Letter Sequence Response to RAI |
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MONTHYEARML11350A0532012-01-0404 January 2012 Plan for the Scoping and Screening Regulatory Audit Regarding the Grand Gulf Nuclear Station, Unit 1 License Renewal Application Review Project stage: Other ML12009A1052012-01-18018 January 2012 Plan for the Aging Management Program Regulatory Audit Regarding the Grand Gulf Nuclear Station, Unit 1, License Renewal Application Review Project stage: Other ML12067A2352012-04-0303 April 2012 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12068A2332012-04-0404 April 2012 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12080A1912012-04-11011 April 2012 Request for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Grand Gulf LRA RAI Set 3 Project stage: RAI ML12074A0082012-04-12012 April 2012 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12076A0142012-04-16016 April 2012 Request for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application (TAC No. ME7493) Grand Gulf LRA Draft RAI Set 5 Project stage: Draft RAI ML12076A0092012-04-17017 April 2012 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal (TAC ME7493) Grand Gulf LRA Draft RAI Set 6 Project stage: Draft RAI ML12087A0012012-04-18018 April 2012 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application (TAC ME7493)Grand Gulf LRA RAI Set 07 Project stage: RAI ML12094A0092012-04-25025 April 2012 Requests for Additional Information for the Review of the Grand Gulf Nulcear Station Licesne Renewal Application Project stage: RAI ML12101A3602012-04-26026 April 2012 Request for Additional Information for the Review of Th Grand Gulf Nuclear Station License Renewal Application (TAC No. ME7493) Grand Gulf LRA RAI Set 09 Project stage: RAI ML12104A2192012-04-30030 April 2012 Request for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application (TAC No. ME7493)LRA RAI Set 10 Project stage: RAI GNRO-2012/00029, Response to Request for Additional Information (RAI) Regarding the License Renewal Application2012-05-0101 May 2012 Response to Request for Additional Information (RAI) Regarding the License Renewal Application Project stage: Response to RAI ML12109A2132012-05-0303 May 2012 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application (TAC No. ME7493) Grand Gulf LRA RAI Set 11 Project stage: RAI GNRO-2012/00036, Response to Request for Additional Information (RAI) Dated April 12, 20122012-05-0909 May 2012 Response to Request for Additional Information (RAI) Dated April 12, 2012 Project stage: Response to RAI ML12118A5392012-05-15015 May 2012 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12125A3732012-05-24024 May 2012 Requests for Additional Information for the Review of the Grant Gulf Nuclear Station License Renewal Application (TAC No. ME7493)Grand Gulf LRA RAI Set 17 Project stage: RAI ML12139A0552012-05-29029 May 2012 LRA RAI Set 19 Project stage: RAI ML12151A2652012-06-15015 June 2012 Request for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application (TAC No. ME7493) Grand Gulf LRA RAI Set 20 Project stage: RAI ML12165A3872012-06-20020 June 2012 Scoping and Screening Methodology Audit Report Regarding the Grand Gulf Nuclear Station, Unit 1, License Renewal Application Project stage: Other ML12151A3682012-06-20020 June 2012 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12152A3932012-06-22022 June 2012 Request for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12152A3452012-06-22022 June 2012 Request for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application (Tac No. ME7493) Project stage: RAI ML12157A0562012-06-27027 June 2012 Request for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application (TAC No. ME7493)Grand Gulf LRA RAI Set 24 Project stage: RAI ML12164A7262012-06-27027 June 2012 RAI for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12180A5412012-07-17017 July 2012 Summary of Telephone Conference Call Held on March 14, 2012, Between NRC and Entergy Operations, Inc., Concerning RAI Pertaining to the Grand Gulf Nuclear Station, LRA Project stage: RAI ML12188A7062012-07-17017 July 2012 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12188A5162012-07-23023 July 2012 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12200A1382012-07-27027 July 2012 