L-MT-14-103, Areva Report ANP-3376NP, Rev. 0, Supplement to Xcel Energy License Amendment Request for Areva Extended Flow Window, Enclosure 2 to L-MT-14-103

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Areva Report ANP-3376NP, Rev. 0, Supplement to Xcel Energy License Amendment Request for Areva Extended Flow Window, Enclosure 2 to L-MT-14-103
ML15022A167
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Issue date: 12/31/2014
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L-MT-14-103 Enclosure 2 AREVA Report ANP-3376NP Non-Proprietary Supplement to Xcel Energy License Amendment Request For AREVA Extended Flow Window Revision 0 23 pages follow

Controlled Document A

AREVA ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window December 2014 (c) 2014 AREVA Inc.

Controlled Document Copyright © 2014 AREVA Inc.

All Rights Reserved

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensing Report Page i

--Nature of Changes Section(s)

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

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensinq Report Page ii Contents NO ME NC LA T UR E .......................................................................................................... iii 1 .0 P UR P O S E ............................................................................................................ 1

2.0 BACKGROUND

............................................................................................... 1 3.0 DECAY HEAT ................................................................................................... 2 4.0 SUPPLEMENTAL INFORMATION ................................................................... 2

5.0 REFERENCES

................................................................................................ 17 Figures Figure 1: Structure of Extended Operating Domain Licensing Using the MELLLA+ Template .................................................................................. 16

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensina Report Paae iii Nomenclature Acronym Definition ANS American Nuclear Society ATWS Anticipated Transient Without Scram ATWS-l ATWS Instability BWROG Boiling Water Reactor Owners Group CAP Containment Accident Pressure DBA Design Basis Accident DSS-CD Detect and Suppress Solution - Confirmation Density ECCS Emergency Core Cooling Systems EEQ Equipment Environmental Qualification EFW Extended Flow Window EOD Extended Operating Domain EO-IlI Enhanced Option III EPG Emergency Procedure Guidelines EPU Extended Power Uprate GL Generic Letter GEH GE Hitachi GNF Global Nuclear Fuels HELB High Energy Line Break HVAC Heating Ventilation Air Conditioning LAR License Amendment Request LOCA Loss-Of-Coolant Accident MCPR Minimum Critical Power Ratio MELLLA+ Maximum Extended Load Line Limit Analysis Plus MNGP Monticello Nuclear Generating Plant NPSH Net Positive Suction Head NPSHa NPSH-available NPSHr NPSH-required NRC Nuclear Regulatory Commission, U.S.

RAI Request for Additional Information RHR Residual Heat Removal RSLB Recirculation Suction Line Break SAG Severe Accident Guidelines SRV Safety Relief Valve SSCs Systems, Structures, and Components

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensing Report Page 1 1.0 PURPOSE This report provides the supplemental information requested by the NRC to complete their acceptance review of the Xcel Energy License Amendment Request (LAR) for AREVA Extended Flow Window (EFW), Reference 1.

2.0 BACKGROUND

By Reference 2, the NRC approved the Xcel Energy LAR to expand the Monticello Nuclear Generating Plant (MNGP) operating domain to the Maximum Extended Load Line Limit Analysis Plus (MELLLA+). This approval applies to Global Nuclear Fuels (GNF) GE14 fuel. In Reference 1, Xcel Energy submitted an LAR to operate AREVA ATRIUM TM 1OXM* fuel within the EFW, which is the AREVA term used to denote the expanded operating domain also known as MELLLA+. In Reference 3, the NRC requested supplemental information to complete their acceptance review of the AREVA EFW LAR. This supplemental information is provided in Section 4.0.

