PLA-7841, Thirty-Day Response to Request for Additional Information Regarding Proposed License Amendment Requesting Application of Advanced Framatome Methodologies

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Thirty-Day Response to Request for Additional Information Regarding Proposed License Amendment Requesting Application of Advanced Framatome Methodologies
ML20037A098
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 02/06/2020
From: Cimorelli K
Susquehanna, Talen Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML20037A097 List:
References
PLA-7841
Download: ML20037A098 (45)
v • d • e


Text

Attachment 1 and Enclosure 1 Contain Proprietary Information -

Withhold in Accordance with 10 CFR 2.390 Kevin Cimorelli Susquehanna Nuclear, LLC Site Vice President 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3795 Fax 570.542.1504 Kevin.Cimorelli@TalenEnergy.com February 6, 2020 Attn: Document Control Desk 10 CFR 50.90 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION THIRTY-DAY RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT REQUESTING APPLICATION OF ADVANCED FRAMATOME METHODOLOGIES Docket No. 50-387 PLA-7841 and 50-388

References:

1) Susquehanna letter to NRC, Proposed Amendment to Licenses NPF-14 and NPF-22: Application of Advanced Framatome Methodologies and TSTF-535 (PLA-7783), dated July 15, 2019 (ADAMS Accession No. ML19196A270)
2) NRC letter to Susquehanna, Requests for Additional Information for Susquehanna Steam Electric Station, Units 1 and 2 to Support Review of the License Amendment Request Regarding Application of Framatome Methodologies to Support Transition to ATRIUM 11 Fuel, dated January 6, 2020 (ADAMS Accession No. ML20010D201)
3) Susquehanna letter to NRC, Request for Due Date Extension to Respond to a Request for Additional Information (PLA-7837), dated January 16, 2020 (ADAMS Accession No. ML20016A337)

Pursuant to 10 CFR 50.90, Susquehanna Nuclear, LLC (Susquehanna), submitted, in Reference 1, a request for an amendment to the Technical Specifications (TS) for the Susquehanna Steam Electric Station (SSES), Units 1 and 2, Facility Operating License numbers NPF-14 and NPF-22. The proposed amendment would revise TS 5.6.5.b to allow application of Advanced Framatome Methodologies for determining core operating limits in support of loading Framatome fuel type ATRIUM 11, revise the low pressure safety limit in TS 2.1.1.1 and TS 2.1.1.2, and remove the neutronic methods penalties on Oscillation Power Range Monitor

Document Control Desk PLA-7841 amplitude setpoint and the pin power distribution uncertainty and bundle power con*elation coefficient.

The NRC provided a Request for Additional Information (RAI) in Reference 2. Attachments 1 and 2 provide the Framatome responses to Questions 1, 2.2 through 4.4.b, and 2.1 subparts b and c. In the response to Question 2.2.a, it is stated that files containing the data requested therein have been provided. Those files are listed in Attachment 4 and provided in Enclosure 1.

Information provided in Attachment 1 is considered proprietary to Framatome. The proprietary information has been denoted therein by brackets. Further, the data files provided in Enclosure 1 are also considered proprietary to Framatome in their entirety. As owners of the proprietary information, Framatome has executed affidavits for the documents which identify the information as proprietary, is customarily held in confidence, and should be withheld from public disclosure in accordance with 10 CFR 2.390. Attachment 2 provides a non-proprietary version of Attachment 1. Because the data files in Enclosure 1 are considered proprietary in their entirety, a non-proprietary version of the enclosure has not been provided. The Framatome affidavits are included as Attachment 3 for the RAI responses and Attachment 5 for the data files included in Enclosure 1. provides the response to Question 5 as well as additional information regarding Question 3. In Reference 2, the NRC indicated that the response to the RAI is due by February 6, 2020, except for the response to Question 2, which was due by March 6, 2020. In Reference 3, Susquehanna requested that be extended to April 6, 2020, for Question 2.1.a, and has provided the response to all other questions in this letter.

Susquehanna has reviewed the information supporting a finding ofNo Significant Hazards Consideration and the Environmental Consideration provided to the NRC in Reference 1 and determined the information provided herein does not impact the original conclusions in Reference 1.

There are no new or revised regulatory commitments contained in this submittal.

Should you have any questions regarding this submittal, please contact Ms. Melisa Krick, Manager - Nuclear Regulatory Affairs, at (570) 542-1818.