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12201B4762012-07-27027 July 2012 LRA RAI Set 30 Project stage: RAI ML12191A1872012-07-31031 July 2012 LRA RAI Telecon 2012-04-13 Project stage: RAI ML12208A2672012-08-0707 August 2012 RAI for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12193A0712012-08-15015 August 2012 Summary of Telephone Conference Call Held on 5/15/12 Between the U.S. Nuclear Regulatory Commission and Entergy Operations, Inc., Concerning Requests for Additional Information Pertaining to the Grand Gulf Nuclear Station, LRA Project stage: RAI ML12220A3372012-08-15015 August 2012 RAI for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12201B5042012-08-15015 August 2012 Summary of Telephone Conference Call Held on 5/23/12 Between the U.S. Nuclear Regulatory Commission and Entergy Operations, Inc., Concerning the RAIs Pertaining to the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12202A2142012-08-15015 August 2012 5/30/12 Summary of Telephone Conference Call Held Between the U.S. Nuclear Regulatory Commission and Entergy Operations, Inc., Concerning Requests for Additional Information Pertaining to the Grand Gulf Nuclear Station, LRA Project stage: RAI ML12230A3102012-08-21021 August 2012 Correction to Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12201B5452012-08-28028 August 2012 Summary of Telephone Conference Call Held on 6/5/12, Between NRC and Entergy, Concerning RAI Pertaining to the Grand Gulf Nuclear Station, LRA Project stage: RAI ML12209A1482012-08-28028 August 2012 6/8/12 Summary of Telephone Conference Call Held Between the U.S. Nuclear Regulatory Commission and Entergy Operations, Inc., Concerning Requests for Additional Information Pertaining to the Grand Gulf Nuclear Station, LRA Project stage: RAI ML12234A6712012-09-0505 September 2012 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12242A5452012-09-0707 September 2012 Revision of Schedule for the Conduct of Review of the Grand Gulf Nuclear Station, LRA Project stage: Approval ML12230A2472012-09-0707 September 2012 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12214A5482012-09-14014 September 2012 7/18/12 Summary of Telephone Conference Call Held Between the U.S. Nuclear Regulatory Commission and Entergy Operations, Inc., Concerning Requests for Additional Information Pertaining to the Grand Gulf Nuclear Station, LRA Project stage: RAI ML12248A1582012-09-14014 September 2012 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12270A2492012-10-0303 October 2012 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12278A0362012-10-17017 October 2012 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Project stage: RAI ML12286A0242012-10-19019 October 2012 RAI for the Review of the Grand Gulf Nuclear Station LRA Project stage: RAI GNRO-2012/00128, Response to Requests for Additional Information (RAI) Set 38 Dated 10/03/20122012-10-22022 October 2012 Response to Requests for Additional Information (RAI) Set 38 Dated 10/03/2012 Project stage: Response to RAI ML12264A3872012-10-31031 October 2012 Summary of Telephone Conference Call Held on 8/21/12, Between the U.S. Nuclear Regulatory Commission and Entergy Nuclear Operations, Inc., Concerning Requests for Additional Information Pertaining to the Grand Gulf Nuclear Station, LRA Project stage: RAI ML12250A1052012-10-31031 October 2012 Summary of Telephone Conference Call Held on 8/15/12 Between the U.S. Nuclear Regulatory Commission and Entergy Operations, Inc., Concerning Requests for Additional Information Pertaining to the Grand Gulf Nuclear Station, LRA Project stage: RAI 2012-05-15
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Category:Letter type:GNRO
