RA-18-0241, Update to Request for License Amendment Regarding Application of Advanced Framatome Methodologies

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Update to Request for License Amendment Regarding Application of Advanced Framatome Methodologies
ML18333A029
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 11/28/2018
From: William Gideon
Duke Energy Progress, Framatome
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML18333A028 List:
References
RA-18-0241
Download: ML18333A029 (40)
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Text

William R. Gideon Vice President Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 Enclosure 1 Contains Proprietary Information o: 910.832.3698 Withhold in Accordance with 10 CFR 2.390 November 28, 2018 Serial: RA-18-0241 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Update to Request for License Amendment Regarding Application of Advanced Framatome Methodologies

Reference:

Letter from William R. Gideon (Duke Energy) to the U.S. Nuclear Regulatory Commission Document Control Desk, Request for License Amendment Regarding Application of Advanced Framatome Methodologies, dated October 11, 2018, ADAMS Accession Number ML18284A395.

Ladies and Gentlemen:

By letter dated October 11, 2018 (i.e., Reference), Duke Energy Progress, LLC (Duke Energy),

submitted a license amendment request (LAR) for the Brunswick Steam Electric Plant (BSEP),

Unit Nos. 1 and 2. The proposed license amendment revises Technical Specification 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.

Revision 0 of Framatome Report ANP-3705P, Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel, was provided as Enclosure Attachment 5a of the subject LAR.

During a recent review of this report, Framatome discovered a discrepancy with the discussion of ATRIUM 11 void fraction correlation information located in Section 5.1 of ANP-3705P. As a result, ANP-3705P was revised (i.e., Revision 1) to correct this discussion and to provide additional clarifying information in other sections. This letter transmits ANP-3705P, Revision 1.

Enclosures 1, 2, and 3 of this letter (i.e., relating to ANP-3705P, Revision 1) replace the subject LAR Enclosure Attachments 5a, 5b, and 5c (i.e., relating to ANP-3705P, Revision 0), in their entirety, respectively. (i.e., ANP-3705P, Revision 1) contains information considered proprietary to Framatome. The proprietary information in this report has been denoted by brackets. As owner of the proprietary information, Framatome has executed the affidavit contained in Enclosure 3 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 the non-proprietary version of this report (i.e., ANP-3705NP, Revision 1).

U.S. Nuclear Regulatory Commission Page 2 of 3 Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 832-2487.

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on November 28, 2018.

s~

William R. Gideon SBY/sby

Enclosures:

1: ANP-3705P, Applicability of Framatome BWR Methods to Brunswick with A TR/UM 11 Fuel, Revision 1 [Proprietary Information - Withhold from Public Disclosure in Accordance with 10 CFR 2.390]

2: ANP-3705NP, Applicability of Framatome BWR Methods to Brunswick with A TR/UM 11 Fuel, Revision 1 3: Affidavit for ANP-3705P, Applicability of Framatome BWR Methods to Brunswick with A TR/UM 11 Fuel, Revision 1

U.S. Nuclear Regulatory Commission Page 3 of 3 cc (with all Enclosures):

U. S. Nuclear Regulatory Commission, Region II ATTN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Mr. Gale Smith, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Mr. Dennis J. Galvin (Mail Stop OWFN 8B1A) 11555 Rockville Pike Rockville, MD 20852-2738 cc (with Enclosures 2 and 3 only):

Chair - North Carolina Utilities Commission (Electronic Copy Only) 4325 Mail Service Center Raleigh, NC 27699-4300 swatson@ncuc.net Mr. W. Lee Cox, III, Section Chief (Electronic Copy Only)

Radiation Protection Section North Carolina Department of Health and Human Services 1645 Mail Service Center Raleigh, NC 27699-1645 lee.cox@dhhs.nc.gov

RA-18-0241 Enclosure 2 ANP-3705NP, Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel, Revision 1

Controlled Document

[Status]

Applicability of Framatome ANP-3705NP Revision 1 BWR Methods to Brunswick with ATRIUM 11 Fuel November 2018 (c) 2018 Framatome Inc.

Controlled Document ANP-3705NP Revision 1 Copyright © 2018 Framatome Inc.

