ML20043F015
| ML20043F015 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 06/08/1990 |
| From: | Cottle W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20043F017 | List: |
| References | |
| AECM-90-0092, AECM-90-92, NUDOCS 9006140096 | |
| Download: ML20043F015 (34) | |
Text
_ - - -
O y
= Entera a ia, 0,.r:ii:a.. i..
'8 PO ibx 756 :
Operat ns u o m us e m TW 601 437-6409 4
W. T. Coltie we. rwm; Ni & N Ol 6 )*V/4 June 8, 1990 U.S. Nuclear Regulatory Commission Mail Station P1-137
' Washington, D.C.
20555 Attentions-Document control Desk Gentlemen:
SUBJECT:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Cycle 5 Reload l
Proposed Amendment to the Operating I
License (PCOL-90/07)
.Entergy Operations, Inc. is submitting by this letter a proposed amendment to the Grand Gulf Nuclear Station Operating License.
I This proposed amendment. includes those Technical Specifications changes required to support the Cycle 5 Reload for Grand Gulf Nuclear Station, Unit 1.
f The majority of these changes were discussed with the NRC Staff in a meeting on January 4,
- 1990, j
l Based on a related action discussed in NRC's letter to System Energy I
~
Resources, Inc., dated January 22, 1990, Entergy Operations will revise the Updated Final Safety Analysis Report (UFSAR) regarding operations with feedwater heater (s) out of service. UFSAR Appendices 15.B and 15.D and related UFSAR esctions will be revised to delete discussion of operations ~with a feedwater' temperature reduction of 100'F.
Entergy Operations intends to l
utilize the capability to operate with a rated feedwater temperature reduction j
of no more than 50*F.
This UFSAR revision will be included in UFSAR Revision l,
5 scheduled for submittal December 1, 1990.
)
i In accordance with the provisions of 10CFR50.4, the signed original of i
the requested amendment is enclosed. The attachments provide the technical justification and discussion to support the requested amendment. This amendment has been reviewed and accepted by the Plant Safety Review Committee and the Safety Review Committee.
j
. Based on the guidelines presented in 10CFR50.92, Entergy Operations has concluded that this proposed amendment involves no significant hazards considerations.
9006140096 900608 PDR ADOCK 05000416 P
PDC l gy g} [
A9005161/SNLICFLR - 1
///
i:
AECM-90/0092 P:gs 2 1;
i l^
_.Entergy Operations requests NRC approval-and issuance'of Technical Specifications changes by. November 1, 1990 to allow planning and scheduling.
for-related work' activities including-procedure development, training and testing.
Yours truly,'
py Omerr-WTCamtc
Enclosure:
Affirmation per 10CFR50.30 i
Attachments:
'l.
GGNS PCOL-90/07
- 2. Cycle 5 Reload Summary Report
'g
- 3. Cycle 5 Proposed Startup Physics Tests
- 4. ANF-90-022, Grand Gulf Cycle 5 Reload Analysis-j
-5. ANF-90-021, Grand Gulf Cycle 5 Plant Transient Analysis l.
cca Mr. D..C..Hintz (w/a)--
Mr. T. H. Cloninger (w/a) j
'Mr.
R. B. McGehee (w/a) l Mr. N. S. Reynolds (w/a)-
Mr. H. L.' Thomas-(w/o) _..
{
Mr. H. O. Christensen (w/a) l l
Mr. Stewart D. Ebneter (w/a)
Regional-Administrator U.S. Nuclear Regulatory Commission Region _II 101 Marietta St.,
N.W.,
Suite 2900 l;
Atlanta, Georgia 30323
-j l
Mr..L'.
L. Kintner, Project Manager (w/a)
Office.of Nuclear Reactor Regulation j
U.S. Nuclear Regulatory' Commission
}
Mail Stop llD21 Washington, D.C.
20555 1
.Dr. Alton B. Cobb (w/a) j jl State Health Officer State Board of Health P.O.
Box 1700 l
' Jackson, Mississippi 39205 i
1+
'A9005161/SNLICFLR - 2 1
E q
4 s
ih, BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION
~l LICENSE NO. NPF-29 DOCKET NO. 50-416 d
i f
IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and SYSTEM ENERGY RESOURCES, INC.
and SOUTH MISSISSIPPI ELECTRIC POWER-ASSOCIATION and ENTERGY OPERATIONS, INC.
AFFIRMATION LI, W. T. Cottle, being duly sworn, state that I am Vice President, Operations Grand Gulf of Entergy Operations, Inc.; that on behalf of Entergy Operations, Inc., System Energy Resources, Inc. and South Mississippi Electric Power Association I am authorized by Entergy Operations, Inc. to sign and-file with the Nuclear Regulatory Commission,.this application for amendment.of the-Operating License of the Grand Gulf Nuclear Station; that I signed this application as=Vice President, Operations Grand Gulf of Entergy Operations, 4
.Inc.; and that the statements made and the matters set forth therein are true and correct to the best of my knowledge, information and belief.
c
>U 0-:-
W. T.-Cottle STATE OF MISSISSIPPI
' COUNTY OF CLAIBORNE SUBSCRIBED AND SWORN TO before me, a Notary PJblic, in and for the County and State above named, this f M-day of Quact -
, 1990.
^,
(7 l'
L(SEAL) 1 60LL}1 Notary Public f L
My. commission expires:
1 " Ju.29,/99/
A9005161/SNLICFLR - 4 i
r
g i
Attachment I to sc!
