoghue (NRC>>) "Final Presentation M:aterial for G"EXL Presentation :Febnlary 11, 2002", FLN-2002-004, February 12, 2002.

4. Letter, John F. Schardt (G'NF-i\) to U.S. Nuclear .Regulatory COffilllissionDocumellt Control Desk with attention to Mel 'B. Fields (NRC), '4Shadow Corrosion 'Effects on SLl\1"CPR (~hannel Bow'Uncertainty'" FLN-2004-030, 'N'o'vember 10, 2004.

5. 'Letter') Jason S. Post (GENE) to 'U.S.:Nuclear ,Regulatory Commission 'Document Control Desk \vith attelltion to Chief, Information Management Branch~ et al. (NRC), '(.Part 21 Final Report: Non-Conservative SL:M:CPR"~rv1,FN04-108, Septenlber 29,2004.

6. Letter, Glen i\. Watford (GNF-i\.) to 'LT.S.NuclearRehY1l1atory Commission Document C:ontrol Desk. with attention to Alan Wang (NRC), "N,R(~ Technology Update Proprietary Slides - July 31 - i\,ugust 1, 2002~', FLN~2002-015, October 31, 2002.

7. Letter, Jens G. ~1'unthe .i\,ndersen (G'NF-A) to U.S.N'uclear Regulatory COllltnission Document Control Desk \vith attention to Alan \\lang (N',RC), "'GEXL Correlation for 1OX 1o Fuel'\ FL'N'-2003-005 ,May 31, 2003.

8. 'Letter, i\ndrevv A. Lingenfelter (G'NF-A) to U.S. 'N'uclear'Regulatory COlnmission

'Document Control Desk \vith cc tol\1CHoncharik (N:RC), "'Removal of Penalty Being Applied to GE14 (~ritical Power Correlatit)n for Outlet Peaked Axial Po\ver Shapes",

FL,N-2007-031, Septenlber 18,2007.

9. Letter, Andre\vA.L.ingenfelter (GN'F-A) to U.S, Nuclear Regulatory C:omnlission DOCUfilent Control Desk with cc to:t\1CHoncharik (NRC)., ~'GNF2 Advantage Generic Compliance withNEDEM24011-P-A (GEST}\R II),NEDC-33270P,Re\lision June GEXL correlation for GNF2Fuel,'NEDC:-33292P,Revision3, June 2009'~

~lFN-09-436, June 2009.

10. NEDC:-33383P "GEXL,97 C:orrelationApplicable to ATRIlJI\1-1 o FueI" Rev. I, June 2008.

Figure 1, Current Cycle Core ,Loading ,Diagranl ~Page 10 of 24

Figure 1. Current Cycle Core Loading Diagram

1. 1.

T~: f'"

I~:

f,_

1,-

~,,:

1\1 ~n' Figure 2. Previous Cycle Core Loading Diagram

3. 4.1 from 4.

111.5-1 froID 4.

GNF NON-PROPRIETARY INFORlv1ATION Class I GNP Attachment

((

Figure 5. Figure 111.5-2 from 'NEDC-3260'lP-l\

'Figure 5. 111.5-2 from 'NEDC-3260 ]'P-i\' 'Page 15 of 24

GNF NON-PROPRIETAR.Y INFORMATlON

].

Table 1. Description of C:or*e Previous Rated CoreFlowY.Linlitillg 1 .4 1

10

GNF NON-PROPRIETAR,Y INFORMATION I

Table 2. S,L:J\(I(~:PRC:alculation J\lethodologies

,Previous Cycle Rated Core Flow Limiting Case

GNF NON~PRO.PRIETAR.Y INFORMATI.ON 1.

Table3. IVlonteCarlo (:alculated SL.~ICP.R vs.Estimate

((

GNF NON~PROPRI.ETAR.YINFORMA.TI.ON Class .I.

GN'F .Attachment Table3. }\/lonte Carlo Calculated SLl\<I(~PR vs..Estimate

.PreviOIIS Cycle "Previous C}fcleRated Current Cycle Current Cy-cleRated Description l\t:ininl umCoreFlow CoreFlo'\\' Limiting l"linimllm Cor"eFlol\l CoreFlo\vLimiting L.imiting Case Case ,Limiting Case Case Tabl e 3. 'l\1onte Carlo Calculated S'LrvICPR vs. Estinlate 19 of

GN.F INFORMATION Table 4. :Non-PowerDistribu.tion *Un.cel"tainties NODlillal (NRC- .Previous C)'cle 'Pre\'ious Cycle Cllrrent Apl>roved)\'allle .l\tlinimum Core Rated Core Flo\v :l\1illinlIIDl

+/- o (CXl) .Flo\vLinlitillg Case Linlitillg Case :FlowLinlitillg G.ETA.B

GNF NON-PRO,PRIETARY INFORMATION

.I.

Table 4. Non,-Po,\\'er Non,*Po,\\'er Distribu,tion Uncertainties NOlnillsl (NRC- Previous Cycle Previous Cycle Cllrl*ent nnl"n'llA,rll ~lallJe l\fillinlum Core :Rated Core Flow 1\'linimunl

+/- G(~) Flo\vLimiting Case Linlitillg Case Flow ,. . . ,. ***** ~ ** II_

N,E'DC-3260,l-:P-A

(( (( (( (( ((

(( (( (( (( ((

(( (( l[ (( ((

(( (( (( (( ((

(( (( (( (( ((

GNF NON~PRO.P.RIETAR.Y INFORMA.TION I

Table 5.Po\vel* .DistributionU*Dcertainties

'Pre\riolls Cycle Millilllum Core Flow Limiting

• N'*EDC-32694-.P-A, 3:DI\1.0*NICOR.E

(( (( (( (( ((

([ (( (( (( ((

(( (( (( (( ((

(( (( (( (( ((

GNF NON*PROPRIETAR.Y INFORMATION 1.

Table 5. :PowerDistributioD 'Uncertainties

.PreviOIIS Cycl.e

.Minim um Core Flo\vLiotitil1g

(( (( (( (( ((

I[ (( [( [( ((

(( (( (( (( ((

(( (( (( (( ([

GNF NON-:PROPRIETAR.Y INFORMA.TION

.I Table 6. Criti.cal :Po,vel*Uncertainties

ATTACHMENT 6 GNRO-2009/00062 GGNS Power/Flow Map - Cycle 17 and Cycle 18

110 A - Natural Circulation B - Low Recirc Pump Speed, Maximum FCV Position 100 C-High RecircPumpSpeed, Minimum FCVPosHion H------~-----~--~-~~-----~--~---~~~~~~~~~~~~~~~~~---~~~-----~----~

90 80

...ns "C

(l) 70 60 0::

W

~

o 50 0-W

~ 40 o

30 20 10 100 14.749 + P 0.14749* WT 45+0.55* Wr o

o 10 20 30 40 50 60 70 80 90 100 110 120 CORE FLOW (% rated)