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MONTHYEARML14325A7522014-11-21021 November 2014 License Amendment Request Application to Revise Current Fluence Methodology Project stage: Request ML15036A5642015-02-18018 February 2015 Updated Fluence Methodology License Amendment Request Unacceptable with Opportunity to Supplement Project stage: Other ML15090A1392015-03-30030 March 2015 NRR E-mail Capture - Grand Gulf Nuclear Station, Unit 1, Request for Additional Information Regarding Fluence License Amendment Request Project stage: RAI GNRO-2015/00021, Follow-up Response to U.S. Nuclear Regulatory Commission Letter, Updated Fluence Methodology License Amendment Request Unacceptable with Opportunity to Supplement, Dated February 18, 2015, to Provide.2015-03-30030 March 2015 Follow-up Response to U.S. Nuclear Regulatory Commission Letter, Updated Fluence Methodology License Amendment Request Unacceptable with Opportunity to Supplement, Dated February 18, 2015, to Provide. Project stage: Supplement NRC-2015-0073, Comment (1) of Anonymous Individual Opposing on Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations2015-04-30030 April 2015 Comment (1) of Anonymous Individual Opposing on Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations Project stage: Request GNRO-2015/00031, Response to Request for Additional Information Regarding Fluence License Amendment Request2015-05-0808 May 2015 Response to Request for Additional Information Regarding Fluence License Amendment Request Project stage: Response to RAI GNRO-2015/00038, Response to Request for Additional Information Regarding Fluence License Amendment Request, Request for Commitment2015-06-11011 June 2015 Response to Request for Additional Information Regarding Fluence License Amendment Request, Request for Commitment Project stage: Response to RAI ML15141A1852015-07-15015 July 2015 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance GNRO-2015/00046, Provides Clarification to Fluence Methodology License Amendment Request Letter GNRO-2014/00080 Dated November 21, 2014 to Include Draft marked-up UFSAR Pages and a Regulatory Commitment to Revise the GGNS UFSAR Upon NRC Approval.2015-08-10010 August 2015 Provides Clarification to Fluence Methodology License Amendment Request Letter GNRO-2014/00080 Dated November 21, 2014 to Include Draft marked-up UFSAR Pages and a Regulatory Commitment to Revise the GGNS UFSAR Upon NRC Approval. ML15229A2182015-08-18018 August 2015 Redacted, Issuance of Amendment Adoption of Single Fluence Methodology Project stage: Approval GNRO-2015/00058, Response to License Renewal Application (LRA) Request for Additional Information (RAI) Set 47, Question 4.2.1-2c (5) (a) I2015-09-0101 September 2015 Response to License Renewal Application (LRA) Request for Additional Information (RAI) Set 47, Question 4.2.1-2c (5) (a) I Project stage: Request 2015-05-08
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Category:Letter
MONTHYEARML24012A1422024-01-31031 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0051 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) IR 05000416/20230042024-01-25025 January 2024 Integrated Inspection Report 5000416/2023004 ML24018A0222024-01-18018 January 2024 Core Operating Limits Report (COLR) Cycle 24, Revision 2 IR 05000416/20243012024-01-16016 January 2024 NRC Initial Operator Licensing Examination Approval 05000416/2024301 ML24012A1962024-01-12012 January 2024 Response to 2nd Round Request for Additional Information Concerning Relief Request Number EN-RR-22-001 Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and ML23349A1672023-12-21021 December 2023 Request for Withholding Information from Public Disclosure ML23348A3572023-12-14014 December 2023 Application to Revise Technical Specifications to Use Online Monitoring Methodology Slides and Affidavit for Pre-Submittal Meeting ML23348A3712023-12-14014 December 2023 Notification of an NRC Fire Protection Baseline Inspection (NRC Inspection Report (05000416/2024011) and Request for Information ML23340A2222023-12-13013 December 2023 Project Manager Assignment ML23352A0292023-12-13013 December 2023 Entergy - 2024 Nuclear Energy Liability Evidence of Financial Protection ML23340A1592023-12-13013 December 2023 Entergy Operations, Inc. - Entergy Fleet Project Manager Assignment ML23333A1362023-11-29029 November 2023 Supplement to Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23325A1422023-11-21021 