AECM 90/0092-
SUBJECT:
NL 90/05 Cycle 5 Reload Technical Specifications 1.8,2.1.2,3/4.1.4.2,3/4.2.1,3/4.2.3, 3/4.2.4, 3/4.4.1.1, and 3/4.10.2.
l l
Figures 3.2.1-1, 3.2.1-la through 3.2.1-le, 3.2.1-2, 3.2.1 3, j
3.2.3-1, 3.2.3-2, 3.2.3-3, 3.2.4-1, 3.2.4-2, 3.2.4-3, and B 3/4 2.3-1.
Bases _2.1.1,2.1.2,3/4.1.4,3/4.1.5,3/4.2.1,3/4.2.3,3/4.2.4, 3/4.2 References, and 3/4.4.1.
Affected Pages:
1-2, 2-1, B 2-1, B 2-la, B 2-2, 3/4 1-16, B 3/4 1-3, B 3/4 1-4, B 3/4 1-4a, 3/4 2-1, 3/4 2-2, 3/4 2-2a through
}
3/4 2-2e, 3/4 2-3a, 3/4 2-3b, 3/4 2-4, 3/4 2-5, 3/4 2-6, 3/4 2-6a, 3/4 2-7, 3/4 2-7a, 3/4 2-7b, 3/4 2-7c, 3/4 4-1, 3/4 4-la, 3/4.10-2, B 3/4 2-1, B 3/4 2-2, B 3/4 2-4, B 3/4 2-5, B 3/4 2-6, B 3/4 2-7 and B 3/4 4-1.
l 3
DESCRIPTION OF CHANGES:
1 L
1.
Specification 1.8:
(Administrative) Change "XN-3" to "ANFB" to
]
reference the applicable correlation.
l
.2.
Specification 2.1.2:
Change Safety Limit MCPRs for two loop and one L
loop operation to 1.08. l b
3.
Bases 2.1.1: '(Administrative) Revise;the text to reference the ANFB Critical Power Correlation' at five locations.
Reformat and clarify the text to delineate discussions applicable to reload fuel and to the initial core (baseline analyses).
4.
Bases 2.1.2:. (Administrative) Change "XN 3" to "ANFB" at four locations.
Reference the. applicable version of the Critical Power Methodology report.
5.
Bases 2.1.2:
Revise text to cite channel bow considerations used in i
MCPR safety limit calculations.
Delete "high" in Sentence 2, Paragraph 3.
6.
Specification 3/4.1.4.2:
Change the minimum power, above which control rods may be bypassed at any time in the Rod Action Control System (RACS), from 20% to 10%, to reflect new analyses bases.
7.
Bases 3/4.1.4:
Change the minimum power, above which control roJs may be bypassed at any time in the RACS, from 20% to 10%, to reflect new analyses bases.
8.
Bases-3/4.1.4:
(Administrative) Revise text to cite applicable references for. baseline and current cycle analyses.
9.
Bases 3/4.1.5:
(Administrative) Renumber references cited in text.
10.
Specification 3/4.2.1:
Revise text to delete references to the fuel (
' type-specific MAPLHGR curves and the flow dependent and
-7 power-dependent MAPLHGR factor (MAPFAC) curves.
Change the Single Loop Operation (SLO) MAPLHGR multiplier.
+
11.
Figure 3.2.1-1: Revise the figure to show the 8x8 and 9x9-5 MAPLHGR curves for ANF fuel.
12.
Figures 3.2.1-la through 3.2.1-le:
Delete the MAPLHGR curvos for ANF 8x8 and 9x9-5 specific fuel types.
l 13.
Figure 3.2.1-2: Delete MAPFAC curves, 7
i 1
14.
Figure 3.2.1-3:
Delete MAPFAC curves, p
i i
- 15. ' Specification 3/4.2.3:
Revise text to reference exposure-dependent MCPR operating limits (MCPR,).
l-limits.
16.
Figure 3.2.3-1:
Revise the figure to show new MCPRf Extend the MCPR curves for "Non-Loop Manual" and " Loop Manual "
f modes to below 30% core flow.
L 17.
Figure 3.2.3-2:
Revise the figure to show new MCPR limits.
p 18.
Figure 3.2.3-3: Add exposure-dependent MCPR operating limit (MCPR )
e Curve.
19.
Specification 3/4.2.4:
Revise text to reference flow-dependent and 3-
I i
l' power-dependent LHGR multipliers.
IU 20.
Figure 3.7. 4-1:- Revise the figure to extend the 8x8 LHGR curve.
21.
Figure 3.2.4-2: Add LHGRFACf curve.
- 22. ' Figure 3.2.4-3: Add LHGRFAC curve.
p
- 23. - Specification 3/4.4.1.1: Delete reference to MCPR safety limit (Section 2.1.2) in three places.
I i
.24.x SpecificationL3/4.10.2:
Change-the minimum power, above which control L
rods may.be bypassed at any time in the RACS, from 20% to 10%, to reflect new analyses bases.
Restate surveillance-requirement-for bypassing sequence constraints, consistent with this change.
-)
+
l t
l' 25.- Bases 3/4.2.1:
Delete references to MAPLHGR curves for 8x8 and 9x9-5-,
ANF specific fuel types.
Limit the discussion on MAPLHGR multipliers to SLO conditions.
Delete: references to GE methodologies for MAPLHGR.
26.
Bases 3/4.2.3:
Provide discussion on MCPR, limit.
Clarify l-L discussion on flow-dependent and power-dependent MCPR limits to state i
their applicability for all exposures during the cycle.
27.
Bases 3/4,2.3: -(Administrative) Revise text to delineate discussions-L applicable to the current cycle and the baseline (initial core) analyses.
