GNRO-2011/00064, License Amendment Request to Revise Technical Specification 2.1.1.2

License Amendment Request to Revise Technical Specification 2.1.1.2

ML11306A063
Person / Time
Site:	Grand Gulf
Issue date:	10/28/2011
From:	Jeremy G. Browning, Mike Perito Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2011/00064
Download: ML11306A063 (17)

Text

Entergy Operations, Inc.

Port Gibson, MS 39150 Mike Perito Vice President, Operations Grand Gulf Nuclear Station Tel. (601) 437-6409 GNRO-2011/00064 October 28, 2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

License Amendment Request to Revise Technical Specification 2.1.1.2 Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCES:

1. GE Nuclear Energy, "Applicability of GE Methods to Expanded Operating Domains," NEDC-33173P, Revision 0, February 2006.

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests approval of an amendment to the Grand Gulf Nuclear Station, Unit 1 (GGNS) Technical Specifications (TS).

The proposed change revises the Minimum Critical Power Ratio Safety Limit values for both two loop and single loop operation in accordance with the requirements set forth in "Applicability of GE Methods to Expanded Operating Domains" (Reference 1). Attachment 1, Analysis of Proposed Technical Specification Changes, discusses the relationship of this license action request (LAR) and the extended power uprate LAR. Attachment 2 contains the proposed technical specification changes.

Global Nuclear Fuels - Americas (GNF-A) considers portions of the information provided in to be proprietary and therefore exempt from public disclosure pursuant to 10 CFR 2.390. An affidavit for withholding information, executed by GNF-A, is provided in Attachment 6.

The proprietary information was provided to Entergy in a GNF-A transmittal that is referenced in the affidavit. Therefore, on behalf of GNF-A, Entergy requests to withhold Attachment 3 from public disclosure in accordance with 10 CFR 2.390(b)(1). A non-proprietary version is provided in Attachment 4. Attachment 5 is the GGNS Power/Flow map for both Cycles 18 and 19 operation as referenced in Attachments 3 and 4.

The proposed change has been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards consideration. The bases for these determinations are included in the attached submittal.

The proposed change does not include new commitments.

GNRO-2011/00064 Page 2 of 3 Entergy requests approval of the proposed amendment within 6 months of the date of submittal to support development of the Core Operating Limits Report for Cycle 19 and the Spring 2012 refueling outage. Once approved, the amendment will be implemented within 90 days.

Although this request is neither exigent nor emergency, your prompt review is requested.

If you have any questions or require additional information, please contact Christina L. Perino at 601-437-6299.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 28, 2011.

Sincerely, MP/JAS Attachments:

1. Analysis of Proposed Technical Specification Changes

2. Proposed Technical Specification Changes (Mark-up)

3. GNF-A Analysis Summary (Proprietary)

4. GNF-A Analysis Summary (Non-Proprietary)

5. GGNS Power / Flow Map - Cycles 18 and 19

6. GNF-A Affidavit for Withholding Information from Public Disclosure cc: (see next page)

GNRO-2011/00064 Page 3 of 3 cc: Mr. Elmo E. Collins, Jr.

Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 612 East Lamar Blvd., Suite 400 Arlington, TX 76011-4125 U. S. Nuclear Regulatory Commission ATTN: Mr. A. Wang, NRR/DORL Mail Stop OWFN/8 G14 11555 Rockville Pike Rockville, MD 20852-2378 State Health Officer Mississippi Department of Health P. 0. Box 1700 Jackson, MS 39215-1700 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment I GNRO-2011/00064 Analysis of Proposed Technical Specification Changes to GNRO-2011/00064 Page 1 of 4 1,0 DESCRIPTION Entergy Operations, Inc. (Entergy) requests an amendment to the Grand Gulf Nuclear Station, Unit 1 (GGNS) Operating License (NPF-29). Specifically, the proposed change revises the Minimum Critical Power Ratio Safety Limit (MCPR SL) reflected in GGNS Technical Specification (TS) 2.1.1.2.

Please note that an unrelated proposed change to TS 2.1.1.2 was included in the GGNS Extended Power Uprate (EPU) license amendment request (LAR) dated September 8, 2010 (GNRO-2010/00056, Nuclear Regulatory Commission (NRC) Agency wide Documents Access and Management System (ADAMS) Accession No. ML102660403) (Reference 1).

2.0 PROPOSED CHANGE

The proposed change revises the MCPR SL stated in TS 2.1.1.2 for two loop operation from 1.09 to 1.11 and for the single recirculation loop from 1.12 to 1.14.

3.0 BACKGROUND

The proposed change implements the following limitation and condition stated in Section 9.0 of the NRC's Safety Evaluation (SE) for GE Hitachi (GEH) Nuclear Energy, "Applicability of GE Methods to Expanded Operating Domains," NEDC-33173P, Revision 1 (Reference 2):

"For EPU operation, a 0.02 value shall be added to the cycle-specific SLMCPR value. This adder is applicable to SLO, which is derived from the dual loop SLMCPR value."