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

Executed on:

Document Control Desk PLA-7841 Attachments:

1. Framatome Topical Report ANP-3823P, Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information [Proprietary Information - Withhold from Public Disclosure in accordance with 10 CFR 2.390]
2. Framatome Topical Report ANP-3823NP, Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information (Non-Proprietary Version)
3. Framatome Affidavit for ANP-3823P, Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information
4. List of Data Files in Enclosure 1
5. Framatome Affidavit for Enclosure 1 to Susquehanna Letter PLA-7841, Thirty-Day Response to Request for Additional Information Regarding Proposed License Amendment Requesting Application of Advanced Framatome Methodologies
6. Susquehanna Response to RAI Questions 3 and 5

Enclosure:

1. Data Files Supporting Response to Question 2.2.a [Proprietary Information -

Withhold from Public Disclosure in Accordance with 10 CFR 2.390]

Copy: NRC Region I Ms. L. Micewski, NRC Sr. Resident Inspector Ms. S. Goetz, NRC Project Manager Mr. M. Shields, PA DEP/BRP (w/out Attachment 1 or Enclosure 1)

Attachment 2 of PLA-7841 Framatome Topical Report ANP-3823NP Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information (Non-Proprietary Version)

For Information Only Susquehanna ATRIUM 11 ANP-3823NP Revision 0 Advanced Methods Response to Request for Additional Information January 2020

© 2020 Framatome Inc.

For Information Only ANP-3823NP Revision 0 Copyright © 2020 Framatome Inc.

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

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page i Nature of Changes Section(s)

Item or Page(s) Description and Justification.

1 All New Document

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page ii Contents Page INTRODUCTION ............................................................................................................ IV 1.0 CONTAINMENT ................................................................................................ 1-1 2.0 ANTICIPATED OPERATIONAL OCCURENCES (AOOS) AND ATWS ................................................................................................................ 2-1 3.0 FUEL: INTRODUCTION OF ATRIUM 11 FUEL TO SUSQUEHANNA ............................................................................................... 3-1 4.0 LOSS OF COOLANT ACCIDENT (LOCA) ........................................................ 4-1 5.0 DEGRADATION AFFECTS ............................................................................... 5-1

6.0 REFERENCES

.................................................................................................. 6-1 List of Tables Table 4-1 Disposition of Operating Domains and Equipment Out-of-Service .............. 4-2 Table 4-2 Local Oxidation [ ] ................................................................ 4-3 List of Figures Figure 4-1 [ ] LHGR vs. Exposure ...................................... 4-5 Figure 4-2 [ ] LHGR vs. Exposure ........................................ 4-6 Figure 4-3 [ ] MAPLHGR Limit .................................. 4-7

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page iii Nomenclature Acronym Definition AOO Anticipated Operational Occurrence ATWS Anticipated Transients Without Scram BOC Beginning of Cycle BWR Boiling Water Reactor CFR Code of Federal Regulations CHF Critical Heat Flux CPR Critical Power Ratio ECCS Emergency Core Cooling System EOC End of Cycle EOOS Equipment out-of-service FoM Figure of Merit GDC General Design Criteria LAR License Amendment Request LHGR Linear Heat Generation Rate LOCA Loss of Coolant Accident LTR Licensing Topical Report LTSS Long-Term Stability Solution MAPLHGR Maximum Average Planar Linear Heat Generation Rate MCPR Minimum Critical Power Ratio MELLLA Maximum Extended Load Line Limit Analysis MSIV Main Steam Isolation Valve NRC Nuclear Regulatory Commission PCT Peak Cladding Temperature FSAR Final Safety Analysis Report RSAR Reload Safety Analysis Report SLO Single Loop Operation SRV Safety Relief Valve TTNB Turbine Trip No Bypass

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page iv INTRODUCTION By letter dated July 15, 2019, Talen Energy submitted a license amendment request (LAR) for Susquehanna Steam Electric Station, Units 1 and 2 (Susquehanna) to allow application of the Framatome analysis methodologies necessary to support a planned transition to ATRIUM 11 fuel under the currently licensed Maximum Extended Load Line Limit Analysis (MELLLA) operating domain, Reference 1 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19196A270). Upon review of the submittal, the NRC staff provided requests for additional information (RAIs) in an email dated 1/6/2020 (Reference 2). This document provides responses to those RAIs.