All Rights Reserved ATRIUM, ULTRAFLOW, FUELGUARD, Z4B, and S-RELAP5 are trademarks or registered trademarks of Framatome (formerly known as AREVA Inc.) or its affiliates, in the USA or other countries.

Controlled Document Framatome Inc. [Status] ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page i Nature of Changes Section(s)

Item or Page(s) Description and Justification 1 2-1 Section 2, 2nd paragraph added up to and including the EPU/extended flow window domain to second sentence and changed validated to justified in the third sentence.

2 2-3 Corrected the title for XN-NF-84-105-(P)(A) Volume 1 and Volume 1 Supplements 1 and 2 3 5-1 Replaced Section 5.1.

4 5-4 Third paragraph replace Brunswick with the validation of the MICROBURN-B2 pressure drop model 5 5-6 Table 5-3, changed from LTP Grid loss coefficient adder to PHTF combined inlet loss coefficient. Adjusted proprietary brackets in the footnotes.

6 5-7 Added proprietary brackets to Figure 5-1.

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page ii Contents Page

1.0 INTRODUCTION

............................................................................................... 1-1 2.0 OVERVIEW ....................................................................................................... 2-1 3.0 ATRIUM 11 FUEL ASSEMBLY DESIGN........................................................... 3-1 4.0 MECHANICAL LIMITS METHODOLOGY ......................................................... 4-1 5.0 THERMAL HYDRAULICS ................................................................................. 5-1 5.1 ATRIUM 11 Void Fraction ....................................................................... 5-1 5.2 ACE/ATRIUM 11 Critical Power Ratio Correlation .................................. 5-1 5.3 Loss Coefficients .................................................................................... 5-4 6.0 TRANSIENTS AND ACCIDENTS...................................................................... 6-1 6.1 Void Quality Correlation Uncertainties .................................................... 6-1 6.2 Assessment of the Void-Quality Correlation ........................................... 6-2 7.0 ATWS ................................................................................................................ 7-1 7.1 ATWS General........................................................................................ 7-1 7.2 Void Quality Correlation Bias .................................................................. 7-1 7.3 ATWS Containment Heatup.................................................................... 7-2 8.0 NEUTRONICS ................................................................................................... 8-1 8.1 Shutdown Margin .................................................................................... 8-1 8.2 Monitoring ............................................................................................... 8-1 8.3 Power Distribution Uncertainty................................................................ 8-1 8.4 Bypass modeling .................................................................................... 8-2

9.0 REFERENCES

.................................................................................................. 9-1

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page iii List of Tables Table 2-1 Framatome Licensing Topical Reports ...................................................... 2-2 Table 3-1 Fuel Assembly and Component Description .............................................. 3-3 Table 3-2 Fuel Channel and Fastener Description .................................................... 3-4 Table 5-1 ACE/ATRIUM 10XM Bounds Checking ..................................................... 5-3 Table 5-2 Comparison of the Range of Applicability for the ATRIUM 11 and ATRIUM 10XM Correlations ...................................................................... 5-3 Table 5-3 Hydraulic Characteristics of ATRIUM 11 Fuel Assemblies ........................ 5-6 Table 7-1 [

] ...................................................................................... 7-3 List of Figures Figure 1-1 Brunswick Power Flow Operating Map with the MELLLA+ EPFOD .......... 1-2 Figure 5-1 Measured versus Predicted (MICROBURN-B2) Bundle Pressure Drop........................................................................................................... 5-7

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page iv Nomenclature (If applicable)

Acronym Definition ACE Framatomes advanced critical power correlation [

]

ASME American Society of Mechanical Engineers ATWS anticipated transient without scram BWR boiling water reactor CHF critical heat flux CPR critical power ratio DIVOM delta-over-Initial CPR versus oscillation magnitude EPFOD Extended Power Flow Operating Domain EPU extended power uprate KATHY Karlstein thermal hydraulic test facility LHGR linear heat generation rate LOCA loss of coolant accident MELLLA+ Maximum Extended Load Line Limit Analysis Plus MCPR minimum critical power ratio NRC Nuclear Regulatory Commission, U. S.

