CNL-22-076, to Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 in Support of Atrium 11 Fuel

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to Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 in Support of Atrium 11 Fuel
ML22209A238
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 07/28/2022
From: Jim Barstow
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML22209A237 List:
References
CNL-22-076, EPID L-2021-LLA-0132
Download: ML22209A238 (34)


Text

Proprietary Information - Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 1 1101 Market Street, Chattanooga, Tennessee 37402 CNL-22-076 July 28, 2022 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296

Subject:

Supplement 4 to Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for Browns Ferry Nuclear Plant Units 1, 2, and 3, in Support of ATRIUM 11 Fuel Use at Browns Ferry (TS-535)

(EPID L-2021-LLA-0132)

Reference:

TVA letter to NRC, CNL-21-053, Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564, Revision 2 for Browns Ferry Nuclear Plant Units 1, 2, and 3, in Support of ATRIUM 11 Fuel Use at Browns Ferry (TS-535), dated July 23, 2021 (ML21204A128 and ML21204A129)

In the referenced letter, Tennessee Valley Authority (TVA) submitted a request for a Technical Specification (TS) amendment for the Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3. The proposed license amendments, in part, revise TS 5.6.5.b, Core Operating Limits Report (COLR), to allow application of Advanced Framatome Methodologies for determining core operating limits in support of loading Framatome fuel type ATRIUMTM 1 11.

In Attachment 4 to the referenced letter, in part, TVA committed to submit the BFN Unit 2 Cycle 23 Fuel Rod Design Report (i.e., ANP-4001P) to the NRC, for information, within 15 days following TVA approval of the report. This report was approved by TVA on July 15, 2022, and is included in Enclosure 1. Enclosure 1 contains information considered proprietary to Framatome Inc. (Framatome). As owner of the proprietary information, Framatome has executed an affidavit contained in Enclosure 3 which identifies the information as proprietary, is customarily held in confidence, and should be withheld from public disclosure in accordance with Title10 of the Code of Federal Regulations (10 CFR) 2.390. Enclosure 2 provides the non-proprietary version of the Enclosure 1 report.

Correspondence with respect to the copyright or proprietary aspects of the item listed 1 ATRIUM 11 is a trademark or registered trademarks of Framatome, Inc., its affiliates and/or its subsidiaries in the United States of America and may be registered in other countries throughout the world. All rights reserved. Unauthorized use is strictly prohibited. Other names may be trademarks of their respective owners.

Proprietary Information - Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 1

Proprietary Information - Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 1 U.S. Nuclear Regulatory Commission CNL-22-076 Page 2 July 28, 2022 above or the supporting Framatome affidavit should reference the corresponding report and should be addressed to Alan Meginnis, Framatome, Manager, Product Licensing, 2101 Horn Rapids Road, Richland, WA 99354.

This letter does not change the no significant hazards consideration or the environmental considerations contained in the referenced letter. Additionally, in accordance with 10 CFR 50.91(b)(1), TVA is sending a copy of this letter and the non-proprietary enclosures to the Alabama Department of Public Health.

There are no new regulatory commitments associated with this submittal. Please address any questions regarding this submittal to Stuart L. Rymer, Senior Manager, Fleet Licensing, at slrymer@tva.gov.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 28th day of July 2022.

Respectfully, Digitally signed by Rearden, Pamela S Date: 2022.07.28 13:35:28 -04'00' James Barstow Vice President, Nuclear Regulatory Affairs & Support Services

Enclosures:

1. ANP-4001P, ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23, Revision 0, Framatome, June 2022 (Proprietary)
2. ANP-4001NP, ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23, Revision 0, Framatome, July 2022 (Non-Proprietary)
3. Framatome Affidavit for Enclosure 1 cc: (Enclosures):

NRC Regional Administrator - Region II NRC Project Manager - Browns Ferry Nuclear Plant NRC Senior Resident Inspector - Browns Ferry Nuclear Plant State Health Officer, Alabama Department of Public Health (w/o Enclosure 1)

Proprietary Information - Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 1

Proprietary Information - Withhold Under 10 CFR § 2.390 Enclosure 1 ANP-4001P, ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23, Revision 0, Framatome, June 2022 (Proprietary)

CNL-22-076 Proprietary Information - Withhold Under 10 CFR § 2.390

Enclosure 2 ANP-4001NP, ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23, Revision 0, Framatome, July 2022 (Non-Proprietary)

CNL-22-076

Controlled Document ATRIUM 11 Fuel Rod Thermal- ANP-4001NP Revision 0 Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report July 2022 (c) 2022 Framatome Inc.

