ML18205A691
| ML18205A691 | |
| Person / Time | |
|---|---|
| Site: | PROJ0728, 99902041 |
| Issue date: | 08/03/2018 |
| From: | Dennis Morey NRC/NRR/DLP/PLPB |
| To: | Peters G Framatome |
| Rowley J, NRR/DLP 415-4053 | |
| Shared Package | |
| ML18178A601 | List: |
| References | |
| ANP-10297P-A, Rev 0, Supp 1, CAC MF6469, EPID L-2015-TOP-0005 | |
| Download: ML18205A691 (8) | |
Text
RESOLUTION OF COMMENTS BY THE OFFICE OF NUCLEAR REACTOR REGULATION ON DRAFT SAFETY EVALUATION FOR TOPICAL REPORT ANP-10297P-A, REVISION 0, SUPPLEMENT 1, THE ARCADIA REACTOR ANALYSIS SYSTEM FOR PWRs METHODOLOGY DESCRIPTION AND BENCHMARKING RESULTS FRAMATOME, INC.
PROJECT NO. 728/DOCKET NO. 99902041 This attachment provides the U.S. Nuclear Regulatory Commission (NRC) staffs review and disposition of the comments made by Framatome Inc. (formerly AREVA Inc.) on the draft safety evaluation for Topical Report ANP-10297P-A, Revision 0, Supplement 1, The ARCADIA Reactor Analysis System for PWRs Methodology Description and Benchmarking Results.
NRC Resolution of Page Line Proposed Change/Comment Proposed Change/Comment 1 37, 40 Delete coupled together and The NRC staff agrees with the coupled. APOLLO2-A is not coupled editorial suggestion. Change with ARTEMIS' in the typical usage of implemented in final SE.
this term. APOLLO2-A generates cross section data files that are used by ARTEMIS'.
1 38 Replace COBRA-FLX with COBRA- The NRC staff agrees with the FLX'. editorial suggestion. Change implemented in final SE.
2 16, 17, Replace COBRA-FLX with COBRA- The NRC staff agrees with the 24 FLX'. editorial suggestion. Change implemented in final SE.
2 22-23 Delete coupled together. APOLLO2-A The NRC staff agrees with the is not coupled with ARTEMIS' in the editorial suggestion. Change typical usage of this term. APOLLO2-A implemented in final SE.
generates cross section data files that are used by ARTEMIS'.
7 8-9 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
9 9 Highlighted information is proprietary The NRC staff agrees with the since it may reveal the specific editorial suggestion. Change interaction being described. Add implemented in final SE.
proprietary brackets.
9 28-29 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
Attachment
NRC Resolution of Page Line Proposed Change/Comment Proposed Change/Comment 11 3-4 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
12 23 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
13 11, 12, Highlighted information is proprietary. The NRC staff agrees with the 14, 17, Add proprietary brackets. editorial suggestion. Change 25, 26, implemented in final SE.
42 14 18, 33 [ Replace Inconel with Alloy-718. The NRC staff agrees with the Inconel is a registered trademark and editorial suggestion. Change the generic term should have been implemented in final SE.
used in the RAI response. ]
15 1, 2 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
17 15 Replace The NRC does not currently The NRC staff agrees with the review and approve applications to editorial suggestion. Change MOX fuels. with The NRC did not implemented in final SE.
review ARCADIA for applications to MOX fuels. Framatome believes this statement is accurate and less confusing.
18 1, 15 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
19 31 The NRC staff agrees with the Replace [ unloaded ] with [ non-Gd-editorial suggestion. Change loaded ] to provide clarity.
implemented in final SE.
19 37, 38 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
21 15, 40 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
25 1 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
NRC Resolution of Page Line Proposed Change/Comment Proposed Change/Comment 27 43 Delete in a stand-alone state to avoid The NRC staff agrees with the confusion and for consistency with editorial suggestion. Change Limitations and Conditions #5. implemented in final SE.
28 46 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
29 6, 7 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
29 11-14 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
29 31-32, Highlighted information is proprietary. The NRC staff agrees with the 46 Add proprietary brackets. editorial suggestion. Change implemented in final SE.
30 4, 10 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
30 30 Replace five with five sets of. The NRC staff agrees with the editorial suggestion. Change implemented in final SE.
31 7 Replace five with five sets of. The NRC staff agrees with the editorial suggestion. Change implemented in final SE.
31 39, 40, Highlighted information is proprietary. The NRC staff agrees with the 42, 43 Add proprietary brackets. editorial suggestion. Change implemented in final SE.
32 15, 23, Highlighted information is proprietary. The NRC staff agrees with the 24, 48, Add proprietary brackets. editorial suggestion. Change 49 implemented in final SE.
33 16-17 Replace the NRC does not review and The NRC staff agrees with the approve applications to MOX fuels. editorial suggestion. Change with the NRC did not review implemented in final SE.
