Text

ANP-3140(NP), Revision 0, Brown Ferry Units 1, 2, and 3 Improved K-factor Model for Ace/Atrium 10XM Critical Power Correlation
	ML13070A324
Person / Time
Site:	Browns Ferry
Issue date:	08/31/2012
From:	; AREVA NP
To:	; Office of Nuclear Reactor Regulation
References
	ANP-3140(NP), Rev 0
	Download: ML13070A324 (71)
	v • d • e

ATTACHMENT 28 Browns Ferry Nuclear Plant (BFN)

Units 1, 2, and 3 Technical Specifications (TS) Change 478 Addition of Analytical Methodologies to Technical Specification 5.6.5.b for Browns Ferry 1, 2, & 3, and Revision of Technical Specification 2.1.1.2 for Browns Ferry Unit 2, in Support of ATRIUM-10 XM Fuel Use at Browns Ferry Browns Ferry ACE Supplement (Non-Proprietary)

Attached is the non proprietary version of the Browns Ferry specific ACE supplemental report.

ANP-3140(NP)

Revision 0 Browns Ferry Units 1, 2, and 3 Improved K-factor Model for ACE/ATRIUM 1OXM Critical Power Correlation August 2012 A

AREVA NP Inc. AREVA

AREVA NP Inc.

ANP-3140(NP)

Revision 0 Browns Ferry Units 1, 2, and 3 Improved K-factor Model for ACE/ATRIUM 1OXM Critical Power Correlation

AREVA NP Inc.

ANP-3140(NP)

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Paqe i Nature of Changes Item Page Description and Justification

1. All This is the initial release.

AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page ii Contents 1.0 Introduction and Summary ............................................................................................ 1-1 2.0 Standard Review Plan Requirements ........................................................................... 2-1 3.0 Revised C orrelation ...................................................................................................... 3-1 3.1 Rod Peaking Function .................... r ....................................... 3-1 3.2 Applying Rod Peaking Function in the Critical Power Correlation ...................... 3-3 3.3 E

Method for Calculation Additive Constants ........................................................

3.3.4 Additive Constants for ACE/ATRIUM 1OXM Correlation ......

"] 3-3

....3-8 3.4 Additive Constant Uncertainty ......................................................................... 3-14 3.5 Critical Power Correlation Conservatisms ....................................................... 3-17 4.0 Transient Benchmarking ............................................................................................... 4-1 5.0 [ ] K-factor Method ....................................................................... 5-1 6.0 Implementation of Improved K-factor Methodology ............................ .................... 6-1 7 .0 Refe re nce s ................................................................................................................... 7-1 AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page iii Tables 3-1: Additive Constant Uncertainty for High Local Peaking ................................................ 3-16 4-1: XCOBRA-T Transient Dryout Results, [ ] .................................. 4-3 4-2: XCOBRA-T [ ] Transient Dryout Results [

.... 4 -5 Figures 1-1: Comparison of Calculated to Measured Critical Power ................................................. 1-3 3-1: Adjacent Rod Identification for K-factor Calculation ...................................................... 3-9 3-2: Rods Observed to Dryout in Testing ........................................................................... 3-10 3-3: Peaked Symmetric Rods Not Observed to Dryout in Testing ...................................... 3-11 3-4: ACE/ATRIUM 1OXM Additive Constants ..................................................................... 3-12 3-5: Additive Constant Comparison ................................................................................... 3-13 AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page iv Nomenclature Acronym Definition ACE AREVA Critical power Evaluator AOO Anticipated Operational Occurrence BT Boiling Transition BWR Boiling Water Reactor CPR Critical Power Ratio ECPR Experimental Critical Power Ratio; the ratio of calculated to the measured critical power LOCA Loss Of Coolant Accident MCPR Minimum Critical Power Ratio PLR Part Length Rod AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page 1-1 1.0 Introduction and Summary Reference 1 presents the approved ACE/ATRIUM 1OXM critical power correlation for ATRIUMTM

1OXM fuel. A concern with the calculation of the K-factor within the approved ACE correlation was identified. Since K-factor was integrated over the entire heated length of the assembly, it was possible for the local peaking factors in the upper lattices to contribute significantly to the K-factor used, even when dryout occurs much lower in the bundle.

Reference 2 presents a revision to the ACE critical power correlation for ATRIUM 1OXM fuel.

