ML15075A033

Response to NRC Request for Additional Information Regarding the Safety Limit Minimum Critical Power Ratio License Amendment Request

ML15075A033
Person / Time
Site:	Pilgrim
Issue date:	03/11/2015
From:	Dent J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15075A013	List: ML15075A033
References
2.15.019, TAC MF5431
Download: ML15075A033 (13)

Text

SEntergy Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 John A. Dent, Jr.

Site Vice President LETTER NUMBER: 2.15.019 March 11,2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Response to NRC Request for Additional Information Regarding the Safety Limit Minimum Critical Power Ratio License Amendment Request (TAC NO. MF5431)

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35

REFERENCES:

1. Entergy Letter to NRC, "Proposed Change to Pilgrim Technical Specifications Concerning the Safety Limit Minimum Critical Power Ratio", dated December 10, 2014 (2.14.076)

2. NRC Letter to Entergy, "Pilgrim Nuclear Power Station - Request For Additional Information Regarding the Safety Limit Minimum Critical Power Ratio License Amendment Request (TAC NO.

MF5431 )", dated February 25, 2015

Dear Sir or Madam:

In Reference 1, Entergy proposed to amend Facility Operating License DPR-35 for the Pilgrim Nuclear Power Station (PNPS) by modifying Technical Specification Section 2.1.2. The application proposed 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 Ž 1.11 to ___

1.12 for single loop operation.

In Reference 2, the Nuclear Regulatory Commission (NRC) staff requested that Entergy provide additional information to support completion of the NRC staff review. contains proprietary information to be withheld from public disclosure under 10 CFR 2.390. When separated, this letter can be made public.

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Letter Number: 2.15.019 Page 2 of 3 Attachments 1, 2, and 4 provide the requested information. Attachment 3 provides the Global Nuclear Fuels Affidavit for the GNF proprietary information contained in.

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 1 1th day of March, 2015 Sincerely, Jon A. Dent, Jr.

Site Vice President JAD/mew Attachments:

1.

Responses to Request for Additional Information (3 pages)

2.

Final Safety Analysis Report Table 3.2-1 "Fuel Data" (1 page)

3.

Global Nuclear Fuels-Americas Affidavit for Withholding Proprietary Report, "NEDC-33270P, Revision 5, GNF2 Advantage Generic Compliance with NEDE-24011-P-A (GESTAR II), May 2013" (3 pages)

4.

Global Nuclear Fuels-Americas Proprietary Report, "NEDC-33270P, Revision 5, GNF2 Advantage Generic Compliance with NEDE-2401 1-P-A (GESTAR II), May 2013", Table 2-1 "GEI4 and GNF2 Dimensions" (1 page) contains proprietary information to be withheld from public disclosure under 10 CFR 2.390. When separated, this letter can be made public.

I

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 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 Plymouth, MA 02360 Letter Number: 2.15.019 Page 3 of 3 Mr. John Priest, Director Massachusetts Department of Public Health Schraft Center Suite 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 contains proprietary information to be withheld from public disclosure under 10 CFR 2.390. When separated, this letter can be made public.

ATTACHMENT I to Entergy Letter 2.15.019 Response to NRC Request for Additional Information (3 Pages)

Response to NRC Request for Additional Information RAI-1 Provide the differences in design and geometrical considerations between GNF2 and GEI4.

Attachments 2 and 4 to this letter list the geometrical differences between GE14 and GNF2 fuel. The GNF2 design is similar to the GE14 design with the following key changes.

1)

Use of a high performance Inconel spacer grid (compared to a Zircaloy ferrule grid used by the GEl4).

2)

Use of two different heights of part length rods (instead of just one part length rod height in the GEl4).

3)

A reduced clad thickness which permits larger fuel pellets for the same outer tube diameter, hence GNF2 allows increased fuel loading per bundle. GNF2 fuel pellet diameter is 0.3496" vs. 0.345" for GE14 pellet. GNF2 pellet length is 0.375" vs. 0.350" for GE14 (See Attachment 2). GNF2 Clad thickness is 23.6 mils vs. 26 mils for GE14. Typical GNF2 bundle contains -181 kgs of Uranium vs. 175 kgs of Uranium in a GE14 bundle.

4)

A thicker wall at the channel bottom which permits the elimination of the finger springs of the lower tie plate.

