ML063240098
| ML063240098 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/16/2006 |
| From: | Brian W R Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-88-016 | |
| Download: ML063240098 (14) | |
Text
m -==- Entergv Entergy Operations, Inc. P.0 Box 756 Port Gibson. MS 39150 Tel601 437 2800 November 16,2006 U.S. Nuciear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Supplement to Amendment Request Changes to the Analytical Methods Referenced in Technical Specification 5.6.5, "Core Operating Limits Report (COLR)" Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29
REFERENCE:
Letter GNRO-2006/00015, License Amendment Request: Changes to the Analytical Methods Referenced in Technical Specification 5.6.5, "Core operating Limits Report (COLR)n dated May 8,2006 (ADAMS Accession No. ML061310084)
Dear Sir or Madam:
By the above referenced letter, Entergy Operations, Inc. (Entergy) proposed a change to the Grand Gulf Nuclear Station, Unit 1 (GGNS) Technical Specifications (TS) to add a NRC previously approved topical report to the analytical methods referenced in Technical Specification (TS) Section 5.6.5, "Core Operating Limits Report (COLR)." On October 18, 2006, Entergy and members of your staff held a call to discuss questions concerning the proposed change. As a result of the call, three questions were determined to need formal response. Entergy's response is contained in Attachment I. There are no technical changes proposed.
The original no significant hazards consideration included in Reference I is not affected by any information contained in the supplemental letter. There are two new commitments contained in this letter.
If you have any questions or require additional information, please contact Ron Byrd at 601-368-5792.
GNRO-2006-00062 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on November 16,2006 Since re I y , 1 W. R. Brian Vice President, Operations Grand Gulf Nuclear Station, Unit 1 RWB/am t Attachments:
I. Response to Request For Additional Information
- 2. Revised Markup and retyped Pages of COLR Changes (for information only) 3. List of Regulatory Commitments cc: Dr. Bruce S. Mallett Regional Administrator U. S. Nuclear Regulatory Commission Region IV 61 I Ryan Plaza Drive, Suite 400 Arlington, TX 7601 1-4005 U. S. Nuclear Regulatory Commission Attn: Mr. Bhalchandra Vaidya MS 0-7D1A Washington, DC 20555-0001 Mr. Brian W. Amy, MD, MHA, MPH Mississippi Department of Health P. 0. Box 1700 Jackson, MS 3921 5-1 700 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 Mr. D. E. Levanway (Wise Carter)
Mr. L. J. Smith (Wise Carter) Mr. N. S. Reynolds Mr. J. N. Compton Attach men t 1 To GNRO-2006/00062 Response to Request for Additional Information Attachment 1 to Page 1 of 4 G N RO-2006/00062 Response to Request for Additional Information Related to Proposed Changes to the Analytical Methods Referenced in TS 5.6.5 Question 1 : As specified in the Generic Letter 88-16, the analytical methods used to determine the core operating limits shall be those previously reviewed and approved by NRC in identifying the Topical Report(s) by number, title, and date, or identifying the staff's safety evaluation report for a plant-specific methodology by NRC letter and date. For each reference listed in TS 5.6.5.b, please clarify which parameter in TS 5.6.5.a is supported.
Response:
GGNS previously provided a table in Reference 2 showing which TS parameters were supported by the TS listed methods. The cross-reference table was provided in response to questions associated with a license amendment for Cycle 12 operation.
The only cross- references affected by the proposed change are those associated with the EXEM BWR models. As noted in the current License Amendment Request (Reference I), the proposed EXEM BWR-2000 analysis method is used to establish the Average Planar Linear Heat Generation Rate (APLHGR) limits required by Technical Specification 3.2.1. The NRC staff indicated that a readily available cross-reference of all listed NRC approved methods would facilitate more efficient NRC staff reviews. Therefore, Entergy agreed to provide this information in the Core Operating Limits Report (COLR).