0414-12-F04 (Rev. 004, 04/27/2020)

Controlled Document ANP-4001NP Revision 0 Copyright © 2022 Framatome Inc.

All Rights Reserved FUELGUARD and ATRIUM is a trademark or registered trademark of Framatome or its affiliates, in the USA or other countries.

0414-12-F04 (Rev. 004, 04/27/2020)

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page i Nature of Changes Section(s)

Item or Page(s) Description and Justification 1 All Initial Issue

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page ii Contents Page

1.0 INTRODUCTION

............................................................................................... 1-1 2.0

SUMMARY

AND CONCLUSIONS .................................................................... 2-1 3.0 FUEL ROD DESIGN EVALUATION .................................................................. 3-1 3.1 Fuel Rod Design ..................................................................................... 3-1 3.2 RODEX4 and Statistical Methodology Summary .................................... 3-2 3.3 Summary of Fuel Rod Design Evaluation ............................................... 3-4 3.3.1 Internal Hydriding ......................................................................... 3-6 3.3.2 Cladding Collapse ........................................................................ 3-6 3.3.3 Overheating of Fuel Pellets.......................................................... 3-6 3.3.4 Stress and Strain Limits ............................................................... 3-7 3.3.5 Fuel Densification and Swelling ................................................... 3-8 3.3.6 Fatigue ......................................................................................... 3-8 3.3.7 Oxidation, Hydriding, and Crud Buildup ....................................... 3-9 3.3.8 Rod Internal Pressure ................................................................ 3-10 3.3.9 Plenum Spring Design (Fuel Assembly Handling)...................... 3-10

4.0 REFERENCES

.................................................................................................. 4-1

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page iii List of Tables Table 2-1 Summary of Fuel Rod Design Evaluation Results (MELLLA+) ................... 2-2 Table 3-1 Key Fuel Rod Design Parameters, ATRIUM 11 for BFE2-23 .................... 3-11 Table 3-2 RODEX4 Fuel Rod Results Equilibrium CycleMELLLA+ ....................... 3-13 Table 3-3 RODEX4 Fuel Rod Results for ATRIUM 11 BFE2-23 Cycle MELLLA+................................................................................................. 3-14 Table 3-4 Cladding and Cladding-End Cap Steady-State Stresses ........................... 3-15 List of Figures Figure 2-1 LHGR Limit (Normal Operation).................................................................. 2-3

Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page iv Nomenclature Acronym Definition 3GFG 3rd generation FUELGUARD AOO anticipated operational occurrences ASME American Society of Mechanical Engineers B&PV Boiler and Pressure Vessel BOL beginning of life BWR boiling water reactor CRWE control rod withdrawal error CUF cumulative usage factor EOL end of life FDL fuel design limit ID inside diameter LAR License Amendment Request LHGR linear heat generation rate LTP lower tie plate MWd/kgU megawatt days per kilogram of initial uranium MELLLA+ maximum extended load line limit analysis plus NRC Nuclear Regulatory Commission, U. S.

OD outside diameter PCI pellet-to-cladding-interaction PLFR part length fuel rod ppm parts per million SRA stress relieved annealed S-N stress amplitude versus number of cycles UTL upper tolerance limit

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 1-1

1.0 INTRODUCTION

Results of the fuel rod thermal-mechanical analyses are presented to demonstrate that the applicable design criteria are satisfied. The analyses are for the Framatome Inc. ATRIUM 11 fuel that will be inserted for operation in Browns Ferry Unit 2 Cycle 23 as reload batch BFE2-23.

These analyses assume the use of chromia additive in the enriched and natural urania portions of the fuel and assume operation in the Maximum Extended Load Line Limit Plus (MELLLA+)

operation domain. Both the design criteria and the analysis methodology have been approved by the U. S. NRC (NRC).

The analysis results are evaluated according to the generic fuel rod thermal and mechanical design criteria contained in ANF-89-98(P)(A) Revision 1 and Supplement 1 (Reference 1) along with design criteria provided in the RODEX4 fuel rod thermal-mechanical topical report (Reference 2)*. Approved methodology for the inclusion of chromia additive in the fuel pellets is also used (Reference 3).