The Reference 2 correlation is very similar to the Reference 1 critical power correlation with a couple of exceptions. The K-factor methodology was modified in response to deficiencies found in the axial averaging process. In addition, the additive constants were revised as a result of the change to the K-factor model. Evaluations confirmed that the Reference 1 critical power correlation coefficients do not require revision as a result of these changes.

The purpose of this document is to present the ACE/ATRIUM 1OXM critical power correlation that will be used in licensing analyses for Browns Ferry Units 1, 2, and 3 until Reference 2 is generically approved and included in the Browns Ferry Plant Technical Specifications. The correlation presented in this document is exactly the same as that presented in Reference 2.

Reference 3 provides a description of the rod local peaking function (called K-factor). The improved K-factor method used in the Browns Ferry ACE/ATRIUM 1OXM critical power correlation is described in this document. This modified method supersedes the one described in Reference 3 and used in Reference 1. This document also describes the minor changes in the method for determining additive constants that became necessary due to the changes in the K-factor methodology.

The comparison between measured and predicted critical power data is shown in Figure 1-1.

The correlation experimental critical power ratio (ECPR) mean with the improved K-factor methodology and updated additive constants is [ ] and the ECPR standard deviation is

[ ]. The ECPR mean and standard deviation from Reference 1 were [ ] and

[ ] respectively.

ATRIUM is a trademark of AREVA NP Inc.

AREVA NP Inc.

Browns Ferry Units 1,2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page 1-2 The range of applicability of the critical power correlation is unchanged from Reference 1. The modified correlation is applicable to Browns Ferry steady-state design and analysis, core monitoring, MCPR safety limit, anticipated operational occurrences (AOO's), accidents, LOCA, and instability analysis for the ATRIUM 1OXM fuel design.

AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Pa(qe 1-3 Figure 1-1: Comparison of Calculated to Measured Critical Power AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page 2-1 2.0 Standard Review Plan Requirements There are no critical power correlation specific requirements in the standard review plan.

AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation PaQe 3-1 3.0 Revised Correlation All modern critical power correlations contain a function that accounts for rod peaking. This function is called K-factor in the ACE formulation of the correlation. The model equation for the

[

ACE correlation is given in Equation 3.1 of Reference 1 (including symbol definitions). The revision is in the [ 3 term:

](3.1)

The K-factor, [

]

This assumption was found to be inappropriate because (1) it allows downstream conditions above the location of dryout to non-physically influence the critical power, and (2) it provides equal weighting to all axial locations (low power regions as well as regions far from the location of dryout). Both of these problems were found to be capable of influencing the predicted results in a non-conservative manner.

3.1 Rod PeakingFunction The K-factor characterizes the rod peaking effect on the bundle critical power. The critical power varies inversely with K-factor. That is, as K-factor increases in value, the critical power decreases in value. [

AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Paqe 3-2 This description of the local rod peaking function is unchanged from the description in References 1 and 3.

AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Paae 3-3 3.2 Applying Rod Peaking Function in the CriticalPower Correlation

] The maximum of the averaged K-factors over all the rods was then chosen for use in the critical power correlation according to Equation 3.46 in Reference 3.

This averaging of the axial K-factor distribution for each rod was found to be inappropriate for the reasons discussed in Section 3.0 and is therefore excluded in the improved K-factor method.

I

] Thus this solution explicitly addresses both problems noted in Section 3.0.

In the improved method, [

3.3 Method for CalculationAdditive Constants The spacers and bundle geometry characteristics influence the critical power behavior of the individual rods within the fuel bundle. Therefore, a factor is needed to distinguish the critical power performance of each rod. These position dependent factors are termed additive constants. Additive constants can be considered as a flow/enthalpy redistribution characteristic for a given bundle and spacer design.

In critical power testing, [

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Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page 3-4 Inaccordance with the [ 3the CHF database was randomly divided into a defining data set and a validating data set.

