ML20210V546

Application for Amend to License NPF-29,reflecting Decrease of Two Recirculation Loop SLMCPR to 1.11 & Single Recirculation Loop SLMCPR Limit to 1.12.Proprietary Info Re SLMCPR for Cycle 10,encl.Proprietary Info Withheld

ML20210V546
Person / Time
Site:	Grand Gulf
Issue date:	09/18/1997
From:	Hagan J ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20046D790	List: ML20210V546 ML20210V558
References
GNRO-97-0087, GNRO-97-87, NUDOCS 9709240041
Download: ML20210V546 (10)

Text

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Enterny operminons, Inc.

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M.ra,-sm September 18, 1997 -

U.S. Nuclear Regulatory Commission Mail Station P137 Washington, D.C. 20555 Attention: Document Control Desk

Subject:

Grand Gulf Nuclear Station Docket No. 50-410 License No. NPF 29 Cycle 10 Reload Proposed Amendment to the Operating License (PCOL 97/ 003)

GNRO 97/00087 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 10 operation. These changes include a change to the minimum critical power safety limit ratio (SLMCPR). Cycle 10 will be the second cycle of operation with a mixed core of Siemens Power Corporation (SPC) 9x9-5 and General Ele stric (GE) GE11 reload fuel.

The proposed amendment reflects a decrease of the two recirculation loop SLMCPR limit to 1.11 and a single recirculation loop SLMCPR limit to 1.12.

On June 10,1997, GE submitted Licensing Topical Report (LTR) No.

NEDC 32694P, Power Distribution Uncertainties for Safety Limit MCPR ,

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Evaluations that addresses the power distribution uncertainties with 3D MONICORE (Reference GE letter from R. J. Reda to the Document Control Desk, submitted June 10,1997). The LTR removes undue conservatism in GE methodology for calculating MCPR safety limits. Entergy intended to use these reduced uncertainties in developing Grand Gulf Nuclear

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Page 2 of 3 l Station's Cycle 10 SLMCPR. Therefore, on July 11,1997 Entergy Operations

submitted GNRO-97/00067 addressed to the Reactor Systems Branch (Attention

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J. E. Lyons) to support the above LTR and also requested the Commission for an expeditious review and approval of the LTR. Subuequent commercial issues were  ;

raised by GE which could not be resolved to the satisfaction of Entergy.  !

Therefore, Entergy developed this PCOL without the use of the above i uncertainties, i 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 decrease in the SLMCPR and supports the requested .

amendment. This amendment request has been reviewed and accepted by the i Plant Safety Review Committee and the Safety Review Committee. i Based on the guidelines in 10CFR50.92, Entergy Operations has concluded that i 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 additionalinformation regarding the two-loop and single-loop cycle specific SLMCPRs for Cycle 10. The additional information is based on the input provided by General Electric. General Electric considers the information l contained in Attachment 4 to be proprietary, in accordance with the requirements to 10CFR2.790(b), an affidavit is enclosed to support the withholding of the information contained in Attachment 4.

Entergy Operations requests NRC approval and issuance of Technical  !

. Specifications changes by March 15,1998 to allow related work activities to be ,

implemented prior to the Grand Gulf Refueling Outage 9 now scheduled to begin April 11,19fv8.

> ' Yours truly, >

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, . attachmentsf 1. Affirmation per 10CFR50.30

- 2. _GGNS PCOL-96/ 008  ;

3.L. Mark-up of Affected Technical Specification Pages i

4. AdditionalInformation Regarding the 1.11 Cycle Specific SLMCPR for Grand Gulf-Cycle 10 l

5. GE Affidavit to Support the Withholding of the Information -

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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. Hi L. Thomes (w/o) l 1

Mr. E. W. Merschoff (w/a)  ;

Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 i Arlington, TX 76011 Mr. J. N. Donohew, Project Manager (w/2)  :

Office of Nuclear Reactor Regulation i i

U.S. Nuclear Regulatory Commission Mail Stoo 13H3 Washington, D.C. 20555 Dr. E. F. Thompson (w/a) >

State Health Officer ~

State Board of Health P.O. Box 1700 Jackson, Mississippi 39205 b

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Attachm:nt 1 to GNRO 97/00000

, BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE NO. NPF 29 -

DOCKET NO. 50-416 t

IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and SYSTEM ENERGY RESOURCES, INC. i and l SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION and ENTERGY OPERATIONG, INC.