The RODEX4 fuel rod thermal-mechanical analysis code is used to analyze the fuel rod for fuel centerline temperature, cladding strain, rod internal pressure, cladding collapse, cladding fatigue and external oxidation. The code and application methodology are described in the RODEX4 topical report (Reference 2). The cladding steady-state stress and plenum spring design methodology are summarized in Reference 1.

The following sections describe the fuel rod design, design criteria and methodology with reference to the source topical reports. Results from the analyses are summarized for comparison to the design criteria.

  • (N.B., the cladding external oxidation limit from that topical report of [ ] was reduced to

[ ] when the RODEX4 methodology was approved for application to the Browns Ferry units (Reference 4)).

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 2-1 2.0

SUMMARY

AND CONCLUSIONS Key results are compared against each design criterion in:

- Table 2-1 for MELLLA+ operating domain Results are presented for the limiting cases. Additional RODEX4 results are given in Section 3.0.

The analyses support a maximum fuel rod discharge exposure of 62 MWd/kgU.

Fuel rod criteria applicable to the design are summarized in Section 3.0. Analyses show the criteria are satisfied when the fuel is operated at or below the LHGR (linear heat generation rate) limit (Fuel Design Limit - FDL) presented in Figure 2-1.

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 2-2 Table 2-1 Summary of Fuel Rod Design Evaluation Results (MELLLA+)

Criteria Description Criteria Result, Margin or Comment Section*

3.2 Fuel Rod Criteria 3.2.1 Internal hydriding [

]

(3.1.1) Cladding collapse [ ]

(3.1.2) Overheating of fuel No fuel melting [ ]

pellets margin to fuel melt > 0, °C 3.2.5 Stress and strain limits (3.1.1) Pellet-cladding [ ]

(3.1.2) interaction 3.2.5.2 Cladding steady-state [

stresses

]

3.3 Fuel System Criteria (3.1.1) Fatigue [ ]

(3.1.1) Oxidation, hydriding, [ ]

and crud buildup (3.1.1) Rod internal pressure [ ]

(3.1.2) 3.3.9 Fuel rod plenum spring Plenum spring to [

(fuel handling)

]

  • Numbers in the column refer to paragraph sections in the generic design criteria document, ANF 98(P)(A) Revision 1 and Supplement 1 (Reference 1). A number in parentheses is the paragraph section in the RODEX4 fuel rod topical report (Reference 2).

Margin is defined as (limit - result).

The cladding external oxidation limit is restricted to [ ] by Reference 4.

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 2-3

[

]

Figure 2-1 LHGR Limit (Normal Operation)

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 3-1 3.0 FUEL ROD DESIGN EVALUATION Summaries of the design criteria and methodology are provided in this section along with analysis results in comparison to criteria. Both the fuel rod criteria and fuel system criteria as directly related to the fuel rod analyses are covered.

The fuel rod analyses cover normal operating conditions and AOOs (anticipated operational occurrences). The fuel centerline temperature analysis (overheating of fuel) and cladding strain analysis take into account slow transients at rated operating conditions.

Other fuel rod-related topics on overheating of cladding, cladding rupture, fuel rod mechanical fracturing, rod bow, axial irradiation growth, cladding embrittlement, violent expulsion of fuel and fuel ballooning are evaluated as part of the respective fuel assembly structural analysis, thermal hydraulic analyses, or LOCA analyses and are reported elsewhere. The evaluation of fast transients and transients at off-rated conditions also are reported separately from this report.

3.1 Fuel Rod Design The ATRIUM 11 fuel rod is conventional in design configuration and very similar to past designs such as the ATRIUM 10XM, ATRIUM-10 and ATRIUM-9 fuel rods.

The fuel rods are made with Zircaloy-2 cladding [

] plenum spring on the upper end of the fuel column assists in maintaining a compact fuel column during shipment and initial reactor operation.

There are two Part-length Fuel Rod (PLFR) designs incorporated in the fuel assembly. The longer is [ ] long, while the shorter is [ ] long. [

].

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 3-2

[

].

As on previous ATRIUM fuel designs that incorporated the 3rd generation FUELGUARD (3GFG)

Lower Tie Plate (LTP), the PLFRs have a [

].

Table 3-1 lists the main parameters for the fuel rod and components.

3.2 RODEX4 and Statistical Methodology Summary RODEX4 evaluates the thermal-mechanical response of the fuel rod surrounded by coolant.