Revise text to delete the MCPR Safety Limit value cited.
4
Revise references for Figure B 3/4 2.3-1.-
Renumber all cited references appropriately.
28.
Figure B 3/4 2.3-1:
Revise the figure to show-power / flow operating domain applicable to GGNS Unit 1.
t 29.
Bases 3/4.2.4:
Reviso text to discuss LHGRFAC and LHGRFAC f
p multipliers applicable to operation during off-rated conditions.
30._ References 3/4.2:
(Administrative) Add references applicable to the discussions =in the Bases.
Delete superseded references.
L 31, Bases 3/4.4.1:
Revise text to cite limits that are affected when changing from two loop to single loop operation and vice versa.
1.
DISCUSSION:
Egasons for Chanaes l
ll-The proposed Technical Specification' changes result from:
l 1
Insertion of reload ANF 9x9-5 fuel for Cycle B operations, i
Use of new methodologies to support Cycle $ operations with ANF 8x8 e
and 9x9 5 fuel types.
TS/ Bases " cleanup" to reflect the appropriate relationship between e
' baseline and reload analyses and the deletion of discussions not j
applicable to the all-ANF core.
Discussion of Chanaes
]
The changes listed in the DESCRIPTION OF CHANGEE Section-are grouped into ten subjects in order to avoid repeating:the discussion and justification for changes with common bases, a) MCPR Safety limits
..i
. Specification 2.1.2 is revised to state the Safety Limit MCPR
~
s1 values established for Cycle 5 operation and clarify the associated bases to be consistent with ANF methodologies.
The-revised Safety Limit is determined consistent with new ANF f.
methodologies that are used in support of Cycle 5.
Specification 1
l 3/4.4.1.1 is revised to delete references to MCPR Safety Limits
.because no-modifications to the Cycle 5-safety limits are required when going from two loop to single loop operation and vice versa.
l I
b) Control Rod Withdrawal Seauence 4
Specifications 3/4.1.4.2 and 3/4.10.2 are revised to state the minimum power, above which control rods may be bypassed at any time in the-RACS' based on approved BWROG. methodology.. This change simplifies low power operations for startups and controlled shutdowns. 4
i 3
c) - MAPLHGR Limits Figure 3.2.1-1'is revised-to'show the consolidated MAPLHGR limits applicable to two loop and single loop operation (SLO) for 8x8 and I
for 9x9-5 ANF fuel types.
The MAPLHGR limits for individual ANF 8x8 Land 9x9-5fueltypesshowninFigures3.2.1-lathrough 3.2.1-le are deleted.
Specification 3/4.2.1 is revised to delete-references to the GE based 8x8 SLO limit and the flow-and power-dependent MAPLHGR multipliers.
multiplier'is introduced, which is applicable to both the 8x8 and 9x9 5 fuel types.
Flow-and power-dependent multipliers are i
applied,to1LHGR.: These changes minimize the cycle-specific and a
= fuel stype-specific dependence of the MAPLHGR limits.
U d) Off-Rated Mechanical limits
?-
Specification 3/4.2.4 is revised to reference the flow-and power-dependent LHGR multipliers applicable to operation at-off-rated conditions.
Figures 3.2.4-2 and 3.2.4-3 are added to show the flow-and power-dependent l'iGR multipliers. The off-rated multipliers are applied to the LHGR limits instead of t
I the MAPLHGR limits; the MAPLHGR multil. liers (Figures 3.2.1-2 and i
L 3.2.1-3) are deleted.
This change mini.112es the cycle-specific E
and fuel type-specific dependence of the MAPLHGR limits.
l e)
LHGR Limits figure 3.2.4-1 is revised to extend the LHGR limits for 8x8 fuel l
types. This is necessary to bound the expected end-of-life exposure. I l
te 1
'l V
i i
e
[
f)
Flow-Denendent limits at low Flows Figures 3.2.3-1 and 3.2.4-2 are revised to extend the limits to below 30% core flow for both the Non-Loop Manual and Loop Manual modes.of operation.
This is necessary to allow startup for SLO when power ascension to above 25% power is required. prior to l
recirculation pump upshift.
g)
Flow-Decendent MCPR Limits Figure 3.2.3-1 is revised to show the flow-dependent MCPR I
t, operating. limits applicable to Cycle 5 for the Non-Loop-Manual and 1
Loop. Manual modes of operation. The revised-flow-dependent MCPR operating limits are determined based on new ANF methodologies that are used in support of Cycle 5.
t h) _ Power-Decendent MCPR Limits-Figure 3.2.3-2 is revised to-increase the MCPR operating p
limits:- (i); Below 40% core power for core flows above 50% of I
rated and, (ii) above 70% power. The revised power-dependent MCPR operating limits are determined based on new ANF methodologies f
that are used in support of Cycle 5.
i)
Exoosure-Decendent MCPR Limits Specification 3/4.2.3 is revised to reference the exposure-dependent MCPR operating limits (MCPR,) in addition to the flow-and power-dependent limits.
Figure 3.2.3 3 is added to define m
MCPR operating limits as a function of exposure.
Exposure-.
dependent limits are introduced for Cycle 5 with progressively.
higher MCPR. limits defined for higher exposures. The MCPR, I
operating limits are an integral part of the Cycle 5 operating plan.. Consistent with the operating plan,.the exposure-dependence of the MCPR, limit is determined based on the severity of the' limiting transients, and the available operational MCPR margin at different exposures.
The use of the-end of cycle transient analysis results to define the operating limit for the entire cycle, as was done for previous cycles, would be overly restrictive for Cycle 5.