AFFlRMAIjQB ,

I, F. W. Titus, being duly sworn, state that I am Vice President, Engineering of Entorgy Operations, Inc.; that on behalf of Entergy Operations, Inc., System Energy hsources, Inc., and -

South Mississippi Electric Power AssociatioriI am authorized by Entergy Operations, Inc. to sign and file with th6.4uclear Regulatory Commission, this application for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed this application as Vice President, Engineering of Entergy Operatians, Inc.; and that the statements made and the matters set forth therein are true and correct to the best of my knWadge, information and belief

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"F. W. Titut STATE OF MISSISSIPPI-COUNTY OF HINDS SUBSCRIBED AND SWORN TO before me, a Notary Public,in and for the County and State above named, this - l1

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GGNS PCOL-97/003 i

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Grand Gulf Nucimr Station Attachment 2 to GNRO - 97/00087 Cycle 10, PCOL 97/003 Page 1 of 5 A. .AFFECTED TECilNICA L SPECIFICATIONS

1. The following Technical Specifications are affected by the proposed change:

21.1 Reactor Core Safety Limits 5 6.5 Core Operating Limits Report

2. The following Technied Specification Dases are affected by the proposed change.

Since Technical Specification 11ases are controlled under 10CFR50.59 Program, the markup of the !!ases Sections are provided for information only.

Il 2.1.1.2 h!CPR 113 2.2 hiinimum Critical Power Ratio (hiCPR)

11. DESCRIPTION OF Cil ANGES

1. IpshnicaLSyscificatigd 1.12: Change the Safety Limit h1CPR for Two Loop Operation and Single Loop Operation to 1.11 and L12, respectively and change the footnote referring to Cycle 9 operation for Cycle 10 operation

2. hqhoigLSprpi0patigal(d Change the footnote referring to Cycle 9 operation for Cycle 10 operation.

3. hch0!G ISP tfiOInlierLilMO Add a statement that the operating limits will be based on the calculated htCPR safety limits rather than the rounded values reported in Technical Specification 21.1.2 and deletion of an unnecessary reference.

C. BACKGROUND Grand Gulf Cycle 16 is the second cycle of operation with GElI reload fuel. The Cycle 10 core will contain 560 GElI bundles and 240 twice-burnt Siemens 9x9 5 bundles. A conventional corc design with a checke: board fresi fuel loading pattern is utilized.

The GGNS Cycle 10 h1CPR safety limits were developed with General Electric's cycle-spect hiCPR safety limit methodol.gy. This methodology has been pr:sented to the NRC Stafrand has been subnutted as Amendment 25 to GESTAR ll, The approved plant uncertainties reported in GETAll were credited in this evaluation although recent GE topicals have concluded that reductions in a number of these uncertainties are warranted

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, i Grand Gulf Nucle:r St tion Att:chment 2 to GNRO . 97/90087 j Cycle 10 PCOL.97/003 .-

Page 2 of 5 l GE's cycle specific methodtdogy includes objective wasures fcr evaiunting the flatness of the core and bundle powcr distsibutions. These measmes tre reported below for the GGNS Cycle 10 core and the core used to dewelop GBil generic MCPR safety limit Table 1 of Attachment 4 contains additional asults. ,

i Comparison of Generle Gell and Grand Gulf Cycle 10 Cores Description Generit Gell Grand Gulf C.vcle 10 Limiting Cycle Exposure Point Pile EOClK Core h1C,PR (for limiting rod pattern) 1.257__ l.2555

% uncontrolled bundles within 0.20 CPR 2#. 16.0 %  ;

hiCPR importance'Ia5 meter, hilP 1662 3.851 l R Factor importance Parame,tes, RIP 14.3% _ 27.6 %

Calculated Safety Limit hiCPR 1.07 1.11

.The Siemens 9x9 5 bundles were modeled with the approach applied in GGNS Cycle 9 and reported in PCOL 96/008, Rev.1 (Letter dated September 5,1996 from C. It liutchinson addressed to the Document Control Desk) New coellicients were developed for GE'a GEXLO2 correlation for the Siemens bundles and bundle R factors were developed in a manner constent with GE's methodology. A conservative CPR uncertainty was applied bar.ed on comparisons of tHs modified GEXL correlation to both Siemens' ANFB correlation (PCOL 96/008, 'Acv.1) and .

Siemens' critical power test dah (GNRO 96/00ll?, letter from J. J.11agan add'essed to the Document Control Desk, submitted October 22,1996) The GGNS Cycle 10 analysis determined that the Siemens handles contributed no rods subject to boiling transitio.und conicquently have no impact on the calculated hiCPR eafety limits.

D. PROPOSED TS CilANGES The proposed changes to the Technical Specifications are to change the h1CPR seley i limit values for two loop and single loop operation te those values calculate 41 by GE's -

methodology for GGNS Cycle 10, These marked up Tecimical Specificatiora 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 and to allow reference to the upeoming revision to i GESTAR which will include this cycle-speciOc analytical approach for the hiCPR safety limit. The SPC reports currently listed in the Technical Specifications will be unafrected

, since SPC fuel will remain in the Cycli 10 core.

L The Cycle 9 hiCPR 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 maintained since Amendment 25 to GESTAR has not yet been approved.

