PLA-7853, Ninety-Day Response to Request for Additional Information Regarding Proposed License Amendment Requesting Application of Advanced Framatome Methodologies PLA-7853
| ML20092K063 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/01/2020 |
| From: | Cimorelli K Susquehanna, Talen Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20092K062 | List: |
| References | |
| PLA-7853 | |
| Download: ML20092K063 (40) | |
Text
Enclosure 1 Contains 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 April 1, 2020 Attn: Document Control Desk 10 CFR 50.90 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION NINETY-DAY RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT REQUESTING APPLICATION OF ADVANCED FRAMATOME METHODOLOGIES PLA-7853 Docket No. 50-387 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).
- 4) NRC email to Susquehanna, Re: Susquehanna Request for RAI Response Due Date Extension, dated February 4, 2020.
- 5) Susquehanna letter to NRC, Thirty-Day Response to Request for Additional Information Regarding Proposed License Amendment Requesting Application of Advanced Framatome Methodologies (PLA-7841), dated February 6, 2020 (ADAMS Accession No. ML20037A098).
Document Control Desk PLA-7853 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 amplitude setpoint and the pin power distribution uncertainty and bundle power correlation coefficient.
The NRC provided a Request for Additional Information (RAI) in Reference 2 with required response dates of March 6, 2020, for Question 2 and February 6, 2020, for all other questions. In Reference 3, Susquehanna requested that the required response date for Question 2.1.a be extended to April 6, 2020, and stated that the responses to all other questions would be provided by February 6. In Reference 4, the NRC approved that request. In Reference 5, Susquehanna provided the response to all questions from the Reference 2 RAI except for Question 2.1.a.
Enclosures 1 and 2 to this letter provide Susquehannas response to Question 2.1.a. The response is provided in the form of a revision to Framatome Topical Report ANP-3823P, which was transmitted as Attachment 1 to Reference 5 (non-proprietary version provided in to Reference 5). The only changes from Revision 0 to Revision 1 of ANP-3823P are the inclusion of the response to RAI Question 2.1.a in Section 2.0 and resulting updates to the nomenclature section on pages iii and iv; no other changes were made to the document or the associated data files previously provided.
Information provided in Enclosure 1 is considered proprietary to Framatome. The proprietary information has been denoted therein by brackets. As owners of the proprietary information, Framatome has executed an affidavit for the document which identifies the information as proprietary, is customarily held in confidence, and should be withheld from public disclosure in accordance with 10 CFR 2.390. Enclosure 2 provides a non-proprietary version of Enclosure 1.
The Framatome affidavit is included as Enclosure 3.
Susquehanna has reviewed the information supporting a finding of No 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 petjury that the foregoing is true and co11*ect.
Executed on:
~~11-i~~~~:~~~
Enclosures:
Document Control Desk PLA-7853
- 1. Framatome Topical Report ANP-3823P, Revision 1, "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, Revision 1, "Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information" (Non-Proprietary Version)
- 3. Framatome Affidavit for ANP-3823P, Revision 1, "Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information" 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 Enclosure 1)
of PLA-7853 Framatome Topical Report ANP-3823NP, Revision 1 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information (Non-Proprietary Version)
Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information ANP-3823NP Revision 1 March 2020
© 2020 Framatome Inc.
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ANP-3823NP Revision 1 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.
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ANP-3823NP Revision 1 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page i Nature of Changes Item Section(s) or Page(s)
Description and Justification.
1 Section 2.0 Provided RAI Response 2.1.a on page 2-1.
2 Nomenclature Updated nomenclature related to Item 1.
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ANP-3823NP Revision 1 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
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ANP-3823NP Revision 1 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 FWCF Feedwater Controller Failure FSAR Final Safety Analysis Report GDC General Design Criteria HPCI High Pressure Coolant Injection LAR License Amendment Request LFWH Loss of Feedwater Heating LHGR Linear Heat Generation Rate LOCA Loss of Coolant Accident LRNB Load Rejection No Bypass LTR Licensing Topical Report LTSS Long-Term Stability Solution MAPLHGR Maximum Average Planar Linear Heat Generation Rate MCPR Minimum Critical Power Ratio MCPRf Flow-dependent MCPR MELLLA Maximum Extended Load Line Limit Analysis MSIV Main Steam Isolation Valve NRC Nuclear Regulatory Commission For Information Only
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ANP-3823NP Revision 1 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page iv PCT Peak Cladding Temperature PRFO Pressure Regulator Failure Open PROOS Pressure Regulator Out-of-Service RCIC Reactor Core Isolation Cooling RHR Residual Heat Removal RSAR Reload Safety Analysis Report SLO Single Loop Operation SRV Safety Relief Valve TTNB Turbine Trip No Bypass For Information Only
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ANP-3823NP Revision 1 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page v 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
[
].