The MCPR, operating limits provide 1
--aadditionalmoperating margin during the initial portion of the
+
cycl e.
This-additional. operating margin allows simpler operation,
1 by reducing the maneuvering-required during startups and the J
L frequency of control rod pattern adjustments. In turn, this 1
reduces the probabliity of operator error during operation.
/
s i
j)
Power / Flow Operatina Domain Figure B 3/4 2.3-1 -is revised to provide the power / flow map consistent with the Grand Gulf Unit 1 operating domain.
The i-revised map is constructed using the Maximum Extended Operating L
Domain boundaries established for previous cycles, the constant FCV position flow lines determined based on Grand Gulf startup l-test data, and the 80% and'100% rod lines shown in the-Grand Gulf Stability Technical Specifications. This change reflects the
[
l revision of the GE-based power / flow operating map, as part of the L
Technical Specification and Bases " clean-up program" discussed during the third fuel reload meeting with the NRC (Letter to
.g.
]
e System Energy Resources, Inc., from L. L. Kintner, NRC, dated September 1, 1988). This change is consistent with the scope of the Cycle 5 analyses, including Item f) discussed above.-
t The affected bases were revised to reflect the Technical Specifications changes that are stated above and to provide the corresponding justification.
i JUSTIFICATION:
l The insertion of 284 ANF 9x9-5 assemblies into the core for Cycle 5 is the first Grand Gulf Unit I reload of this fuel type.
The assemblies are of a design that-has been shown to be mechanically..neutronically, and thermal-hydraulically compatible with the ANF 8x8 fuel inserted in the core during previous reloads.
New-methodologies are introduced in--
1
- support of Cycle 5. operations with ANF 8x8 and 9x9-5 fuel. These methodologies are applicable for Grand Gulf Unit 1.
The detailed justification for the specific changes follows.
Additional justification is provided in the References cited, a)
MCpR Safety limits As appropriate, MCPR Safety Limits have been established (Reference II, Section 3, and Reference II, Appendix A) for all s
fuel types that will be resident in the core during Cycle 5 for Two Loop and Single Loop Operation. The supporting analyses include the effects associated with channel bow. u
i
...i<
b)
Control Rod Withdrawal Sequence The minimum power above which control rods may be bypassed 1
(cutoff power level) at any time in the Rod Action Control System r
(RACS) is lowered from 20% to 10% of rated power.
Based on BWROG methodo1'ogy (as approved by the NRC, Reference III), the Control i
Rod Drop Accident has been shown to be inherently self-limiting for powers above 10% due. to the presence of voids in the core.
The reduction in the cutoff power level is based on generic analyses (Reference III) applicable to GGNS-1 and is consistent l
with the ANF rod drop analyses for Cycle 5 (Reference I, Section 6).
c)
MAPLHGR Limits The MAPLHGR limit for ANF 8x8 fuel = is established as a c-consolidated value,for all 8x8 fuel types that will be present in the core for Cycle 5.
It consists of the bounding MAPLHGR values i
assumed in the Cycle 2 LOCA heatup analysis to calculate the Peak.
~ Clad Temperature (PCT) values.
Similarly, the MAPLHGR limit for the 9x9-5 fuel is revised to include the MAPLHGR limit for both the Lead Test Assemblies (LTAs) and the reload 9x9-5 batch.
The revised MAPLHGR limits replace the existing limits and are-applicable to two loop operation. The MAPLHGR limit for SLO is the two loop MAPLHGR limit times the SLO multiplier.
This ensures that the PCT during SLO is bounded by the PCT during two.
loop operation. The existing MAPLHGR limits were established consistent with the LHGR-limits in order to provide LHGR protection at off-rated conditions.
This protection is now provided directly by the LHGR limits and the applicable LHGRFAC mul tipliers.
Based on ANF's evaluation, the MAPLHGR limits 1
ensure compliance with the 10CFR50.46 requirements (Reference I, Section.6).
l d)
Off-Rated Mechanical Limits The LHGR' limits for the 8x8 and 9x9-5 fuel types have.been -
established consistent with mechanical design criteria.
In order to ensure that these criteria are met during off rated operating conditions, the LHGR limits are multiplied by the smaller of H
m LHGRFAC or LHGRFAC. This method is similar to that used m
f p
, -during Cycle 4 for the MAPLHGR multipliers (MAPFAC7 and MAPFAC ) but directly relates the LHGR to the mechanical design j
p criteria for both rated and off-rated conditions.- The' method.
t k
used to demonstrate compliance with the mechanical design criteria is consistent with that used for previous cycles since the rated MAPLHGR limits for Cycle 4 were established to meet both the LOCA/ECCS and the mechanical design criteria.
The LHGR limits and LHGRFAC multipliers have been confirmed to be 1
applicable for all fuel types that will 'be resident in the core l
during Cycle 5 (Reference I, Section 2).
1..
e)
- LHGR Limits b
The LHGR limits for 8x8 fuel are extended to bound the expected end-of-life exposure. These limits were established previously L
on a generic basis to satisfy the mechanical design criteria (Reference I, Section 2). -
a
'f)
Flow Decendent' Limits at low Flows j
i The' flow dependent MCPR and LHGRFAC limits are extended below 30%
core flow by assuming constant values for this flow range. The flows corresponding to these limits bound the flows during normal l
operations for both SLO and two loop operations.
This change is introduced to allow rtartup for SLO when power ascension to
> above 25% power is required prior to recirculation pump upshift.
