ML090630422

Response to Request for Additional Information on Proposed Change to Technical Specification Concerning the Safety Limit Minimum Critical Power Ratio

ML090630422
Person / Time
Site:	Pilgrim
Issue date:	02/19/2009
From:	Bronson K Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.09.006, TAC ME0241
Download: ML090630422 (6)

Text

iEn 1'"Enterg-- Entergy Nuclear Operations, Inc.

tg Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Kevin H. Bronson February 19, 2009 Kevin H. Bronson Site Vice President 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

SUBJECT:

Entergy Nuclear Operations, Inc Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 Proposed Change to Pilgrim's Technical Specification Concerning the Safety Limit Minimum Critical Power Ratio (TAC # ME0241')

REFERENCES:

1. Entergy Letter No. 2.08.057, "Proposed Change to Pilgrim's Technical Speciation Concerning the Safety Limit Minimum Critical Power Ratio", dated December 16, 2008

2. GNF Additional Information Regarding the Requested Changes to the Technical Specifications SLMCPR, Pilgrim Cycle 18, Proprietary Version, eDRF Section 000-0090-6001, dated October 16, 2008 LETTER NUMBER: 2.09.006

Dear Sir/Madam,

By Reference 1, Entergy proposed changes to Pilgrim's Technical Speciation section 2.1.2, concerning Safety Limit Minimum Critical Power ratio (SLMCPR). In support of this proposed change NRC Staff requested additional information by electronic mail. The attachment to this letter provides the NRC requests and Pilgrim's responses.

The additional information included in the Attachment does not invalidate the safety evaluation of the proposed changes, the Determination of No Significant Hazards Consideration, or the Environmental Assessment presented in the original application (Reference 1). Reference 2 was submitted as part of Reference 1.

There are no regulatory commitments included in this submittal.

Entergy Nuclear Operations, Inc. Letter No. 2.09.006 Pilgrim Nuclear Power Station Page 2 If you have questions regarding this subject, please feel free to contact Joseph Lynch at (508) 830-8304.

I declare under the penalty of perjury that the foregoing information is true and correct.

Executed on the day of eo4dtAE,2009 Sincerely, Kevin H. Bronson Site Vice President

Attachment:

Pilgrim Response to NRC Request for Additional Information (4 pages) cc: Mr. James S. Kim, Project Manager Mr. RobertWalker, Director Plant Licensing Branch I-1 Massachusetts Department of Public Health Division of Operator Reactor Licensing Schrafft Center Suite 1 M2A Office of Nuclear Reactor Regulation Radiation Control Program U.S. Nuclear Regulatory Commission 529 Main Street One White Flint North O-8C2 Charlestown, MA 02129 11555 Rockville Pike Rockville, MD 20852 Regional Administrator, Region 1 Mr. John Giarrusso, Jr.

U.S. Nuclear Regulator Commission Nuclear Preparedness Manager 475 Allendale Road Mass. Emergency Management Agency King of Prussia, PA 19406 400 Worcester Road Framingham, MA 01702 Senior Resident Inspector Pilgrim Nuclear Power Station

Pagqe 1/4 ATTACHMENT TO ENTERGY LETTER 2.09.006 PILGRIM RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)

RELATED TO CYCLE 18 SLMCPR TECHNICAL SPECIFICATION (TS) CHANGE FOR PILGRIM NUCLEAR POWER STATION (PILGRIM)

(TAC # ME0241)

NRC RAI 1:

Please describe the key differences that exist between the core designs for Cycles 17 and 18 which resulted the values of safety limit minimum critical power ratio (SLMCPR) for Cycle 18 to be higher than currently approved values in the Technical Specification (TS).

Pilgrim Response:

Cycle 18 uses 156 new GNF2 Fuel bundles. Cycle 17 has all GE14 fuel. Thus the proposed change relates to the fuel type change. Both cycles have similar design energy requirements and are control cell core designs. For each new fuel cycle, Safety Limit MCPR is calculated.

When the fuel type is changed, it is not unusual to have a more restrictive SLMCPR result, as shown in the summary of core design comparisons between Cycles 17 and 18, in Table 1 of Reference 2 attached to the Entergy Letter.No. 2.08.057. For Cycle 17, the MELLLA case was more limiting (SLMCPR calculated 1.061 rounded to 1.06), whereas for Cycle 18 the Rated Core Flow case is more limiting (SLMCPR 1.078 rounded to 1.08), as shown in Table 3 of the GE Report (Reference 2).

NRC RAI 2:

Provide the currently approved Power/Flow map for Pilgrim. If Pilgrim was authorized to operate in the Maximum Extended Load Line Limit Analysis (MELLLA) domain, please indicate for how long the plant has been operating with MELLLA.