The proprietary information in this document is marked with single brackets such as

[ ].

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 1-1 1.0 CONTAINMENT NRC RAI 1. Regulatory Basis - Title 10, Energy of the Code of Federal Regulations (10 CFR), Section 50, General Design Criteria (GDCs) 16, 38, and 50 In Section 8.3 of ANP-3753P of the LAR, the licensee states that fuel design differences may impact the power and pressure excursion experienced during an anticipated transient without scram (ATWS) event. The licensee further stated that ATRIUM-10 analysis bounds the ATRIUM 11 fuel because [

]

a. Describe the analysis done to justify that [

].

b. Provide quantitative results for the containment pressure and suppression pool temperature response changes due to the change in fuel type. Describe the analyses performed to confirm the ATRIUM-10 analysis bounds the ATRIUM 11 fuel transition.

Response 1.a:

Analysis to confirm that [

]

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 1-2

[

]

Response 1.b:

The Framatome description of the approach for evaluating containment impacts and results of that evaluation are described in Section 8.3 of Reference 3. This approach is based on [ ]. A review of the current licensing basis for Susquehanna ATWS containment shows that peak suppression pool temperature for MELLLA was 206 °F and the peak containment pressure was 16.1 psig, Table 9-4 of Reference 6. [

]

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-1 2.0 ANTICIPATED OPERATIONAL OCCURENCES (AOOS) AND ATWS Regulatory Basis - 10 CFR 50, GDCs 10, 13, 15, 20, 25, 26, and ATWS acceptance criteria NRC RAI 2.1 ANP-3753P and ANP-3783P provide a subset of the events analyzed in the Susquehanna Chapter 15 Updated Final Safety Analysis Report (UFSAR) and covered by the AURORA-B AOO/ATWS methodology. To ensure the methodology is implemented appropriately for the events not covered in ANP-3753P and ANP-3783P, provide the following:

a. Describe how each Chapter 15 UFSAR event (that is covered by the AURORA-B AOO/ATWS methodology) will be analyzed in the AURORA-B AOO methodology framework (e.g., a table identifying UFSAR Section/Event Name/Disposition)
b. Describe how the methodology is implemented (including steps prior to the execution of the uncertainty analysis) to ensure nuclear power plant - specific options are covered in the analyses.
c. Void quality correlation uncertainties are discussed in Section 6.1 of ANP-3753P. Provide information about which parameters are sampled and which parameters are biased. How is a conservative approach ensured regarding the sampled and biased parameters?

Response 2.1.a:

To be provided later.

Response 2.1.b:

Once the disposition of events has been completed, a calculation plan is constructed.

The calculation plan defines the minimum analysis set required to license a given cycle.

The events to be analyzed are defined by the disposition of events. The calculation plan will also define all operational flexibility options that are to be supported. These include items such as equipment out-of-service options (EOOS) and exposure windows.

The calculation plan is generated on a cycle specific basis and is reviewed and approved by Talen. Note that the calculation plan defines the minimum set of analyses

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-2 required to license a cycle. Additional analyses may be added during the evaluation process if unexpected trends arise. These are added on an as-needed basis to ensure that the limits are appropriately conservative.

The statepoints to be analyzed are also defined in the calculation plan. The initial transition to AURORA-B methods will include [

]

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-3 Response 2.1.c:

[

]

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-4 NRC RAI 2.2 To ensure there is appropriate coverage of the parameters used in the uncertainty analysis and to ensure there is no significant trends with respect to the uncertainty parameters in the results such that the Susquehanna implementation of the AURORA-B methodology is sufficient, provide the following for the load rejection no bypass/turbine trip without bypass event at 100% power / 108% flow, main steam isolation valve closure ATWS event at 100% power and 99% flow, and high pressure coolant injection event at 100% power / 108% flow:

a. The sampled values of the uncertainty parameters for all cases executed in the set
b. The figure of merit results for all cases executed in the set Response 2.2.a:

Files containing the requested data have been provided. CKSUM identification is provided below.

3675706268 43303 100P108F_EOC_TTNB_LRNB.xlsx 2158763815 43650 100P99F_BOC_ATWS.xlsx 1416056480 49678 100P108F_EOC_HPCI.xlsx Response 2.2.b:

See response 2.2.a.