OLMCPR operating limit minimum critical power ratio PLFR part length fuel rod SLMCPR safety limit minimum critical power ratio SER safety evaluation report TIP traversing incore probe

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 1-1

1.0 INTRODUCTION

This document reviews the Framatome approved licensing methodologies to demonstrate that they are applicable to licensing and operation of the Brunswick Nuclear Plant with ATRIUM' 11 in the extended power uprate (EPU) operating domain with a representative power/flow operating map in Figure 1-1 (Extended Flow Domain).

General applicability of Framatome licensing methods to the Brunswick units in the EPU operating domain was discussed in ANP-3108P Revision 1. Application of the new methods added for ATRIUM 11 (ACE ATRIUM 11, RODEX-4 for Chromia doped fuel, AURORA-B AOO, CRDA* and LOCA) for EPU applications are addressed in this document or in plant specific applications of the new methodologies.

This document applies to both Brunswick units since both Brunswick BWR/4s have only minor differences. The most significant difference between the units is the core loadings and corresponding core designs. The impact of the differences in core designs between units and cycles is addressed in the cycle specific reload report for each unit.

Minor differences between the plants and units, such as orifice diameters and bypass valve capacities do not impact the application of Framatomes methodology as presented in this document.

For the introduction of ATRIUM 11 at EPU conditions with extended flow operating domain a review of the RAIs received from previous license applications was used to identify anything that needed to be addressed.

For the Brunswick ATRIUM 11 plant-specific application of CRDA, [ ] has been applied for the startup range evaluations.

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 1-2 Figure 1-1 Brunswick Power Flow Operating Map with the MELLLA+ EPFOD

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 2-1 2.0 OVERVIEW ANP-3108P Revision 1 (Reference 1) demonstrated the applicability of Framatome methods for analyses for ATRIUM 10XM at EPU power levels and extended flow domains. The introduction of ATRIUM 11 fuel coincides with the application of a new modern suite of methodologies (References 2 through 9) that also address a number of industry concerns. This is the first application of the entire suite of new and upgraded methodologies. The design characteristics of the ATRIUM 10XM and ATRIUM 11 are explicitly accounted for in all of the models for operation with EPU and extended flow domains. The differences in fuel design characteristics between the ATRIUM 10XM and ATRIUM 11 are discussed in Section 3.0.

The first step in determining the applicability of current licensing methods to Brunswick operating conditions was a review of Framatome BWR topical reports listed in Table 2-1 to identify SER restrictions. This review identified that there are no SER restrictions on core power level or core flow for the Framatome topical reports up to and including EPU/extended flow window domain. The review also indicated that the [

]. This is discussed in the Thermal Hydraulics section.

Based on the fundamental characteristics of the fuel designs, each of the major analysis domains thermal-mechanics, thermal-hydraulics, mechanics (Reference 10), core neutronics, transient analysis, LOCA (Reference 11) and stability (Reference 12) are assessed to determine any challenges to application.

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 2-2 Table 2-1 Framatome Licensing Topical Reports Document Number Document Title XN-NF-79-56(P)(A) Revision 1 "Gadolinia Fuel Properties for LWR Fuel Safety Evaluation,"

and Supplement 1 Exxon Nuclear Company, November 1981 XN-NF-85-67(P)(A) Revision 1 Generic Mechanical Design for Exxon Nuclear Jet Pump BWR Reload Fuel, Exxon Nuclear Company, September 1986 XN-NF-85-92(P)(A) "Exxon Nuclear Uranium Dioxide/Gadolinia Irradiation Examination and Thermal Conductivity Results," Exxon Nuclear Company, November 1986 ANF-89-98(P)(A) Revision 1 "Generic Mechanical Design Criteria for BWR Fuel Designs,"

and Supplement 1 Advanced Nuclear Fuels Corporation, May 1995 ANF-90-82(P)(A) Revision 1 "Application of ANF Design Methodology for Fuel Assembly Reconstitution," Advanced Nuclear Fuels Corporation, May 1995 EMF-93-177(P)(A) "Mechanical Design for BWR Fuel Channels," Framatome ANP, Revision 1 August 2005 EMF-93-177P-A Revision 1 "Mechanical Design for BWR Fuel Channels Supplement 1:

Supplement 1P-A Revision 0 Advanced Methods for New Channel Designs," AREVA Inc.,