MONTHYEARGNRO-2023/00014, License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2023-06-0606 June 2023 License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b GNRO-2023/00015, Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors2023-06-0606 June 2023 Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors GNRO-2021/00037, 2021 Annual Report of Changes and Errors to 10 CFR 50.46 Analysis Grand Gulf Nuclear Station, Unit 12021-11-30030 November 2021 2021 Annual Report of Changes and Errors to 10 CFR 50.46 Analysis Grand Gulf Nuclear Station, Unit 1 GNRO-2021/00017, Notification of Readiness for Supplemental Inspection2021-06-22022 June 2021 Notification of Readiness for Supplemental Inspection GNRO-2021/00014, Inservice Testing Program Relief Request VRR-GGNS-2021-1 Pressure Isolation Valve Testing Frequency2021-06-0101 June 2021 Inservice Testing Program Relief Request VRR-GGNS-2021-1 Pressure Isolation Valve Testing Frequency GNRO-2021/00015, Annual Radioactive Effluent Release Report2021-04-28028 April 2021 Annual Radioactive Effluent Release Report GNRO-2021/00011, Revision of Original Report of 10CFR50.59 and Commitments Change Evaluations - July 1, 2018 Through May 21, 20202021-04-19019 April 2021 Revision of Original Report of 10CFR50.59 and Commitments Change Evaluations - July 1, 2018 Through May 21, 2020 GNRO-2021/00012, Annual Report of Individual Monitoring - NRC Form 5 for 2020 Per 10 CFR 20.22062021-04-13013 April 2021 Annual Report of Individual Monitoring - NRC Form 5 for 2020 Per 10 CFR 20.2206 GNRO-2020/00045, 2020 Report of Changes and Errors to 10 CFR 50.46 Analysis2020-12-16016 December 2020 2020 Report of Changes and Errors to 10 CFR 50.46 Analysis GNRO-2020/00034, Notification of Spent Fuel Cask Use2020-10-0808 October 2020 Notification of Spent Fuel Cask Use GNRO-2020/00033, Response to NRC Integrated Inspection Report 05000416/20200022020-09-10010 September 2020 Response to NRC Integrated Inspection Report 05000416/2020002 GNRO-2020/00029, Report of 10 CFR 72.48 Evaluations July 1, 2018 Through June 30, 20202020-08-18018 August 2020 Report of 10 CFR 72.48 Evaluations July 1, 2018 Through June 30, 2020 GNRO-2020/00022, Report of Technical Specification Bases Changes2020-07-21021 July 2020 Report of Technical Specification Bases Changes GNRO-2020/00027, Core Operating Limits Report (COLR) Cycle 23 Revision 1 for Grand Gulf Nuclear Station, Unit 1 (GGNS)2020-07-16016 July 2020 Core Operating Limits Report (COLR) Cycle 23 Revision 1 for Grand Gulf Nuclear Station, Unit 1 (GGNS) GNRO-2020/00023, Response to Request for Additional Information - License Amendment Request for Permanent Extension of Appendix J Type a Integrated Leakage Rate Test Frequencies2020-06-26026 June 2020 Response to Request for Additional Information - License Amendment Request for Permanent Extension of Appendix J Type a Integrated Leakage Rate Test Frequencies GNRO-2020/00020, Core Operating Limits Report (COLR) Cycle 23, and Pressure and Temperature Limits Report (PTLR) Update for Grand Gulf Nuclear Station, Unit 1 (GGNS)2020-05-0505 May 2020 Core Operating Limits Report (COLR) Cycle 23, and Pressure and Temperature Limits Report (PTLR) Update for Grand Gulf Nuclear Station, Unit 1 (GGNS) GNRO-2020/00018, Annual Radiological Effluent Release Report2020-04-30030 April 2020 Annual Radiological Effluent Release Report GNRO-2020/00016, Annual Report of Individual Monitoring -NRC Form 5 for 2019 Per 10 CFR 20.22062020-04-16016 April 2020 Annual Report of Individual Monitoring -NRC Form 5 for 2019 Per 10 CFR 20.2206 GNRO-2020/00015, Response to Request for Additional Information - License Amendment Request for One-Cycle Extension of Appendix J Type a Integrated Leakage Rate Test and Drywell Bypass Leakage Rate Test2020-04-0707 April 2020 Response to Request for Additional Information - License Amendment Request for One-Cycle Extension of Appendix J Type a Integrated Leakage Rate Test and Drywell Bypass Leakage Rate Test GNRO-2020/00007, Spent Fuel Storage Radioactive Effluent Release Report for 20192020-02-20020 February 2020 Spent Fuel Storage Radioactive Effluent Release Report for 2019 GNRO-2020/00006, License Amendment Request for Permanent Extension of Appendix J Type a Integrated Leakage Rate Test Frequencies2020-02-19019 February 2020 License Amendment Request for Permanent Extension of Appendix J Type a Integrated Leakage Rate Test Frequencies GNRO-2019/00052, Report of Changes and Errors to 10 CFR 50.46 Analysis2019-12-13013 December 2019 Report of Changes and Errors to 10 CFR 50.46 Analysis GNRO-2019/00051, Notification of Readiness of 92723 Inspection2019-12-11011 December 2019 Notification of Readiness of 92723 Inspection GNRO-2019/00045, Emergency Plan, Revision 792019-10-29029 October 2019 Emergency Plan, Revision 79 GNRO-2019/00037, Notification of Spent Fuel Cask Use2019-09-20020 September 2019 Notification of Spent Fuel Cask Use