Reference 4, which is enclosure 11 in Reference 1, summarizes AREVA licensing analyses performed to support MNGP operation with ATRIUM 1OXM fuel at Extended Power Uprate (EPU) and EFW conditions. Some of the information in Reference 4 is useful to understand the licensing analyses supporting the EFW LAR. For instance; Figure 1.1 presents the MNGP power/flow map for EPU/EFW, which is the same parametric envelope as the power/flow map for EPU/MELLLA+

Section 2.0 presents a disposition of events for EPU/EFW Section 4.1 presents the thermal-hydraulic compatibility of GE14 and ATRIUM 1OXM fuel at EFW operating conditions (pressure drop is very similar, which is important during the transition between fuel types)

Reference 5, which is enclosure 13 in Reference 1, addresses the applicability of AREVA methods to MNGP EFW.

  • ATRIUM is a trademark of AREVA Inc.

k'ont~rofl.e.d Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensing Report Page 2 References 6 and 7, which are enclosures 7 and 9 in Reference 1, present the MNGP specific methodology which has been developed and applied to evaluate the core response for GEl4 and ATRIUM 1OXM fuel during Anticipated Transient Without Scram (ATWS) with Instability.

3.0 DECAY HEAT Decay heat is the only fuel-related input for several licensing analyses not analyzed by AREVA. Decay heat is principally a function of the reactor power level, the irradiation time, and the time after shutdown. [

] Review of the MNGP licensing calculations for EPU and MELLLA+

show industry standards (e.g. References 18, 19, 20) were used to calculate decay heat. Since these standards are applicable for ATRIUM 1OXM fuel, [

] Computer codes like ORIGEN, that could be used to perform more detailed calculations for decay heat that would account for differences between fuel designs, have not been used. [

Below, the NRC questions are provided in italic font and the responses are provided in the normal font.

4.0 SUPPLEMENTAL INFORMATION The NRC staff requested the following information:

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensing Report Page 3 4.2 Please provide the following document: EMF-2279(P) Revision 0, STAIF:

A Computer Programfor BWR Stability in the Frequency Domain -

Theory Manual, dated January2011.

The requested document has been provided to Xcel Energy for transmittal to the NRC.

4.3 Please provide additionaljustificationfor the adequacy of the Enhanced Option Ill in the Extended Flow Window (EFW) operatingdomain.

At a fundamental level, Enhanced Option III (EO-Ill) is justified in the EFW operating domain because it is explicitly approved for such use when the application satisfies the conditions and limitations of the NRC-approved license topical report (Reference 10). The applicability of that topical to MNGP is specifically addressed in enclosure 13 of Reference 1, and addresses positively all the conditions and limitations.

On a global level, the LAR did much more than validate the applicability of EO-Ill. In effect, the LAR took the licensing infrastructure created by the MNGP-specific application of the GEH MELLLA+ licensed topical reports (LTRs) and ensured that comparable analysis and evaluation was performed to embody the same topics using AREVA methods. This relationship is depicted and explained in Figure 1. In summary:

For the top tier of Global Evaluation of Systems, Structures, and Components (SSCs) in the Extended Operating Domain (EOD):

1) Whereas the MELLLA+ licensing invoked the generic LTR NEDC-33006 and used NEDC-33435 (MNGP Safety Analysis Report) to ensure a thorough evaluation of plant performance in the EOD, the EFW LAR used AREVA ANP-3295 to perform the same scope and breadth of evaluation, with due consideration that EFW represents the very same parametric envelope of power-flow domain described for the MNGP MELLLA+. Furthermore, as the EFW implementation involves

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensing Report Page 4 no physical change to plant systems, structures, components, or operating procedures, the ANP-3295 takes considerable credit for the plant performance evaluations performed previously (and demonstrated as satisfactory by actual plant operation in the MELLLA+

EOD following Amendment 180).

2) For the special event of Anticipated Transient Without Scram Instability (ATWS-I), the EFW LAR provides a comparable set of analyses that use AREVA-proprietary methods (AISHA, SINANO) that are described extensively in the EFW LAR.

