ML20206K524
| ML20206K524 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 05/06/1999 |
| From: | Eaton W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20137N459 | List: |
| References | |
| NUDOCS 9905130189 | |
| Download: ML20206K524 (15) | |
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Entergy operations, Inc.
P. O. Box 766 i
h Port Gibson, MS 39150 Tel 001437 6409 i Fax 601437 2795 l William A. Eaton Vice Pres +nt.
b thcies Statm i
May 6, 1999 i
i U.S. Nuclear Regulatory Commission Mail Station P1-37 Washington, D.C. 20555 Attention: Document Control Desk I
Subject:
Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Cycle 11 Reload Proposed Amendment to the Operating License (LDC-1999/ 0034) l GNRO-99/00037 Gentlemen:
In accordance with 10CFR50.90, Entergy Operations, Inc. is submitting by this letter a proposed amendment to the Grand Gulf Nuclear Station (GGNS) .,
Operating License.
The proposed amendment requests changes to those Technical Specifications (TS) required to support Grand Gulf Nuclear Station, Cycle 11 operation. These changes include a change to the minimum critical power ratio safety limit (SLMCPR). Cycle 11 will be the third cycle of operation with a mixed core of Siemens Power Corporation (SPC) 9x9-5 and General Electric (GE) GE11 reload fuel. Only 36 SPC 9x9-5 bundles will be included in the Cycle 11 core and all of these bundles will be in low power locations on the core periphery.
The proposed amendment reflects a decrease of the two recirculation loop SLMCPR limit from 1.11 to 1.09 and the single recirculation loop SLMCPR limit from 1.12 to 1.10.
These values were developed with General Electric's cycle-specific SLMCPR methodology in GESTAR-il Amendment 25 which was recently approved by the NRC by Safety Evaluation Report dated March 11,1999.
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GNRO-99/00037 Page 2 of 3 In accordance with the provisions of 10CFR50.4, the signed original of the requested amendment is enclosed. Attachment 2 provides the discussion and justification for the decrease in the SLMCPR and supports the requested amendment. This amendment request has been reviewed and accepted by the Plant Safety Review Committee and the Safety Review Committee.
Based on the guidelines in 10CFR50.92, Entergy Operations has concluded that this proposed amendment involves no significant hazards considerations. Attachment 2 details the basis for this determination. Attachment 3 includes marked-up pages of the GGNS Technical Specifications and Bases.
Attachment 4 provides additional information regarding the two-loop and single-loop cycle specific SLMCPRs for Cycle 11. The additional information is based on the input provided by General Electric. General Electric considers the information contained in Attachment 4 to be proprietary. In accordance with the requiements to 10CFR2.790(b), an affidavit is enclosed (Attachment 5) to support the withholding of the information contained in Attachment 4. A non-proprietary version is provided in Attachment 6.
Entergy Operations requests NRC approval and issuance of the proposed Technical Specifications changes prior to the Grand Gulf Refueling Outage 10 now scheduled to begin October 23,1999.
Yours truly, ,
We m qfa4.
WAE/ACG/ %' ,
attachments: 1. Affirmation per 10CFR50.30
- 2. GGNS LDC-1999/ 0034
- 3. Mark-up of Affected Technical Specification Pages
- 4. Additional Information Regarding the 1.09 (calculated 1.08) Cycle Specific SLMCPR for Grand Gulf -Cycle 11 (Proprietary) ,
- 6. Additional Information Regarding the 1.09 (calculated 1.08) Cycle Specific SLMCPR for Grand Gulf -Cycle 11 (Non-proprietary) i I
cc: (See Next Page)
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e GNRO-99/00037 Page 3 of 3 cc: Ms. J. L. Dixon-Herrity, GGNS Senior Resident (w/a)
Mr. L. J. Smith (Wise Carter) (w/o)
Mr. N. S. Reynolds (w/o)
Mr. H. L. Thomas (w/o)
Mr. E. W. Merschoff (w/a)
Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 l Arlington, TX 76011
, Mr. Patrick Sekerak, Project Manager (w/2) l U.S. Nuclear Regulatory Commission l One White Flint North, Mail Stop 13D18 l 11555 Rockville Pike Rockville, MD 20852-2378 Dr. E. F. Thompson (w/a)
State Health Officer State Board of Health P.O. Box 1700 Jackson, Mississippi 39205 l
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Attachment 5 to GNRO-99/00037 GGNS LDC-1999/0034 GE Affidavit to support the withholding of the information 1
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( ,. l GE NuclearEnergy a w e mee coismay P. o. mar reo newesen, Nc seder Amdavit I, Glen A. Watford, being duly sworn, depose and state as follows:
(1) I am Manager, Nuclear Fuel F2j= -ug, General Electnc Company ("GE") and have been delegated the fnactian of reviewmg the information described in paragraph (2) which is sought to be withheld, and have been authonzod to apply for its withholdmg (2) The information sought to be withhold is matninad in the letter, R E Kingston (GE) to J. Lee (EOI), " Calculation ofGGNS Cycle 11 Safety LimitMCPR, " REK:99-057, April 19,1999.