The fuel rod model considers the fuel column, gap region, cladding, gas plena and the fill gas and released fission gases. The fuel rod is divided into axial and radial regions with conditions computed for each region. The operational conditions are controlled by the [

].

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 3-3 The heat conduction in the fuel and clad is [

].

Mechanical processes include [

].

As part of the methodology, fuel rod power histories are generated [

].

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 3-4 Since RODEX4 is a best-estimate code, uncertainties are taken into account by a [

]. Uncertainties taken into account in the analysis are summarized as:

x Power measurement and operational uncertainties - [

].

x Manufacturing uncertainties - [

].

x Model uncertainties - [

].

[

].

3.3 Summary of Fuel Rod Design Evaluation Results from the analyses are listed in Table 3-2 and Table 3-3. Summaries of the methods and codes used in the evaluation are provided in the following paragraphs. The design criteria are also listed along with references to the sections of the design criteria topical reports (References 1 and 2).

The fuel rod thermal and mechanical design criteria are summarized as follows.

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 3-5 x Internal Hydriding. The fabrication limit [

] to preclude cladding failure caused by internal sources of hydrogen (Section 3.2.1 of Reference 1).

x Cladding Collapse. Clad creep collapse shall be prevented. [

] (Section 3.1.1 of Reference 2).

x Overheating of Fuel Pellets. The fuel pellet centerline temperature during anticipated transients shall remain below the melting temperature (Section 3.1.2 of Reference 2).

x Stress and Strain Limits. [

] during normal operation and during anticipated transients (Sections 3.1.1 and 3.1.2 of Reference 2).

Fuel rod cladding steady-state stresses are restricted to satisfy limits derived from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV)

Code (Section 3.2.5.2 of Reference 1).

x Cladding Fatigue. The fatigue cumulative usage factor for clad stresses during normal operation and design cyclic maneuvers shall be below [ ] (Section 3.1.1 of Reference 2).

x Cladding Oxidation, Hydriding and Crud Buildup. Section 3.1.1 of Reference 2 limits the maximum cladding oxidation to less than [ ] to prevent clad corrosion failure. The oxidation limit is further reduced to [

] (Reference 4).

x Rod Internal Pressure. The rod internal pressure is limited [

] to ensure that significant outward clad creep does not occur and unfavorable hydride reorientation on cooldown does not occur (Section 3.1.1 of Reference 2).

x Plenum Spring Design (Fuel Handling). The rod plenum spring must maintain a force against the fuel column stack [ ] (Section 3.3.9 of Reference 1).

Cladding collapse, overheating of fuel, cladding transient strain, cladding cyclic fatigue, cladding oxidation, and rod pressure are evaluated [ ]. Cladding stress and the plenum spring are evaluated [ ].

Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 3-6 3.3.1 Internal Hydriding The absorption of hydrogen by the cladding can result in cladding failure due to reduced ductility and formation of hydride platelets. Careful moisture control during fuel fabrication reduces the potential for hydrogen absorption on the inside of the cladding. The fabrication limit [

] is verified by quality control inspection during fuel manufacturing.

3.3.2 Cladding Collapse Creep collapse of the cladding and the subsequent potential for fuel failure is avoided in the design by limiting the gap formation due to fuel densification subsequent to pellet-clad contact.

The size of the axial gaps which may form due to densification following first pellet-clad contact shall be less than [ ].

The evaluation is performed using the RODEX4 code and methodology. RODEX4 takes into account the [

].

Table 3-2 lists the results for an equilibrium cycle operating in the MELLLA+ operating domain.

Table 3-3 lists the results for the ATRIUM 11 BFE2-23 cycle operating in the MELLLA+

operating domain.

3.3.3 Overheating of Fuel Pellets Fuel failure from the overheating of the fuel pellets is not allowed. The centerline temperature of the fuel pellets must remain below melting during normal operation and AOOs. The melting point of the fuel includes adjustments for [ ]. Framatome establishes an LHGR limit to protect against fuel centerline melting during steady-state operation and during AOOs.

Fuel centerline temperature is evaluated using the RODEX4 code and methodology for both normal operating conditions and AOOs.

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 3-7 Table 3-2 lists the results for an equilibrium cycle operating in the MELLLA+ operating domain.

Table 3-3 lists the results for the ATRIUM 11 BFE2-23 cycle operating in the MELLLA+

operating domain.