ARCADIA for applications to MOX fuels. Framatome believes this statement is accurate and less confusing.
33 27, 28 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
NRC Resolution of Page Line Proposed Change/Comment Proposed Change/Comment 35 12, 14 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
36 18, 21 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
37 11, 48 Replace ARCADIA with The NRC staff agrees with the ARTEMIS'. editorial suggestion. Change implemented in final SE.
38 40-41 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
39 39-40 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
41 15 Highlighted information is proprietary. The NRC staff agrees with the Add proprietary brackets. editorial suggestion. Change implemented in final SE.
51 Table Highlighted information is proprietary. The NRC staff agrees with the 3.5 Add proprietary brackets. editorial suggestion. Change implemented in final SE.
NRC Resolution of Page Line Proposed Change/Comment Proposed Change/Comment 53 35-36 Framatome does not believe that a NRC staff agrees. Lines 35-restriction on cycle length is 36 on page 53 have been appropriate. Shorter, or premature, updated to remove reference cycle lengths are covered by the to a cycle length range.
validation suite. The validation also included burnups approaching licensing The following text was added limits so any cycle length that does not to clarify the intent of the exceed licensed burnup limits is within original wording:
the range of applicability.
Additionally, the ARCADIA code system, as presented in Supplement 1, may be considered applicable for analyses up to 71 GWd/MTU rod average burnup. The range of burnup is based on the NRC staffs assessment of the capability of APOLLO2-A to predict nuclear data.
However, this should not be interpreted as allowance to operate fuel beyond currently licensed burnup limits as explicitly stated (e.g., in the latest approved version of COPERNIC, Reference 17) and implicitly indicated throughout Framtomes licensing methodology.
54 2-3 Replace continuous comparisons to NRC staff agrees. Lines 2-3 measured plant data with on page 54 have been comparisons to measured plant data updated with the following text:
as needed (e.g., application of ARCADIA to a current cycle) to avoid Additionally, Framatome will ambiguity on the interpretation of make comparisons to continuous comparisons. measured plant data as needed (e.g., application of ARCADIA to a current cycle) to ensure there is no drift
NRC Resolution of Page Line Proposed Change/Comment Proposed Change/Comment 54-57 Section Framatome requests that this entire NRC staff partially agrees.
3.9.3 section be removed and replaced with Lines 8-39 on page 54 that NRCs latest evaluation of the code describe Framatomes change process that requires submittal proposed change process of changes for confirmation that the have been retained. Lines 40-change is within the scope of the 41 on page 54 have been approved methodology. The current updated with the following text:
section as written, including the evaluation of different categories of contain nuances that may changes, is incompatible with the latest not be consistent with the draft evaluation. reviewed and approved methodology described in the TR and would therefore warrant further examination.
Line 43 on page 54 through line 23 on page 57 have been deleted and replaced with the latest NRC staff evaluation of the change process.
Line 25 on page 57 has been updated with the following text:
Any changes must ensure 58 Item 4 Replace COBRA-FLX with COBRA- The NRC staff agrees with the FLX'. editorial suggestion. Change implemented in final SE.
NRC Resolution of Page Line Proposed Change/Comment Proposed Change/Comment 59 Items 6, Replace the two limitations associated NRC staff agrees. Item 7 on 7 with the change process with a page 59 has been deleted.
limitation that is consistent with NRCs Item 6 on page 59 has been latest draft evaluation of the code updated with the following text:
change process.
- 6. Any changes made to the ARCADIA code system must:
- a. ensure the validation suite acceptance criteria (Table 10-2 of Supplement 1) remain applicable,
- b. be consistent with the methodology described in ANP-10297P, as supplemented, and
- c. not invalidate the NRC staffs SE.
In instances where it is unclear if a change is consistent with the approved methodology, Framatome may submit descriptions of a change to the NRC for confirmation that the change is within the scope of the approved methodology, as discussed in Section 3.9.3 of this SE.
(This is a new condition from this SE) 60 1, 2 Replace COBRA-FLX with COBRA- The NRC staff agrees with the FLX'. editorial suggestion. Change implemented in final SE.
NRC Resolution of Page Line Proposed Change/Comment Proposed Change/Comment 60 19-28 Replace the two limitations associated NRC staff agrees. Limitation 7 with the change process with a on page 60 has been deleted.
limitation that is consistent with NRCs Limitation 6 on page 60 has latest draft evaluation of the code been updated with the change process. following text:
- 6. Any changes made to the ARCADIA code system must:
- a. ensure the validation suite acceptance criteria (Table 10-2 of Supplement 1) remain applicable,
- b. be consistent with the methodology described in ANP-10297P, as supplemented, and
- c. not invalidate the NRC staffs SE.
In instances where it is unclear if a change is consistent with the approved methodology, Framatome may submit descriptions of a change to the NRC for confirmation that the change is within the scope of the approved methodology, as discussed in Section 3.9.3 of this SE.
(This is a new condition from this SE)