L-MT-14-042, Areva Atrium 10XM Fuel Transition - Errata Re License Amendment Request

Areva Atrium 10XM Fuel Transition - Errata Re License Amendment Request

ML14132A197
Person / Time
Site:	Monticello
Issue date:	05/09/2014
From:	Fili K Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML14132A191	List: L-MT-14-042, Areva Atrium 10XM Fuel Transition - Errata Re License Amendment Request
References
L-MT-14-042, TAC MF2479
Download: ML14132A197 (14)

Text

ENCLOSURE 2 CONTAINS PROPRIETARY INFORMATION WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390 Monticello Nuclear Generating Plant X~ceI Energy 2807 W County Rd 75 Monticello, MN 55362 May 9, 2014 L-MT-14-042 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket 50-263 Renewed License No. DPR-22 AREVA ATRIUM IOXM Fuel Transition - Errata Regqarding License Amendment Request (TAC MF2479)

References:

1) Letter from M A Schimmel (NSPM), to Document Control Desk (NRC),

"License Amendment Request for Transition to AREVA ATRIUM 1OXM Fuel and AREVA Safety Analysis Methodology," L-MT-1 3-055, dated July 15, 2013. (ADAMS Accession No. ML13200A185)

In Reference 1, Northern States Power Company, a Minnesota corporation (NSPM),

doing business as Xcel Energy, requested approval of an amendment to the Monticello Nuclear Generating Plant (MNGP) Renewed Operating License (OL) and Technical Specifications (TS). The proposed change would allow operation using AREVA ATRIUM 1OXM fuel.

The purpose of this letter is to identify errata discovered in four different enclosures to Reference 1. These errata were self-discovered as AREVA engineers revise and re-validate the safety analyses for the Extended Flow Window (EFW) License Amendment Request (LAR), which NSPM plans to submit in July, 2014. Each of these errata will be discussed below. However, in summary, none of them affect the conclusions of the LAR.

1. LAR Enclosures 6/7: ANP-3224P/NP, Applicability of AREVA NP Methods to Monticello, Revision 2 Erratum: ANP-3224 Section A.4 correctly states the design criterion to ensure that sufficient coolant flow is provided in the bypass region. However, the cited reference (listed as Reference 25) is incorrect. Thus, Reference 25 in the subject enclosures is revised to indicate the proper reference, which is ANF-89-98(P)(A) Revision 1 and

Document Control Desk Page 2 Supplement 1, Generic Mechanical Design Criteriafor BWR Fuel Designs, Advanced Nuclear Fuels Corporation, May 1995. The correct reference is an approved topical report described in the LAR (Section 2-7 of Enclosures 6/7).

Effect: This is an editorial error with no bearing on the technical accuracy of the subject report. Corrections are annotated in Enclosure 1.

2. LAR Enclosure 8: ANP-3119P, Design Report for Monticello ATRIUM 10XM Fuel Assemblies, Revision 0 Erratum: Recent fuel channel gusset strength testing by AREVA resulted in a gusset load rating that was lower than what had been reported in ATRIUM 10XM and ATRIUM-10 mechanical design reports (ANP-3119P/NP). In addition, the ATRIUM-10 mechanical design report erroneously referenced a fuel channel gusset strength calculation applicable to the ATRIUM 9 design. (The calculation determines a vertical seismic load on the fuel channel gusset and compares that to the load rating to demonstrate that a positive margin is maintained.) A calculation applicable to the ATRIUM-1 0 fuel design was prepared in 2001, but was not referenced in this ATRIUM-10 mechanical design report.

Effect: A new calculation was performed for the ATRIUM 1OXM and results demonstrated that the calculated vertical seismic load was below the fuel channel gusset load rating established from the recent gusset testing. The revised values of "allowable load rating" and "estimated bounding load" are provided in Enclosure 2 (see annotations to Table 3-2 of the subject report). Results continue to show adequate margin between the allowable value and the estimated load.

3. LAR Enclosures 16/17: ANP-3213P/NP, Monticello Fuel Transition Cycle 28 Reload Licensing Analysis (EPU/MELLLA), Revision 1 Erratum: Section 4.3 of the subject reports provide the limits for decay ratios to be used in the AREVA STAIF Code. The value of these limits is accurately presented in the reports; however, the equality symbols are incorrect. The NRC Safety Evaluation Report requires these decay ratios to be "less than" the corresponding acceptable value. The reports presented them as "less than or equal to" symbols.

Effect: In all cases, the underlying calculation was determined to contain sufficient margin to support the limit expressed with a different equality symbol. The revised symbology is presented as a markup in Enclosure 1.