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-5 NRC RAI 2.3 Please provide the schedule for Reload Safety Analysis Report (RSAR) submittal. Discuss how the information in the RSAR is used to confirm the AURORA-B limitations and conditions in ANP-2637P, Boiling Water Reactor Licensing Methodology Compendium, Rev. 8, are appropriately applied.

Response 2.3:

The initial application cycle RSAR report is scheduled to be provided for information in November 2020. The approved AURORA-B AOO topical report, Reference 7, contains several limitations and conditions that require plant specific review. In addition those items that require plant-specific review are split into two categories: those that are provided as part of the initial submittal (initial LAR submittal) and those that are provided as part of the initial application (first transition licensing reports). The items that are provided with the initial submittal are generally found in References 3 and 8. There remains four plant specific L&Cs to be provided for the initial application, L&Cs 7, 11, 16, and 18a. The application of the L&Cs to the Susquehanna licensing evaluations are discussed below:

Limitation and Condition 7 As discussed in Section 3.6 of this SE, licensees should provide justification for the key plant parameters and initial conditions selected for performing sensitivity analyses on an event-specific basis. Licensees should further justify that the input values ultimately chosen for these key plant parameters and initial conditions will result in a conservative prediction of FoMs when performing calculations according to the AURORA-B EM described in ANP-10300P.

As part of the initial preparations for licensing Susquehanna, Framatome will review the plant parameters document for the key parameters associated with the potentially limiting events. We would also look for parameters that have a range of values that may be allowed for operational flexibility. Likewise, for initial conditions, we will examine the range allowed during normal operation. This will include initial conditions such as power, flow, pressure, and inlet subcooling. We will perform sensitivity studies for all of

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-6 these key parameters/conditions for all FoM (MCPR, LHGR, and overpressure) and

[ ]

Limitation and Condition 11 AREVA will provide justification for the uncertainties used for the highly ranked plant specific PIRT parameters C12, R01, R02, and SL02 on a plant-specific basis, as described in Table 3.2 of this SE.

The parameter C12 is the [

]

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-7

[

]

Limitation and Condition 16

[ ] is not sampled as part of the methodology, justification should be provided on a plant-specific basis that a conservative flow rate has been assumed [ ]

The [ ] is provided by Talen in the plant parameters document. This flow accounts for [ ]. The AURORA-B model [

]

Limitation and Condition 18a Plant-specific licensing applications shall describe and provide justification for the method for determining and applying conservative measures in future deterministic analyses for each FoM (e.g. , biasing calculational inputs, postprocessing adjustments to calculated nominal results).

For licensing calculations at Susquehanna, [

]

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-8 For the LHGRFACp evaluations [

]

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-9 NRC RAI 2.4 Section 5.4 of ANP-3753P describes the safety limit minimum critical power ratio methodology at SUSQUEHANNA. This methodology is used to determine that 99.9% of the fuel rods are expected to avoid boiling transition during normal reactor operation and anticipated operation occurrences. The analysis provided by the licensee shows that

[

] Please provide the approach used to confirm the bounds will be checked in the appropriate assemblies of the core for future reloads. What process is applied if [

]?

Response 2.4:

[

]. These uncertainties are used in SAFLIM3D to account for the nodal rod power uncertainty due to channel bow.

[

]

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-10

[

]

NRC RAI 2.5 In the AOO event analysis in ANP-3753P, the load rejection no bypass event is combined with the turbine trip without bypass event even though plant systems may respond differently for each event. Justify that one event bounds the other without doing explicit analysis for both events.

Confirm that the bounding analysis can be determined by combining these two events.

Response 2.5:

Per Section 15.2.3 of the Susquehanna FSAR:

The turbine trip with the steam bypass system failed is defined as closure of the turbine stop valves followed almost immediately by closure of all turbine control valves with coincident failure of the turbine bypass valves to open. The generator load rejection without bypass is defined as the rapid closure of all of the turbine control valves followed by the closure of all of the turbine stop valves with coincident failure of the turbine bypass valves to open.

The differences between the load rejection without bypass and the turbine trip without bypass events which may impact the severity of the events is the order of the valve closures/closure characteristics and the resultant delay to scram.

By starting closure of the turbine control valves and turbine stop valves concurrently, the effective rate of steam flow isolation is increased resulting in more rapid core pressurization and a larger power spike than either of the non-concurrent events.