GNRO-2019/00036, Correction to Gnro 2019-00017 Emergency Plan Revision 782019-08-0808 August 2019 Correction to Gnro 2019-00017 Emergency Plan Revision 78 GNRO-2019/00027, Notification of Readiness of 95001 Supplemental Inspections2019-07-0303 July 2019 Notification of Readiness of 95001 Supplemental Inspections GNRO-2019/00031, Annual Report of Individual Monitoring - NRC Form 5 for 2018 Per 10 CFR 20.2206 - Corrected Report2019-06-25025 June 2019 Annual Report of Individual Monitoring - NRC Form 5 for 2018 Per 10 CFR 20.2206 - Corrected Report GNRO-2019/00028, Supplement to Revise Technical Specification (TS) 3.3.1.1, Reactor Protection System (RPS) Instrumentation, and TS 3.3.4.1, End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation.2019-06-13013 June 2019 Supplement to Revise Technical Specification (TS) 3.3.1.1, Reactor Protection System (RPS) Instrumentation, and TS 3.3.4.1, End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation. GNRO-2019/00026, Response to Requests for Additional Information Regarding Relief Request Number GG-ISI-023, Inservice Inspection Impracticality - Limited Coverage Examinations During the Third 10-Year Inservice Inspection Interval2019-05-0606 May 2019 Response to Requests for Additional Information Regarding Relief Request Number GG-ISI-023, Inservice Inspection Impracticality - Limited Coverage Examinations During the Third 10-Year Inservice Inspection Interval GNRO-2019/00024, Annual Radioactive Effluent Release Report2019-04-30030 April 2019 Annual Radioactive Effluent Release Report GNRO-2019/00020, Annual Radiological Operating Report (AREOR)2019-04-30030 April 2019 Annual Radiological Operating Report (AREOR) GNRO-2019/00022, Annual Report of Individual Monitoring - NRC Form 5 for 2018 Per 10 CFR 20.22062019-04-22022 April 2019 Annual Report of Individual Monitoring - NRC Form 5 for 2018 Per 10 CFR 20.2206 GNRO-2019/00017, Emergency Plan, Revision 782019-03-14014 March 2019 Emergency Plan, Revision 78 GNRO-2019/00014, Snubber Testing Program for Fourth Inspection Interval2019-03-13013 March 2019 Snubber Testing Program for Fourth Inspection Interval GNRO-2019/00012, Internal Events Probabilistic Risk Assessment (PRA) Sensitivity Study Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program2019-03-0606 March 2019 Internal Events Probabilistic Risk Assessment (PRA) Sensitivity Study Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program GNRO-2019/00016, Spent Fuel Storage Radioactive Effluent Release Report for 20182019-02-21021 February 2019 Spent Fuel Storage Radioactive Effluent Release Report for 2018 GNRO-2019/00003, Application to Revise Technical Specification (TS) 3.3.1.1, Reactor Protection System (RPS) Instrumentation, and TS 3.3.4.1, End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation2019-01-23023 January 2019 Application to Revise Technical Specification (TS) 3.3.1.1, Reactor Protection System (RPS) Instrumentation, and TS 3.3.4.1, End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation GNRO-2018/00057, Submittal of Revision 17 to the Grand Gulf Nuclear Station Physical Security, Safeguards Contingency, and Training and Qualification Plan2018-12-0404 December 2018 Submittal of Revision 17 to the Grand Gulf Nuclear Station Physical Security, Safeguards Contingency, and Training and Qualification Plan GNRO-2018/00055, Response to Request for Additional Information for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a ...2018-11-30030 November 2018 Response to Request for Additional Information for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a ... GNRO-2018/00054, Relief Request No. GG-ISI-023, Inservice Inspection Impracticality: Limited Coverage Examination During the Third 10-Year Inservice Inspection Interval2018-11-30030 November 2018 Relief Request No. GG-ISI-023, Inservice Inspection Impracticality: Limited Coverage Examination During the Third 10-Year Inservice Inspection Interval GNRO-2018/00052, License Amendment Request to Incorporate Tornado Missile Risk Evaluator Into Licensing Basis - Partial Response to Request for Additional Information and Extension of Response to Request for Additional Information2018-10-24024 October 2018 License Amendment Request to Incorporate Tornado Missile Risk Evaluator Into Licensing Basis - Partial