Pilgrim Response:

Pilgrim Power-Flow Maps for Cycle 17 for Two Loop (Figure 2) and Single Loop (Figure 4)

Operations are enclosed. PNPS has had MELLLA beginning with Cycle 11, which began on 6/7/1995. The MELLLA Analysis report is NEDC-32306P dated March 1994. MELLLA was implemented using 10 CFR 50.59.

NRC RAI 3:

The SLMCPR value for Single Loop Operation (SLO) in Cycle 17 is 0.02 higher than that of Two Loop Operation (TLO); whereas, the SLMCPR value for SLO in Cycle 18 is 0.03 higher than that of TLO. Please explain why a higher margin in SLMCPR is necessary in order to operate with SLO in Cycle 18, as opposed to Cycle 17.

Pilgrim Response:

Single Loop Operation is analyzed separately from the Two Loop Operation and GNF Nuclear rounds off results. There is no particular attempt to provide a fixed adder on to TLO analysis for SLO as shown in Table 3 (Reference 2) for SLMCPR calculations for Cycle 18.

NRC RAI 4:

It is required that the latest approved amendment of NEDE-24011-P-A (GESTAR II) methodology be used to perform cycle-specific reload analysis. The staff has noted that in page 1 of Attachment 1 of the submittal, it is stated that Pilgrim reload analysis for Cycle 18 followed

I Page 2/4 NEDE-2401 1-P-A (GESTAR II), Amendment 22 process; while in page 7 of Attachment 4 of the submittal, Amendment 25 to NEDE-2401 1-P-A was mentioned. Please respond to the following concerns:

a) Clarify the above mentioned apparent inconsistency in the submittal.

b) Confirm whether the most recent amendment to NEDE-2401 1-P-A (GESTAR II) methodology was used to perform Pilgrim Cycle 18 reload analysis; and if not, then why not.

Pilgrim Response:

As described in the GNF Report, GESTAR II, Rev. 16 was used. This is the latest GESTAR II Revision.

GESTAR II, Revision 16 includes all GESTAR Amendments including 22 and 25. There is no inconsistency. The confusion is caused by use of Revision numbers vs. Amendment numbers.

GE publishes GESTAR Revisions that may include multiple Amendments. The Amendment 22 process defines the generic activities and criteria for the licensing of a new fuel product. Future amendments have not superseded Amendment 22 process, they deal with different issues. All fuel types subsequent to establishment of Amendment 22 process were licensed using that process. GNF2, the reload fuel for Cycle 18 was licensed by GNF using the Amendment 22 process. Reload Design uses methods described in the most current Revision 16 of GESTAR I1. Amendment 22 is referred to document that generic fuel licensing process was followed, not to indicate use of an older Revision of GESTAR I1. Reload Design uses methods described in the most current Revision 16 of GESTAR I1.

Enclosure:

Figure 2, Pilgrim Power/Flow Map, dated 05/01/07 Figure 4, Pilgrim Power/Flow Map- Single Loop Operation, dated 05/01/07

REPORT NO. PNPS-RPT-03-00001, REV. 3 PAGE -__* OF4 FIGURE 2 PILGRIM POWER / FLOW MAP Scram and Rod Block Data based on Nominal Trip Setpoints CORE FLOW, MLBIHR 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 125 120 f APRM SCRAM CLAMP AT 1t8%

110 APRM ROD BLOCK CLAMP AT 113% a 105J OPERATION 100 0 95

_* 90 85 3:

w W 75F T CORE FLOW ,

70 REGION 0

_1 65

_160 55 OPERATION n,50 PROUHIBTED w

=

I-X 45 UJ I--

Lw 40 LOWER BOUND 0 0, 35 NAT CIRC LINE 0.

30PROHIBITED 25 20 15 -4.I MINIMUM POWER 15 CmC EN PUMP SPEED (26%)

10 LINE 5

0= 1 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 CORE FLOW, MLBIHR Pilgrim C17 P-F Map.xls 05/01/2007

REPORT NO. PNPS-RPT-03-00001, REV. 3 PAGE A of 4 FIGURE 4 PILGRIM POWER I FLOW MAP - Single Loop Operation Scram and Rod Block Data based on Nominal Trip Setpoints CORE FLOW, MLBIHR 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 125 2535 120 rt 1-yrrrppIIp i--r I!! "II 1mr i -rr-j!

riiim t-i-r-l-i- 2434 115 2332 110 2231 105 2129 100 2028 0 95 1927 w

90 1825 85 1724 60 80 1622 75 uJ uJ 1521 o 70 1420 0 CL 65 1318 60 1217 55 1115 0~

0 50 1014 -J o1 45 913 40 811 0 35 710 30 608 25 507 20 406 15 304 10 203 5 101 0 0 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 CORE FLOW, MLBIHR Pilgrim C17 P-F Map.xls,Fig 4 - SLO Chart - NTSP 05/01/2007