ML14349A495
| ML14349A495 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/10/2014 |
| From: | Dent J Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML14349A493 | List: |
| References | |
| 2.14.076 | |
| Download: ML14349A495 (11) | |
Text
==W Entergy Nuclear Operations, Inc.
-600 Rocky Hill Road Plymouth, MA 02360 contains proprietary information to be withheld from public disclosure under 10 CFR 2.390.
When separated, this letter can be made public.
December 10, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Proposed Change to Pilgrim Technical Specifications Concerning the Safety Limit Minimum Critical Power Ratio Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 LETTER NUMBER: 2.14. 076
Dear Sir or Madam:
Pursuant to 10 CFR 50.90, Entergy proposes to amend Facility Operating License DPR-35 for the Pilgrim Nuclear Power Station by modifying Technical Specification Section 2.1.2.
This application proposes to change the Safety Limit Minimum Critical Power Ratio (SLMCPR) in Technical Specification (TS) Section 2.1.2 from _ 1.08 to __ 1.10 for two recirculation loop operation and from _> 1.11 to ___
1.12 for single loop operation. contains a description of the proposed changes, a safety evaluation of the changes, the Determination of No Significant Hazards Consideration, and an Environmental Assessment. contains the current Technical Specification page marked up with the proposed revisions. contains the proposed revised Technical Specification page.
Entergy requests the NRC staff's timely review and approval of this proposed amendment to support startup from Refueling Outage (RFO)-20, on or about May 1, 2015. Therefore, in order to support Cycle 21 operation, it is requested the proposed changes be issued by April 1, 2015, to provide sufficient time to revise affected documents prior to startup from RFO-20.
Am ii
Entergy Nuclear Operations, Inc.
Letter Number: 2.14.076 Pilgrim Nuclear Power Station Page 2 of 3 contains proprietary information to be withheld from public disclosure under 10 CFR 2.390.
When separated, this letter can be made public.
Following approval of the proposed amendment, the Core Operating Limits Report and applicable operating procedures will be revised prior to start-up from RFO-20.
This submittal contains no new regulatory commitments.
If you have questions regarding this subject, please feel free to contact Everett P.
Perkins at (508) 830-8323.
I declare under the penalty of perjury that the foregoing information is true and correct.
Executed on the
,/V day of 2014 Sincerely, John A. D nt, Jr.
Site Vice President JAD/mew Attachments:
- 1.
Description and Evaluation of Proposed Technical Specification Change to Safety Limit Minimum Critical Power Ratio (3 pages)
- 2.
Technical Specification Marked Up Page (1 page)
- 3.
Technical Specification Revised Page (1 page)
- 4.
Global Nuclear Fuels Non-Proprietary Report, GNF-001N8659-R1-NP, "GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR, Pilgrim Cycle 21", dated September 2014 (26 pages)
- 5.
Global Nuclear Fuels-Americas Affidavit for Withholding Proprietary Report, GNF-001N8659-R1-P, "GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR, Pilgrim Cycle 21" (3 pages)
- 6.
Global Nuclear Fuels Proprietary Report, GNF-001N8659-R1-P, "GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR, Pilgrim Cycle 21", dated September 2014 (29 pages)
Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station Letter Number: 2.14.076 Page 3 of 3 contains proprietary information to be withheld from public disclosure under 10 CFR 2.390.
When separated, this letter can be made public.
cc:
U.S. Nuclear Regulatory Commission ATTN: Dan Dorman Regional Administrator, Region 1 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Ms. Nadiyah Morgan, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North O-8F4 11555 Rockville Pike Rockville, MD 20852 NRC Senior Resident Inspector Pilgrim Nuclear Power Station Mr. John Priest, Director Massachusetts Department of Public Health Schraft Center Sui te 1 M2A Radiation Control Program 529 Main Street Charlestown, MA 02129 Mr. John Giarrusso, Jr.