RAI-2.a Discuss the methodology and the scheme used for Pilgrim's Cycles 20, and 21 core reloads. Is there a noticeable change in the core radial and axial power shapes between Cycles 20 and 21 reloads?

Methodology Discussion:

RELOAD METHODOLOGY:

The methods used to analyze the core loading pattern are in accordance with the methods and processes defined in GESTAR I1. There is no change in approved core design or SLMCPR methodologies. This Technical Specification (TS) change based on the Pilgrim Cycle 21 design was completed within approved methodologies.

SLMCPR is not the primary driver in developing fuel cycle core designs. The energy plan, reactivity and thermal margins are the primary drivers.

SAFETY LIMIT METHODOLOGY:

The SLMCPR methodology uses set of random perturbations (Monte Carlo) in the calculation process to determine the cycle-specific SLMCPR. For each cycle, cycle-specific SLMCPR calculations are performed for the specific fuel bundle design and core loading used in the cycle reload design. The core radial power distribution must represent a reasonable bound on the number of fuel bundles at or near thermal limits, and the fuel assembly local power distribution must be based on the actual bundle design. The cycle specific analysis is performed at multiple exposure points throughout the cycle and the most limiting calculated SLMCPR is compared to the TS value. In most cycles, the SLMCPR does not change to the extent that a request for a TS change is necessary. If the calculated cycle specific SLMCPR is not bounded by the TS value then TS change is required. Cycle 21 specific SLMCPR calculation to Letter 2.15.019 Sheet 1 of 3

resulted in values higher than the current TS 2.1. Therefore, a Licensing Amendment to increase both the Two Loop and Single Loop SLMCPR was submitted.

LOADING SCHEMES:

Pilgrim cycles, including Cycle 20 and Cycle 21, are designed and operated using Control Cell Core (CCC) approach for control rod insertions.

The loading pattern is developed by GNF based on Entergy input. Among the inputs are:

Batch size and cycle energy - fuel bundle design (nuclear) and loading patterns are developed together Thermal limit design margins Reactivity margins - Minimum shutdown margin, minimum and maximum hot excess reactivity Discharge exposure limitations and other limits as established by safety analysis Desired control rod patterns - sequences and durations Minimize channel bow - Cycle 21 was designed to minimize Channel Friction Metric (CFM) with core location specific goals. Cycle 20 design was done to minimize overall CFM.

Minimize preconditioning limitations Due to differences in the scheduled refueling outage durations and start dates, both cycles were designed to deliver different final energy. Cycle 20 was designed to deliver 648 Effective Full Power Days (EFPD) of nominal energy, while Cycle 21 was designed to deliver 661 EFPD of nominal cycle energy. Cycles 20 and 21 were designed with the same design margin requirements. Therefore, the cycle designs met very similar requirements. Both cycles used similar rod patterns and sequence intervals.

Cycle 20 is the last transition core from GE14 to GNF2 fuel design. Cycle 21 loaded 120 thrice burnt GE14 bundles and 460 GNF2 bundles, while Cycle 21 is the first core uniformly loaded with the GNF2 fuel design (see core content in RAI answer 2.b).

Pilgrim alternates hot and cold center designs in consecutive cycles in order keep a high number of bundles in the same place between the consecutive cycles. A Hot Center Design has fresh bundles face adjacent to the center cell. A Cold Center design has no fresh face adjacent bundles to the center cell. Cycle 20 is a hot center design. Cycle 21 is a cold center loading. Both cycles are scatter loaded.

Radial and Axial Power Shape comparison between Cycles 20 and 21 Radial and Axial peaking in both Cycles 20 & 21 is similar. At steady state rated power maximum Axial Peaking Factors are less than 1.6 in both cycles. In Cycle 21, the maximum Radial Peaking factor is expected to be -1.65 vs. -1.6 in Cycle 20.

This is an expected result of a slightly smaller reload batch size and is within the experience base for Pilgrim. Both cycles are bottom peaked near BOC and top peaked towards EOC. Both cycles were designed with similar steady state thermal limit margins at rated power. Rod patterns used in both cycles are similar. to Letter 2.15.019 Sheet 2 of 3

RAI 2.b For the initial core loadings of the Pilgrim Cycles 20 and 21, specify the fuel type and the number of fresh, once burned, twice burned, and thrice burned fuel.