Response to Request for Additional Information and Extension of Response to Request for Additional Information GNRO-2018/00051, Supplement to Revise Technical Specifications to Adopt Technical Specification Task Force Traveler TSTF-542, Reactor Pressure Vessel Water Inventory Control2018-10-23023 October 2018 Supplement to Revise Technical Specifications to Adopt Technical Specification Task Force Traveler TSTF-542, Reactor Pressure Vessel Water Inventory Control GNRO-2018/00046, Submittal of 2018 Report of Changes and Errors to 10CFR50.462018-10-16016 October 2018 Submittal of 2018 Report of Changes and Errors to 10CFR50.46 GNRO-2018/00047, Submittal of 2018 Inservice Inspection Summary Report2018-10-16016 October 2018 Submittal of 2018 Inservice Inspection Summary Report GNRO-2018/00048, Response to Request for Additional Information License Amendment Request, Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 62018-10-10010 October 2018 Response to Request for Additional Information License Amendment Request, Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6 GNRO-2018/00042, Core Operating Limits Report Cycle 22, Revision 12018-09-18018 September 2018 Core Operating Limits Report Cycle 22, Revision 1 GNRO-2018/00043, Revised Offsite Dose Calculation Manual2018-09-18018 September 2018 Revised Offsite Dose Calculation Manual GNRO-2018/00039, Report of Technical Specification Bases Changes2018-08-20020 August 2018 Report of Technical Specification Bases Changes GNRO-2018/00040, Report of 10CFR50.59 Evaluations and Commitment Change Evaluations - July 1, 2016 Through June 30, 20182018-08-20020 August 2018 Report of 10CFR50.59 Evaluations and Commitment Change Evaluations - July 1, 2016 Through June 30, 2018 2023-06-06
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Text
Fnh~rnv Ope~ratic:ms, Inc.
Kevin J. Mulligan GNRO-201 September 23, 3 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Response to Requests for Additional Information (RAI) Set 47, dated August 28,2013 Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29
REFERENCE:
U.S. Nuclear Regulatory Commission Letter, "Requests for Additional Information for the Review of the Grand Gulf Nuclear Station, License Renewal Application," dated August 28, 2013 (Accession No.:
ML13227A394)
Dear Sir or Madam:
Entergy Operations, Inc. is providing, in the Attachment, the response to the referenced Request for Additional Information (RAI) Set 47.
If you have any questions or require additional information, please contact Mr. Christopher R.
Robinson at (601) 437-7326.
This letter contains no new commitments. I declare under penalty of perjury that the foregoing is true and correct Executed on the 23rd day of September, 2013.
Sincerely, KJM/jas
Attachment:
Response to Requests for Additional Information cc: (see next page)
cc:
U.S. Nuclear Regulatory Commission AnN: Mr. Steven Reynolds Acting Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 U.S. Nuclear Regulatory Commission AnN: Mr. Alan Wang, NRRlDORL Mail Stop OWFN/8 G14 Washington, DC 20555 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150
Attachment to GNRO-2013/00069 Response to Requests for Additional Information
GNRO-201 GGNS RAI 4.2.1-2c The in response to requests for information (RAls) that to reactor vessel neutron fluence calculations.
Although the license renewal application states, "the neutron fluence for the welds and shells of the reactor pressure vessel beltline region was determined using the General Electric-Hitachi method for neutron flux calculation documented in report NEDC-32983P-A and approved by the NRC," an additional method was also used. The applicant stated in a letter dated July 25,2012, that, "Pre-EPU fluence values were generated from the MPM Technologies, Inc. (MPM) analysis. MPM analysis is consistent with the guidance contained in RG 1.190 and is approved by the NRC in TAG No. MB6687, Nine Mile Point Nuclear Station, Unit NO.1-Issuance of Amendment RE: Pressure-Temperature Limit Curves and Tables, October 27,2003 ... "
(ML12208A166). The applicant also stated that the uncertainty associated with using a combination of the MPM calculations with the General Electric-Hitachi (GEH) fluence calculations would fall between the uncertainty associated with either method (ML13022A474).