September 2013 BAW-10247PA Revision 0 "Realistic Thermal-Mechanical Fuel Rod Methodology for Boiling Water Reactors," AREVA NP, April 2008 XN-NF-80-19(P)(A) Volume 1 "Exxon Nuclear Methodology for Boiling Water Reactors -

and Supplements 1 and 2 Neutronic Methods for Design and Analysis," Exxon Nuclear Company, March 1983 XN-NF-80-19(P)(A) Volume 4 "Exxon Nuclear Methodology for Boiling Water Reactors:

Revision 1 Application of the ENC Methodology to BWR Reloads," Exxon Nuclear Company, June 1986 EMF-CC-074(P)(A) Volume 1 "STAIF - A Computer Program for BWR Stability Analysis in the Frequency Domain," and Volume 2 "STAIF - A Computer Program for BWR Stability Analysis in the Frequency Domain - Code Qualification Report," Siemens Power Corporation, July 1994 EMF-2158(P)(A) Revision 0 "Siemens Power Corporation Methodology for Boiling Water Reactors: Evaluation and Validation of CASMO-4/

MICROBURN-B2," Siemens Power Corporation, October 1999 EMF-CC-074(P)(A) Volume 4, "BWR Stability Analysis Assessment of STAIF with Input from Revision 0 MICROBURN-B2," Siemens Power Corporation, August 2000

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 2-3 Table 2-1 Framatome Licensing Topical Reports (Continued)

Document Number Document Title BAW-10255PA Revision 2 "Cycle-Specific DIVOM Methodology Using the RAMONA5-FA Code," AREVA NP, May 2008 EMF-3028P-A Volume 2 RAMONA5-FA: A Computer Program for BWR Transient Revision 4 Analysis in the Time Domain Volume 2: Theory Manual, AREVA NP, March, 2013 XN-NF-79-59(P)(A) "Methodology for Calculation of Pressure Drop in BWR Fuel Assemblies," Exxon Nuclear Company, November 1983 XN-NF-80-19(P)(A) Volume 3 "Exxon Nuclear Methodology for Boiling Water Reactors, Revision 2 THERMEX: Thermal Limits Methodology Summary Description,"

Exxon Nuclear Company, January 1987 ANP-10298PA Revision 1 "ACE/ATRIUM 10XM Critical Power Correlation," AREVA, March 2014 ANP-10307PA Revision 0 "AREVA MCPR Safety Limit Methodology for Boiling Water Reactors," AREVA NP, June 2011 XN-NF-84-105(P)(A) Volume 1 "XCOBRA-T: A Computer Code for BWR Transient Thermal-and Volume 1 Supplements 1 Hydraulic Core Analysis," Exxon Nuclear Company, February and 2 1987 EMF-2292(P)(A) Revision 0 "ATRIUM'-10: Appendix K Spray Heat Transfer Coefficients,"

Siemens Power Corporation, September 2000 ANF-1358(P)(A) Revision 3 The Loss of Feedwater Heating Transient in Boiling Water Reactors, Framatome ANP, September 2005 BAW-10247PA, Realistic Thermal-Mechanical Fuel Rod Methodology for Boiling Supplement 1P-A, Revision 0 Water Reactors Supplement 1: Qualification of RODEX4 for Recrystallized Zircaloy-2 Cladding BAW-10247P-A, Realistic Thermal-Mechanical Fuel Rod Methodology for Boiling Supplement 2P-A, Revision 0 Water Reactors Supplement 2: Mechanical Methods ANP-10340PA Revision 0 Incorporation of Chromium-Doped Fuel in AREVA Approved Methods ANP-10335P-A Revision 0 ACE/ATRIUM 11 Critical Power Correlation

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 2-4 Table 2-1 Framatome Licensing Topical Reports (Continued)

Document Number Document Title ANP-10300P-A Revision 0 AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Transient and Accident Scenarios ANP-10332P Revision 0 and AURORA-B: An Evaluation Model for Boiling Water Reactors; Draft Safety Evaluation Application to Loss of Coolant Accident Scenarios ANP-10333P-A Revision 0 AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Control Rod Drop Accident Scenarios

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 3-1 3.0 ATRIUM 11 FUEL ASSEMBLY DESIGN The ATRIUM 11 fuel assembly design consists of a lower tie plate (LTP) and upper tie plate (UTP), 112 fuel rods, 9 spacer grids, a central water channel, and miscellaneous assembly hardware.