NEDC-33173P is applicable to fuel designs through GE14. Grand Gulf Cycle 19 is being designed to operate at an uprated power level based on the NRC's approval of the GGNS EPU LAR (Reference 1) with a core design that includes Global Nuclear Fuel 2 (GNF2). Appendix A of Attachment 5 of the EPU LAR describes the application of NEDC-33173P, Revision 0 (Reference 3) to GNF2 fuel. As such limitation and condition 9.4 stated in the NRC SE for NEDC-33173P (Revision 0 and Revision 1) is applicable to the Cycle 19 reload analysis.

Section 8.1 of the NRC SE also states: "If LTR NEDC-33173P is revised or supplemented, the topics addressed in this SE, associated commitments and the limitations and conditions specified in Section 9.0 should be covered, unless GE demonstrates that the limitations are not needed due to changes in methods or that the additional benchmarking is provided to the NRC staff in another LTR." GEH has submitted a supplement to NEDC-33173P for NRC review to eliminate the 0.02 adder (Reference 4) and has received a draft safety evaluation from the NRC (Reference 5). However, until the NRC has approved this GEH submittal, the requirement for the MCPR SL adder is still applicable.

The proposed MCPR SL values for the upcoming operating cycle were developed with Global Nuclear Fuel's MCPR SL methodology found in NEDE-2401 1P-A, "General Electric Standard Application for Reactor Fuel (GESTAR-Il)" (Reference 6) as referenced in GGNS TS 5.6.5, Core Operating Limits Report.

The MCPR operating limits are presented and controlled in accordance with the GGNS Core Operating Limits Report (COLR).

to GNRO-2011/00064 Page 2 of 4

4.0 TECHNICAL ANALYSIS

The change is required to implement the following limitation and condition stated in the NRC SE for NEDC-33173P (Reference 2):

"For EPU operation, a 0.02 value shall be added to the cycle-specific SLMCPR value. This adder is applicable to SLO, which is derived from the dual loop SLMCPR value."

The MCPR SL is developed to assure compliance with General Design Criterion 10, "Reactor Design," of 10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants." The Bases to Technical Specification 2.1.1.2 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."

The MCPR SLs for dual and single loop operation for Cycle 19, without consideration of this adder, are 1.09 and 1.12 respectively. These values are consistent with the current TS values.

Therefore, the reason for the increase in the MCPR SLs is only related to the addition of the 0.02 value specified in NRC SE limitations and conditions. The resulting values add additional margin to the MCPR SLs.

Information to support the cycle specific MCPR SL is included in Attachment 3. This attachment summarizes the MCPR SL Analysis, methodology, inputs, and results.

5.0 REGULATORY ANALYSIS

5.1 Applicable Regulatory Requirements/Criteria Entergy has determined that the proposed changes do not require any exemptions or relief from regulatory requirements, other than the TS, and do not affect conformance with any General Design Criterion (GDC) differently than described in the Updated Final Safety Analysis Report (UFSAR).

The Minimum Critical Power Ratio Safety Limit (MCPR SL) satisfies the requirements of General Design Criterion 10, "Reactor Design," of 10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants" regarding acceptable fuel design limits. The MCPR SL is reevaluated for each reload using NRC-approved methodologies.

5.2 No Significant Hazards Consideration The proposed change to the Grand Gulf Nuclear Station (GGNS) Technical Specifications (TS) revises the Minimum Critical Power Ratio Safety Limit (MCPR SL) for two recirculation loop and single recirculation loop operation. Entergy Operations, Inc. has evaluated whether or not a significant hazards consideration is involved with the proposed changes by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

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

Response: No to GNRO-2011/00064 Page 3 of 4 The Bases to TS 2.1.1.2 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."

Certain limitations and conditions referenced in the NRC Safety Evaluation for GE Nuclear Energy, "Applicability of GE Methods to Expanded Operating Domains," NEDC-33173P, Revision 0, February 2006 are applicable for extended power uprate operation.

The proposed change addresses the following limitation and condition stated in the NRC SE for NEDC-33173P:

"For EPU operation, a 0.02 value shall be added to the cycle-specific SLMCPR value. This adder is applicable to SLO, which is derived from the dual loop SLMCPR value."

Based on the application of Global Nuclear Fuels' NRC approved MCPR SL methodology, the conclusions of the Cycle 19 reload analyses indicate that the values for two-loop and single-loop MCPR SL should be increased to account for this 0.02 margin. The resulting values add additional margin to the MCPR SLs and continue to ensure the conservatism described in the Bases to TS 2.1.1.2.

The requested Technical Specification change does 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 change does not affect any postulated accident precursors, any accident mitigating systems, or introduce any new accident initiation mechanisms.

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

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

Response: No The proposed change does not involve any new modes of operation, any changes to setpoints, or any plant modifications. The proposed change to the MCPR SLs accounts for the 0.02 adder specified in the NRC Safety Evaluation limitations and conditions associated with NEDC-33173P. 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. The proposed MCPR SLs do not result in the creation of any new precursors to an accident.