The NRC staff does not agree that this information and evaluation adhere to the guidance contained in NRC Regulatory Guide (RG) 1.190, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence." Regulatory Position 1.4, "Methodology Qualification and Uncertainty Estimates," provides guidance concerning the qualification of an acceptable fluence method, stating the following:
The methods qualification consists of three parts: (1) the analytic uncertainty analysis (Regulatory Position 1.4.1 ), (2) the comparison with benchmarks and operating reactor measurements (Regulatory Position 1.4.2), and (3) the estimate of uncertainty in the calculated fluence (Regulatory Position 1.4.3).
The NRC staff notes that the GEH fluence calculations adhere to a methodology that has received generic NRC staff approval, and is acceptable for referencing in licensing actions. This approval is documented in the NRC staff safety evaluation (SE) approving NEDC-32983P-A.
The SE also documents generic adherence of the GEH calculative method to the guidance, listed above, in RG 1.190. The GEH methodology qualification adequately addresses the three aspects noted above and consists of an analytic uncertainty analysis (described in Chapter 7 of NEDC-32983P-A), comparisons to the Oak Ridge National Laboratory Pool Critical Assembly (PCA) benchmark, solution of the generic boiling-water reactor (BWR) benchmark fluence problem documented in NUREG/CR 6115, code-to-code comparisons of the BWR benchmark fluence problem, and an extensive database of comparisons to BWR surveillance capsule dosimetry analyses. The database includes blind benchmark calculations.
The staff also notes that its review of fluence calculations as presented in BWR license amendments have been of the type where one methodology is applied throughout a reactor vessel's life (Le., from 0 effective full-power year (EFPY) to the desired endpoint EFPY); the staff could not locate any successful amendment where one methodology was used from 0
of RG 1.1 states, in part,
'n"'\n~r,C'/"'\nC' of and nO'-Tnfn'\c;,rI for the specific reactor being analyzed or for reactors of similar II The BWRl2 design lacks jet pumps and cannot be considered to be similar in design to a BWRl6 such as GGNS11 . Therefore, the basis on which the NRC staff approved the reactor vessel pressure temperature limits revision at Nine Mile Point Station, Unit 1, does not pertain to GGNS. Furthermore, since the method used to perform the MPM calculations is not documented in an NRC-approved methodology, a detailed description of the calculative methods, and their qualification, as both pertain to GGNS, must be submitted for NRC staff review and approval for referencing in the license renewal application.
This will enable the staff to reach a determination regarding whether the MPM fluence calculations are adherent to RG 1.190, or are otherwise acceptable.
Similarly, the NRC staff has determined that the applicability of the GEH fluence methodology to GGNS should also be established. This effort may include plant-specific dosimetry comparisons, or establishing that the existing qualification contained in NEDC-32983P-A is adequate.
The use of a combined method - using fluence from two separate methods - requires an additional analytic uncertainty analysis and an extensive amount of further validation and verification. The staff is not aware of any such combined method being approved in the past, and therefore such a proposal would require significant review to determine whether this approach could be found to comply acceptably with NRC guidance or not. For example, any codependent terms in the uncertainty associated with either method must be appropriately treated in the analysis, and any uncertainties associated with either method that could propagate must be investigated. In addition, the significant difference in flux values associated with each method (limiting location flux values differ by approximately 70 percent) warrants a thorough investigation of the causes, and GGNS would need to provide extensive justification.
The results of this investigation need to be adequately explained in order to establish that both calculations are reasonably accurate.
In addition, the staff noted that the applicant's response to RAI 4.2.1-2b dated January 18, 2013, did not clearly address why the modeling variation between the MPM and GEH methods resulted in the MPM method yielding conservative bounding-case flux values for core shroud welds H1, V1, V2, V3, and V4.