4. LAR Enclosures 18/19: 3211 P/NP, Monticello LOCA Break Spectrum Analysis for ATRIUM 1OXM Fuel (EPU/MELLLA), Revision 1 Erratum: In Table 6.1 of the subject reports, the value of Maximum Planar Average Metal Water Reaction (MWR) is reported as 1.12%. This value was provided in the report after the actual calculated value of 1.161 was transferred incorrectly and

Document Control Desk Page 3 rounded to a value of 1.12%. The correct value is the calculated value of 1.161%

rounded up to 1.17%.

Effect: AREVA has confirmed that the base calculations were accurately performed.

The maximum planar average MWR itself is not related to a technical requirement, but is used as a basis for evaluating the acceptance criterion for core-wide MWR.

AREVA confirmed that the planar and core-wide MWR values reported to NRC were accurate. Enclosures 1 and 2 provide a markup of Table 6.1 to illustrate the corrected information.

Each of the above conditions has been identified in the NSPM Corrective Action Program for evaluation and trending. Since all of the affected analyses relate to prospective conditions associated with the LAR, they are not associated with current plant operations and do not constitute an immediate safety concern. provides the non-proprietary corrections to AREVA reports that were enclosed to the Reference I LAR. provides the proprietary corrections to AREVA reports that were enclosed to the Reference 1 LAR. provides an affidavit executed to support withholding Enclosure 2 from public disclosure. Information in Enclosure 2 contains proprietary information as defined by 10 CFR 2.390. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in 10 CFR 2.390(b)(4). Accordingly, NSPM respectfully requests that the AREVA proprietary information in Enclosure 2 be withheld from public disclosure in accordance with 10 CFR 2.390(a)4, as authorized by 10 CFR 9.17(a)4.

Correspondence with respect to the copyright or proprietary aspects of the AREVA information in Enclosure 2 or the supporting AREVA affidavit in Enclosure 3 should be addressed to Mr. Alan Meginnis, Manager- Product Licensing, AREVA Inc.,

2101 Horn Rapids Road, Richland, Washington 99354.

The errata provided and corrected herein does not change the conclusions of the No Significant Hazards Consideration and the Environmental Consideration evaluations provided in the Reference 1 LAR.

In accordance with 10 CFR 50.91(b), a copy of this application supplement is being provided to the designated Minnesota Official without enclosures.

If there are any questions or if additional information is needed, please contact Glenn Adams at 612-330-6777.

Document Control Desk Page 4 Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.

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

Executed on: May 9, 2014 Karen D. Fili Site Vice-President Monticello Nuclear Generating Plant Northern States Power Company-Minnesota Enclosures (3) cc: Administrator, Region Ill, USNRC (w/o enclosures)

Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC (w/o enclosures)

Minnesota Department of Commerce (w/o enclosures)

L-MT-14-042 Non-Proprietary Corrections to AREVA Reports Enclosed in Fuel Transition License Amendment Request (LAR)

L-MT-1 3-055 LAR Enclosure Affected Report Corrected Page 6 ANP-3224P 3-2 7 ANP-3224NP 3-2 16 ANP-3213P 4-2 17 ANP-3213NP 4-2 19 ANP-321 1 NP 6-3 5 Pages Follow

Controlled Document RRIETAR ANP-3224F D

Applicability of AREVA NP IThis page contains no IRevision 2 BWR Methods to Monticello 'proprietary content~ iPg -

14. Letter, James F. Mallay (Framatome ANP) to Document Control Desk (NRC), "BWR CHF Bounds Checking," NRC:01:023, June 12, 2001.

15. Letter, James F. Mallay (Framatome ANP) to Document Control Desk (NRC), "BWR CHF Correlation Bounds Checking," NRC:02:003, January 11, 2002.

16. Letter, William H. Ruland (NRC) to James F. Mallay (Framatome ANP), "Safety Evaluation for BWR CHF Correlation Bounds Checking Clarifications Relating to Topical Reports EMF-1997(P)(A) Revision 0 and EMF-2209(P)(A) Revision 1 (TAC No. MB3107)," July 2, 2002.

17. StandardReview Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, NUREG-0800, U.S. Nuclear Regulatory Commission, July 1981.

18. CladdingSwelling and Rupture Models for LOCA Analysis, NUREG-0630, U.S. Nuclear Regulatory Commission, April 1980.

19. XN-NF-84-105(P)(A) Volume I Supplement 4, XCOBRA-T: A Computer Code for BWR TransientThermal-HydraulicCore Analysis - Void FractionModel Comparisonto ExperimentalData, Advanced Nuclear Fuels Corporation, June 1988.

20. Letter, James F. Mallay (SPC) to USNRC, "Clarification of SRP Chapter 15 Analyses Performed with XCOBRA-T and Checking of CHF Limits for Pump Seizure During SLO,"

NRC:98:037, June 3, 1998.

21. Letter, Don Curet (SPC) to USNRC, "Equilibrium Quality Limits for Hench-Levy Limit Line Correlation," NRC:98:044, June 25, 1998.