For the second tier of Evaluations:

3) Whereas GE provided a licensed topical report (NEDC-33173) to determine that GEH safety analysis methods remained valid (applicable) in the EOD of MELLLA+, the EFW LAR provided a specific report (AREVA ANP-3135) to conclude that AREVA methods also remained valid in the same EOD.
4) Lastly, for the topic of Reactor Protection for Long-Term Core Instability Protection, the MELLLA+ licensing of MNGP invoked two GEH generic LTRs that support the GEH protection scheme involving Detect and Suppress Solution - Confirmation Density (DSS-CD, NEDC-33075) and the supporting thermal-hydraulics per TRACG (NEDC-33147). To implement the approved alternative reactor protection scheme for EO-III, the LAR invokes AREVA's LTR ANP-10262 with a necessary supplement (the attachment to enclosure 1 of Reference 1) that develops the site-specific design required by the LTR.

In whole, the EFW LAR covers all the same elements of the approved MELLLA+ licensing basis, but uses different methods where necessary.

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensing Report Page 5 The Enhanced Option III topical report (Reference 10) contains a discussion of the allowed plant operating modes in Section 5.6. Included in this discussion is a bound on the applicable power/flow window. The allowed operating domain includes extended flow windows corresponding to a control rod line defined at 80% of rated flow at an EPU power level of 120% of original licensed thermal power. Limitation and Condition 3 of the Safety Evaluation to Reference 10 also identifies the applicable operating range for Enhanced Option III as follows:

"The confirmation analyses documented in Section 5 of (topical report)

ANP-10262(P), Revision 0, and the response to the NRC staff (request for additional information), indicate that the EO-Ill Long Term Stability Solution methodology provides significant protection against (minimum critical power ratio (MCPR)) criteria violations during anticipated instability events even under high-power-density conditions, including EPU and MELLLA+. Under all analyzed conditions, the loss of MCPR margin induced by the instability event is compensated by the gain in MCPR margin induced by the reduction in flow, so that the net MCPR margin is positive. Based on this analysis, the NRC staff finds that the EO-Ill Long Term Stability Solution is a technically acceptable methodology for any reactor operating up to MELLLA+ conditions.

Extension of operating domains beyond MELLLA+ have not been considered by the NRC staff and will require a re-evaluation of the EO-Ill Long Term Stability Solution scram effectiveness by the NRC staff."

Since the MNGP EFW flow window does not extend the currently approved MELLLA+ flow window, and the minimum flow at EPU power level is defined as 80%, Enhanced Option III will be applicable and used within its approved range.

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensinq Report Page 6 4.4 For the following analyses, please describe and specificallyprovide (1) the differences between the currentlylicensed and proposed EFW analysis methodologies; (2) a comparison of analysis results between the currentlicensing basis and the proposedEFW analysis, and (3) in case the conclusion is obtained from a qualitative evaluation,provide justification that the results are bounding:

On a global level, the EFW LAR (Reference 1) leveraged the similarities to the approved MELLLA+ evaluations and the benign implementation requirements to evaluate MNGP plant performance and conclude that MNGP-specific plant performance (including containment and ventilation system performance) is not affected by the transition from MELLLA+ operation (with GNF fuel) to EFW operation (with AREVA and GNF fuel). This global evaluation is based on the following similarities and principles:

1) The parametric envelope of the EFW EOD is identical to MELLLA+.
2) The thermal-hydraulic effect of the different fuel geometry (core differential pressure) is negligible (less than 1 psi at rated core conditions), but is explicitly considered in thermal-hydraulic analyses nonetheless.
3) EFW implementation requires no significant change to plant design or operation. [
4) EFW implementation does not change any of the inputs that define the decay heat rates, which could, in turn, affect system performance and mass-energy release rates. Traditionally, the industry standards for calculating decay heat rates (e.g., ANS) do not depend on fuel assembly geometry, but rely predominantly on power operating history parameters.