Cycle Fresh Once Twice Thrice

1. of

1. of GNF2 Burned Burned Burned GNF2 GE14

__(GNF2)

(GNF2) 20 152 152 156 120 (GEl4) 460 120 21 144 152 152 132 (GNF2) 580 0 to Letter 2.15.019 Sheet 3 of 3

ATTACHMENT 2 to Entergy Letter 2.15.019 Final Safety Analysis Report Table 3.2-1 "Fuel Data" (1 Page)

PNPS-FSAR Table 3.2-1 FUEL DATA GEl1 AND GE14 FUEL DESIGNS Fuel Assembly Geometry Rod Pitch (in.)

Active Fuel Length (in.)

Heat Transfer Area (ft 2)

Debris Filter Fuel Rods Fill Gas Fill Pressure (atm)

Getter Number of Fuel Rods Fuel Material Pellet Diameter (in.)

Pellet Length (in.)

Pellet Immersion Density (%TD)

Cladding Material Outside Diameter (in.)

Total Thickness (in.)

Barrier Thickness (in.)

Water Rod Material Outside Diameter (in.)

Thickness (in.)

Number of Water Rods Number of Fuel Rods Displaced GEl1 9x9 0.566 141.24 95.5 No helium 10 yes 74 GEl4 10x10 0.510 145.24 109 Yes helium 10 No 92 GNF2 1Oxl0 0.510 145.24 110 Yes helium 10 No 92 sintered U02 0.376 0.380 96.5 Zr-2+

Zirconium 0.440 0.028 0.0035 sintered U02 0.345 0.350 97 Zr-2+

Zirconium 0.404 0.026 0.0035 sintered U02 0.3496 0.375 97 Zr-2+

Zirconium 0.4039 0.0236 0.0035 Zr-2 0.980 0.030 2

7 Zr-2 0.980 0.030 2

8 Zr-2 0.980 0.030 2

8 Spacers Material Number per Bundle Fuel Channel Material Inside Dimension (in.)

Equivalent** Wall Thickness (in.)

Flow Trippers Zr-2 with Alloy X-750 Springs 7

Zr-2 with Alloy X-750 Springs 8

Alloy-X-750 8

Zr-2 5.278 0.0745 Yes Zr-2 5.278 0.0745 No ZRY-2/ZRY-4 5.283 No table is maintained In cycle 17 core, there is no GEl1 fuel.

The information in this as legacy information as GEl1 fuel is in the spent fuel pool.

• Based on cross-sectional area.

1 of 1 Rev 28 - Oct 2011 to Letter 2.15.019 Sheet 1 of 1

ATTACHMENT 3 to Entergy Letter 2.15.019 Global Nuclear Fuels-Americas Affidavit for Withholding Proprietary Report, "NEDC-33270P, Revision 5, GNF2 Advantage Generic Compliance with NEDE-24011-P-A (GESTAR II), May 2013" (3 Pages)

Global Nuclear Fuel - Americas, LLC Affidavit I, Lukas Trosman, state as follows:

(1) 1 am Engineering Manager, Reload Design and Analysis, Global Nuclear Fuel - Americas, LLC

("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 tor its withholding.

(2) The information sought to be withheld is contained in the GNF report NEDC-33270P, Revision 5, GNF2 Advantage Generic Compliance wiith NEDE-24011-P-A (GEST7R II),

May 2013. The proprietary intbrmation in GNF report NEDC-33270P, Revision 5, GNF2 Advantage Generic Compliance with iVEDE-24011-P-A (GESTAR II), May 2013 is identified by [La.dottcd underline inside double squareand other large equation objects are identified with double square brackets before and after the object. In each case, the superscript notation 13 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, GNF-A relies upon the exemption from disclosure set tbrth 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 qualifti 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 Reaulatoly Commission, 975F2d871 (DC Cir. 1992), and Public Citizen H-ealth Research Group v. FDA, 704F2dl280 (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;

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.

NEDC-33270P1 Revision 5 Affidavit Page I

(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 tinder 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 the analytical models and methods, including computer codes, and NRC approval were achieved at a significant cost to GNF-A.

The development of the evaluation methodology along with the interpretation and application of the analytical results is derived from an 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 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.

NEDC-33270P Revision 5 "U't" I avit Page 2

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 2 4 th day of May 2013.

Engineering Manager, Reload Design and Analysis Global Nuclear Fuel - Americas, LLC NE-DC-332)?70P Revision 5 ItaitPg3

,U1'idavit Page 3