22. Letter, Cynthia A. Carpenter (NRC) to James F. Mallay (SPC), "Modification to Procedures for Use of XCOBRA-T," June 10, 1999.

23. ANP-3138(P) Revision 0, Monticello Improved K-factor Model for ACE/A TRIUM IOXM Critical Power Conrelation,AREVA NP, August 2012.

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

25. XN-Nr 6:7(r)(A) Revision 1,Gcemet Mechanes!a Ge~s* fer Exxon Nulefer Jet rump BIAR Relokad r~uc: Emn Nuelear Cornpany, September 1986.

26. NEDO-32047-A, "ATWS Rule Issues Relative to BWR Core Thermal-Hydraulic Stability,"

June 1995.

27. ANP-10262PA, Revision 0, EnhancedOption Ill Long Term Stability Solution, May 2008.

28. NEDO-32164 Revision 0, "Mitigation of BWR Core Thermal-Hydraulic Instabilities in ATWS," December 1992.

ANF-89-98(P)(A) Revision 1 and Supplement 1, Generic Mechanical Design Criteriafor BWR Fuel Designs, Advanced Nuclear Fuels Corporation, May 1995.

AREVA NP Inc.

Controlled Document ANP-3224NP Applicability of AREVA NP Revision 2 BWR Methods to Monticello Page 3-2

14. Letter, James F. Mallay (Framatome ANP) to Document Control Desk (NRC), "BWR CHF Bounds Checking," NRC:01:023, June 12, 2001.

15. Letter, James F. Mallay (Framatome ANP) to Document Control Desk (NRC), "BWR CHF Correlation Bounds Checking," NRC:02:003, January 11, 2002.

16. Letter, William H. Ruland (NRC) to James F. Mallay (Framatome ANP), "Safety Evaluation for BWR CHF Correlation Bounds Checking Clarifications Relating to Topical Reports EMF-1997(P)(A) Revision 0 and EMF-2209(P)(A) Revision 1 (TAC No. MB3107)," July 2, 2002.

17. StandardReview Plan for the Review of Safety Analysis Reports for NuclearPower Plants,NUREG-0800, U.S. Nuclear Regulatory Commission, July 1981.

18. Cladding Swelling and Rupture Models for LOCA Analysis, NUREG-0630, U.S. Nuclear Regulatory Commission, April 1980.

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

20. Letter, James F. Mallay (SPC) to USNRC, "Clarification of SRP Chapter 15 Analyses Performed with XCOBRA-T and Checking of CHF Limits for Pump Seizure During SLO,"

NRC:98:037, June 3,1998.

21. Letter, Don Curet (SPC) to USNRC, "Equilibrium Quality Limits for Hench-Levy Limit Line Correlation," NRC:98:044, June 25, 1998.

22. Letter, Cynthia A. Carpenter (NRC) to James F. Mallay (SPC), "Modification to Procedures for Use of XCOBRA-T," June 10, 1999.

23. ANP-3138(P) Revision 0, Monticello Improved K-factor Model forACE/ATRIUM IOXM CriticalPower Correlation,AREVA NP, August 2012.

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

25. XN NP 85 6:7(P)^A) R.-i-io. 1, Gene&. Me2haniei DPeignf*or E...n Nuclear Jet Pump BWR Ro!33d F!,", RKNOn Nuc9oar C.mpany, So*po*,r 1086.

26. NEDO-32047-A, "ATVVS Rule Issues Relative to BWR Core Thermal-Hydraulic Stability,"

June 1995.

27. ANP-10262PA, Revision 0, Enhanced Option Ill Long Term Stability Solution, May 2008.

28. NEDO-32164 Revision 0, "Mitigation of BWR Core Thermal-Hydraulic Instabilities in ATWS," December 1992.

ANF-89-98(P)(A) Revision 1 and Supplement 1, Generic MechanicalDesign Criteriafor BWR Fuel Designs, Advanced Nuclear Fuels Corporation, May 1995.

AREVA NP Inc.

AREVA M Pr rR0 PRr1EIETARY Monticello ANP-3213(P)

Fuel Transition Cycle 28* Revision 1 Reload Licensing Analysis (EPU/MELLLA) IThis page contains no Page 4-2 4.3 Core Hydrodynamic Stability proprietary content I Monticello has implemented BWROG Long Term Stability Solution Option III (Oscillation Power Range Monitor-OPRM). Reload validation has been performed in accordance with Reference 18. The stability based Operating Limit MCPR (OLMCPR) is provided for two conditions as a function of OPRM amplitude setpoint in Table 4.3. The two conditions evaluated are for a postulated oscillation at 45% core flow steady-state operation (SS) and following a two recirculation pump trip (2PT) from the limiting full power operation state point. The Cycle 28 power- and flow-dependent limits provide adequate protection against violation of the SLMCPR for postulated reactor instability as long as the operating limit is greater than or equal to the specified value for the selected OPRM setpoint.