With these global principles in mind, each of the specific questions is evaluated below:

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensing Report Page 7 4.4.1 Short term containment pressureanalysis for most limiting peak pressure The licensing basis for MNGP short term containment pressure (at EPU/MELLLA+ conditions) is summarized in Section 4.1.1 of Reference 8, which was transmitted to the NRC as Attachment 3 of Reference 9. The limiting event is a design basis accident (DBA) recirculation suction line break (RSLB). That analysis concluded that the peak drywell pressure and the peak drywell-to-wetwell differential pressure are both slightly lower for the MELLLA+ operating domain.

The short term containment pressure depends on the break energy which is derived from the break flow rate and enthalpy. Break flow and enthalpy from a design basis break in the recirculation suction line depend on conditions inside the reactor vessel (pressure, power, feedwater temperature, etc.), but do not depend on the fuel design.

Thus, the analysis of record for short-term containment pressure remains valid (bounding) for AREVA ATRIUM 1OXM fuel operating within EFW because: (1) the analysis results do not depend on fuel design, and (2) the methodology for MNGP containment analyses is not being changed by the EFW LAR.

4.4.2 Containmentpeak gas temperatureresponse for Equipment EnvironmentalQualification (EEQ) purposes The licensing basis for environmental qualification of equipment (at EPU/MELLLA+ conditions) is summarized in Section 10.3 of Reference 8. The evaluations for MNGP MELLLA+ were confirmed to be consistent with the generic disposition in the MELLLA+ LTR (Reference 11). The MELLLA+

operating domain does not change any of the normal process temperatures, pressures, or flow rates. [

I

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensing Report Page 8 Review of the containment calculations shows industry standards were used to calculate decay heat (e.g. References 18, 19, 20). Since these standards are applicable for ATRIUM 1OXM fuel (as discussed in Section 3.0 above), the containment peak gas temperature calculations remain valid (bounding) for ATRIUM 1OXM fuel operating within EFW.

4.4.3 Containment limiting wall temperatureresponse The licensing basis for MNGP containment temperature response is provided in Section 4.1.1 of Reference 8. [

] However, the decay heat standards used in the analysis of record were not fuel dependent. Also, the methodology for MNGP containment analyses is not being changed by the EFW LAR. Therefore, the containment wall temperature response in the analysis of record remains applicable (bounding) for ATRIUM 1OXM fuel operating within EFW.

4.4.4 Containmentminimum pressure for ECCS performance analysis The licensing basis for containment minimum pressure for ECCS performance (at EPU / MELLLA+ conditions) is provided in References 12 - 14. Since the licensing basis for MNGP is associated with SECY 11-0014, the response to this item is addressed in the following responses.

4.4.5 Suppression pool temperatureresponse for limiting net positive suction head (NPSH) analysis,NPSH analysis for the residualheat removal (RHR) and core spraypumps, specificallyaddressinguncertaintyin requiredNPSH per SECY-11-0014 for the design basis accident (DBA) loss-of-coolant accident(LOCA)

The licensing basis for suppression pool response for limiting NPSH analysis is provided in References 12 - 14. A review of supporting analyses shows that conservative bounding core conditions are assumed when calculating the mass

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensing Report Page 9 and energy release into the suppression pool, and other plant conditions are conservatively biased to minimize NPSH-available (NPSHa). Fuel design is not constrained in this analysis. This approach is typically taken to ensure that suppression pool conditions and NPSHa do not have to be recalculated for variations in fuel or core design. In this regard, the transition to AREVA fuel operation in the same parametric envelope of EPU/MELLLA+ has no effect on the mass and energy release that drives the suppression pool response.

On the NPSH-required (NPSHr) side, the transition to AREVA fuel operation at EFW has no effect on the ECCS pump design (or plant conditions such as pump speed, wear ring leakage, or air content) that would affect the value of NPSHr or the uncertainties assumed in the analyses of record.

Thus, with no impact on NPSHa or NPSHr, the transition to AREVA fuel operating in the same parametric envelope as EPU/MELLLA+, the NPSH analyses of record remain valid.

4.4.6 NPSH analysis for the RHR and core spraypumps per SECY-11-0014 for special events RHR and Core Spray Pump NPSH requirements were evaluated for ATWS and Appendix R special events in the MNGP licensing basis (References 12 - 14).