Nuclear Preparedness Manager Mass. Emergency Management Agency 400 Worcester Road Framingham, MA 01702
ATTACHMENT 1 to Entergy Letter 2.14.076 Description and Evaluation of Proposed Technical Specification Change to Safety Limit Minimum Critical Power Ratio (3 Pages)
Page 1 of 3 ATTACHMENT 1 Description and Evaluation of Proposed Technical Specifications Change to Safety Limit Minimum Critical Power Ratio BACKGROUND Entergy is proposing to amend the Pilgrim Technical Speciation (TS) Section 2.1.2 to revise the Safety Limit Minimum Critical Power Ratio (SLMCPR) for the Operating Cycle (OC) 21. OC 21 commences from the restart of Refueling Outage (RFO) 20.
PROPOSED CHANGES Based upon GE calculations for Pilgrim core reload analysis for Operating Cycle 21, the calculated SLMCPR changed from _> 1.08 to Ž_ 1.09 for two recirculation loop operation and SLMCPR changed from _ 1.11 to >-_ 1.12 for single recirculation loop operation. Accordingly, TS Section 2.1.2 is revised to read as follows:
"MINIMUM CRITICAL POWER RATIO shall be ___
1.10 for two recirculation loop operation and _ 1.12 for single recirculation loop operation."
REASONS FOR THE PROPOSED CHANGES The current required Safety Limit MCPR (SLMCPR) for Pilgrim Station is _ 1.08 for two loop operation and _ 1.11 for single loop operation. Calculations performed by Global Nuclear Fuel for Pilgrim Station Operating Cycle 21 resulted in a minimum calculated SLMCPR value of _
1.09 for two loop operation and __ 1.12 for single loop operation.
Entergy is proposing to operate with a SLMCPR of > 1.10 to account for SLMCPR variances in fuel cycle(s) subsequent to Cycle 21 for two loop recirculation loop operation and Ž_ 1.12 SLMCPR for single recirculation loop operation. This is conservative.
Page 2 of 3 ATTACHMENT 1 (Cont.)
SAFETY EVALUATION The Fuel Cladding Integrity Safety Limit is set such that no mechanistic fuel damage is calculated to occur if the limit is not violated. Since the parameters which result in fuel damage are not directly observable during reactor operation, the thermal and hydraulic conditions resulting in a departure from nucleate boiling have been used to mark the beginning of the region where fuel damage could occur. Although it is recognized that a departure from nucleate boiling would not necessarily result in damage to BWR fuel rods, the critical power at which boiling transition is calculated to occur has been adopted as a convenient limit. The uncertainties, however, in monitoring the core operating state and in the procedures used to calculate the critical power result in an uncertainty in the value of the critical power. Therefore, the Fuel Cladding Integrity Safety Limit is defined as the minimum critical power ratio (MCPR) in the limiting fuel assembly for which more than 99.9% of the fuel rods in the core are expected to avoid boiling transition considering the power distribution within the core and all uncertainties Global Nuclear Fuel's calculation of the revised plant-specific SLMCPR value for Pilgrim's Cycle 21 was performed as part of the Reload Licensing Analysis for Pilgrim Cycle 21 and is based upon NRC approved methods specified in the Reference section of the TS BASES for Section 2.0 SAFETY LIMITS. The new Pilgrim Station SLMCPR is _1.10 for two recirculation loop operation and _>1.12 for single recirculation loop operation.
Based on the above, it is concluded that the proposed SLMCPR values are appropriate for the Pilgrim Cycle 21 core. Entergy will include the Cycle 21 Power/Flow map in the Core Operating Limits Report for Cycle 21.
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS The Code of Federal Regulations, 10 CFR 50.91, requires licensees requesting an amendment to provide an analysis, using the standards in 10 CFR 50.92, which determines whether a significant hazards consideration exists. The following analysis is provided in accordance with 10 CFR 50.91 and 10 CFR 50.92 for the proposed amendment.
- 1. The proposed changes to Technical Specification do not involve a significant increase in the probability of an accident previously evaluated.
The proposed Safety Limit MCPR (SLMCPR), and its use to determine the Operating Cycle 21 thermal limits, have been derived using NRC approved methods specified in the Reference section of the Technical Specification Bases Section for 2.0 SAFETY LIMITS.
These methods do not change the method of operating the plant and have no effect on the probability of an accident initiating event or transient.