3.3.4 Stress and Strain Limits 3.3.4.1 Pellet/Cladding Interaction Cladding strain caused by transient-induced deformations of the cladding is calculated using the RODEX4 code and methodology. [

]. The strain limit is 1%.

Table 3-2 lists the results for an equilibrium cycle operating in the MELLLA+ operating domain.

Table 3-3 lists the results for the ATRIUM 11 BFE2-23 cycle operating in the MELLLA+

operating domain.

3.3.4.2 Cladding Stress Cladding stresses are calculated using solid mechanics elasticity solutions and finite element methods. The stresses are conservatively calculated for the individual loadings and are categorized as follows:

Category Membrane Bending Primary [

]

Secondary [

]

Stresses are calculated at the cladding outer and inner diameter in the three principal directions for both beginning of life (BOL) and end of life (EOL) conditions. At EOL, the stresses due to mechanical bow and contact stress are decreased due to irradiation relaxation. The separate

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 3-8 stress components are then combined, and the stress intensities for each category are compared to their respective limits.

The cladding-to-end cap weld stresses are evaluated for loadings from differential pressure, differential thermal expansion, rod weight, and plenum spring force.

The design limits are derived from the ASME (American Society of Mechanical Engineers)

Boiler and Pressure Vessel (B&PV) Code Section III (Reference 5) and the minimum specified material properties.

Table 3-4 lists the results in comparison to the limits for Beginning-of-Life (BOL) Hot conditions and End-of-Life (EOL) at both Hot and Cold conditions.

3.3.5 Fuel Densification and Swelling Fuel densification and swelling are limited by the design criteria for fuel temperature, cladding strain, cladding collapse, and rod internal pressure criteria. Although there are no explicit criteria for fuel densification and swelling, the effect of these phenomena are included in the RODEX4 code and methodology.

3.3.6 Fatigue Fuel rod cladding fatigue is calculated using the RODEX4 code and methodology. [

]. The CUF (cumulative usage factor) is summed for each of the axial regions of the fuel rod using Miners rule. The axial region with the highest CUF is used in the subsequent [

]. The maximum CUF for the cladding must remain below [ ] to satisfy the design criterion.

Table 3-2 lists the results for an equilibrium cycle operating in the MELLLA+ operating domain.

Table 3-3 lists the results for the ATRIUM 11 BFE2-23 cycle operating in the MELLLA+

operating domain.

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 3-9 3.3.7 Oxidation, Hydriding, and Crud Buildup Cladding external oxidation is calculated using the RODEX4 code and methodology. The corrosion model includes an enhancement factor that is derived from poolside measurement data to obtain a fit of the expected oxide thickness. An uncertainty value for the model enhancement factor also is determined from the data. The model uncertainty is included as part of the [ ].

[

].

In the event abnormal crud is observed at a plant, a specific analysis is required to address the higher crud level. An abnormal level of crud is defined by a formation that increases the calculated fuel average temperature by 25°C above the design basis calculation. The formation of crud is not calculated within RODEX4. Instead, an upper bound of expected crud based on plant observations is input by the use of the crud heat transfer coefficient. The corrosion model also takes into consideration the effect of the higher thermal resistance from the crud on the corrosion rate. A higher corrosion rate is therefore included as part of the abnormal crud evaluation. A similar specific analysis is required if an abnormal corrosion layer is observed instead of crud.

In the case of the Browns Ferry units, no additional crud is taken into account in the calculations because an abnormal crud or corrosion layer (beyond the design basis) has not been observed at the Browns Ferry units.

[

].

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 3-10 Currently, [

].

The oxide limit is evaluated such that greater than [

].

Table 3-2 lists the results for an equilibrium cycle operating in the MELLLA+ operating domain.

Table 3-3 lists the results for the ATRIUM 11 BFE2-23 cycle operating in the MELLLA+

operating domain.

3.3.8 Rod Internal Pressure Fuel rod internal pressure is calculated using the RODEX4 code and methodology. The maximum rod pressure is calculated under steady-state conditions and also takes into account slow transients. Rod internal pressure is limited to [

]. The expected upper bound of rod pressure [

] is calculated for comparison to the limit.

Table 3-2 lists the results for an equilibrium cycle operating in the MELLLA+ operating domain.

Table 3-3 lists the results for the ATRIUM 11 BFE2-23 cycle operating in the MELLLA+

operating domain.

3.3.9 Plenum Spring Design (Fuel Assembly Handling)

The plenum spring must maintain a force against the fuel column to prevent [

]. This is accomplished by designing and verifying the spring force in relation to the fuel column weight. The plenum spring is designed such that the [

].