ATWS events have two phases, the short term response (before boron shut-down) and the long term response (after boron shut-down). [

] In addition, the MNGP licensing basis (Reference 2) credits operator actions to control core power during an ATWS by following the BWROG

Controlled Document AREVA Inc. AlNP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensing Report Page 10 Emergency Procedure Guidelines/Severe Accident Guidelines (EPG/SAPs). Any small differences in the core response resulting from the differences between GEl4 and ATRIUM 1OXM fuel will be compensated for by the operator actions.

Therefore, introduction of ATRIUM 1OXM fuel will not significantly impact the short-term ATWS containment response and the current analysis remains valid (bounding). For ATWS long-term response and Appendix R (which assumes scram at time zero), the impact is only dependent on decay heat (see Section 3.0 for decay heat considerations). The use of bounding assumptions in the analyses-of-record provides confidence that any possible neutronic effect from variation in fuel design is inconsequential to the conclusion. In fact, the analysis-of-record uses bounding core power operating history with no constraints on fuel design. This approach was taken to ensure that suppression pool conditions and NPSHa do not have to be recalculated for variations in fuel or core design. In this manner, the analysis of record will remain valid (bounding) for the introduction of ATRIUM 1OXM fuel.

4.4.7 Containment dynamic loads, including subcompartmentpressurization loads, LOCA loads, and safety relief valve (SRV) loads The licensing basis for MNGP MELLLA+ is summarized in Sections 4.1.3 and 4.1.4 of Reference 8, which concludes that MELLLA+ operating domain containment dynamic loads are bounded by the EPU/MELLLA operating domain responses. Since the methodology for MNGP containment analyses is not being changed by the EFW LAR, the only way the change from GE14 to ATRIUM 1OXM fuel could potentially impact the containment dynamic loads would be due to differences in sensible heat (short-term) and decay heat (long-term). As detailed in the response to question 4.4.6, the comparison of the two fuel designs shows that the analysis of record containment dynamic loads response to both sensible heat and decay heat remains valid (bounding) for the introduction of ATRIUM 1OXM fuel.

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensing Report Page 11 4.5 Please describe and provide the impact of the proposed EFW operating domain on the following:

4.5.1 Post-LOCA Combustible Gas Control System The licensing basis for MNGP MELLLA+ is summarized in Section 4.7 of Reference 8 and recognizes that MNGP does not credit a Combustible Gas Control System to maintain hydrogen and oxygen below the lower flammability limit in containment. Rather, MNGP has eliminated the requirements for hydrogen recombiners and committed to maintain hydrogen and oxygen monitoring systems. Thus, the licensing basis makes no limitations on combustible gas generation rates, but rather, it relies on monitoring gas levels and taking appropriate action. Thus, Reference 8 concluded that operation in the MELLLA+ operating domain had no effect on the design of these monitoring systems or on the ability of these systems to perform their intended functions.

For the same reasons, operation with AREVA fuel in the EFW domain will likewise have no effect.

4.5.2 ContainmentIsolation The licensing basis for containment isolation at MNGP MELLLA+ conditions is summarized in Section 4.1.5 of Reference 8, and is based on the evaluation that is provided in Section 4.1.1 (short term pressure and temperature response) of Reference 8. For the same reasons that operation in the MELLLA+ domain had no effect on limiting containment conditions (and therefore, no effect on containment isolation functions), the change to plant operation in the same operating envelope (i.e., EFW) with AREVA fuel will have no effect on containment isolation functions. Refer to Section 4.4.1 above for the determination that operation with AREVA fuel in the EFW domain will not change the limiting containment conditions.

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensinq Report Page 12 4.5.3 Response to Generic Letter 89-10 The licensing basis for MNGP MELLLA+ is summarized in Section 4.1.6 of Reference 8. GL 89-10 addresses safety related motor operated valve testing and surveillance. The evaluation is based on the evaluations provided in Sections 4.1.1 (short term pressure and temperature response), 6.6 Heating Ventilation Air Conditioning (HVAC), and 10.1 High Energy Line Break (HELB) of Reference 8.