The fuel design utilizes a square internal water channel which occupies nine (3x3) lattice positions. The upper and lower ends of the water channel are attached to connecting hardware which provides a load chain between the upper and lower tie plates.

The 11x11 rod array is comprised of 92 full length fuel rods, 8 long part length fuel rods (PLFR) and 12 short PLFRs. The PLFRs are captured in the LTP grid to prevent axial movement.

The fuel rod pitch is slightly larger in the upper section of the assembly relative to the fuel rod pitch in the lower section of the assembly. The array of fuel rods remain orthogonal throughout the assembly.

The nine ULTRAFLOW' spacers are fabricated from Alloy 718 material and utilize integrated spring and dimple elements. Eight spacers are axially distributed over the heated length, while a ninth spacer is located just above the LTP to restrain the lower ends of the fuel rods.

The fuel assembly design reflects improvements to keep debris out of the fuel assembly. The LTP and UTP designs are now modular to take advantage of optimized components within those major component assemblies. The UTP has a spacer-like grid construction that provides a lower pressure drop and closed openings where larger debris could enter the top of the fuel assembly. The LTP utilizes the 3rd Generation FUELGUARD' (3GFG) filter insert that is captured within a two piece assembly of frame and transition piece. The inlet region of the transition piece can be configured to provide similar pressure drop characteristics of co-resident fuel designs.

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 3-2 The new fuel channel uses the Advanced Fuel Channel (AFC) design configuration.

This design has exterior machining between the corners and for ATRIUM 11, introduces additional interior milling of the [ ]. This provides additional [ ]. To address channel bow, the desired and default material is [

]

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 3-3 Table 3-1 Fuel Assembly and Component Description

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 3-4 Table 3-2 Fuel Channel and Fastener Description

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 4-1 4.0 MECHANICAL LIMITS METHODOLOGY The LHGR limit is established to support plant operation while satisfying the fuel mechanical design criteria. The methodology for performing the fuel rod evaluation is described in References 4 through 6. The extension of these methods to fuel incorporating chromia is described in Reference 7. Fuel rod design criteria evaluated by the methodology are contained in References 4 and 13.

Fuel rod power histories are generated as part of the methodology for equilibrium cycle conditions as well as cycle-specific operation. These power histories include the impact of channel bow as described in Reference 4. A comprehensive number of uncertainties are taken into account in the categories of operating power uncertainties, code model parameter uncertainties, and fuel manufacturing tolerances. In addition, adjustments are made to the power history inputs for possible differences in planned versus actual operation. Upper limits on the analysis results are obtained for comparison to the design limits for fuel melt, cladding strain, rod internal pressure and other topics as described by the design criteria.

Since the power history inputs, which include LHGR, fast neutron flux, reactor coolant pressure and reactor coolant temperature, are used as input to the analysis, the results explicitly account for conditions representative of the ATRIUM 11 operation. The resulting LHGR limit is used to monitor the fuel so it is maintained within the same maximum allowable steady-state power envelope as analyzed.

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 5-1 5.0 THERMAL HYDRAULICS 5.1 ATRIUM 11 Void Fraction The [ ] void-quality correlation has been qualified by Framatome against both the FRIGG void measurements, ATRIUM-10 and ATRIUM 10XM measurements. The standard deviation for the FRIGG tests was shown to be [ ]

while the standard deviation for the ATRIUM-10 and ATRIUM 10XM tests was found to be [ ] respectively. [

] the use of the [ ] correlation for ATRIUM 11 is justified. A discussion can be found in Appendix B of Reference 1 on the applicability of the [ ] correlation.

The ATRIUM 11 [ ] void fraction measurements. S-RELAP5 was assessed against previous measurements based upon fundamental hydraulic characteristics. The Marviken assembly of FRIGG had a 2-sigma error of [ ] in void prediction. The ATRIUM-10 has a 2-sigma error of

[ ] for void. [ ]; therefore, the use of a 2-sigma error of [ ] is justified for the ATRIUM 11.