(3) In makmg this application for withholdmg of proprietary infonnation of which it is the owner, GE relies upon the exemption from disclosure set forth in the Freedom ofInformation Act ("FOIA"),
5 USC Sec. 552(b)(4), and the Trade Secrets Act,18 USC Sec.1905, and NRC regulatims 10 CFR 9.17(a)(4) and 2.790(a)(4) for " trade secrets and commercial or financial inforwdon obtamed from a person and privdeged or confidatial" (Fv-ntina 4). The matenal for which evemntina from diecinmure is here sought is all "anandantial commercial infonnatinn," and some portions also quahfy under the narrower definition of" trade secret," within the meanings assigned to those terms for purposes of FOIA F==atian 4 in, respectively, Critical Mass Enerav Proiect v.
Nuclear Reaulatory Commission. 975F2d871 (DC Cir.1992), and Public Citizen Health Research Groun v. FDA. 704F2dl280 (DC Cir.1983).
(4) Some examples of categones of information wisch fit into the definition of proprietary information are:
- a. Information that discloses a process, method, or apparates, including supportmg data and analyses, where presention of its use by Gmeral Cm 's compentors without license from General Electnc constitutes a cowpetitive econonuc advantage over other compames;
- b. Information wiuch, if. wd by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or hcensmg of a similar product;
- c. Information winch reveals cost or price information, production capacities, budget levels, or w... Al strategpes of General Electnc, its customers, or its suppliers;
- d. Information which reveals aspects of past, preset, or future Geeral Electric customer-funded dcvi,,..= plans and programs, of potential commercial value to Gmeral Electnc;
- c. Information wiuch discloses patentahle subM matter for which it may be desirable to obtain patet prntar*ina.
'Ibe information sought to be withheld is considered to be proprietary for the reasons set forth in both paragraphs (4)a. and (4)b., above.
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AWidtvit (5) De information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in -he by GE, and is in fact so held. Its initial designation as proprietary informaten, and the subsequent steps taken to prevent its unauthonzed disclosure, are i as set forth in (6) and (7) followmg. De informaton sought to be withheld has, to the best of my knowledge and belief, consistently been held in -h* by GE, no public disclosure has been
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made, and it is not avadable in public sources. All disclosures to third partes including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for inaintenance of the information in en h, (6) Initial approval of proprietary treatment of a h=at is made by the manager of the originating en==rv-*. the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such h==ts within GE is limited on a "need to know" basis.
(7) He 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 cogmzant marketing function (or his delegate), and by the legal Operation, for j technical content, competitive effect, and deternunation of the accuracy of the proprietary designation Disclosures outside GE are limited to regulatory bodes, 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 idemedied in paragraph (2) is classified as propnetary because it contains details of GE's Safety Limit aw*hadalogy and the miA results which GE has applied to actual core designs with GE's fuel.
The development of the methods used in these analyses, along with the testing, development and approval of the supporting awkadalogy was achieved at a significant cost, on the order of several million dollars, to GE.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the avadability of profit-rnaking opportunities.
De Safdy Limit analysis is part of GE's comprehensive BWR safety and technology base, and its commercial value extends beyond the onginal dcydo, ..a4 cost. De value of the technology base goes beyond the extensive physical datah==e and analytical methodology and includes dcydo,,...a4 of the expertise to decrmine and apply the appropriate evaluation process In addition, the technology base includes the value derived from providmg analyses done with NRC-approved methods
%e research, dcydo,,...aa, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GE.
De precise value of the expertise to devise an evaluatma process and apply the correct analytical methodology is difBcult to quantify, but it clearly is substantal ;
GE's compostive advantage will be lost if its en aadhars are able to use the results of the GE exponence to normahme or verify their own process or if they are able to claim an equivalent
==4:=t by demonstrating that they can arrive at the same or simdar conclusions.
