View source for GNRO-2014/00091, Revision to Technical Specification 5.6.5.b to Add Reference NEDC-33075P-A, GE Hitachi Boiling Water Reactor Detect and Suppress Solution - Confirmation Density

{{Adams
| number = ML15006A238
| issue date = 01/06/2015
| title = Revision to Technical Specification 5.6.5.b to Add Reference NEDC-33075P-A, GE Hitachi Boiling Water Reactor Detect and Suppress Solution - Confirmation Density
| author name = Mulligan K
| author affiliation = Entergy Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000416
| license number = NPF-029
| contact person = 
| case reference number = GNRO-2014/00091, NEDC-33075P-A
| document type = Letter type:GNRO
| page count = 9
}}

=Text=
{{#Wiki_filter:Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150 Kevin Mulligan Site Vice President Tel. (601) 437-7500 GNRO-2014/00091 January 6, 2015 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

==SUBJECT:==
Revision to Technical Specification 5.6.5.b to add reference NEDC-33075P-A, GE Hitachi Boiling Water Reactor Detect and Suppress Solution - Confirmation Density, Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

==REFERENCE:==
Letter: Grand Gulf Nuclear Station Unit 1, Maximum Extended Load Line Limit Analysis Plus (MELLLA+) License Amendment Request dated September 25, 2013 (GNRO-2013/00012, NRC ADAMS Accession No. ML3269A140)

==Dear Sir or Madam:==

Entergy Operations Inc. (Entergy) proposes to revise the Grand Gulf Nuclear Station, Unit 1, (GGNS) Technical Specifications (TS) by adding to the reference listed in TS 5.6.5.b the following reference: NEDC-33075P-A, GE Hitachi Boiling Water Reactor Detect and Suppress Solution - Confirmation Density.
This reference will be added upon NRC approval of Reference.
This letter contains no new commitments. If you have any questions or require additional information, please contact James Nadeau at 601-437-2103.
th I declare under penalty of perjury that the foregoing is true and correct. Executed on the 6 day of January, 2015.
Sincerely,
---V-r---                                ~---
KJM/ram

GNRO-2014/00091 Page 2 of 2 Attachments:            1) Description and Assessment of the Proposed Change .
: 2) Technical Specification Page 5.0-21 Clean cc:
u.S. Nuclear Regulatory Commission AnN: Mr. A. Wang, NRR/DORL Mail Stop OWFN/8 G14 11555 Rockville Pike Rockville, MD 20852-2378 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150
: u. S. Nuclear Regulatory Commission AnN: Marc L. Dapas (w/2)
Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511

Attachment 1 to GNRO-2014/00091 Description and Assessment of the Proposed Change

GNRO-2014/00091 Page 1 of 4

== Description:==

This amendment is administrative in nature and is being submitted to add "NEDC-33075P-A, GE Hitachi Boiling Water Reactor Detect and Suppress Solution - Confirmation Density," to the references contained in TS 5.6.5.b. This amendment is being submitted in support of the NRC's approval of the MELLLA+ amendment requested by Entergy in Letter GNRO-2013/00012.
Entergy has reviewed the regulatory analysis and environmental considerations provided in Letter GNRO-2013/00012 and has concluded this request does not alter the conclusion reached in this letter. The regulatory analysis and environmental considerations provided in Letter GNRO-2013/00012 are provided below for your consideration in support of the adoption of this amendment.
, Regulatory Analysis:
Applicable Regulatory Requirements and Guidance 10 CFR 50.36 (c)(2)(ii) Criterion 2 requires TS Limiting Conditions for Operations (LCO) include process variables, design features, and operating restrictions that are initial conditions of design basis accident analysis. Compliance with TS ensures that system performance parameters are maintained within the values assumed in the safety analyses. The proposed OL and TS changes are supported by the safety analyses and continue to provide a level of protection comparable to the current TS. Applicable regulatory requirements and significant safety evaluations performed in support of the proposed changes are described in the M+SAR (Attachment 4). 5.2 No Significant Hazards Determination In accordance with the requirements of 10 CFR 50.90, Entergy Operations, Inc. (Entergy) requests an amendment to Operating License NPF-29, for the Grand Gulf Nuclear Station, Unit 1 (GGNS). This license amendment request proposes to revise the GGNS Operating License (OL) and Technical Specifications (TS) to allow operating in the expanded Maximum Extended Load Line Limit Analysis Plus (MELLLA+) domain.
Entergy has evaluated the proposed license amendment request in accordance with 10 CFR 50.91 against the criteria of 10 CFR 50:92 and has determined that operating GGNS in accordance with the proposed amendment presents no significant hazards. Entergy's evaluation against each of the criteria in 10 CFR 50.92 is provided below.
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
RESPONSE: No.
The probability (frequency of occurrence) of design basis accidents occurring is not affected by the MELLLA+ operating domain because GGNS continues to comply with the regulatory and design basis criteria established for plant equipment. Furthermore, a probabilistic risk assessment demonstrates that the calculated core damage frequencies do not significantly change due to the MELLLA+.