AREVA has performed calculations for the relative change in CPR as a function of the calculated hot channel oscillation magnitude (HCOM). These calculations were performed with the RAMONA5-FA code in accordance with Reference 19. This code is a coupled neutronic-thermal-hydraulic three-dimensional transient model for the purpose of determining the relationship between the relative change in ACPR and the HCOM on a plant specific basis. The stability-based OLMCPRs are calculated using the most limiting of the calculated change in relative ACPR for a given oscillation magnitude or the generic value provided in Reference 18.

The generic value was determined to be limiting for Cycle 28.

In cases where the OPRM system is declared inoperable, Backup Stability Protection (BSP) is provided in accordance with Reference 22. BSP curves have been evaluated using STAIF (Reference 23) to determine endpoints that meet decay ratio criteria for the BSP Base Minimal Region I (scram region) and Base Minimal Region II (controlled entry region). Stability boundaries based on these endpoints are then determined using the generic shap nerating function from Reference 22.

The STAIF acceptance criteria for t endpoints are global decay ratios g 0.85, and regional and channel decay ratios g 0.80. Endpoints for the BSP regions provided in Table 4.4 have global decay ratios < 0.85, and regional and channel decay ratios K-0.80.

+LW t'EW AREVA NP Inc.

.1 Monticello ANP-3213(NP)

Fuel Transition Cycle 28 Revision 1 Reload Licensing Analysis (EPU/MELLLA) Page 4-2 4.3 Core Hydrodynamic Stability Monticello has implemented BWROG Long Term Stability Solution Option III (Oscillation Power Range Monitor-OPRM). Reload validation has been performed in accordance with Reference 18. The stability based Operating Limit MCPR (OLMCPR) is provided for two conditions as a function of OPRM amplitude setpoint in Table 4.3. The two conditions evaluated are for a postulated oscillation at 45% core flow steady-state operation (SS) and following a two recirculation pump trip (2PT) from the limiting full power operation state point. The Cycle 28 power- and flow-dependent limits provide adequate protection against violation of the SLMCPR for postulated reactor instability as long as the operating limit is greater than or equal to the specified value for the selected OPRM setpoint.

AREVA has performed calculations for the relative change in CPR as a function of the calculated hot channel oscillation magnitude (HCOM). These calculations were performed with the RAMONA5-FA code in accordance with Reference 19. This code is a coupled neutronic-thermal-hydraulic three-dimensional transient model for the purpose of determining the relationship between the relative change in ACPR and the HCOM on a plant specific basis. The stability-based OLMCPRs are calculated using the most limiting of the calculated change in relative ACPR for a given oscillation magnitude or the generic value provided in Reference 18.

The generic value was determined to be limiting for Cycle 28.

In cases where the OPRM system is declared inoperable, Backup Stability Protection (BSP) is provided in accordance with Reference 22. BSP curves have been evaluated using STAIF (Reference 23) to determine endpoints that meet decay ratio criteria for the BSP Base Minimal Region I (scram region) and Base Minimal Region II (controlled entry region). Stability boundaries based on these endpoints are then determined using the generic shapergenerating function from Reference 22.

The STAIF acceptance criteria for eBLP endpoints are global decay ratios 0.85, and regional and channel decay ratios g 0.80. Endpoints for the BSP regions provided in Table 4.4 have global decay ratios g 0.85, and regional and channel decay ratios g 0.80.

4Ž-tz t{-w AREVA NP Inc.

Controlled Document Monticello EPU ANP-3211 (NP)

LOCA Break Spectrum Analysis Revision 1 for ATRIUMTM 1OXM Fuel Page 6-3 Table 6.1 Results for Limitinp TLO Recirculation Line Break 3.3 ft Split Pump Suction SF-LPCI Mid-Peaked Axial 102% Power [

PCT 2130°F Maximum local MWR 3.96%

Maximum planar average MWR 4-44%

AREVA NP Inc.

L-MT-14-042 AREVA AFFIDAVIT FOR WITHHOLDING PROPRIETARY INFORMATION 3 Pages Follow

AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) ss.

CITY OF LYNCHBURG

1. My name is Philip A. Opsal. I am Manager, Product Licensing, for AREVA Inc. (AREVA) and as such I am authorized to execute this Affidavit.

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

3. I am familiar with the AREVA information contained in the following document:

"AREVA ATRIUM IOXM Fuel Transition - Errata on License Amendment Request (TAC MF2479)," and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 to determine whether information should be classified as proprietary:

(a) The information reveals details of AREVA'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.

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

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

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

7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA 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.

SUBSCRIBED before me this ____

day of / 4 p2C I 2014.

Ella F. Carr-Payne NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 8/31/17 Reg. # 309873