Below 30% core flow, the flow runout event for SLO is bounded by-the flow runout event for two loop operation,- which in turn, is
~
- bounded by> the analyses.results at 30% core flow.
The extension
^
4,
to -the flow-dependent limits is applicable for both,the Non Loop.,
Manual and the Loop Manual modes.
In the Non-Loop Manual modes, the analyses assume that both loops runup to the maximum flow.
rate with both recirculation pumps at fast speed; the maximum
(
core flow is assumed to reach =110% of rated on the limiting
(
rod-line.
In the Loop Manual mode, the analyses assume that both l
recirculation pumps are at fast speed;. the loop with the lower flow is conservatively assumed to runup.
For flow runout events I
initiated from core flows below 30% of reted, the final core flow 1
1 (and therefore, the change in CPR) is bounded by the analysis I
results at 30% core flow. This is due to the limited flow increase-when the recirculation pumps are at slow speed (Reference II, Section 3),
i' g)
Flow-Decendent MCPR Limits l
The flow-dependent MCPR operating limit curves were constructed.
n i
based on the Cycle 5 ANF' analyses for Grand Gulf Unit I to protect the safety limit following a flow runout event.
These limits were established by ANF for the Cycle 5 core based on the ANFB Critical Power Correlation. As was done for Cycle 4, the limits were determined for both the Non-Loop Manual and the loop Manual modes of-operation (Reference II, Section 3).
h)
Power-Deoendent MCPR Limits The MCPR operating limits are revised for:
(i) core powers p
below 40% power with core flows above 50% of' rated and, (ii)
~ above 70% power, based on the Cycle 5 ANF analyses for Grand Gulf
+
+
Unit 1. 'The Cycle 5 -analyses results.show that the limiting -
4 avents will result in a minimum CPR that is at or above the MCPR f
safety limit with the plant initially at the MCPR operating p
limit (Reference II, Section 3).
I i)'
Exoosure-Decendent MCPR Limit.1 i
The exposure-dependent MCPR operating limits (MCPR,) were established by analyzing the most limiting local events and core-wide transients for Cycle 5 (Reference II, Section 3). 'The Control Rod Withdrawal Error and Loss of Feedwater Heating events i
L were analyzed for several exposure points throughout the cycle l
and < establish a bounding delta-CPR applicable to all exposures.
The Load Rejection No Bypass and Feedwater Controller Failure l.
transients were analyzed for thre-exposure intervals during the cycle (Reference I, Figure 5.5).
For each interval, analyses n
l were performed at the most limiting exposure (i.e., at the end of l-e l'
i i
the interval) and establish the maximum delta-CPR for that interval. The MCPR, operating limits were established to ensure that the safety limit will not be exceeded during the most limiting event in each of the three exposure intervals.
j)
Power / Flow Ooeratina Dombin The power / flow map is revised consistent-with the operating-domain applicable to Grand Gulf Unit 1.
The revised map is constructed using the Maximum Extended Operating Domain boundaries (Reference IV) established for previous cycles, the constant FCV position. flow lines determined based on Grand Gulf startup test data (Reference V), and the 80% and 100% rod lines shown in the Grand Gulf Stability Technical Specifications (Reference VI).
The revised map was used as an input to the Cycle 5 reload analyses. The analyses show that operation within the operating domain delineated by the revised power / flow map will.not challenge any safety limits.
. i
NO SIGNIFICANT HAZARDS CONSIDERATIONS:
The Commission has provided standards for determining whether a no significant hazards consideration exists as stated in 10CFR50.92(c). A proposed amendment to an operating license involves a no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:
(1) involve a significant increase in the probability..
or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of
- safety, i
The licensee has evaluated the no significant hazards considerations in its request for a license amendment.
In accordance with 10CFR50.91(a), the licensee is providing the analysis of the proposed amendment against the l
three standards in 10CFR50.92(c).
I i
The proposed Technical Specification changes addrecs the following:
L i
a)
The revision of MCPR safety limits for Two Loop and Single Loop Operation, b)
The revision of the minimum power level above which the Rod Action Control System (RACS) may be bypassed at any time.
c) The consolidation of the MAPLHGR limit curves for 8x8 and for 9x9 5 i
fuel types that will be resident in the core during Cycle 5. -
l 1
1 d) The replacement of MAPLHGR multipliers by LHGR multipliers.
e) The extension of LHGR limits for 8x8 fuel types to bound the expected i
end-of-life exposures, f) The extension of MCPR and LHGRFACf curves at low flows.
f g) The revision of MCPRf operating limits curves for Non loop Manual and
(
Loop Manual modes of operation.
l l
h) The revision of MCPR operating limits.
p l
- 1) The introduction of exposure dependent MCPR operating limits, l
j) The revision of the power / flow map to show the operating domain I
applicable to GGNS Unit 1.
1 k) Administrative changes (See Description of Changes section).
A description of the no significant hazards considerations determination i
follows:
l l.
No significant increase in the probability or consequences of an accident previously evaluated results from these changes.
I.
l i
a) This change consists of revisions to the MCPR safety limits for Two Loop and Single Loop Operation. The revised limits are determined using the ANF Safety Limit methodology and the ANFB critical power correlation and account for the effects of channel bow.
This change only redefines the safety limits and does not affect the precursors to any event evaluated previously. Therefore, the change to the MCPR safety limits does not involve a significant increase in the probability of any event previously evaluated.
As a result of this change, increases in the Cycle 4 safety limits t
'are observed.
The revised limits account for the uncertainties
. associated with safety limit determination and the effects of channel bow.