He value of this informataan to GE would be lost if the information were disclosed to the public.
Making such information avadable to competitors without their having been required to undertake cuuem ma a.
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Af5d:vit l
a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.
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l State ofNorth Carolina ) 8S2 County ofNew Hanover ) l Glen A. Watford, being duly sworn, deposes and says:
'Ihat he has read the foregoing affidavit and the matters stated therem are true and correct to the best of his knowledse,information, and behef Executed at Wilnungton, North Carolina, this I day of h . 19 L) /
Glen A. ord General Electnc Company Subscribed and sworn before me this M day of b .Id I '
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Notary Public, State of North Carohna My Commission Expires 8~c2 Y -9 f l
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Attachment 1 to GNRO - 99/00037 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE NO. NPF-29 DOCKET NO. 50-416 IN THE MATTER OF ENTERGY OPERATIONS, INC.
and SYSTEM ENERGY RESOURCES, INC.
and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION and ENTERGY MISSISSIPPI, INC.
AFFIRMATION I, W. A. Eaton, being duly sworn, state that I am Vice President, Operations GGNS 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 GGNS of Entergy Operations, 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.
MA h m A L L.
W. A. Eaton STATE OF MISSISSIPPI COUNTY OF CLAIBORNE l
l a Notary Public, in and for the County and State SUBSCRIBED above named, this AND JdSWORN day of TO before me,M .1999.
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(SEAL) i 1 a,/ ~
Notary Public
-M" ma5'een NY C0wlMS$0t O')W.S OCT. 27,20)0 i
DONDED THRU STEGA!LICTARY SERVICE !
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Attachment 2 to GNRO- 99/00037 i
1 GGNS LDC-1999/0034 I Cycle Specific SL MCPR for Grand Gulf-Cycle 11 1 1 j
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Grand Gulf Nuclear Station Attachmnnt 2 to GNRO-99/00037 Cycla 11. LDC-1999/0034 Page 1 of 5 A. AFFECTED TECIINICAL SPECIFICATIONS
- 1. The following Technical Specifications are affected by the proposed change:
2.1.1 Reactor Core Safety Limits 5.6.5 Core Operating Limits Report
- 2. The following Technical Specification Bases are affected by the proposed change. Since Technical Specification Bases are controlled under 10CFR50.59 Program, the markup of the Bases Sections are provided for information only:
B 2.1.1.2 MCPR B 3.2.2 Minimum Critical Power Ratio (MCPR)
B. DESCRIPTION OF CIIANGES
- 1. Technical Specification 2.1.1.2: The proposed change revises the Safety Limit :
MCPR for Two Loop Operation and Single Loop Operation to 1.09 and 1.10, respectively and deletes the footnote referring to Cycle 10 operation since the l GE cycle-specific methodology has been NRC approved and GESTAR-Il is l included in the methodology documents of Technical Specification 5.6.5.
- 2. Technical Soecification 5.6.5: The proposed change deletes the footnote referring to Cycle 10 operation since the GE cycle-specific methodology has ,
been NRC approved.
- 3. Technical Specification Bases: The proposed change deletes the cycle-specific references associated with the SLMCPR methodology.
C. BACKGROUND Grand Gulf Cycle 11 is the third cycle of operation with GElI reload fuel. The Cycle 11 core will contain 764 GElI bundles and 36 thrice-burnt Siemens 9x9-5 bundles. The SPC bundles are in low power locations on the core periphery and do not contribute rods in boiling transition to the MCPR safety limit calculation. A conventional core design with a checkerboard fresh fuel loading pattern is utilized.
The GGNS Cycle 11 MCPR safety limits were developed with General Electric's cycle-specific MCPR safety limit methodology that has been recently approved as Amendment 25 to GESTAR-ll. The revised plant uncertainties approved in NEDC-3260lP were applied in this calculation.
Grand Gulf Nucinr Station Attachment 2 to GNRO-99/00037 Cycla 11, LDC-1999/0034 Page 2 of 5 )
GE's cycle-specific methodology includes objective measures for evaluating the flatness of the core and bundle power distributions. These measures are reported below to compare the GGNS Cycles 10 and 11 cores. For the proposed Technical Specifications changes the calculated two-loop Cycle 1i SLMCPR of 1.08 has been conservatively rounded up to 1.09 in I order to accommodate any potential impacts from future Cycle 10 operations.