Approximately [ ] was set aside-as the validating set of data. The remaining [ ] form the defining data set and were used to develop the critical power correlation. The additive constants for all the rod positions were determined from the defining data set. The calculation of additive constants uses the same partition of data as was used during the critical power correlation development. [

]

The defining and validating data sets used for correlation development in Reference 1 are unchanged. The additive constants are determined [

AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Paqe 3-5 AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page 3-6 AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page 3-7 AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page 3-8 3.3.4 Additive Constants for ACE/ATRIUM 1 OXM Correlation The revised ATRIUM 1OXM additive constants are shown in Figure 3-4. For comparison purposes, both the revised ATRIUM 1OXM additive constants and the ACE/ATRIUM 1OXM additive constants from Reference 1 are presented in Figure 3-5. The observed changes in additive constant are generally small and [

]

AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page 3-9 Figure 3-1: Adjacent Rod Identification for K-factor Calculation AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page 3-10 Figure 3-2: Rods Observed to Dryout in Testing AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page 3-11 Figure 3-3: Peaked Symmetric Rods Not Observed to Dryout in Testing AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Paqe 3-12 Figure 3-4: ACE/ATRIUM 1OXM Additive Constants AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page 3-13 Figure 3-5: Additive Constant Comparison AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Paqe 3-14 3.4 Additive Constant Uncertainty The overall uncertainty in additive constants is determined [

]. The following steps are applied:

AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page 3-15 The resulting overall additive constant uncertainty for the Browns Ferry ACE/ATRIUM 1OXM correlation is [ 1. The additive constant uncertainty from Reference 1 is [

An additional high peaking uncertainty is imposed in the MCPR safety limit methodology for those rods whose local peaking exceeds [

] Table 3-1 shows the results of these calculations.

AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Paae 3-16 Table 3-1: Additive Constant Uncertainty for High .Local Peaking AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page 3-17 3.5 CriticalPower CorrelationConservatisms With the improved K-factor model, the Browns Ferry ACE/ATRIUM 1OXM correlation has an average ECPR of [ ] with a standard deviation of [ ]. For the Reference 1 correlation, the average ECPR was [ ] with a standard deviation of [ ]. The correlation was used to assess each rod in each of the tests. The associated critical powers of each rod were then compared to the measured critical power and a count made of the number of rods which were predicted to be in boiling transition (BT) and this was compared to the number of rods actually observed to be in boiling transition in the experimental data. With the improved K-factor methodology and additive constants, this ratio of predicted to measured rods in boiling transition is [ ]. This compares with a value of [ ] in Reference 1.

AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page 4-1 4.0 Transient Benchmarking An industry accepted standard in BWR transient methodology is that steady-state dryout correlations are conservative for use in transient methodology. Transient dryout tests [

] were performed to reconfirm this for the ATRIUM 1OXM fuel design when using the ACE/ATRIUM 1OXM critical power correlation.

The limiting transient tests of interest are the simulated load rejection without bypass (LRNB) events that consist of power and pressure ramps and flow decay and the simulated loss of flow events that consist of flow decay and power decay. The power, pressure, and flow were all controlled by a function generator. The forcing functions were programmed to produce the transient rod surface heat flux typical of the various events.

A total of [ ] ATRIUM 1OXM LRNB and loss of flow transients were run which were either measured or predicted to have dryout. Of these [ ] transient critical power tests, [

] The initial conditions for these tests are given in Table 7-7 of Reference 1.

Evaluations of the transient critical power tests were repeated using the improved K-factor methodology. [

] The AREVA NP transient thermal hydraulic code XCOBRA-T (References 5 and 6), was used to predict the transient test results using the ACE/ATRIUM 1OXM critical power correlation. The test power forcing function provides the boundary condition of power, which is modeled in XCOBRA-T [

AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Paue 4-2 I

I The results [ ] are summarized in Table 4-1.

I The transient benchmark results with the modified correlation are consistent with those presented in Reference 1.

AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Paqe 4-3 Table 4-1: XCOBRA-T Transient Dryout Results, [ I AREVA NP Inc.

Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Paae 4-4 Table 4-1: XCOBRA-T Transient Dryout Results, [

(continued)

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Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Paae 4-5 Table 4-2: XCOBRA-T [ ] Transient Dryout Results

]

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Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Paqe 5-1 5.0 [ ] K-factor Method With the improved K-factor method, the critical power correlation is used to [

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Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page 6-1 6.0 Implementation of Improved K-factor Methodology The improved K-factor methodology has been implemented into MICROBURN-B2 (Reference 8), POWERPLEX*-XD Core Monitoring Software System (CMSS), SAFLIM3D (Reference 7), XCOBRA (Reference 11), XCOBRA-T (References 5 and 6), RELAX (Reference 9), and RAMONA5-FA (Reference 10). It will be used in Browns Ferry core design and analysis, core monitoring, MCPR safety limit methodology, AOO's, LOCA, and other codes and methods that use the critical power correlations.