They ensure compliance with the applicable criterion for incipient boiling transition. Therefore, the revision of the MCPR safety limits does not involve a significant increase in the consequences of any event previously evaluated.
b) This change consists of a revision to the minimum power level above which control rods may be bypassed at any time in the RACS (cutoff l
l power level).
It only redefines the power level below which the enthalpy deposition considerations associated with the Rod Drop l
l Accident are significant.
It does not affect the precursors to any.
event previously evaluated.
Therefore, the revision to the minimum power level does not involve a significant increase in the probability of any event previously evaluated.
The revised power level has been shown to be acceptable based on 1
l
'BWROG methodology, which has been approved. The generic analysis supporting a reduced cutoff power level has been shown to be applicable to Grand Gulf Unit 1.
The analysis demonstrates that no significant control rod drop can occur above 10% power. Therefore, the revision to the minimum power level does not involve a significant increase in the consequences of any event previously evaluated.
c) This change consists of revisions to the MAPLHGR limits for 8x8 and-for 9x9-5 fuel types. This change only redefines the MAPLHGR
" limits for all 8x8 and for 9x9 5 fuel types that will be resident in the core for Cycle 5; it does not affect the precursors to any l
event previously evaluated. -Therefore, the revision of the MAPLHGR limits does not involve a significant increase in the probability i
of any event previously evaluated.
3 i
The peak clad-temperature (PCT) for the 8x8 fuel types that will.be resident in the core for Cycle 5 was calculated previously based on 4
a bounding MAPLHGR curve. This curve is used as the consolidated limit for all 8x8 fuels.
Similarly, a bounding MAPLHGR curve for all 9x9-5 fuel types is introduced. Consistent with the use of bounding MAPLHGR curves, a revised MAPLHGR multiplier is provided j
for single loop operation (SLO).
The PCT for SLO is bounded by the PCT for two loop operation.
For two loop operation, the calculated l
PCT for 9x9-5 fuel is 5 degrees F higher than the PCT that was calculated previously for the 8x8 fuel.
However, the PCT for 9x9-5 fuel is well below the 10CFR50.46 limit of 2200 degrees F. !
i Therefore, the revision of the MPLHGR limits does not involve a significant increase in the consequences of any event previously evaluated.
d)
This change addresses the replacement of MPLHGR multipliers by LHGR multipliers for operation at off-rated conditions.
The LHGR multipliers ensure that the mechanical design criteria are satisfied; this serves the same purpose as the MAPLHGR multipliers for previous cycles. This change does not affect the precursors to any event previously evaluated. Therefore, the replacement of the MPLHGR multipliers by LHGR multipliers does not involve a 4.
'significant increase in the probability of any event previously evaluated.
The use of LHGR multipliers that are applied to the LHGR limit is equivalent to the use of MAPLHGR multipliers applied to a MAPLHGR limit (which was defined based on the LHGR linilt in previous cycles) in meeting the mechanical design criteria.
Therefore, the replacement of MAPLHGR multipliers by LHGR multipliers does not
+
involve a significant increase in the consequences of any event previously evaluated.
~ e) This change extends the-LHGR limit for 8x8 fuel types to bound the expected end-of-life exposure. This change only extends the Cycle 4 LHGR limit for all 8x8 fuel types that will be resident in the core for Cycle 5; it does not affect the precursors to any event evaluated previously. Therefore, the extension of the LHGR.
a o
q limits for 8x8 fuel types does not involve a significant increase in the probability of any event previously evaluated, i
The LHGR limits for the 8x8 fuel types that will be resident in the core for Cycle 5 were established previously in order to satisfy t
the fuel mechanical design criteria, and are based on approved ANF methodologies. Therefore, the extension of the LHGR limits for 8x8 fuel types does not involve a significant increase in the consequences of any event previously evaluated.
e'-"
f)- This change, which is introduced for Cycle 5, extends the and LHGRFAC ) at low flows. The flow-dependent limits (MCPRf f
core flows for which these limits are defined bound the core flows during normal operations for both single ' loop and two loop operation.
These limits ensure protection of the MCPR safety limit for the slow flow runout event.
For these conditions, the MCPR safety limit.is protected by the MCPR limits for. all other p
events. This change only defines the flow dependent limits at low flows and does not affect the precursors to any event previously evaluated.
Therefore, the extension of the flow dependent limits at low flows does not involve a significant increase in the probability of any event previously evaluated.
L l
For initial core flows below 30% of rated, the credible flow l
increase and the resulting change in CPR for both single loop and two loop operation are bounded by the analysis results for two loop operation. -The_ extension to the flow dependent limits is applied - -
for both loop Manual and Non-Loop Manual modes.
Therefore, the extension of the flow dependent limits at low flows does not p
involve a significant increase in the consequences of any event previously evaluated, g) This change consists of revisions to the MCPRf operating limits.
The revised limits are defined for specific modes of operation and are based on ANF's methodology.
These changes only redefine the flow-dependent MCPR limits established for Cycle 4 and do not affect the precursors to any event previously evaluated.
.i
~Therefore, the revision of the MCPRf operating limits does not
~'
. involve.a significant increase in the probability of any event previously evaluated.
As a result of this change, both reductions and increases relative t
to the Cycle 4 limits are observed. However, the revised MCPRf operating limits were-constructed in a conservative manner. -The limiting flow runout event will not cause the plant to exceed the MCPR safety limit. Therefore, the revision of the MCPRf i
operating limits does not involve a significant increase in the consequences of any event previously evaluated.
1 h) This change consists of revisions to the MCPR operating limits.
p As a result of this change, increases in the Cycle 4 MCPRp operating limits are observed at the low power /high flow and high power statepoints for Cycle 5.