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation IR 05000416/20234032023-11-13013 November 2023 Security Baseline Inspection Report 05000416/2023403 Cover Letter ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV IR 05000416/20230032023-11-0808 November 2023 Integrated Inspection Report 05000416/2023003 ML23270B9932023-09-29029 September 2023 Request to Update ASME Boiler & Pressure Vessel Code Relief Request SE with NRC-Approved Revision of Bwrip Guidelines (GG-ISI-020 & RBS-ISI-019) (EPID L-2022-LLR-0090) - Non-Proprietary ML23270B1892023-09-27027 September 2023 Evacuation Time Estimate Study ML23269A1242023-09-27027 September 2023 Request for Withholding Information from Public Disclosure ML23240A3952023-08-28028 August 2023 Reply to a Notice of Violation; EA-23-019 IR 05000416/20230052023-08-21021 August 2023 Updated Inspection Plan for Grand Gulf Nuclear Station (Report 05000416/2023005) ML23226A1002023-08-18018 August 2023 Regulatory Audit in Support of License Amendment Requests to Adopt TSTF-505, Revision 2, and 10 CFR 50.69 IR 05000416/20230022023-08-0808 August 2023 Integrated Inspection Report 05000416/2023002 and Independent Spent Fuel Storage Installation Inspection Report 07200050/2023001 IR 05000416/20234042023-08-0707 August 2023 Material Control and Accounting Program Inspection Report 05000416/2023404 IR 05000416/20230912023-07-28028 July 2023 Final Significance Determination of a Green Finding and Notice of Violation; NRC Inspection Report 05000416/2023091 ML23208A2112023-07-27027 July 2023 Entergy Operations Inc., Application to Revise Technical Specifications to Adopt TSTF-205, Revision of Channel Calibration, Channel Functional Test, and Related Definitions ML23166B0712023-06-15015 June 2023 Reply to Notice of Violation EA-22-104 and EA-22-115 ML23166B0662023-06-15015 June 2023 Response to NRC Integrated Inspection Report 05000416/2023001 ML23159A2302023-06-0808 June 2023 Response to Request for Additional Information Concerning Request to Update ASME Code Relief Request Safety Evaluations with NRC-Approved Revision of BWRVIP Guidelines (GG-ISI-020, and RBS-ISI-019) GNRO-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 ML23122A1632023-05-18018 May 2023 NRC Inspection Report 05000416/2023090 and Preliminary White Finding IR 05000416/20234022023-05-17017 May 2023 Security Baseline Inspection Report 05000416/2023402 ML23110A8002023-05-10010 May 2023 Notice of Violation; Integrated Inspection Report 05000416/2023001 and NRC Investigation Report 4-2022-004 ML23130A2732023-05-10010 May 2023 and Waterford 3 Steam Electric Station - Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations IR 05000416/20230012023-05-10010 May 2023 Notice of Violation; Integrated Inspection Report 05000416/2023001 and NRC Investigation Report 4-2022-004 ML23117A2172023-05-0101 May 2023 Safety Evaluation for Quality Assurance Program Manual Reduction in Commitment ML23117A0422023-04-27027 April 2023 Annual Radioactive Effluent Release Report (ARERR) ML23111A2132023-04-21021 April 2023 Responses to RAI Concerning Relief Request Number EN-RR-22-001 Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities ML23110A1122023-04-20020 April 2023 Annual Report for Entergy Quality Assurance Program Manual Changes Under 10 CFR 50.54(a)(3), 10 CFR 71.106, and 10 CFR 72.140(d). Notification of Application of Approved Appendix B to 10 CFR 72 Subpart G ML23110A0552023-04-20020 April 2023 Annual Radiological Environmental Operating Report (AREOR) ML23103A1022023-04-13013 April 2023 Annual Report of Individual Monitoring - NRC Form 5 for 2022 Per 10 CFR 20.2206 ML23102A1482023-04-12012 April 2023 Notification of NRC Initial Operator Licensing Examination 05000416/2024301 ML23089A0602023-03-30030 March 2023 Entergy Operations, Inc. - Fleet Project Manager Assignment ML23088A3922023-03-29029 March 2023 Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3)) ML23079A2772023-03-21021 March 2023 U.S. Nuclear Regulatory Commission Presentation at the May 1, 2023, Port Gibson City Council Meeting ML23080A2882023-03-21021 March 2023 Decommissioning Funding Status Report Per 10 CFR 50.75(f)(1) Entergy Operations, Inc IR 05000416/20230112023-03-0808 March 2023 Design Basis Assurance Inspection Report 05000416/2023011 2024-01-31