Reactor scram mitigates the consequences of each of the events. Accounting for the time to reach the turbine stop valve position scram setpoint, the delay from the start of turbine stop valve motion to the start of reactor scram is the same as the delay from the start of turbine control valve motion to the start of reactor scram. For the combined event, reactor scram occurs at the same time as either of the non-combined events.

Therefore, the severity of the combined event bounds either of the non-combined events.

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 3-1 3.0 FUEL: INTRODUCTION OF ATRIUM 11 FUEL TO SUSQUEHANNA NRC RAI 3 Regulatory basis -10 CFR 50, GDCS 10, 13, 15, 20, 25, 26, and ATWS Acceptance Criteria GDC 10 requires that specified acceptable fuel design limits are not exceeded during normal operation including the effects of AOOs.

Oxidation and hydriding are two specified acceptable fuel design limits that ensure components maintain strength and ductility. Section 3.5.1 of ANP-3762P mentions that water chemistry is controlled to reduce oxidation in the fuel channel. Please describe what process is used to control the water chemistry and what are the key figures-of-merit monitored to ensure satisfactory performance of ATRIUM 11 fuel and the Z4B water channel.

Response 3:

In order to ensure satisfactory fuel and water channel performance, the utility is required to operate the plant water chemistry in accordance with the EPRI BWR Water Chemistry Guidelines (BWRVIP-190). The key figures of merit for water chemistry are those defined as Needed or Control parameters in Chapter 2 of BWRVIP-190, Volume 1. The measurement frequencies and operating limits for these parameters are defined in the Guidelines, as is the response timeline for any excursions. Any deviations from the Guidelines requirements for Needed or Control parameters must be justified by the utility and documented in the plants Strategic Water Chemistry Plan.

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 4-1 4.0 LOSS OF COOLANT ACCIDENT (LOCA)

Regulatory Basis -10 CFR 50, GDCS 10, 13, 15, 20, 25, 26, and ATWS Acceptance Criteria The regulatory bases for the following LOCA related requests for additional information are the requirements contained in 10 CFR 50.46, Acceptance Criteria for Emergency Core Cooling Systems for Light-Water Nuclear Power Reactors, insofar as they establish the requirements and acceptance criteria for emergency core cooling system (ECCS) design, and for the evaluation models used to evaluate ECCS performance during a hypothetical LOCA. Specific considerations include:

  • CFR 50.46(a)(1)(i) requires the use of an acceptable evaluation models to evaluate ECCS performance under the conditions of a hypothetical LOCA, and 10 CFR 50.46(a)(1)(ii) allows for the development of an evaluation models that conforms to the required and acceptable features specified in Appendix K to 10 CFR 50.
  • CFR 50.46(a)(1)(i) also requires ECCS cooling performance to be calculated for a number of postulated LOCAs of different sizes, locations, and other properties sufficient to provide assurance that the most severe hypothetical LOCAs are calculated.
  • Acceptance criteria set forth in paragraph (b) of 10 CFR 50.46, and the results of the ECCS evaluation must show that the acceptance criteria are met. Among others, these include requirements related to peak cladding temperature (PCT),

maximum cladding oxidation, and maximum hydrogen generation.

NRC RAI 4.1 For licensed operating domain and equipment-out-of-service, please provide justification to assure that the LOCA analysis has been performed conservatively to cover Susquehanna licensed operating domain and equipment out-of-service conditions.

Response 4.1:

Table 4-1 summarizes the disposition of the operating domains and equipment out-of-service (OOS) conditions applicable to LOCA presented in ANP-3784P, Rev. 0.

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 4-2 Table 4-1 Disposition of Operating Domains and Equipment Out-of-Service Operating Disposition Result or Rationale Domain MELLLA Analyzed [

]

SLO Analyzed [

]

NRC RAI 4.2 For, limiting PCT: Explain why the limiting PCT of [

] of exposure-dependent LOCA analysis.

Response 4.2:

The break spectrum calculations were performed [

]

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 4-3 NRC RAI 4.3 For local Cladding Oxidation (Table 9.1 of ANP-3784P): Explain why the change of local cladding oxidation from the assembly average planar exposure of [

].