The revised MCPR limits are p
l established based on ANF methodology. This change only redefines
, i
the MCPR limits and does not affect the precursors to any event
{
p prt
,dsly evaluated.
Therefore, the revision of the MCPRp operating limits does not involve a significant increase in the 1
probability of any event previously evaluated.
The Cycle 5 analyses have demonstrated that the revised limits ensure that the limiting events will result-in a final MCPR at or.
above the MCPR safety limit. Therefore, the revision of the l
MCPR operating limits does not involve a significant increase in p
the consequences of any event previously evaluated.
- 1) This th nge comprises the introduction of exposure-dependent MCPR operating limits for Cycle,5 (MCPR,).
The MCPR, limits are established based on ANF methodology.
This change only redefines the MCPR operating limits and does not affect the precursors to any event previously evaluated. Therefore, the introduction of the MCPR, operating limits does.not involve a significant increase in-the probability of any event previously evaluated.
l :.
The Cycle 5 analyses have demonstrated that the exposure-dependent limits ensure that the limiting events will result in a CPR at or above the MCPR safety limit. Therefore, the introduction of the MCPR, operating limits does not involve a significant increase in the consequences of any event previously evaluated.
L j) This change consists of a revision to the power / flow map consistent with the Grand Gulf Unit 1 operating domain. The revised map is
l i
constructed from a combination of the Maximum Extended Operating i
Domain boundaries established for previous cycles, the constant flow control valve (FCV) position lines determined based on Grand Gulf startup test data, and the 80% and 100% rod lines defined in the Grand Gulf core stability-related technical specifications.
)
This change only redefines the power / flow map to be consistent with the Grand Gulf Unit 1 operating domain and does not affect the precursors to any event previously evaluated.
Therefore, the revision of the power / flow map does not involve a significant increase in the probability of any event previously evaluated.
The domain of the revised map is an analysis input for the Cycle 5 reload analyses. These analyses have shown that the safety limits are not challenged. Therefore, the revision of the power / flow map does not-involve a significant increase in the consequences of any event previously evaluated, k) These changes are administrative.
Therefore, they do not involve a significant increase in the probability or consequences of an accident previously evaluated.
Overall, the proposed changes define parameters determined conservatively and consistent with the fuel which will be resident in the core during Cycle 5.
They do not affect the precursors to any I
accident previously evaluated. These changes, therefore, do not involve a significant increase in the probability or consequence of any accident previously evaluated.
I..
I l
2.
These changes do not create the possibility of a new or different kind of accident from any previously evaluated.
This response addresses Items a) through j).
The 9x9-5 fuel' type has been shown to be of a design compatible with the fuel present in the core.
It has been determined that the 9x9 5 fuel will not create the possibility of a new or different kind of accident.
The proposed changes do not involve any new modes of operation, any changes to setpoints, or any plant modifications.
They n
only introduce revised limits that have been shown to be acceptable for..
Cycle 5 operation. Therefore,,the proposed changes do not result in the creation of any new precursors to an accident.
The administrative
= changes have no effect on any accidents.
Therefore, the proposed changes do not create the possibility of a new or different type of accident from any accident previously evaluated.
l l
3.
These changes do not involve a significant reduction in the margin of safety.
a) This change consists of revisions to the MCPR safety limits for Two-l-
Loop and Single Loop Operation.
The revised limits are based on ANF methodology and account for the nffects of channel bow.
These changes only redefine the safety limits resulting in a change l
(
in the limits from 1.06 and 1.07 (Cycle 4) to 1.08 (Cycle 5) for.
- - - - -. - ~. - - - - - - - -
a----
l two loop and single loop operation, respectively.
The available i
margin to the MCPR corresponding to incipient boiling transition is 1
not decreased.
Therefore, the revision of the MCPR safety limits does not involve a significant reduction in the margin of safety.
b) This change consists of a revision to the minimum power level, j
above which control rods may be bypassed at any time in the RACS.
It only reduces the power level (from 20% for Cycle 4 to 10% for Cycle 5) above which the enthalpy deposition considerations associated with the Rod Drop Accident (RDA) are insignificant.
'-Therefore,s the revision of the minimum power level does not involve c
a-significant-reduction in the margin of safety.
c)
This change revises the MAPLHGR limits by introducing a consolidated MAPLHGR limit for the 8x8 and for the 9x9 5 fuel types that will be resident in the core for Cycle 5.
Consistent with this change, a revised MAPLHGR multiplier is provided for single loop operation (SLO).
For two loop operation, the peak clad
- temperature (PCT) for the 8x8 fuel types was calculated previously to be 1691 degrees F using the consolidated 8x8 MAPLHGR limit. The l
PCT for the 9x9 5 fuel types (1696 degrees F) was calculated using the same methodology that was used for 8x8 fuel types. The results show that for two loop operation, the PCT for 9x9-5 fuel is-l.
l essentially unchanged from the PCT for 8x8 fuel types inserted during < evious cycles.
The PCT for SLO is bounded by the PCT for I
two loop operation.
Compared to the 5 degrees F increase in PCT (from 1691 degrees F to 1696 degrees F), the available margin to - -
j 1
the 10CFR50.46 limit of 2200 degrees F remains greater than 500 degrees F for both two loop operation and SLO. Therefore, the revision of the MAPLHGR limits does not involve a significant reduction in the margin of safety.
d) This change addresses the replacement of MAPLHGR multipliers by LHGR multipliers *1r operation at-off-rated conditions.