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ANP-3823NP Revision 1 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 [
]
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ANP-3823NP Revision 1 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. [
]
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ANP-3823NP Revision 1 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:
FSAR Section Event Name Disposition Status Comments 15.1.1 Loss of Feedwater Heater (LFWH)
Address each reload Potentially limiting AOO.
15.1.2 Feedwater Controller Failure (FWCF) -
Maximum Demand Address each reload Potentially limiting AOO.
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ANP-3823NP Revision 1 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-2 FSAR Section Event Name Disposition Status Comments 15.1.3 Pressure Regulator Failure Open (PRFO)
Address for initial reload.
Consequences of this event, relative to AOO thermal operating limits are non-limiting.
If the core voiding due to the depressurization rate is large enough, the sensed vessel water level trip set point (L8) may be reached initiating a turbine and feedwater pump trip early in the transient.
Turbine trip will initiate reactor scram and shut down the reactor. Thermal margins will be better than a typical turbine trip event because of the power reduction initially experienced due to increased core voids in this event.
This event must be evaluated to ensure that the current low MSIV pressure setpoint of 825 psig will protect the lower ACE/ATRIUM 11 pressure bound during the depressurization event.
15.1.4 Inadvertent Safety/Relief Valve Opening No further analysis required The event causes a mild depressurization. Thermal margins decrease only slightly through the transient and no fuel damage results from the transient. Consequences of this event are non-limiting.
15.1.6 Inadvertent RHR Shutdown Cooling Operation No further analysis required This event is not considered credible for power operation.
15.2.1 Pressure Regulator Failure - Closed Address each reload Consequences of this event, relative to one pressure regulator out-of-service (PROOS) may be limiting; therefore, this equipment out-of-service will be addressed each cycle.
15.2.2 Generator Load Rejection with and without bypass (LRNB)
Address each reload This event without bypass operable is a potentially limiting AOO. Load rejection with bypass operable is bound by the load rejection without bypass.
The LRNB and TTNB events can be combined into a single event with the turbine control valves and turbine stop valves being assumed to start their closure at the same time. This assumption can provide a single analysis with consequences that are equal to or bounding of both events.
15.2.3 Turbine Trip with and without bypass (TTNB)
Address each reload This event without bypass operable is a potentially limiting AOO. Turbine trip with bypass operable is bound by the turbine trip with no bypass.
The LRNB and TTNB events can be combined into a single event with the turbine control valves and turbine stop valves being assumed to start their closure at the same time. This assumption can provide a single analysis with consequences that are equal to or bounding of both events.
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ANP-3823NP Revision 1 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-3 FSAR Section Event Name Disposition Status Comments 15.2.4 MSIV Closures No further analyses required Consequences of this event, relative to thermal operating limits, are bound by the generator load rejection and turbine trip events which have much faster valve closure times (FSAR Sections 15.2.2 and 15.2.3, respectively).
15.2.5 Loss of Condenser Vacuum No further analyses required This transient is similar to a normal turbine trip with bypass operable. Consequences of this event are bound by the turbine trip event (FSAR Section 15.2.3).
15.2.6 Loss of AC Power No further analysis required The loss of AC power long-term water level response is bound by the loss of feedwater flow event (FSAR Section 15.2.7).
If complete connection with the external grid is lost, the reactor will experience a generator load rejection. The coastdown of the recirculation pumps initiated at time = 0 will reduce the severity of the event, compared to the generator load rejection event, by reducing core power. Therefore the consequences of this event are bound by the LRNB event (FSAR Section 15.2.2).
15.2.7 Loss of Feedwater Flow No further analyses required This event does not pose any direct threat to the fuel in terms of a thermal power increase from the initial conditions. The fuel will be protected provided the water level inside the shroud does not drop below the top of active fuel. Previous evaluations for a different fuel design showed that the lowest level following a loss of feedwater event remained above L1. The MSIVs do not close and the system pressure remains low. Either the HPCI or RCIC system is capable of maintaining adequate core coverage and will provide inventory control.
The long term water level transient is dependent upon the decay heat which is [
]. This is a benign event.
15.2.9 Failure of RHR Shutdown Cooling No further analysis required Consequences of this event are benign.
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ANP-3823NP Revision 1 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-4 FSAR Section Event Name Disposition Status Comments 15.3.1 Recirculation Pump Trip No further analyses required For the single pump trip event, MCPR remains approximately at the operating limit, thus the fuel thermal margins are not violated. Level swell is not sufficient to cause turbine trip and scram. This is a benign event.
The two pump trip does not directly initiate a scram. The vessel swell due to the rapid flow coastdown is expected to reach the high level trip thereby shutting down the main turbine and feed pump turbines, and indirectly initiating scrams as a result of the main turbine trip. Thus this event is bounded by the turbine trip with no bypass event (FSAR Section 15.2.3).