The MCPR safety limit methodology performs a rod-by-rod evaluation to estimate the number of rods in BT associated with a particular safety limit. [

POWERPLEX is a trademark of AREVA NP Inc. registered in the United States and various other countries.

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Browns Ferry Units 1, 2, and 3 ANP-3140(NP)

Improved K-factor Model for Revision 0 ACE/ATRIUM 1OXM Critical Power Correlation Page 7-1 7.0 References

1. ANP-10298PA Revision 0, "ACE/ATRIUM 1OXM Critical Power Correlation," AREVA NP Inc., March 2010.

2. ANP-10298PA Revision 0, Supplement 1P Revision 0, "Improved K-Factor Model for ACE/ATRIUM 1OXM Critical Power Correlation," AREVA NP, Inc., December 2011.

3. ANP-1 0249PA Revision 1, "ACE/ATRIUM-1 0 Critical Power Correlation," AREVA NP Inc.,

September 2009.

4. C. Bennett and N. L. Franklin. "Statistical Analysis in Chemistry and the Chemical Industry," Marbern House, October 1987.

5. XN-NF-84-105(P)(A) Volume 1 and Volume 1 Supplements 1 and 2, "XCOBRA-T: A Computer Code for BWR Transient Thermal-Hydraulic Analysis," Exxon Nuclear Company, February 1987.

6. XN-NF-84-105(P)(A) Volume 1 Supplement 4, "XCOBRA-T: A Computer Code for BWR Transient Thermal-Hydraulic Core Analysis Void Fraction Model Comparison to Experimental Data," Advanced Nuclear Fuels Corporation, June 1988.

7. ANP-10307PA Revision 0, "AREVA MCPR Safety Limit Methodology for Boiling Water Reactors," AREVA NP Inc., June 2011.

8. EMF-2158(P)(A) Revision 0, "Siemens Power Corporation Methodology for Boiling Water Reactors: Evaluation and Validation of CASMO-4 / MICROBURN-B2," Siemens Power Corporation, October 1999.

9. EMF-2361(P)(A) Revision 0, "EXEM BWR-2000 ECCS Evaluation Model," Framatome ANP Richland, Inc., May 2001.

10. BAW-10255PA Revision 2, "Cycle-Specific DIVOM Methodology Using the RAMONA5-FA Code," AREVA NP Inc., May 2008.

11. XN-NF-80-19(P)(A) Volume 3 Revision 2, "Exxon Nuclear Methodology for Boiling Water Reactors, THERMEX: Thermal Limits Methodology Summary Description," Exxon Nuclear Company, Inc., January 1987.

12. [

]

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ATTACHMENT 29 Browns Ferry Nuclear Plant (BFN)

Units 1, 2, and 3 Technical Specifications (TS) Change 478 Addition of Analytical Methodologies to Technical Specification 5.6.5.b for Browns Ferry 1, 2, & 3, and Revision of Technical Specification 2.1.1.2 for Browns Ferry Unit 2, in Support of ATRIUM-10 XM Fuel Use at Browns Ferry AREVA NP Affidavits Attached are the AREVA NP affidavits supporting the request to withhold proprietary information from the public.

AFFIDAVIT STATE OF WASHINGTON )

) ss.

COUNTY OF BENTON )

1. My name is Alan B. Meginnis. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary. I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.

3. I am familiar with the AREVA NP information contained in the report ANP-3150P, Revision 0, "Mechanical Design Report for Browns Ferry ATRIUMTM1OXM Fuel Assemblies," dated October 2012 and referred to herein as "Document." Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP 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 AREVA NP 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 AREVA NP to determine whether information should be classified as proprietary:

(a) The information reveals details of AREVA NP's 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 AREVA NP.

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

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

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 AREVA NP's 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 AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA NP 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.

(,~'6d I7 SUBSCRIBED before me this / c day of ,2012.

Susan K. McCoy ,

NOTARY PUBLIC, STATE OF WASQGTON MY COMMISSION EXPIRES: 1/14/2016

AFFIDAVIT STATE OF WASHINGTON )

) ss.

COUNTY OF BENTON )

1. My name is Alan B. Meginnis. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA NP to determine, whether certain AREVA NP information is proprietary. I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.

3. I am familiar with the AREVA NP information contained in the report ANP-3082(P), Revision 1, "Browns Ferry Thermal-Hydraulic Design Report for ATRIUMTM 1OXM Fuel Assemblies," dated August 2012 and referred to herein as "Document."

Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP for the control and protection of proprietary and confidential information.