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML23348A1222023-12-14014 December 2023 NRR E-mail Capture - Grand Gulf, River Bend, and Waterford, Unit 3 - 2nd Round of Official RAIs for RR EN-RR-22-001, Use ASME Code Case N-752, Risk Informed Categorization for Class 2 and 3 Systems ML23116A1462023-04-26026 April 2023 NRR E-mail Capture - Entergy Fleet (Grand Gulf and River Bend) - Final RAI for Request to Update ASME Code Relief Request Safety Evaluations with NRC-Approved Revision of BWRVIP Guidelines (GG-ISI-020, and RBS-ISI-019) ML23059A0742023-02-27027 February 2023 Information Request, Security IR 2023402 ML22353A6122022-12-19019 December 2022 March 2023 Emergency Preparedness Exercise Inspection - Request for Information ML22271A8572022-10-0303 October 2022 Notification of Commercial Grade Dedication Inspection (05000416/2023011) and Request for Information ML22110A1172022-04-19019 April 2022 (GG) 2022 Emergency Preparedness (EP) Program Inspection RFI Sdh 041922 ML21179A1202021-06-28028 June 2021 Notification of NRC Supplemental Inspection of Action Matrix Column 3 (Degraded Performance) Inputs and Request for Information ML21074A0822021-03-15015 March 2021 Notification of Evaluations of Changes, Tests, and Experiments Inspection (Inspection Report 05000416/2021002) and Request for Information ML20363A1462020-12-22022 December 2020 Request for Information: Grand Gulf EP Exercise Inspection - March 2021 ML20258A0202020-09-0909 September 2020 EP Program Inspection RFI, Request for Information to Support and Prepare for Emergency Preparedness (EP) Program Inspection Scheduled to Occur the Week of November 16, 2020 ML20260H4422020-09-0808 September 2020 NRR E-mail Capture - Entergy Fleet (Grand Gulf and River Bend) - Official RAIs for RR Associated with Updating ASME Code RR SEs with NRC-Approved Revision of BWRVIP Guidelines (GG-ISI-020 and RBS-ISI-019) ML20155K7172020-06-0303 June 2020 Notification of NRC Fire Protection Baseline Inspection (NRC Inspection Report 05000416/2020013) and Request for Information ML20150A6012020-05-29029 May 2020 NRR E-mail Capture - Grand Gulf - Official RAI for LAR Associated with Containment ILRT Interval Change from 10 Years to 15 Years ML19302E1082019-10-29029 October 2019 Document Request - GG 95001 - August 2 2019 ML19078A3772019-03-19019 March 2019 NRR E-mail Capture - Grand Gulf - Official Rais for Relief Request GG-ISI-023, Inservice Inspection Impracticality, Limited Coverage Examinations During the Third 10-Year Inservice Inspection Interval ML19063B4882019-03-0404 March 2019 Notification of NRC Triennial Heat Sink Performance Inspection (05000416/2019002) and Request for Information ML18304A4602018-10-31031 October 2018 NRR E-mail Capture - Final Request for Additional Information - TSTF-425 (L-2018-LLA-0106) ML18250A3042018-08-30030 August 2018 NRR E-mail Capture - Final Request for Additional Information - Emergency Action Level Scheme Change (L-2018-LLA-0116) ML18250A3032018-08-0101 August 2018 NRR E-mail Capture - Correction: Draft RAI - EAL Scheme Change (L-2018-LLA-0116) ML18187A3292018-07-20020 July 2018 Request for Additional Information, Request to Revise Updated Final Safety Analysis Report to Incorporate Tornado Missile Risk Evaluator Methodology Into Licensing Basis ML18138A4682018-05-23023 May 2018 Supplemental Information Needed for Acceptance of Request for Licensing Action Adoption of TSTF-425, Relocate Surveillance Frequencies to License Control ML18058A0572018-02-23023 February 2018 Enclosurequest for Additional Information (Letter to J. Giddens Request for Additional Information Regarding Entergy Operations, Inc.'S Decommissioning Funding Plan Update) ML17257A1422017-09-14014 September 2017 NRR E-mail Capture - Grand Gulf - Official Requests for Additional Information (Rais) for RR GG-ISI-020 to Use BWRVIP Guidelines ML17235B1752017-08-23023 August 2017 NRR E-mail Capture - Grand Gulf - Official RAI for Relief Request GG-ISI-021 Associated with Fourth Interval Inservice Inspection Using Code Case N-702 ML17214A0992017-08-0202 August 2017 NRR E-mail Capture - Grand Gulf - Official RAIs for LAR Associated with One Cycle Extension of Appendix J Type a ILRT and Drywell Bypass Test Interval ML17142A2582017-05-19019 May 2017 Notification of NRC Design Bases Assurance Inspection (05000416/2017007) and Initial Request for Information ML16181A1122016-07-12012 July 2016 Request for Additional Information on Severe Accident Mitigation Alternatives for the Review of the Grand Gulf Nuclear Station, Unit 1, License Renewal Application Environmental Review ML16117A1862016-04-26026 April 