The basis of the SLMCPR is to ensure no mechanistic fuel damage is calculated to occur if the limit is not violated. The new SLMCPR preserves the margin to transition boiling, and the probability of fuel damage is not increased.
Therefore, the proposed changes to Technical Specifications do not involve an increase in the probability or consequences of an accident previously evaluated.
Page 3 of 3 ATTACHMENT 1 (Cont.)
- 2. The proposed changes to Technical Specifications do not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes result only from the analysis for the Cycle 21 core reload using methods described in NEDE2401 1 P-A (GESTAR II). These methods have been reviewed and approved by the NRC, do not involve any new or unapproved method for operating the facility, and do not involve any facility modifications. No new initiating events or transients result from these changes.
Therefore, the proposed changes to technical specifications do not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. The proposed changes to Technical Specifications do not involve a significant reduction in a margin of safety.
The margin of safety as defined in the TS bases will remain the same. The new SLMCPR was derived using NRC approved methods which are in accordance with the current fuel design and licensing criteria. The SLMCPR remains high enough to ensure that greater than 99.9% of all fuel rods in the core will avoid transition boiling if the limit is not violated, thereby preserving the fuel cladding integrity.
Therefore, the proposed changes to technical specifications do not involve a significant reduction in the margin of safety.
The proposed changes have been reviewed and recommended for approval by the Pilgrim Station On-site Safety Review Committee (OSRC).
ENVIRONMENTAL IMPACT The proposed Technical Specification changes were reviewed against the criteria of 10 CFR 51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, a significant increase in the amounts of effluents that may be released offsite, or a significant increase in individual or cumulative occupational radiation exposure.
Based on the foregoing, Entergy concludes the proposed Technical Specifications meet the criteria in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.
ATTACHMENT 2 to Entergy Letter 2.14.076 Technical Specification Marked Up Page (1 Page)
2.0 SAFETY LIMITS 2.1 Safety Limits 2.1.1 With the reactor steam dome pressure < 785 psig or core flow < 10% of rated core flow:
THERMAL POWER shall be _ 25% of RATED THERMAL POWER.
2.1.2 With the reactor steam dome pressure Ž 785 psig and core flow >__ 10% of rated core flow:
MINIMUM CRITICAL POWER RATIO shall be _ 4-.N 1.10 for two recirculation loop operation or > -44 1.12 for single recirculation loop operation.
2.1.3 Whenever the reactor is in the cold shutdown condition with irradiated fuel in the reactor vessel, the water level shall not be less than 12 inches above the top of the normal active fuel zone.
2.1.4 Reactor steam dome pressure shall be _* 1340 psig at any time when irradiated fuel is present in the reactor vessel.
2.2 Safety Limit Violation With any Safety Limit not met within two hours the following actions shall be met:
2.2.1 Restore compliance with all Safety Limits, and 2.2.2 Insert all insertable control rods.
Amendment No. 15, 27, 12, 72, 133, 16, 171, 191, 219, 223, 232, 235, 2-1
ATTACHMENT 3 to Entergy Letter 2.14.076 Technical Specification Revised Page (1 Page)
2.0 SAFETY LIMITS 2.1 Safety Limits 2.1.1 With the reactor steam dome pressure < 785 psig or core flow < 10% of rated core flow:
THERMAL POWER shall be <_ 25% of RATED THERMAL POWER.
2.1.2 With the reactor steam dome pressure _ 785 psig and core flow >_ 10% of rated core flow:
MINIMUM CRITICAL POWER RATIO shall be _> 1.10 for two recirculation loop operation or _> 1.12 for single recirculation loop operation.
2.1.3 Whenever the reactor is in the cold shutdown condition with irradiated fuel in the reactor vessel, the water level shall not be less than 12 inches above the top of the normal active fuel zone.
2.1.4 Reactor steam dome pressure shall be *_ 1340 psig at any time when irradiated fuel is present in the reactor vessel.
2.2 Safety Limit Violation With any Safety Limit not met within two hours the following actions shall be met:
2.2.1 Restore compliance with all Safety Limits, and 2.2.2 Insert all insertable control rods.
Amendment No. 15, 27, 42, 72, 133, 116,171,101, 219, 223, 232, 235, 2-1