Response 4.3:

The abrupt change in local oxidation is due to [

]

Table 4-2 Local Oxidation [ ]

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 4-4 NRC RAI 4.4 Linear heat generation rate (LHGR) and maximum average planar LGHR (MAPLHGR) Data Used in Exposure-Dependent Analysis

a. What is the process for determining the LHGR used, for both UO2 and Gd2O3-UO2 pellets during exposure-dependent analysis, in the AURORA-B LOCA analysis? Specifically, are the LHGR limit curves presented in Figures 2.2 and 2.3 shown in ANP-3784P, Susquehanna ATRIUM 11 Introduction - Exposure-Dependent LOCA Analysis, [

]

b. Please demonstrate the analysis margin for the MAPLHGR limit in Figure 2.1 of ANP-3784P, [

].

Response 4.4.a:

The LHGR limit curves presented in Figures 2.2 and 2.3 from the exposure analysis

[

]

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 4-5 Figure 4-1 [ ] LHGR vs. Exposure

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 4-6 Figure 4-2 [ ] LHGR vs. Exposure

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 4-7 Response 4.4.b:

Figure 4-3 shows the [ ] MAPLGHR limit [

]

Figure 4-3 [ ] MAPLHGR Limit

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 5-1 5.0 DEGRADATION AFFECTS NRC RAI 5 Please address how the implementation of Atrium 11 fuel affects the aging degradation on the reactor vessel pressure and reactor pressure internal components.

Regulatory Basis - 10 CFR 50, GDCS 10, 13, 15, 20, 25, 26, and ATWS Acceptance Criteria If the neutron fluence values associated with Atrium 11 are higher than the Atrium 10 fuel, the licensee should provide a technical explanation how it intends to manage the aging degradation related to irradiation embrittlement, irradiation-assisted stress corrosion cracking, and, irradiation stress relaxation at Susquehanna units in the current licensing period.

Response 5:

To be provided by Talen.

For Information Only Framatome Inc. ANP-3823NP Revision 0 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 6-1

6.0 REFERENCES

1. Talen Energy, Susquehanna Steam Electric Station Proposed Amendment to Licenses NPF-14 AND NPF-22: Application of Advanced Framatome Methodologies And TSTF-535 PLA-7783, July 15, 2019, (ADAMS Accession No. ML19196A270).
2. Email, (USNRC) to Shane Jurek (Talen Energy), Requests For Additional Information for Susquehanna Steam Electric Station, Units 1 And 2 to Support Review of The License Amendment Request Regarding Application Of Framatome Methodologies to Support Transition to Atrium 11 Fuel, (EPID: L-2019-LLA-0153), January 6, 2020.
3. ANP-3753P Revision 0, Applicability of Framatome BWR Methods to Susquehanna with ATRIUM 11 Fuel, Framatome Inc., May 2019.
4. BAW-10247PA Revision 0, Realistic Thermal Mechanical Fuel Rod Methodology for Boiling Water Reactors, AREVA NP Inc., February 2008.
5. ANP-10307PA Revision 0, AREVA MCPR Safety Limit Methodology for Boiling Water Reactors, AREVA NP, June 2011.
6. Susquehanna Steam Electric Station Units 1 and 2 Safety Analysis Report for Constant Pressure Power Uprate, ML062900401, October 2006.
7. ANP-10300P-A Revision 1, AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Transient and Accident Scenarios, Framatome Inc., January 2018.
8. ANP-3783P Revision 0, Susquehanna ATRIUM 11 Transient Demonstration, June 2019.

Attachment 3 of PLA-7841 Framatome Affidavit for ANP-3823P, Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information

AFFIDAVIT

1. My name is Alan B. Meginnis. I am Manager, Product Licensing, for Framatome Inc. and as such I am authorized to execute this Affidavit.
2. I am familiar with the criteria applied by Framatome to determine whether certain Framatome information is proprietary. I am familiar with the policies established by Framatome to ensure the proper application of these criteria.
3. I am familiar with the Framatome information contained in the report ANP-3823P Revision 0, "Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information," dated January 2020 and referred to herein as "Document."

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

4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by Framatome and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."
6. The following criteria are customarily applied by Framatome to determine whether information should be classified as proprietary:

(a) The information reveals details of Framatome'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 Framatome.

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

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

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

7. In accordance with Framatome'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 Framatome only as required and under suitable agreement providing for nondisclosure and limited use of the information.
8. Framatome policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

Alan Meginnis STATE OF WASHINGTON ss.