5.2 ACE/ATRIUM 11 Critical Power Ratio Correlation The critical power ratio (CPR) correlation used in MICROBURN-B2, SAFLIM3D, S-RELAP5, RAMONA5-FA, X-COBRA, and X-COBRA-T is based on the ACE/ATRIUM 11 critical power correlation described in Reference 8. As with all Framatome correlations, the range of applicability is enforced in Framatome methods through automated bounds checking and corrective actions. The ATRIUM 11 bounds checking process is the same as the ATRIUM 10XM as provided in Table 5-1. The ACE CPR correlation uses K-factor values to account for rod local peaking, rod location and bundle geometry effects.

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 5-2 The K-factor parameter is described in detail in Section 6.10 of Reference 8.

The ranges of applicability of the ACE/ATRIUM 11 and ACE/ATRIUM 10XM are compared in Table 5-2

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 5-3 Table 5-1 ACE/ATRIUM 10XM Bounds Checking Table 5-2 Comparison of the Range of Applicability for the ATRIUM 11 and ATRIUM 10XM Correlations

  • The information on the ACE/ATRIUM 10XM correlation is provided in this document for the purpose of comparison to the ACE/ATRIUM 11 correlation only. Reference 8 should not be used for any licensed application of the ACE/ATRIUM 10XM correlation. For Information Only

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 5-4 5.3 Loss Coefficients Wall friction and component loss coefficients were determined for Brunswick based on single-phase testing of a prototypic ATRIUM 11 fuel assembly in the Portable Hydraulic Test Facility (PHTF). Prototypical fuel rods, spacer grids, flow channel, upper tie plate and lower tie plate were used in the testing. A description of the PHTF facility and an overview of the process for determining the component loss coefficients are described in Reference 14.

The ATRIUM 11 PHTF tests form the basis for the single phase loss coefficients currently used for design and licensing analyses supporting U.S. BWRs. The PHTF is used by Framatome to obtain single phase loss coefficients for the spacers. The friction factor correlation is a Reynolds dependent function based on the Moody friction model and the measured surface roughness. The pressure drops across the spacers are measured in the PHTF for each new design. [

]

The wall friction and component loss coefficients determined from the PHTF and utilized in the validation of the MICROBURN-B2 pressure drop model for the ATRIUM 11 fuel design are provided in Table 5-3.

PHTF data was reduced to determine single phase losses for the spacers in the [

] of the bundle. The values have been selected because they are representative of the hydraulic characteristics of actual ATRIUM 11 fuel assemblies loaded into the reactor.

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 5-5 The modeling of the two-phase spacer pressure drop multiplier for the ATRIUM 11 fuel design has been confirmed with two-phase pressure drop measurements taken in the KATHY facility.

Figure 5-1 shows measured versus the MICROBURN-B2 predicted two phase pressure drop for a range of conditions. This figure confirms the applicability of the thermal-hydraulic models to predict pressure drop for the ATRIUM 11 design.

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 5-6 Table 5-3 Hydraulic Characteristics of ATRIUM 11 Fuel Assemblies

  • Loss coefficients are referenced to the adjacent assembly bare rod flow area.

[

]

Controlled Document Framatome Inc. [Status] ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 5-7 Figure 5-1 Measured versus Predicted (MICROBURN-B2) Bundle Pressure Drop

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 6-1 6.0 TRANSIENTS AND ACCIDENTS 6.1 Void Quality Correlation Uncertainties The Framatome analyses methods and the correlations used are applicable for all Framatome designs in EPU conditions. The approach for addressing the void-quality correlation bias and uncertainties remains unchanged and is applicable for Brunswick operation with the ATRIUM 11 fuel design.

The OLMCPR is determined based on the safety limit MCPR (SLMCPR) methodology and the transient analysis (CPR) methodology. Void-quality correlation uncertainty is not a direct input to either of these methodologies; however, the impact of void-correlation uncertainty is inherently incorporated in both methodologies as discussed below.

The SLMCPR methodology explicitly considers important uncertainties in the Monte Carlo calculation performed to determine the number of rods in boiling transition. One of the uncertainties considered in the SLMCPR methodology is the bundle power uncertainty. This uncertainty is determined through comparison of calculated to measured core power distributions. Any miscalculation of void conditions will increase the error between the calculated and measured power distributions and be reflected in the bundle power uncertainty. Therefore, void-quality correlation uncertainty is an inherent component of the bundle power uncertainty used in the SLMCPR methodology.