The assessment of the applicability for Section 4.1.1 of Reference 8 for EFW was provided in Section 4.4.1.

Section 6.6 of Reference 8 states for MNGP HVAC systems, the process temperatures and heat load from motors and cables are bounded by the EPU process temperatures and heat loads and as such are within the design of the HVAC equipment chosen for worst case conditions. This statement is applicable to EFW since EFW is the same power/flow operating domain as MELLLA+.

Section 6.6 does not mention fuel designs or decay heat.

The only potential for changing the heat loads as a result of changing the fuel designs is if the fuel designs have different decay heat. However, review of the decay heat calculations supporting MNGP EPU and MELLLA+ demonstrate that standard models (e.g. References 18, 19, 20), which are applicable to ATRIUM 10XM fuel, have been used to calculate decay heat. Computer codes like ORIGEN, that could be used to perform more detailed calculations for decay heat that would account for differences between fuel designs, have not been used.

Section 10.1 of Reference 8 discusses heat loads from potential line breaks.

Potential breaks of a main steam line and a feedwater line are specifically mentioned as well as other liquid lines. The discussion addresses heat balances and the impact of changes in the energy in piping resulting from the expanded power/flow operating domain. Section 10.1 does not mention fuel designs or

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensing Report Page 13 decay heat. The evaluation concludes that operation in the expanded power/flow domain would not result in more severe conditions. This conclusion is applicable to EFW since EFW is the same power/flow operating domain as MELLLA+.

The review of Sections 4.1.1, 4.1.6, 6.6, and 10.1 of Reference 8 demonstrates that EFW does not impact GL 89-10.

4.5.4 Response to Generic Letter 89-16 The licensing basis for MNGP MELLLA+ is summarized in Section 4.1.7 of Reference 8. This GL addresses the ability of the hardened wetwell vent system to prevent containment overpressure conditions. Section 4.1.7 concludes the ability of the vent system is unaffected by MELLLA+. This conclusion is applicable to EFW since EFW is the same power/flow operating domain as MELLLA+.

4.5.5 Response to Generic Letter 95-07 The licensing basis for MNGP MELLLA+ is summarized in Section 4.1.8 of Reference 8. This GL addresses pressure locking and thermal binding of safety related power operated gate valves. The evaluation is based on the evaluation provided in Section 4.1.1 (short term pressure and temperature response) of Reference 8. The assessment of the applicability for Section 4.1.1 for EFW was provided in Section 4.4.1. Section 4.1.1 of that report concludes that operation in the expanded power/flow domain would not result in a more severe containment pressure and temperature response. This conclusion is applicable to EFW since EFW is the same power/flow operating domain as MELLLA+.

4.5.6 Response to Generic Letter 96-06 The licensing basis for equipment operability and containment integrity during design basis accidents initiated from the MELLLA+ domain is summarized in Section 4.1.9 of Reference 8 and is based on the evaluation provided in Section 4.1.1 of Reference 8 (short term pressure and temperature response).

Controled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensing Report Page 14 The assessment of the applicability for Section 4.1.1 for EFW was provided in Section 4.4.1. Section 4.1.1 of Reference 8 concluded that the peak drywell temperature, the peak drywell pressure and the peak drywell-to-wetwell differential pressure are all slightly lower for the MELLLA+ operating domain.

This conclusion is applicable to EFW since EFW is the same power/flow operating domain as MELLLA+.

4.5.7 Main Control Room Atmosphere Control System design parameters The licensing basis for MNGP MELLLA+ is summarized in Section 4.4 of Reference 8. Section 4.4 points to Section 8.0 to state the MELLLA+ operating domain expansion does not change the source terms or release rates and therefore does not adversely affect the main control room atmosphere control system. This conclusion is applicable to EFW since EFW is the same power/flow operating domain as MELLLA+.