COUNTY OF BENTON SUBSCRIBED before me this ;2-f$t day of Jtfnunr t , 2020.

Katherine Kerr NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 9/12/2022

Attachment 4 of PLA-7841 List of Data Files in Enclosure 1 File Name Size (kB) 100P108F_EOC_TTNB_LRNB.xlsx 43 100P99F_BOC_ATWS.xlsx 43 100P108F_EOC_HPCI.xlsx 49

Attachment 5 of PLA-7841 Framatome Affidavit for Enclosure 1 to Susquehanna Letter PLA-7841, Thirty-Day Response to Request for Additional Information Regarding License Amendment Requesting Application of Advanced Framatome Methodologies

AFFIDAVIT

1. My name is Alan B. Meg innis. I am Manager, Product Licensing, for Framatome Inc. and as such I am authorized to execute this Affidavit.
2. I am familiar with the criteria applied by Framatome to determine whether certain Framatome information is proprietary. I am familiar with the policies established by Framatome to ensure the proper application of these criteria.
3. I am familiar with the Framatome information contained in the computer files named 1OOP1 08F_EOC_TTNB_LRNB.xlsx, 1OOP99F_BOC_A TWS.xlsx, and 1OOP1 08F_EOC_HPCI.xlsx which are included as Enclosure 1 to Susquehanna Letter PLA-7841, "Thirty-Day Response to Request for Additional Information Regarding Proposed License Amendment Requesting Application of Advanced Framatome Methodologies," and referred to herein as "Documents." Information contained in these Documents has been classified by Framatome as proprietary in accordance with the policies established by Framatome for the control and protection of proprietary and confidential information.
4. These Documents contain information of a proprietary and confidential nature and are of the type customarily held in confidence by Framatome and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in these Documents as proprietary and confidential.
5. These Documents have been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in these Documents be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure

is requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."

6. The following criteria are customarily applied by Framatome to determine whether information should be classified as proprietary:

(a) The information reveals details of Framatome'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 Framatome.

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

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

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

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

"\ "'

~\_j.?ez~~-

Aian Meginnis {!3?

STATE OF WASHINGTON ss.

COUNTY OF BENTON SUBSCRIBED before me this 2 9 fJ, day of JctV!uary , 2020.

Katherine Kerr NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 9/12/2022

Attachment 6 of PLA-7841 Susquehanna Response to RAI Questions 3 and 5

Attachment 6 to PLA-7841 Page 1 of 3 Response to Request for Additional Information On July 15, 2019, Susquehanna Nuclear, LLC (Susquehanna) submitted a license amendment request (LAR) for the Susquehanna Steam Electric Station (SSES). Specifically, Susquehanna requested a revision to Technical Specification (TS) 5.6.5.b to allow application of Advanced Framatome Methodologies for determining core operating limits in support of loading Framatome fuel type ATRIUM 11, the low pressure safety limit in TS 2.1.1.1 and TS 2.1.1.2, and removal of the neutronic methods penalties on Oscillation Power Range Monitor amplitude setpoint and the pin power distribution uncertainty and bundle power correlation coefficient. By letter dated January 6, 2020, the NRC requested additional information. Additional information regarding the response to Question 3 and the complete response to Question 5 of this Request for Additional Information (RAI) is provided below.

NRC RAI Question 3 Regulatory Basis - 10 CFR 50, GDCs [General Design Criteria] 10, 13, 15, 20, 25, 26, and ATWS [Anticipated Transient without a Scram] Acceptance Criteria GDC 10 requires that specified acceptable fuel design limits are not exceeded during normal operation including the effects of AOOs [Anticipated Operational Occurrences]. Oxidation and hydriding are two specified acceptable fuel design limits that ensure components maintain strength and ductility. Section 3.5.1 of ANP-3762P mentions that water chemistry is controlled to reduce oxidation in the fuel channel. Please describe what process is used to control the water chemistry and what are the key figures-of-merit monitored to ensure satisfactory performance of ATRIUM 11 fuel and the Z4B water channel.