The LHGR. _
l multipliers ensure that the mechanical design criteria are satisfied.
This is equivalent to the MAPLHGR multipliers being applied to the LHGR based MAPLHGR limits, as was done for previous
-cycles. The LHGR limits and the multiplier values that were defined for Cycle 4 are unchanc:J for Cycle 5 (other than extensions to address higher exposures and lower flows, as discussed in items e) and f) below). Therefore, the replacement of MAPLHGR multipliers by LHGR multipliers does not involve a significant reduction in the margin of safety.
e) This change addresses the extension of the LHGR limits for 8x8 fuel types to bound the expected end-of-life exposure.
The LHGR limits, l
which were established previously on a generic basis, ensure that the mechanical design criteria are satisfied. Therefore, the extension of the LHGR limits for 8x8 fuel types does not, involve a significant reduction in the margin of safety.
l f) This change, introduced for Cycle 5, extends the flow dependent limits at low flows. The flows corresponding to these limits bound the core flows riuring normal operations for both SLO and two loop.
l
i operation.
For SLO, the flow increase is bounded by the increase for two loop operation.
For flow runout events initiated from below 30% core flow, the final core flow and therefore the change
'I in CPR, is bounded by the analysis results for two loop operation at 30% core flow. This is due to the limited flow increase when the recirculation pumps are at slow speed for two loop operation.
Therefore,6the extension of the flow-dependent limits at low flows..
does not involve a significant reduction in the margin of safety.
g) This change consists of revisions to the MCPRf operating limits.
E.
, -The revised limits are defined for specific modes of operation and are based on ANF's methodology.
The revised MCPR limits show f
both reductions and increases relative to Cycle 4.
However, the ANF Grand Gulf linit 1 Cycle 5 specific safety analyses ensure that the safety limit is protected.
l l
The MCPR limits consist of two curves corresponding to Non-Loop 7
Manual and Loop Manual modes of operation.
For the Non-Loop Manual modes,' the limiting flow runout event consists of a two loop runcut whereas for the Loop Manual mode, the limiting event consists of a L
one loop runout. The MCPR7 operating limits are constructed based on a number of conservative assumptions:
- 1) The increase in 1
-flow rates for both one and two loop runout events. are l
conservative, 2) the ANF analysis assumes a conservative rod line limits for the limiting flow runout event, and 3) the MCPRf include an added conservatism to allow for possible performance variations in subsequent cycles.
l.
j With the plant initially at the revised MCPR7 operating limit, the limiting flow runout event, for both Non-Loop Manual and Loop Manual operations, will result in a final CPR at or above the MCPR safety limit. This ensures that an adequate margin of safety is available. Therefore, the revision of the MCPRf operating limits does not involve a significant~ reduction.in the margin of. safety...._
h) This change consists of revisions to the MCPR operating limits.
p As a result of this change, increases in the Cycle 4 MCPR p
-~ operating. limits.are observed at the low power /high flow and high j
-power statepoints.
Cycle 5 analyses have demonstrated that the limiting events will result in a minimum CPR which is at or above-
)
the MCPR safety limit.
Therefore, the revision of the MCPRp operating limits does not involve a significant reduction in the margin of safety.
- 1) This change introduces exposure-dependent MCPR operating limits for Cycle 5.
This change only redefines the MCPR operating limits as a function of cycle exposure.
Cycle 5 analyses have demnstrated that the limiting events will result in a minimum CPR which is at or above the MCPR safety limit.
Therefore, the introduction of the j
.MCPR, operating limits does not involve a,significant reduction.
L in the margin of safety.
j) This change consists of a revision to the power / flow map consistent I
with the Grand Gulf Unit 1 operating domain.
The revised map is
i constructed using a combination of the Maximum Extended Operating Domain boundaries established for previous cycles, the constant FCV position lines determined based on Grand Gulf startup test data, and the 80% and 100% rod lines defined in the Grand Gulf core i
stability-related technical specifications. The revised map is an analysis input for the Cycle 5 operating limits. Operation within l
these. limits ensures that no safety limits will.be challenged.
Therefore, the revision of the power / flow map does not involve a i
significant reduction in the margin of safety.
-.- k)--These changes are administrative. Therefore, they do not involve a 9
significant reduction in the margin of safety.
f Therefore, these changes do not involve a significant reduction in the margin of safety, l
l 1 -
1
REFERENCES:
i
!) ANF-90 022, Revision 1, " Grand Gulf Unit 1 Cycle 5 Reload Analysis,"
Advanced Nuclear fuels Corporation, Ma;a 1990.
]
II) ANF 90 021, Revision 1
" Grand Gulf Unit 1 Cycle 5 Plant Transient Analysis," Advanced Nuclear fuels Corporation, May 1990.
~
III)
Safety Evaluation by the Office of Nuclear Reactor Regulation relating to Amendment 17 of GE Topical Report NEDE 240ll-P, " General Electric Standard Application for Reactor Fuel," December 27, 1987.
2..
IV)
" Maximum Extended Operating Domain Analysis," General Electric
~
Company, March 1986.
s V) AECM 86/0066, " Final Summary Startup Test Report 12," Letter, O. D.
Kingsley, MP&L, to J. fl. Grace, NRC, February 28, 1986.
'VI)
" Issuance of Amendment No. 62 to Facility Operating License No.
NPF Grand Gulf Nuclear Station, Unit 1. Regarding Technical Specifications Revisions - Thermal-Hydraulic Stability (TAC No.
l l
71808)," Letter from L. L. Kintner, NRC, to W. T. Cottle, SERI, August 31, 1989.
l l