Generic Letter (GL) 88-1 6 and NUREG-I 434, "Standard Technical Specifications, General Electric Plants, BWW6" provide guidance on the method of referencing topical reports in the TS and the COLR but do not provide any guidance on a method of providing the requested cross- references. Since there is no standard format, Entergy will add the cross-references by including the supported TS references in brackets following each listed analytical method. A mark-up of the COLR to identify these cross-references is provided in Attachment 2 and will be included in the COLR revision for the upcoming reload cycle. TS 5.6.5.d requires the COLR revision to be provided to the NRC after issuance.
Question 2: It appears that the core loading for Cycle 16 will be FRA-ANP ATRIUM 10 Fuel, however, NEDE-24011-P-A, which is a GE License Topical Report (LTR), is listed under TS 5.6.5.b.24.
Please provide the reason why TS 5.6.5.b.24 - a GE LTR is still listed in the COLR. Response:
Although GGNS does not currently plan to have GE fuel loaded into the reactor next cycle, it is possible that circumstances could require some fuel replacement using GE fuel.
For instance, in May 2006 the GGNS reactor was shutdown mid-cycle to replace leaking fuel. The GGNS spent fuel pool contains used GE fuel that is available for reinsertion into the reactor if needed to replace failed or nonconforming fuel (e.g., leaking fuel or bowed fuel channels).
Although no GE fuel was reinserted in the mid-cycle outage, the option to use GE fuel was available.
Removing the GE references would limit choices of replacement fuel or Attachment 1 to Page 2 of 4 GNRO-2006/00062 require NRC approval to add the references back into the TS if any GE fuel was to be loaded into the reactor. The principle of GL 88-16 and the Standard TS NUREGs is to reduce unnecessary burden on both licensee and NRC staff resources by relocating cycle-specific information from the TS to a licensee controlled document.
The TS refers to the licensee controlled document as the COLR and establishes controls and reporting requirements for changes to the COLR. Leaving the GE reference in the TS is consistent with this principle of reducing unnecessary burden. Entergy agrees that the COLR should indicate when these methods are not being used. Therefore, the COLR will be revised to indicate which methods are applicable when GE fuel is in the reactor core. A mark-up of the COLR to identify these changes is provided in Attachment 2 and will be included in the COLR revision for the upcoming reload cycle. Question 3: With respect to the use of the proposed EXEM BWR-2000 model, please provide:
(1) the detailed explanation why the increase in PCT is beyond 50°F using the proposed EXEM BWR-2000 model. Since the 98°F PCT increase is a significant increase above the 50°F, a more detailed explanation is required; Response: The increase in Peak Clad Temperature (PCT) is the result of the change in methodology as well as more conservative assumptions for two input parameters as stated in Section 4.0 of the GGNS License Amendment Request (Reference 1). The input parameters used for both analyses are provided in Tables 1 through 5 of Attachment 1 to Reference
- 1. Processes in place at GGNS ensure that the input parameters bound actual plant performance.
The two input parameters changed are the number of Automatic Depressurization System (ADS) valves available and the initial Minimum Critical Power Ratio (MCPR). Specifically, the new analyses assumed operation of only 6 ADS valves; whereas, the current analyses assumed operation of 7 ADS valves. Additionally, a lower initial MCPR was assumed for the new analyses (i.e., 1.16 vs. 1.19). Both of these changes represent more conservative conditions.
As such, the input parameters for the new analyses continue to bound actual plant performance.
With respect to the change in PCT, the impact associated with the operation of one less ADS valve is not significant since the limiting break for GGNS is the large break, which is not significantly affected by operation of the ADS valves. The lower MCPR impacts the PCT because the hot assembly reaches the critical heat flux sooner during the event precluding the continued use of nucleate boiling as required by Appendix K of 1 OCFR50. Subsequent heat transfer regimes represent a significant degradation in the heat transfer rate from the assembly resulting in a large increase in PCT. Thus, the observed increase in PCT is due primarily to the combination of the lower assumed initial MCPR and the change in methodology.