Comparison of Grand Gulf Cycles to and 11 Cores Description Grand Gulf Cycle 10 Grand Gulf Cycle 11 j Limiting Cycle Exposure Point EOC-lK _ EOC-1.5K j MCPR Importance Parameter, MlP 3.851 2.32 j R-Factor importance Parameter, RIP 27.6% 20.2 %
Calculated Two-Loop Safety Limit MCPR 1.11 1.08 Current / proposed Tech. Spec. SLMCPR 1.11 1.09 l
The Siemens 9x9-5 bundles were modeled with the same approach as applied in GGNS Cycles 9 and 10 and reported in PCOL 96/008, Rev.1 (letter dated September 5,1996 from C. R.
Hutchinson addressed to the Document Control Desk). New coeflicients were developed for GE's GEXLO2 correlation for the remaining Siemens bundles and bundle R-factors were I developed in a manner consistent with GE's methodology. As in previous analyses for cycles 9 and 10 a conservative CPR uncertainty was applied based on comparisons of this modified GEXL correlation to both Siemens' ANFB correlation (PCOL 96/008, Rev.1) and Siemens' <
critical power test data (GNRO-96/00119, letter from J. J. Hagan addressed to the Document l Control Desk, submitted October 22,1996). The GGNS Cycle 11 analysis determined that the 1 few remaining Siemens bundles contributed no rods subject to boiling transition and consequently have no impact on the calculated MCPR safety limits. ;
D. PROPOSED TS CHANGES The proposed changes to the Technical Specifications are to change the MCPR safety limit values for two-loop and single-loop operation to those values calculated by GE's rnethodology for GGNS Cycle 11. These marked-up Technical Specifications are included as Attachment 3.
The GESTAR reference is maintained on the list of documents that have been reviewed and approved by the NRC without a revision number to maintain consistency with the other COLR methodology references. The SPC reports currently listed in the Technical Specifications will be unaffected since SPC fuel will remain in the Cycle 11 core.
The Cycle 9 MCPR safety limit report will remain in Technical Specification 5.6.5 since it contains information regarding the modeling of the Siemens bundles that is not included in GESTAR. The cycle-specific footnote will be removed since GE's cycle-specific methodology in Amendment 25 to GESTAR has been approved by the NRC.
Grand Gulf Nucbar Station Attachment 2 to GNRO-99/00037 Cycla 11. LDC-1999/0034 Page 3 of 5 Removal of the footnote is consistent with similar changes approved for Perry Nuclear Plant, Unit 1, Amendment No.104 to Facility Operating License No. NPF-58 Docket No. 50-440 and NRC SER dated March 26,1999 and for River Bend Station, Unit 1 Amendment No.105 to Facility Operating License No. NPF-47 Docket No. 50-458 dated April 27, 1999. The proposed removal of the cycle-specific footnote is acceptable since the analysis is already performed using plant- and cycle-specific parameters, and the procedures specified in Amendment 25 to NEDE-240ll-P-A, which is now a NRC approved methodology, is acceptable for use at Grand Gulf Nuclear Station for Cycle 11 and future cycles.
E. JUSTIFICATION The MCPR Safety Limit is developed to assure compliance with General Design Criterion 10 of 10CFR50 Appendix A. The Bases to Technical Specification 2.1.1 states that "The MCPR SL ensures sufficient conservatism in the operating MCPR limit that, in the event of an Anticipated Operational Occurrence (AOO) from the limiting condition of operation, at least 99.9% of the fuel rods in the core would be expected to avoid boiling transition" Attachment 4 of this submittal documents additional information for the 1.09 cycle specific SLMCPR. The information is based on the GE provided input.
F. CONCLUSION For two-loop operation, a Safety Limit MCPR of 1.09 was demonstrated to be adequate to ensure that 99.9 percent of the rods in the core avoid a boiling transition during the most limiting AOO. For single-loop operation, the limit is increased by 0.01 to 1.10. The MCPR fuel cladding integrity safety limits for GGNS Cycle 11 two-loop and single-loop operation were determined by applying GE's NRC-approved cycle-specific MCPR safety limit methodology to the GGNS Cycle 11 core design. The SPC fuel was explicitly considered and found to not contribute to the Cycle 11 MCPR safety limit. The resulting values, therefore, represent bounding measures of the GGNS Cycle 11 MCPR safety limits.