2016 Entergy Fleet Relief Request EN-ISI-15-1 Request for Additional Information - 04/26/16 Email from R. Guzman to G. Davant (CAC Nos. MF7133-MF7136) ML16013A0642016-01-13013 January 2016 NRR E-mail Capture - Request for Additional Information Entergy CNRO-2015-00023 - Revision to Entergy Quality Assurance Program Manual (Fleet Submittal CAC Nos. MF7086-MF7097) ML15341A1662015-12-0707 December 2015 NRR E-mail Capture - Entergy Fleet RR-EN-15-1, Request for Additional Information (CACs MF6341-MF6349) ML15286A1082015-10-28028 October 2015 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station, License Renewal Application ML15261A5652015-09-24024 September 2015 Request for Additional Information Regarding Proposed Revision of Technical Specifications for Containment Leak Rate Testing ML15085A4932015-04-0606 April 2015 Request for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application, Set 52 GNRO-2015/00002, Response to Electronic Request for Additional Information Regarding Modification of Technical Specification (TS) 3.8.4, DC Sources Operating Surveillance Requirements (Srs) 3.8.4.2 and 3.8.4.5. Amendment Request Dated 12/9/20142015-03-27027 March 2015 Response to Electronic Request for Additional Information Regarding Modification of Technical Specification (TS) 3.8.4, DC Sources Operating Surveillance Requirements (Srs) 3.8.4.2 and 3.8.4.5. Amendment Request Dated 12/9/2014 ML15036A5642015-02-18018 February 2015 Updated Fluence Methodology License Amendment Request Unacceptable with Opportunity to Supplement GNRO-2014/00079, Request for Additional Information Regarding Request for Adoption of TSTF-423, Revision 1, Change in Technical Specification End States (CE-NPSD-1186)2014-11-13013 November 2014 Request for Additional Information Regarding Request for Adoption of TSTF-423, Revision 1, Change in Technical Specification End States (CE-NPSD-1186) GNRO-2014/00076, Response to Request for Additional (RAI) Set 51 Dated September 11, 20142014-11-0606 November 2014 Response to Request for Additional (RAI) Set 51 Dated September 11, 2014 GNRO-2014/00031, Response to Electronic Request for Additional Information Regarding Maximum Extended Load Line Limit Plus Amendment Request, Dated 3/18/20142014-04-11011 April 2014 Response to Electronic Request for Additional Information Regarding Maximum Extended Load Line Limit Plus Amendment Request, Dated 3/18/2014 ML13318A8052014-01-0202 January 2014 Request for Additional Information for the Review of the Grand Gulf Nuclear Station, License Renewal Application (TAC No. ME7493) - Set 50 ML13353A6572013-12-19019 December 2013 Licensed Operator Positive Fitness-For-Duty Test ML13345A1822013-12-19019 December 2013 Supplemental Information Needed for Acceptance of Licensing Action, Request to Revise Technical Specification to Allow Operation in Expanded Maximum Extended Load Line Limit Analysis Plus (Mellla+) Domain ML13316B9862013-11-25025 November 2013 Interim Staff Evaluation and Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) ML13263A2252013-11-21021 November 2013 LRA Draft RAI Set 48 ML13304B4182013-11-0101 November 2013 Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns ML13260A0062013-09-16016 September 2013 Email, Request for Additional Information, Round 3, Request to Revise Technical Specifications and Surveillance Requirements to Support Operation with a 24-Month Fuel Cycle in Accordance with Generic Letter 91-04 ML13238A2342013-09-12012 September 2013 Requests for Additional Information for the Review of the Grand Gulf Nuclear Station, License Renewal Application (TAC No. ME7493) - Set 49 ML13227A3942013-08-28028 August 2013 Request for Additional Information for the Review of the Grand Gulf Nuclear Station, License Renewal Application (TAC No. ME7493) - Set 47 ML13226A1902013-08-14014 August 2013 Request for Additional Information Email, Round 2, Request to Revise FOL to Delete 2.C(32), Partial Feedwater Heating, to Allow Plant to Operate with Final Feedwater Temperature Reduction at End of Fuel Cycle ML13207A1242013-07-30030 July 2013 Request for Additional Information, Overall Integrated Plan in Response to 3/12/2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051) ML13149A3662013-05-29029 May 2013 Request for Additional Information Email Decommissioning Funding Status Report 2023-04-26
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 18, 2015 Vice President, Operations Entergy Operations, Inc.
Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150
SUBJECT:
GRAND GULF NUCLEAR STATION, UNIT 1 -RE: UPDATED FLUENCE METHODOLOGY LICENSE AMENDMENT REQUEST UNACCEPTABLE WITH OPPORTUNITY TO SUPPLEMENT (TAC NO. MF5303)
Dear Sir or Madam:
By letter dated November 21, 2014, Entergy Operations, Inc. (Entergy, the licensee), submitted a license amendment request for the Grand Gulf Nuclear Station, Unit No. 1 (GGNS). The proposed amendment would revise its licensing basis to adopt a single fluence method. The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of this amendment request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Consistent with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, "Application for amendment of license, construction permit, or early site permit," an amendment to the license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications-. Section 50.34 of 10 CFR, "Contents of applications: technical information," addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations .
. The NRC staff has reviewed your application, and concluded that the information delineated in the enclosure to this letter is necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed amendment request in terms of regulatory requirements and the protection of public health and safety and the environment.
In order to make the application complete, the NRC staff requests that Entergy supplement the application to address the information requested in the enclosure by February 24, 2015.
This will enable the NRC staff to complete its detailed technical review. If the information response to the NRC staff's request is not received by the above date, the application will not be
- accepted for review pursuant to 10 CFR 2.101, "Filing of application," and the NRC staff will cease its review activities associated with the application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the NRC staff's detailed technical review by separate correspondence.
The information requested and associated time frame in this letter were discussed with Richard Scarbrough of your staff on February 5, 2015.
If you have any questions, please contact the GGNS, Project Manager, Alan B. Wang, at (301) 415-1445 or by e-mail at Alan.Wang@nrc.gov.
Sincerely, Al9t P~:r.:er Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416
Enclosure:
Request for Information
- cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 REQUEST FOR INFORMATION REGARDING FLUENCE METHODOLOGY LICENSE AMENDMENT REQUEST ENTERGY OPERATIONS. INC.
GRAND GULF NUCLEAR STATION, UNIT NO. 1 DOCKET NO. 50-416 By* letter dated November 21, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14325A752), Entergy Operations, Inc., the licensee for Grand Gulf Nuclear Station, Unit 1 (GGNS) requested a license amendment that would revise its licensing basis to adopt a single fluence methodology.
The U.S. Nuclear Regulatory Commission (NRC) staff has performed an acceptance review of the proposed change in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-109, "Acceptance Review Process" (ADAMS Accession No. ML091810088).
Per LIC-109, Appendix B, "Guide for Performing Acceptance Reviews," Section 3.1.2, "Technical Staff Criteria," the NRC staff finds the amendment does not meet the following criteria:
- Sufficiency of Information
- Regulatory Basis The NRC staff has determined the following information is needed complete our acceptance review.
Methods Qualification Outside of the Beltline Region By letter dated November 21, 2014, the statement below from Attachment 2, Topical Report from MP Machinery and Testing, LLC (MPM)-614993, "Benchmarking of MPM Methods for Nuclear Plant Neutron Transport Calculations," is insufficient to qualify fluence calculations outside of the beltline region. It is stated explicitly that "there are no dosimetry data available at present from regions above and below the active core region to enable checking of 3D results in those regions of the plant." It is then implied that benchmarking the 3D method against the 2D synthesis method would be sufficient to qualify the 3D method for fluence calculations outside of the beltline region.