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

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

Response: No to GNRO-2011/00064 Page 4 of 4 The MCPR SLs have been evaluated in accordance with Global Nuclear Fuels NRC-approved cycle-specific safety limit methodology to ensure that during normal operation and during AOOs at least 99.9% of the fuel rods in the core are not expected to experience transition boiling. The proposed revision to the MCPR SLs accounts for the 0.02 adder specified in the NRC Safety Evaluation limitations and conditions associated with NEDC-33173P, which results in additional margin above that specified in the TS Bases.

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

Based on the above, Entergy concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.3 Environmental Considerations The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Grand Gulf Nuclear Station License Amendment Request, Extended Power Uprate, dated September 8, 2010 (GNRO-2010/00056, NRC ADAMS Accession No. ML102660403).

2. GE Hitachi Nuclear Energy, "Applicability of GE Methods to Expanded Operating Domains," NEDC-33173P, Revision 1, September 2010.

3. GE Nuclear Energy, "Applicability of GE Methods to Expanded Operating Domains,"

NEDC-33173P, Revision 0, February 2006.

4. GEH letter to the NRC, "NEDC-33173P, Revision 2 and Supplement 2, Parts 1 Analysis of Gamma Scan Data and Removal of Safety Limit Critical Power Ratio (SLMCPR) Margin," dated August 14, 2009 (GEH letter No. MFN 09-552) (NRC ADAMS Accession No. ML092300243).

5. NRC letter to GEH, "Draft Safety Evaluation for GE Hitachi Nuclear Energy Americas, LLC (GEH) Licensing Topical Report (LTR) NEDC-33173P, Revision 2 and Supplement 2, Parts 1-3, "Analysis of Gamma Scan Data and Removal of Safety Limit Critical Power Ration (SLMCPR) Margin" (TAC NO. ME1891), dated May 11,2011 (NRC ADAMS Accession No. ML11129A194).

6. NEDE-2401 1-P-A, "General Electric Standard Application for Reactor Fuel (GESTAR-II).

Attachment 2 GNRO-2011/00064 Proposed Technical Specification Changes (Mark-up)

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

THERMAL POWER shall be s 25% RTP.

2.1.1.2 With the reactor steam dome pressure Ž 785 pstg and core flow 2:10% rated coreflw MCPR shall be k E-)9ior two rec rculatton loop operation or a -. 12A "

operation.

gle recirculation loop I 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 LS Reactor steam dome pressure shall be s 1325 pslg.

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.

1continued)

GRAND GULF 2.0-1 Amendment No. 46 -%84-

Attachment 5 GNRO-2011100064 GGNS Power ! Flow Map - Cycles 18 and 19 to GNRO-2011/00064 Page 1 of 2 Cycle 18 110 100 90 80 S70 0

60 w

o 50

_1

-0 I--

30 20 10 0 10 20 30 40 50 60 70 80 90 100 110 120 CORE FLOW (% Rated) to GNRO-2011/00064 Page 2 of 2 Cycle 19 110 100 90 80

")

70 60 a.o 50 40 3O 30 20 10 0

0 10 20 30 40 50 60 70 80 90 100 110 120 Core Flow (% Rated)

Attachment 6 GNRO-2011/00064 GNF-A Affidavit for Withholding Information from Public Disclosure

Global Nuclear Fuel - Americas AFFIDAVIT I, Andrew A. Lingenfelter, state as follows:

(1) I am Vice President, Fuel Engineering, Global Nuclear Fuel - Americas, L.L.C.

(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 information sought to be withheld is contained in GNF-A proprietary report GNF S-0000-0136-7814 RO-P, GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR, Revision 0, August 2011. GNF-A proprietary information in GNF S-0000-0136-7814 RO-P, GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR, Revision 0, August 2011, is identified by a single ((d.ttq.d

..*...d..e...n..e....n.s..d..e....d..u..b.*.e.....u..a.r...e...b:..ra....e.t.s.!.. ]. iFbia gures id and inside double sqiuare brackets 13 111.

-ndrline Figures ntiidother withed ular large eequation squa reo objects containing GNF-A 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, 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 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 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, 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC Cir. 1983).

(4) Some examples of categories of information which 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 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;

c. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products to GNF-A; GNF S-0000-0136-7841 RO-P Revision 0 Affidavit Page 1 of 3

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

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 information, 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 information identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology for the Boiling Water Reactor (BWR). Development of these methods, techniques, and information and their application to the design, modification, and analyses methodologies and processes was achieved at a significant cost to GNF-A. 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 GNF-A asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's 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 GNF S-0000-0136-7841 RO-P Revision 0 Affidavit Page 2 of 3

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-A's 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 information 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.

Executed on this 1st day of August 2011.

Andrew A. Lingenfelter Vice President, Fuel Engineering Global Nuclear Fuel - Americas, L.L.C.

GNF S-0000-0136-7841 RO-P Revision 0 Affidavit Page 3 of 3