The PCT impact for Attachment 1 to Page 3 of 4 GNRO-2006/00062 each of these changes has not been quantified because a thorough sensitivity analysis is not practical.
(2) the reason that an increase in PCT of 98°F due to changing the old EXEM BWR model to EXEM BWR-2000 model in the Grand Gulf LOCA analysis does not impact the current MCPR Safety Limits; Response As described in the bases of GGNS Technical Specification 2.1.1.2, the MCPR Safety Limit ensures sufficient conservatism in the operating MCPR limit that, in the event of an Anticipated Operational Occurrence (AOO) from the limiting condition of operation, at least 99.9% of the fuel rods in the core would be expected to avoid boiling transition. As stated in the response above, the primary reason for the increased PCT is the conservatively lower initial MCPR assumed in the analyses. This initial MCPR is lower (i.e., less limiting) than the MCPR operating limits, which are established by the transient analyses.
As such, GGNS operation in accordance with the MCPR operating limits of Technical Specification
3.2.2 ensures
that the MCPR Safety Limit will not be violated for AOO's as well as ensures that the acceptance criteria given in 10CFR50.46 will be met for the Design Basis Accident (DBA).
(3) justification as to why a lower MCPR input at the start of the event is assumed for EXEM BWR-2000 evaluation model; and Response MCPR operating limits based on the transient analyses are developed each cycle and they may vary slightly from cycle to cycle depending on factors such as core designs, operations, etc. A lower initial MCPR was assumed in the EXEM BWR-2000 analyses to provide additional margin to the MCPR operating limits to ensure the MCPR associated with the LOCA analyses would always remain non-limiting.
(4) the actions to be taken if the assumption of a lower MCPR input at the start of the event is not met. Response As described above, this change results in additional margin between the MCPR value assumed in the LOCA analyses and the actual MCPR operating limits.
As such, operation with a MCPR lower than that assumed in the LOCA analyses would not be in compliance with Technical Specification 3.2.2 and the required action statements would be implemented. to Page 4 of 4 G N RO-2006/00062
References:
- 1. Letter GNRO-2006/00015, "License Amendment Request: Changes to the Analytical Methods Referenced in Technical Specification 5.6.5, "Core Operating Limits Report (COLR)" dated May 8, 2006 (ADAMS Accession No. ML061310084)
- 2. Letter GNRO-2001/00025, "Response to NRC Request for Additional Information Regarding Cycle 12 Reload Proposed Amendment]
LDC- 2000-076," dated March 22, 2001 (ADAMS Accession No. ML010850145).
Attachment 2 To GNRO-2006/00062 Revised Markup and Retyped Pages of COLR Changes Attachment 2 to Page 1 of 4 G N RO-2006/00062 3.3.1 3.3"2 3.3.3 3.3.4 3.3.5 3.3.6 3.3+7 3.3.8 3.3,9 3.3.18 3.3-11 3.3.12 3.3%13 3.3. f4 , "RODEXZ Fuel Rod Muclear Company, -1 XN-NF-81-58(P)(A)
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- No:$: These references are applicable when Gf fuel is in tfw reactor. COFR Page 6 Attachment 3 To GNRO-2006/00062 List of Regulatory Commitments to Page 1 of 1 GN RO-2006/00062 The planned COLR changes will be included in the List of Regulatory Commitments ACTION Required)
X 4/30/2007 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. COLR revision for the upcoming reload cycle.
Therefore, the COLR will be revised to indicate which methods are applicable when GE fuel is resident in the reactor core. The planned COLR changes will be included in the COLR revision for the upcoming reload cycle.
COMMITMENT X 4/30/2007 I 1 YPt I I (Check one)
SCHEDULED ONE- I CONTINUING COMPLETION I TIME I COMPLIANCE I DATE(1f I