There are no dosimetry data available at present from regions above and below the active core region to enable checking of 3D results in those regions of the plant. Therefore, once TORT is benchmarked against the results of standard 2D synthesis, these 3D methods can be used routinely for flux calculations in the beltline, and outside of the beltline region.
Enclosure
To qualify the 3D fluence method for fluence calculations outside of the beltline region, some type of benchmarking of the 3D fluence method is necessary specific to the various regions-of-interest outside the beltline.
Furthermore, on Page 6 of Document GNR0-2014/00080, by letter dated November 21, 2014, , "Analysis of Proposed Single Fluence Methodology," Regulatory Position ,__
(RP) 1.4.3 of Regulatory Guide (RG) 1.190, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence, states, in part, as follows:
For other applications [other than RT NDT determination], the accuracy should be determined using the approach described in Regulatory Position 1.4, and ah uncertainty allowance should be included in the fluence estimate as appropriate in the specific application.
Page 7 of Document GNR0-2014/00080, Attachment 1, includes the following response from licensee:
An extensive evaluation of all contributors to the uncertainty .in the calculated fluence was made for the BWR plant calculations performed to date. This evaluation indicated that the uncertainty in calculated fluences in the reactor beltline region is below 20% as specified in the guide. In addition, the comparisons with measurements indicate agreement well within the 20% limit.
- The agreement of calculations with measurements to within +/-20% uncertainty
. indicates.that the MPM calculations can be applied for fluence determination with no bias. This meets the requirement of RP 1.4.3.
The NRC staff did not locate specific information evaluating the uncertainty of the proposed methods for locations outside the reactor vessel beltline. Information describing uncertainty allowances and application for fluence estimates outside of the reactor vessel beltline is required, or the NRC staff review of the method will be limited to the vessel beltline. Further application of the method would require additional justification.
Applicability of 20 Method Validation to 30 Method Method qualification was done primarily for the 2D synthesis method; however, the 3D method is used for calculating fluence results. The licensee uses the 3D code results with aspects of the 2D synthesis bias and uncertainty analysis. Applying the validation of one method to another is inappropriate as there may be certain deficiencies that are masked in the method that is not formally qualified.
- Seven 2D synthesis calculations were cqmpared to corresponding measurements for the pool critical assembly calculational benchmark, 25 2D synthesis calculations were compared to corresponding measurements for the boiling-water reactor calculational benchmark, eight 2D synthesis calculations were compared to corresponding measurements as part of dosimetry benchmarking, and only one 3D calculation was compared to a corresponding measurement as part of dosimetry benchmarking. In summary, 40 calculations support the validation of the 2D synthesis method and 1 calculation supports the validation of the 3D method; however, the 3D method is relied upon to support all fluence projections as discussed in Section 7, "Summary
and Conclusions," of Document GNR0-2014/00080, Attachment 3, "Single Fluence Method Applied to GGNS MPM-814779 Revision 1, 'Neutron Transport Analysis for Grand Gulf Nuclear Station,' November 2014" (nonpublic).
To qualify the 3D fluence method for fluence calculations inside the beltline region, a complete independent benchmarking of the 3D method is required. ,
Maximum Extended Load Line Limit Analysis Plus Operating Conditions Document GNR0-2014/00080, Attachment 1, states, in part:
GGNS has calculated the fluence for every cycle up to the present. This gives the most accurate value of the present fluence. Extrapolations to future times are made using best estimate values of future fuel designs in a cycle 21 best estimate projection cycle. As changes in fuel core loadings are made, updated extrapolations will be made. Further, the flux values from the cycle 21 transport calculation were multiplied with a factor of 1.1 applied for projection to exposures
. after cycle 21. This 10% conservatism was applied by Entergy to ensure that fluence estimates remain conservative.
The NRC staff is presently concluding its review of Entergy's request to implement the Maximum Exten9ed Load Line Limit Analysis Plus (MELLLA+) operating domain. The NRC staff requires confirmation that the flux evaluation for Cycle 21 includes the water density and neutron spectral conditions reflective of a MELLLA+ core design.
ML15036A564 OFFICE NRR/DORL/LP~4-2/PM NRR/DORL/LPL4/LA NRR/DORL/LPL4-2/BC NRR/DORL/LPL4/PM NAME AWang PBlechman MKhanna AWang DATE 2/10/15 2/10/15 2/12/15 2/18/15