GNRO-2014/00091 Page 2 of4 There is no change in consequences of postulated accidents when operating in the MELLLA+
operating domain compared to the operating domain previously evaluated. The results of accident evaluations remain within the NRC-approved acceptance limits.
The spectrum of postulated transients has been investigated and shown to meet the plant's currently licensed regulatory criteria. In the area of fuel and core design, for example, the Safety Limit Minimum Critical Power Ratio (SLMCPR) is still met. Continued compliance with the SLMCPR is confirmed on a cycle specific basis consistent with the criteria accepted by the NRC.
Challenges to the reactor coolant pressure boundary were evaluated for the MELLLA+
operating domain conditions (pressure, temperature, flow, and radiation) and were found to meet their acceptance criteria for allowable stresses and overpressure margin.
Challenges to the containment were evaluated and the containment and its associated cooling systems continue to meet the current licensing basis. The calculated post LOCA suppression pool temperature remains acceptable.
Based on the above, operating in the MELLLA+ domain does not increase the probability or consequences of an accident previously evaluated.
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
RESPONSE: No.
Equipment that could be affected by theMELLLA+ operating domain has been evaluated. No new operating mode, safety-related equipment lineup, accident scenario, or equipment failure mode was identified. The full spectrum of accident considerations has been evaluated and no new or different kind of accident has been identified. The MELLLA+ operating domain uses developed technology, which is applied within the capabilities of existing plant safety-related equipment in accordance with the regulatory criteria (including NRC-approved codes, standards and methods). No new accident or event precursor has been identified. In addition, the changes have been assessed and determined not to introduce a different accident than that previously evaluated.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
RESPONSE: No.
The MELLLA+ operating domain affects only design and operating margins. Challenges to the fuel, reactor coolant pressure boundary, and. containment were evaluated for MELLLA+
operating domain conditions. Fuel integrity is maintained by meeting existing design and regulatory limits. The calculated loads on affected structures, systems, and components, including the reactor coolant pressure boundary, will remain within their design allowables for design basis event categories. No NRC acceptance criterion is exceeded.

GNRO-2014/00091 Page 30f4 Because the GGNS configuration and responses to transients and postulated accidents do not exceeq the NRC-approved acceptance limits, the proposed changes do not involve a significant reduction in a margin of safety.
Based on the above, Entergy has determined that operation of the facility in accordance with the proposed change does not involve a significant hazards consideration as defined in 10 CFR 50.92(6), in that it:
(1) Does not involve a significant increase in the probability or consequences of an accident previously evaluated; or       "
(2) Does not create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Does not involve a significant reduction in a margin of safety.
5.3 Environmental Consideration The radiological environmental effects of operating in the MELLLA+ domain are controlled to the same limits as the current analyses. None of the present limits for plant radiological releases to the environment are increased as a consequence of operating in the MELLLA+ domain. In addition, MELLLA+ has no effect on the non-radiological elements of concern, and the plant will continue to operate in an environmentally acceptable manner as documented by the Environmental Assessment for GGNS' current licensed operating domain. .Existing federal, state, and local regulatory permits presently in effect accommodate operating in the MELLLA+
domain without modification.
The evaluation of the effects of the MELLLA+ operating domain on normal radiological effluents is included in Section 8.0 of the M+SAR. This section indicates that the offsite doses from airborne releases of iodine and particulates could potentially increase by approximately 20%
due to the increased moisture carryover predicted during operation in the MELLLA+ domain.
With this increase, the normal effluents and doses continue to remain well below 10 CFR 20 limits and 10 CFR 50, Appendix I guidance. There is no change to the predicted doses from postulated accidents; 10 CFR 50.67 dose criteria continue to be met. In addition, the quantity of spent fuel does not increase as a result of operating in the MELLLA+ domain.
As addressed in Footnote 3 to Table B-1 of 10 CFR Part 51, Appendix B, for the purposes of assessing radiological impacts, the NRC has concluded that those impacts that do not exceed permissible levels in the NRC regulations are considered small. Therefore, since GGNS will continue to remain well below 10 CFR 20 limits and 10 CFR 50, Appendix I guidance, Entergy has concluded the environmental impacts of operating in the MELLLA+ domain would be small.
Based on the above discussion, Entergy has determined that the proposed amendment would not change a requirement with respect to installation or use of a facility or component located within the restricted area, as defined in 10 CFR 20, nor would it change an inspection or surveillance requirement. Hence, this proposed amendment:
(i) Does not involve a significant hazards consideration; or

GNRO-2014/00091 Page 4 of4 (ii) Does not authorize a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite; or (iii) Does not result in a significant increase in individual or cumulative occupational radiation exposure.
Accordingly, this proposed amendment meets the eligibility criterion for a categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), Entergy concludes no environmental impact statement or environmental assessment need be prepared in connection with this proposed amendment. 6

Attachment 2 to GNRO-2014/00091 Technical Specification Page 5.0-21 Clean

Reporting Requirements 5.6 5.6   Reporting Requirements 5.6.5        Core Operating Limits Report (COLR)      (continued)
: 21. NEDE-33383-P, "GEXL97 Correlation Applicable to ATRIUM-10 Fuel," Global Nuclear Fuel.
: 22. EMF-CC-074 (P) (A), Volume 4, "BWR Stability Analysis Assessment of STAIF with Input from MICROBURN-B2",
Siemens Power Corporation, Richland, WA.
: 23. EMF-2292(P) (A), "ATRIUM-10 Appendix K Spray Heat Transfer Co~fficients", Siemens Power Corporation, Richland, WA.
: 24. NEDE-24011 -P-A, General Electric Standard Application for Reactor Fuel (GESTAR-II).
25_   NEDO-31960-A, "BWR Owners' Group Long-Term Stability Solutions Licensing Methodology"
: 26. NEDO-32465-A, "Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology and Reload Applications"
: 27. NEDC-33075P-A, "GE Hitachi Boiling Water Reactor Detection and Suppress Solution - Confirmation Density."
: c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.
: d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.
GRAND GULF                               5.0-21         Amendment No. +/--+-3-, ~ 188,}}