However, a change in fuel design has the potential to change the source terms when fuel designs are significantly different such as the fissile and the fertile contents, e.g., PuO2 versus U02. [

]

For the release rates, the path of fission products released from fuel to the control room atmosphere remains the same between the two fuel designs.

4.5.8 Standby Gas Treatment System design parameters The licensing basis for MNGP MELLLA+ is summarized in Section 4.5 of Reference 8. The standby gas treatment system is designed to maintain secondary containment at a negative pressure and to filter the exhaust air for removal of fission products potentially present during abnormal conditions: The

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensing Report Page 15 conclusion in Section 4.5 of Reference 8 is that no further evaluation was required for MELLLA+. This conclusion is applicable to EFW since EFW is the same power/flow operating domain as MELLLA+.

Controlled Document AREVA Inc. AlNP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensinn Renort Paoe 16 Licensinn Report Pane 16 Figure 1: Structure of Extended Operating Domain Licensing Using the MELLLA+ Template The following graphic shows the general structure for MELLLA+ licensing, which is perceived as the benchmark for achieving operation in the Extended Operating Domain (EOD) of the Power-Flow map.

~ ~~~~

In this graphic, the ..hierarchy ...of GEH MELLLA+ topical licensing

. starts-with

... .*.%NEDC-33006,which

,'. .'A describes how the global evaluation of plant systemsstructures, and components (SSCs), accidents, and transients should be conducted. Subltier GEH topicals.that support NEDC-33006 include NEDC 33173 (which determines theapplicability of GE methods in the EOD) and topicals NEDC-33075 / 33147 (which describes the reactor protection approach forlong-term core stability, The GEH MELLLA+ topicals are shaded in BLUE.

o As discuse'in,p'reapplic(tion me=tihgs* te FW LAR approach was .to leverage the global evaluations already approved.for the EODj(MELLLA+ Amendmenti80), but to apply AREVA.

methodology where.the poprietar;GEH methods blocked the applicability of AREVA fuel types..

This a.pplied.mostly to core instability topics. As seen in the graphiic below, the.EFW LAR provided all the necessary evaluations that were provided under the. MELLLA+topicals. AREVAreports ar. .

shaded in RED.

.Tphe purpIle sha&d box describeý the global evaluations of MNGP plant-sp'dfi SSCsthat were approved in Amendment 180 for the EOD and remainvalid for the AREVA EFW EOD.

Global Evaluation of SSCs in the Extended Operating Domain ATWS-. Global Plant Evaluation ATWS-I .

GE Methods NEDC-33006:provides a generic ANP-3274 ANP-3284 template fo,revaluating plant Enclosure 7' Enclosure 9

___  :: perform ance criteria in the EO D. _*_"_'":_* _....... _ ....

Site-specific evaluation demonstrate d that MNGP SSCs met performance.

requirements; NRC approved in MNGP Amendmeni 180.

In the EFW LAR, NSPM takes credit.for the.above siteýspeLc ic evaluation that was approved by. NRC This is provided in the Disposition of Events of ANP- :

3295,

Enclosure:

11.

Applicability of Methods Reactor Protection for Long-Term Core Instability Protection NEDC-33173 ANP-3135. NEDC-33075 NEDC-33147 ANP-20262 Enclosure 1I" Enclosure 13 Attachment.,'...

Determines Determines. DSS-CD TRACG ECIII -method Develops topically that ispecifically for applyinig . ireactor GE methods that AREVA channelt protection are applicable methods are instability based on ClER.

in the EOD. applicable ini . exclusion ".