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 3-11 Table 3-1 Key Fuel Rod Design Parameters, ATRIUM 11 for BFE2-23

[

]

Active fuel length, inch Full length rod 150.00

  • The theoretical density of enriched and naturally enriched UO2-Cr pellets is 10.94 g/cm3 while that for UO2-Gd2O3 pellets is 10.96 g/cm3.

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 3-12 Table 3-1 Key Fuel Rod Design Parameters, ATRIUM 11 for BFE2-23 (contd)

[

]

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 3-13 Table 3-2 RODEX4 Fuel Rod Results Equilibrium CycleMELLLA+*

[

]

  • Note that the results are provided up to fuel assembly discharge.

Margin is defined as (limit - result).

Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 3-14 Table 3-3 RODEX4 Fuel Rod Results for ATRIUM 11 BFE2-23 Cycle MELLLA+*

[

]

  • Note that the results are provided up to fuel assembly discharge.

Margin is defined as (limit - result).

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 3-15 Table 3-4 Cladding and Cladding-End Cap Steady-State Stresses Result Description, Stress Category Criteria BOL BOL EOL Cold Hot Hot Cladding stress Pm (primary membrane stress) [ ]

Pm + Pb (primary membrane + [ ]

bending)

P + Q (primary + secondary) [ ]

Cladding-End Cap stress Pm + Pb [ ]

Controlled Document Framatome Inc. ANP-4001NP Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23 Licensing Report Page 4-1

4.0 REFERENCES

1. ANF-89-98(P)(A) Revision 1 and Supplement 1, Generic Mechanical Design Criteria for BWR Fuel Designs, Advanced Nuclear Fuels Corporation, May 1995.
2. BAW-10247PA Revision 0, Realistic Thermal-Mechanical Fuel Rod Methodology for Boiling Water Reactors, AREVA NP Inc., February 2008.
3. ANP-10340P-A Revision 0. Incorporation of Chromia-Doped Fuel Properties in AREVA Approved Methods, Framatome Inc., May 2018.
4. Letter from Farideh E. Saba (NRC) to Joseph W. Shea (TVA), Browns Ferry Nuclear Plants, Units 1, 2, and 3 - Issuance of Amendments Regarding Technical Specifications (TS) Changes TS-478 Addition of Analytical Methodologies to TS 5.6.5 and Revision of TS 2.1.1.2 for Unit 2 (TAC NOS. MF0878 and MF0879), ML14108A334, July 31, 2014.
5. ASME Boiler and Pressure Vessel Code,Section III, Rules for Construction of Nuclear Power Plant Components, 1977.
6. ODonnell, W.J., and B. F. Langer, Fatigue Design Basis for Zircaloy Components, Nuclear Science and Engineering, Vol. 20, 1964.

Enclosure 3 Framatome Affidavit for Enclosure 1 CNL-22-076

AFFIDAVIT

1. My name is Alan B. Meginnis. I am Manager, Product Licensing, for Framatome Inc. and as such I am authorized to execute this Affidavit.
2. I am familiar with the criteria applied by Framatome to determine whether certain Framatome information is proprietary. I am familiar with the policies established by Framatome to ensure the proper application of these criteria.
3. I am familiar with the Framatome information contained in the report ANP-4001P, Revision 0 ATRIUM 11 Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Unit 2 Cycle 23, dated June 2022 and referred to herein as Document. Information contained in this Document has been classified by Framatome as proprietary in accordance with the policies established by Framatome for the control and protection of proprietary and confidential information.
4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by Framatome and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) Trade secrets and commercial or financial information.
6. The following criteria are customarily applied by Framatome to determine whether information should be classified as proprietary:

(a) The information reveals details of Framatomes research and development plans and programs or their results.

(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for Framatome.

(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Framatome in product optimization or marketability.

(e) The information is vital to a competitive advantage held by Framatome, would be helpful to competitors to Framatome, and would likely cause substantial harm to the competitive position of Framatome.

The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above.

7. In accordance with Framatomes policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside Framatome only as required and under suitable agreement providing for nondisclosure and limited use of the information.
8. Framatome policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

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

Executed on: July 13, 2022 MEGINNIS Alan Digitally signed by MEGINNIS Alan Date: 2022.07.13 15:42:41 -07'00' Alan B. Meginnis