1 The presence or lack of jet pumps is not the only defining characteristic. Other relevant design considerations, including but not limited to vessel diameter and material composition, number of jet pumps, locations of welds, nozzles and other appurtenances, must also be addressed in establishing a valid calculational benchmark
Attachment to GNRO-2013/00069 Page 3 5 Finally, the applicant's response dated January 18, 2013, indicates that the fluence values for the reactor vessel internals are calculated by using several different calculational methods depending on the availability of pre-EPU fluence values, the internal components' locations, and the perceived validity of the chosen methods. The staff needs additional information to determine whether the use of these different calculational methods is adequate to calculate the fluence values of reactor vessel internals.
Request:
- 1) Provide the following information regarding reactor vessel fluence:
(a) Provide a detailed description of the MPM fluence calculations. Include a description of the methods and data sets used to perform the calculations, describe the analytic representation of the reactor geometry, and provide a detailed description of the problem setup, execution, and post-processing. Also provide detailed results from the analysis.
(b) Provide a description of the qualification of the MPM fluence calculational methods in sufficient detail to establish adherence to RG 1.190 as it applies to the BWRl6 design and GGNS in particular, or provide sufficient details to demonstrate to the staff that the calculations are otherwise acceptable for use at GGNS.
(c) Provide information to demonstrate that the GEH analytic method is suitably qualified for analysis of the GGNS reactor vessel.
(d) Provide a detailed, analytic uncertainty analysis of that accounts for any additional uncertainty or bias associated with adding fluence values together from these two methods. Also provide benchmarking information to show that the results of the vessel fluence analyses remain valid when combined.
(e) Provide information to establish that the difference between the two flux values calculated using the different methods is valid. For example, compare the two methods in calculational benchmarks: provide an estimate of the pre-extended power uprate (EPU) fluence using GEH calculational methods and provide an estimate of the post-EPU fluence using MPM calculational methods.
- 2) Provide a description, including a technical basis, for each of the different calculational methods that are used to determine the fluence values of the reactor vessel internals. For each of the reactor vessel internal components, describe the fluence calculational method
GNRO-201 GEH methods (H1 V2, V3, the MPM
\Jllh1::11'ht::l ... the analysis with the MPM method the ...cn:lrln as water, without explicitly modeling the stainless steel top In addition, clarify whether the analysis with the GEH method uses this approximation as well.
- 5) As an alternative to Items 1-3 above, please provide:
a) Fluence values that have been determined from Beginning Of Life to End of Life Extended in accordance with a single method.
i) If the method is NRC-approved insofar as it applies to vessel fluence calculations, provide the reference to the staff-accepted methodology.
ii) If the method is not NRC-approved, provide the plant-specific calculations and documentation, and include sufficient information, to enable the NRC staff to determine whether the calculation adheres to NRC Regulatory Guide (RG) 1.190, IICalculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence,lI or other justification as required to establish that the fluence calculation is acceptable.
1 iii) Refer to Regulatory Position 3, IIReporting/ for the specific documentation required to establish adherence to NRC RG 1.190.
b) Finally, confirm whether, and describe how, the remaining neutron fluence-related timelimited aging analyses are affected by this new fluence calculation.
GGNS RAI 4.2.1-2c Response:
- 1) GGNS has chosen to respond to question 5. Therefore, no answer is provided to this question.
- 2) GGNS has chosen to respond to question 5. Therefore, no answer is provided to this question.
- 3) GGNS has chosen to respond to question 5. Therefore, no answer is provided to this question.
- 5) A to this RAI is being developed and will provided to the NRC within 7 to 9 months from the date of letter. The supplemental response will provide the answers to the following questions.
a) Fluence values that have been determined from Beginning Of Life to End of Life Extended in accordance with a single method.
i) If the method is NRC-approved insofar as it applies to vessel fluence calculations, provide the reference to the staff-accepted methodology.
ii) If the method is not NRC-approved, provide the plant-specific calculations and documentation, and include sufficient information, to enable the NRC staff to determine whether the calculation adheres to NRC Regulatory Guide (RG) 1.190, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence," or other justification as required to establish that the fluence calculation is acceptable.
iii) Refer to Regulatory Position 3, "Reporting," for the specific documentation required to establish adherence to NRC RG 1.190.
b) Finally, confirm whether, and describe how, the remaining neutron fluence-related timelimited aging analyses are affected by this new fluence calculation.