G. SIGNIFICANT IIAZARDS CONSIDERATION Entergy Operations, Inc. proposes to change the current Grand Gulf Nuclear Station Technical Specifications to modify the Minimum Critical Power Ratio (MCPR) safety limits reported in Technical Specification 2.1.1.2, and associated Bases changes. The proposed change is necessary in order to reflect the results of the GGNS Cycle 11 analysis.
The Commission has provided standards for determining whether no significant hazards considerations exists as stated in 10 CFR 50.92 (c). A proposed amendment to an operating license involves no significant hazards if operation of the facility in
Grand Gulf Nucisar Station Attachment 2 to GNRO-99/00037 Cycla 11, LDC-1999/0034 Page 4 of 5 accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or ditTerent kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
Entergy Operations, Inc. has evaluated the no significant hazards consideration in its request for this license amendment and determined that no significant hazards considerations result from this change. In accordance with 10 CFR 50.91(a), Entergy Operations, Inc. is providing the analysis of the proposed arnendment against the three standards in 10 CFR 50.92(c). A description of the no significant hazards consideration determination follows:
1 1. The proposed change does not significantly increase the probability or consequences of an accident previously evaluated. ,
The Minimum Critical Power Ratio (MCPR) safety limit is defined in the Bases i to Technical Specification 2.1.1 as that limit which " ensures that during normal operation and during Anticipated Operational Occurrences (AOOs), at least 99.9% of the fuel rods in the core do not experience transition boiling." The 4 MCPR safety limit is re-evaluated for each reload and, for GGNS Cycle 11, the analyses have concluded that a two-loop MCPR safety limit of 1.09, based on the application of GE's NRC-approved cycle-specific MCPR safety limit methodology demonstrates that this acceptance criterion is satisfied. For single-loop operation, a MCPR safety limit of 1.10, based on GE's NRC-approved cycle-specific MCPR safety limit methodology, also demonstrates that this acceptance criterion is satisfied. Core MCPR operating limits are developed to support the Technical Specification 3.2 requirements and ensure these safety limits are maintained in the event of the worst-case transient. Since the MCPR safety limit will be maintained at all times, operation under the proposed changes will ensure at least 99.9% of the fuel rods in the core do not experience transition boiling. Therefore, these changes to the Minimum Critical !
Power Ratio (MCPR) safety limit do not affect the probability or consequences )
l of an accident.
l GE's NRC-approved GESTAR-Il cycle-specific MCPR safety limit methodology has been applied and has no efTect on the probability or consequences of any accidents previously evaluated. As previously licensed, one exception to GESTAR is that the mis-oriented and mis-located bundle events will continue to be analyzed as accidents subject to the acceptance criteria in the currert licensing basis. The design of the gel 1 fuel bundles is such that the bundles are not likely to be mis-oriented or mis-located and the normal administrative controls will be in effect for assuring proper orientation and location. Therefore, the probability of a fuel loading error is not increased.
This analysis ensures that postulated dose rReases will not exceed a small i
Grand Guif Nucl:ar Station Attachm:nt 2 to GNRO-99/00037 Cycis 11, LDet ac99/0034 Page 5 of 5
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l fraction (10 percent) of 10CFR100 limits. Therefore, the probability or consequences of accidents previously evaluated are unchanged.
II. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The gel 1 fuel to be used in Cycle 11 is of a design compatible with fuel present in the core and used in the previous cycle. Therefore, the gel 1 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. The proposed revised MCPR safety limits have been shown to be acceptable for Cycle 11 operation. Compliance with the applicable criterion for incipient boiling transition continues to be ensured. The proposed ,
MCPR safety limits do not result in the creation of any new precursors to an )
accident. l l
Therefore, the proposed changes do not create the possibility of a new or difTerent type of accident f:vm any accident previously evaluated.
III. The proposed change does not involve a significant reduction in a margin of safety.
l The MCPR safety limits have been evaluated in accordance with GE's NRC-approved cycle-specific methodology to ensure that during normal operation und during AOOs, at least 99.9% of the fuel rods in the core are not expected to experience transition boiling. One exception to GESTAR is that the mis-oriented and mis-located bundle events will continue to be analyzed as accidents subject to the acceptance criteria in the current licensing basis. This analysis ensures that postulated dose releases for the worst case mis-oriented and mis-located bundle will not exceed a small fraction (10 pement) of 10CFR100 limits. On this basis, the implementation of this GE methodology does not involve a significant reduction in a margin of safety.
Attachment 3 to GNRO- 99/00037 GGNS LDC-1999/0034 Mark-up Pages of the affected Technical Specifications Technical Specification Bases 1