15.3.2 Recirculation Flow Control Failure -
Decreasing Flow No further analyses required The consequences of this event cannot be more severe than the single or two Recirculation Pump Trip events (FSAR Section 15.3.1).
15.3.3 Recirculation Pump Seizure Address each reload While this event is classified as an accident, it will be conservatively analyzed using the AOO acceptance criteria.
15.3.4 Recirculation Pump Shaft Break No further analyses required The consequences of this accident are bounded by the effects of the pump seizure event (FSAR Section 15.3.3).
15.4.4 Abnormal Startup of Idle Recirculation Pump No further analyses required Consequences of this event are non-limiting.
15.4.5 Recirculation Flow Controller Failure with Increasing Flow Address each reload The slow run-up event determines the MCPRf limits.
15.5.1 Inadvertent HPCI Startup Address each reload This event is a potentially limiting AOO.
15.5.3 BWR Transients Which Increase Reactor Coolant Inventory No further analysis required These events are discussed in FSAR Sections 15.1 and 15.2.
15.6.1 Inadvertent Safety Relief Valve Opening No further analysis required This event is discussed in FSAR Section 15.1.4.
15.8 Anticipated Transient Without Scram Address each reload ATWS overpressurization analyses need to be addressed each reload.
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.
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ANP-3823NP Revision 1 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-5 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 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 [
]
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ANP-3823NP Revision 1 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-6 Response 2.1.c:
[
]
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ANP-3823NP Revision 1 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-7 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.
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ANP-3823NP Revision 1 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-8 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
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ANP-3823NP Revision 1 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-9 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 [
]
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ANP-3823NP Revision 1 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-10
[
]
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, [
]
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ANP-3823NP Revision 1 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-11 For the LHGRFACp evaluations [
]
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ANP-3823NP Revision 1 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-12 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.
[
]
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ANP-3823NP Revision 1 Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information Page 2-13
[
]
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.
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ANP-3823NP Revision 1 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.
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ANP-3823NP Revision 1 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.
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ANP-3823NP Revision 1 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 Domain Disposition Result or Rationale 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 1 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 1 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 1 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 1 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 1 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 1 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 1 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.
For Information Only
of PLA-7853 Framatome Affidavit for ANP-3823P, Revision 1, Susquehanna ATRIUM 11 Advanced Methods Response to Request for Additional Information
- 1.
My name is Aiao B. Meginnis. I am Manager, Product Licensing, for Framatome Inc. and as such f am authorized to execute this Affidavtt 2~
. 1 am familiar with the otiteria
- appJ!ed by*Framatome to determine whether cettam Frarnatome fl1fonnation iS*. proprietary, 1 am familiarwith the poticiesestabtished by Framatome to ensure the proper appliCation of these criteria.
.. ** 3.
- fam fammar Withth~ Framatome informatiorroontained in the report *.
- ANP...S82.3P. Revisioo 1, "Su.squeharma ATRIUM 11 Advanced Methods Response to Request for Addffiorratlnformation," <fated Man'lh 2020 and.referred to herein as "Document';
lnfortnati¢~n co~ained in this Ooeument has been classified by Framatome as proprietary in accordance With the policies eStablished by Framatome for the control and protection of proprletary.and confidential infonnationi 4~
This Document oontains inft:lrf'qat{on of a proprietary and oonfictentiat nature and.lsotthe type customarily hetd inootlfideno.e by.framatome and not made available to the pUbliC; Based E:~tl my ex~flenoe.J am awarettu~t other companies regard information of the
. kind coritained in this Document as proprietarY and* confidential.
- 5.
This Document has been made available to the U.S. Nuclear Regulatory Comrriissi()hJn tffi.nce with the requeSt that the information contained in this Document be wittthetd* trom.public: di$ctosure. The requegtfor withholding *of. proprietary information *is made in accordance<'Mfh 10 CFR 2.39CL The information for which withholding from disclosure is req.uesteti qualifies under *1o CFR 2.390(a}(4) !l>Tr.ade secrets ancl commercial* or financial inrormatron.t>
- 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 pfans 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.
(e)
The information includes test data or analytical techniques concerning a process, methodology t 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 vltaf to a competitive advantage hefd by Framatome, would be helpful to competitors to Framatome. *and would likely cause substantial harm to the competitive position of Framatome.
The information ln the Document is considered proprietary for the reasons set forth in paragraphs 6{b), 6(d) and 6(e} above.
- 7.
In atlcorda.nce wrth 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 ethers outside Framatome only as required and under suitable *agreement providing for nondisclosure and Umited use of the infotmation.
- 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.
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STATE OF WASHINGTON )
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SUBSCRlBED before me this *.* 2.0~ day of. ~
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! 2020.