. ,thue.EOD for (ClER) lregIon

'_MNGP . . ".__._.___ __________

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensing Report Page 17

5.0 REFERENCES

1. Letter from Xcel Energy to NRC, "License Amendment Request for AREVA Extended Flow Window", L-MT-14-044, October 3, 2014 (ADAMS Accession No. ML14283A119).
2. NRC letter to Karen D. Fili (NSPM), "Issuance of Amendment No. 180 to Renewed Facility Operating License Regarding Maximum Extended Load Line Limit Analysis Plus (TAC No.ME3145)," Dated March 28, 2014 (ADAMS Accession No. ML14035A248).
3. Email from NRC (Terry Beltz) to Xcel Energy (Glenn Adams), "Monticello Nuclear Generating Plant - Acceptance Review (Opportunity to Supplement) re: AREVA Extended Flow Window License Amendment Request (TAC No.MF5002).
4. -AN P-3295P Revision 2, Monticello Licensing Analysis EFW (EPU/MELLLA+),

AREVA, September 2014.

5. ANP-3135P Revision 0, Applicability of AREVA BWR Methods to Extended Flow Window for Monticello, AREVA, April 2014.
6. ANP-3274P Revision 1, Analytical Methods for Monticello A TWS-I, AREVA, July 2014.
7. AN P-3284P Revision 0, Results of Analysis and Benchmarking of Methods for Monticello ATTWS-I, AREVA, April 2014.
8. GEH Report, "Safety Analysis Report for Monticello Regarding Maximum Extended Load Line Limit Analysis Plus", NEDC-33435P Revision 1, December 2009.
9. Letter from Xcel Energy to NRC, "License Amendment Request: Maximum Extended Load Line Limit Analysis Plus", L-MT-10-003, January 21, 2010 (ADAMS Accession No. ML100280558).
10. ANP-10262PA Revision 0, Enhanced Option Ill Long Term Stability Solution, AREVA NP, May 2008.
11. GE Nuclear Energy, "General Electric Boiling Water Reactor Maximum Extended Load Line Limit Analysis Plus Licensing Topical Report," NEDC-33006P-A Revision 3, June 2009.
12. Letter from Xcel Energy to NRC, "Monticello Extended Power Uprate and Maximum Extended Load Line Limit Analysis Plus Licensing Amendment Requests: Supplement to Address SECY 11-0014 Use of Containment Accident

Controlled Document AREVA Inc. ANP-3376NP Revision 0 Supplement to Xcel Energy License Amendment Request for AREVA Extended Flow Window Licensinq Report Page 18 Pressure (TAC Nos. MD 9990 and ME3145)," L-MT-12-082, September 28, 2012.

13. Letter from Xcel Energy to NRC, "Monticello Extended Power Uprate and Maximum Extended Load Line Limit Analysis Plus Licensing Amendment Requests: Supplement to Address SECY 11-0014 Use of Containment Accident Pressure, Sections 6.6.4 and 6.6.7 (TAC Nos. MD 9990 and ME3145),"

L-MT-12-107, November 30, 2012.

14. Letter from Xcel Energy to NRC, "Monticello Extended Power Uprate: SECY 11-0014 Use of Containment Accident Pressure - Responses to Request for Additional Information (TAC MD9990)," L-MT-13-033, March 21, 2013.
15. ANP-321 1P Revision 1, Monticello Break Spectrum Analysis for ATRIUM IOXM fuel (EPU/MELLLA), AREVA NP, July 2013.
16. ANP-3212P Revision 0, Monticello EPU LOCA-ECCS Analysis MAPLHGR Limits forATRIUM IOXM Fuel, AREVA NP, May 2013.
17. Letter from Xcel Energy to NRC, "License Amendment Request for Transition to AREVA ATRIUM 1OXM Fuel and AREVA Safety Analysis Methodology",

L-MT-13-055, July 15, 2013 (ADAMS Accession No. ML13200A187).

18. ANSI/ANS-5.1-1971, "American Nuclear Society Decay Energy Release Rates Following Shutdown of Uranium-Fueled Thermal Reactors", October 1971.
19. ANSI/ANS-5.1-1979, "American Nuclear Society Decay Heat Power in Light Water Reactors", August 1979.
20. ANSI/ANS-5.1-1994, "American Nuclear Society Decay Heat Power in Light Water Reactors", August 1994.
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