The transient analyses methodology is a combination of deterministic, bounding analyses and a statistical evaluation of the impact of model uncertainties that contains conservatism in addition to uncertainties in individual phenomena. Conservatism is incorporated in the methodology in two ways: (1) computer code models are developed to produce conservative results on an integral basis relative to benchmark tests, and (2) important input parameters are biased in a conservative direction in licensing calculations.

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 6-2 The transient analyses methodology results in predicted power increases that are bounding relative to benchmark tests. In addition, for licensing calculations a multiplier is applied to the calculated integral power to provide additional conservatism to account for uncertainties in individual phenomena as defined in the transient analyses methodology. Therefore, uncertainty in the void-quality correlation is inherently incorporated in the transient analysis methodology.

In addition to the impact of void-quality correlation uncertainty being inherently incorporated in the analytical methods used to determine the OLMCPR, biasing of important input parameters in licensing calculations provides additional conservatism in establishing the OLMCPR. No additional adjustments to the OLMCPR are required to address void-quality correlation uncertainty.

6.2 Assessment of the Void-Quality Correlation As discussed in Section 5.1, the [ ] is equally applicable to the ATRIUM 11 applications at Brunswick.

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 7-1 7.0 ATWS 7.1 ATWS General The AURORA-B methodology is used for the ATWS overpressurization analysis. The ACE/ATRIUM 11 critical power correlation pressure limit is not a factor in the analysis.

Dryout might occur in the limiting (high power) channels of the core during the ATWS event. For the ATWS overpressurization analysis, ignoring dryout for the hot channels is conservative in that it maximizes the heat transferred to the coolant and results in a higher calculated pressure.

The ATWS event is not limiting relative to acceptance criteria identified in 10 CFR 50.46. The core remains covered and adequately cooled during the event. Following the initial power increase during the pressurization phase, the core returns to natural circulation conditions after the recirculation pumps trip and fuel cladding temperatures are maintained at acceptable low levels. The ATWS event is significantly less limiting than the loss of coolant accident relative to 10 CFR 50.46 acceptance criteria.

7.2 Void Quality Correlation Bias Framatome performs cycle-specific ATWS analyses of the short-term reactor vessel peak pressure using the AURORA-B methodology. The ATWS peak pressure calculation is a core-wide pressurization event that is sensitive to similar phenomenon as other pressurization transients. Bundle design is included in the development of input for the coupled neutronic and thermal-hydraulic S-RELAP5 core model. Important inputs to the S-RELAP5 system model are biased in a conservative direction.

The Framatome transient analysis methodology is a deterministic, bounding approach that contains sufficient conservatism and evaluates uncertainties in individual phenomena. As demonstrated in Section 5.1 the void-quality correlation is robust for past and present designs including the ATRIUM 11.

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 7-2 The reference ATWS analysis evaluation presented in the topical report (Reference 2) of the core active density response, which is closely related to the void quality correlation, showed minimal changes in the peak vessel pressure. A study was also performed for the ASME overpressure event (FWCF) with similar results.

7.3 ATWS Containment Heatup Fuel design differences may impact the power and pressure excursion experienced during the ATWS event. This in turn may impact the amount of steam discharged to the suppression pool and containment.

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Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 7-3

[

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Table 7-1 [

]

  • Boron worth is quoted as a positive value since it refers to the boron defect. The ppm boron used is 720 at 68 F. The calculation uses the equivalent boron at 360.8 F, used in BRK SLCS calculations.

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 8-1 8.0 NEUTRONICS From the neutronics perspective, the ATRIUM 11 fuel design differs from the ATRIUM-10XM fuel design primarily in the fuel rod pitch and position and number of the part length rods. The CASMO-4 code is designed to model a wide range of fuel rod pitches. The neutronic models have already been demonstrated to accurately model the vacant positions and this continues to be true for the ATRIUM 11 fuel design.