Susquehanna Response In order to ensure satisfactory fuel and water channel performance, Susquehanna operates the plant water chemistry in accordance with the Electric Power Research Institute (EPRI) Boiling Water Reactor (BWR) Water Chemistry Guidelines (BWRVIP-190). The key figures of merit for water chemistry are those defined as Mandatory or Needed parameters in Chapter 2 of BWRVIP-190, Volume 1. The measurement frequencies and operating limits for these parameters are defined in the guidelines, as is the response timeline for any excursions. Any deviations from the guidelines requirements for Mandatory or Needed parameters must be justified by Susquehanna and documented in the SSES Strategic Water Chemistry Plan.

The BWR Water Chemistry Program at SSES implements the EPRI BWRVIP-190, BWR Vessel and Internals Project, BWR Water Chemistry Guidelines, to ensure relevant chemistry parameters that impact fuel assembly components are sampled, monitored, and controlled properly. Specifications for conditions, practices, and limits necessary to achieve the required

Attachment 6 to PLA-7841 Page 2 of 3 water chemistry program performance are controlled by plant procedures and tracked using the Chemistry Sampling Schedule, Analysis, and Controls (SSA&C) Matrix. Directives exist in the Chemistry SSA&C Matrix and plant procedures for the Susquehanna Chemistry department to notify the Nuclear Fuels organization of chemistry incidents that impact fuel and report, investigate, and resolve adverse conditions in accordance with the station Corrective Action Program. The Susquehanna Water Chemistry Program, therefore, encompasses appropriate steps for measuring and controlling chemistry parameters significant to fuel performance to ensure the integrity of fuel assembly components. Additionally, a reload risk assessment will be performed for the introduction of ATRIUM 11 fuel that will evaluate potential impacts to fuel performance and water chemistry parameters consistent with BWR fuel reliability guidelines.

NRC RAI Question 5 Please address how the implementation of Atrium 11 fuel affects the aging degradation on the reactor vessel pressure and reactor pressure internal components.

Regulatory Basis - 10 CFR 50, GDCs 10, 13, 15, 20, 25, 26, and ATWS Acceptance Criteria If the neutron fluence values associated with Atrium 11 are higher than the Atrium 10 fuel, the licensee should provide a technical explanation how it intends to manage the aging degradation related to irradiation embrittlement, irradiation-assisted stress corrosion cracking, and, irradiation stress relaxation at Susquehanna units in the current licensing period.

Susquehanna Response One of the benefits of the ATRIUM 11 fuel design is that smaller reload batch sizes will be required. To successfully design a core with smaller reload batch sizes, a greater number of older bundles are moved to the periphery core locations. Due to their higher exposures, the older bundles will have lower fission power and, therefore, generate fewer fast neutrons at the core periphery when compared to an ATRIUM 10 core. Based on this general understanding of the core physics, the expectation is that the neutron fluence at the reactor pressure vessel (RPV) wall, and also for beltline components located within the RPV (e.g., core shroud, jet pump components), will decrease.

An analysis of the fast neutron fluence in the RPV plates, welds, and nozzles throughout the beltline region, determined at 60 years, has been completed using the NRC-approved RAMA fluence methodology. The fast neutron fluence was determined in accordance with the guidelines and requirements presented in NRC Regulatory Guide (RG) 1.190, Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence, (ADAMS Accession No. ML010890301). The damage fluence determined at the 1/4T and 3/4T depths in the RPV wall were determined using the displacements-per-atom attenuation method prescribed in RG 1.99, Radiation Embrittlement of Reactor Vessel Materials, (ADAMS Accession No.

Attachment 6 to PLA-7841 Page 3 of 3 ML031430205). A review of the analysis results determined that the fast neutron fluence levels at the reactor vessel wall throughout the beltline region with ATRIUM 11 fuel is lower than with ATRIUM 10 fuel when analyzed out to 60 years. Similarly, an analysis was performed for RPV beltline internal components (e.g., core shroud, jet pump components, top guide, core plate) using the same methods as described above. A review of the results determined that the fast neutron fluence levels in the RPV beltline internal components with ATRIUM 11 fuel is lower than with ATRIUM 10 fuel when analyzed out to 60 years. These results are consistent with the fundamental understanding of the core physics for ATRIUM 11 fuel.

Based on the above discussion, the change from ATRIUM 10 fuel to ATRIUM 11 fuel results in a lower fast neutron fluence for both the RPV and components located within the RPV. Based on this result, there is no effect on the aging degradation due to the transition to ATRIUM 11 fuel. Therefore, there are no changes to the current aging management program.

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