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Grand Gulf Nuclear St: tion Att chment 2 to GNRO 97/00087 Cycle 10 PCOL.97/003 Page 3 of 5 ,

i E. JUSTlFICATION i

The MCPR Safety Limit is developed to assure compliance with General Design '

Criterion 10 of 10CFR$0 Appendix A. The Bases to Technical Specification 2.1.1 states that "The h1CPR SL ensures sufficient conservatism in the operating h1CPR limit t that, in the event of an Anticipated Operational Occurrence (A00) from the limiting ,

condition of operation, at least 99.9% of the fuel rods in the core would be expected to  :

avoid boiling transition" The new hiCPR SL was developed with considerable conservatism in the methodology.

Attachment 4 of this PCOL documents additional information for the 1.11 Cycle specine SLh1CPR. The information is based on the GE provided input.

F. CONCLUSION  :

For two-loop operation, a Safety Limit h1CPR of 1.11 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 ADO. For single-loop operation, the limit is increased by 0.01 to 1.12. The hiCPR fuel cladding integrity safety limits for GGNS Cycle 10 two-loop and single +1oop operation were determined by applying GE's cycle-specific MCPR safety limit methodology to the GGNS Cycle 10 core design. his approach has been presented to the NRC StalT and contains considerable conservatism in the applied uncertainties. The SPC fuel was explicitly considered and found to not contribute to the Cycle 10 MCPR safety limit. The resulting values, therefore, represent bounding measures of the GGNS Cycle 10 MCPR safety limits.

G. SIGNIFICANT ll AZARDS CONSIDERATION Entergy Operations, Inc. proposes to change the current Grand Gulf Nuclear Station Technical Specifications. The specific change is to modify the Minimum Critical Power Ratio (h1CPk) safety limits reported in Technical Specification 2.1.1.2, and associated Bases changes. The proposed change is necessary in order to reucet the results of the GGNS Cycle 10 analysis.

The Commission has provided standards for determining whether no significant hazards conaiderations 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 accordance with the proposed amendment would not: (1) involve a signincant 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)inso e a signincant reduction in a margin of safety.

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l Orand Gulf Nuclear Station Attachment 2 to GNRO . 97/00087 Cycle 10 PCol 97/003 Page 4 of 5

' i 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 amendment against the three standards in 10 CFR 50.92(c) A description of the no sigr.ificant hazards consideration  ;

determination follows:  ;

l. The proposed change does not significantly increase the prohnhility or consequences of an accident previously evaluated.  ;

The hiinimum Critical Power Ratio (hiCPR) safety limit is dermed in the Bases 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 hiCPR safety limit is re-evaluated for each reload and, for GGNS Cycle 10, the analyses have concluded that a two loop hiCPR safety limit of 1.11 based on the _

application of GE's cycle specific h1CPR safety limit methodology is necessary to ensure that this acceptance criterion is satisfied. For single loop operation, a hiCPR safety limit of 1.12 based on GE's cycle-specific h1CPR safety limit methodology was determined to be necessary. Core h1CPR operating limits are developed to suppon the Technical Specification 3.2 requirements and ensure these safety limits are maintained in the event of the worst case transient. Since the hiCPR 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 hiinimum Critical Power Ratio (h1CPR) safety limit do not alrect the probability or consequences of an accident. -

GE's GESTAR il approved methodology will continue to be implemented and has no efTect on the probability or consequences of any accidents previously evaluated 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. The design of the Gell 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 releases will not exceed a small 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 difTerent kind of accident from any accident previously evaluated.

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Grand Gulf Neelear Station Attachment 2 to GNRO 97/00087 Cycle 10. PCOI 97/003 Page 5 of 5

, The GElI fuel to be used in Cycle 10 is of a design compatible with fuel present in the core and_ used in the previous cycle. Therefore, the Gell 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 introduce revised MCPR safety limits that have been proven to be acceptable for Cycle 10 operation. Compliance with the applicable criterion foi incipient boiling transition continues to be ensured. The proposed MCPR safety limits do not result in the creation of any ne.v precursors to an accident.

Therefore, the proposed changes do not create the possibility of a new cr different type of accident from any accident previously evaluated.

Ill. The proposed change does not involve a signlGcant reduction in a margin of safety.

The MCPR safety limits have been evaluated in accordance with GE's current cycle specific methodology to ensure that during normal operation and during AOOs, at least 99.9% of the fuel rods in the core are not expected to experience transition boiling. Unless othenvise approved, GGNS will implement only the NRC approved revisions to GE's GESTAR methodology. This GE methodology is similar to those SPC reports currently listed in TS 5.6.5 and it will be applied in

- a similar, conservative fashion. 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 will not exceed a small fraction (10 percent) of 10CFR100 limits On this basis, the implementation of this GE methodology does not involve a significant reduction in a margin of safety.