8.1 Shutdown Margin The part length rod in the corner of the assembly improves the shutdown margin performance of the fuel design because of the flux trap that is created in the cold condition with the vacant rod position of all four assemblies in a control cell being in close proximity. The heterogeneous solution of CASMO-4 accurately models the vacant rod position and the associated reactivity. No change in predicted hot operating or cold critical eigenvalue is anticipated with the ATRIUM 11 fuel design.

8.2 Monitoring The part length rod in the corner of the assembly has an impact on the corner flux that influences the detector response. The heterogeneous solution of CASMO-4 accurately calculates this corner flux depression. This characterization is used directly in the MICROBURN-B2 determination of the predicted detector response. For the Brunswick analyses the plena have been explicitly modeled with the heterogeneous CASMO-4 model, thus providing the most accurate model available.

8.3 Power Distribution Uncertainty No significant change in the uncertainty of the predicted detector response relative to the measurements is anticipated.

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 8-2 8.4 Bypass modeling The bypass behavior of the ATRIUM 11 fuel design is identical to the ATRIUM-10XM fuel design, thus there is no difference in the modeling. Any differences in bypass heat deposition are treated explicitly.

Controlled Document Framatome Inc. ANP-3705NP Revision 1 Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel Page 9-1

9.0 REFERENCES

1. ANP-3108P Revision 1, "Applicability of AREVA BWR Methods to Brunswick Extended Power Flow Operating Domain," AREVA Inc., July 2015.
2. ANP-10300P-A Revision 1, "AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Transient and Accident Scenarios," Framatome Inc.,

January 2018.

3. ANP-10333P-A Revision 0, "AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Control Rod Drop Accident (CRDA) ," Framatome Inc.,

March 2018

4. BAW-10247PA Revision 0, "Realistic Thermal-Mechanical Fuel Rod Methodology for Boiling Water Reactors, " AREVA NP Inc., February 2008.
5. BAW-10247PA Revision 0 Supplement 1P-A, "Realistic Thermal-Mechanical Fuel Rod Methodology for Boiling Water Reactors Supplement 1: Qualification of RODEX4 for Recrystallized Zircaloy-2 Cladding," AREVA Inc., April 2017.
6. BAW-10247 Supplement 2P-A, "Realistic Thermal-Mechanical Fuel Rod Methodology for Boiling Water Reactors Supplement 2: Mechanical Methods,"

Framatome Inc., August 2018.

7. ANP-10340PA Revision 0, "Incorporation of Chromia-Doped Fuel Properties in AREVA Approved Methods," Framatome Inc., May 2018.
8. ANP-10335P-A Revision 0, "ACE/ATRIUM 11 Critical Power Correlation,"

Framatome Inc., May 2018.

9. EMF-93-177P-A Revision 1 Supplement 1P-A Revision 0 "Mechanical Design for BWR Fuel Channels Supplement 1: Advanced Methods for New Channel Designs," AREVA Inc., September 2013.
10. ANP-3686P Revision 0, "Mechanical Design Report for Brunswick ATRIUM 11 Fuel Assemblies," Framatome Inc., August 2018.
11. ANP-3674P&NP Revision 0, "Brunswick Units 1 and 2 LOCA Analysis for ATRIUM 11 Fuel," Framatome Inc., August 2018.
12. ANP-3703P Revision 0, "Best Estimate Option-III Analysis Methodology for Brunswick Using RAMONA5-FA," Framatome Inc., August 2018.
13. ANF-89-98(P)(A) Revision 1 and Supplement 1, "Generic Mechanical Design Criteria for BWR Fuel Designs," Advanced Nuclear Fuels Corporation, May 1995.
14. I.K. Madni, et al., "Development of Correlations for Pressure Loss/Drop Coefficients Obtained From Flow Testing of Fuel Assemblies In Framatome ANPS PHTF," Paper Number 22428, Proceedings of ICONE10, Arlington, VA, April 14-18,2002.

RA-18-0241 Enclosure 3 Affidavit for ANP-3705P, Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel, Revision 1

AFFIDAVIT STATE OF WASHINGTON )

) ss.

COUNTY OF BENTON )

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-3705P, Revision 1 "Applicability of Framatome BWR Methods to Brunswick with ATRIUM 11 Fuel," dated November 2018 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(a), 6(b), 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.

SUBSCRIBED before me this _ _,_j __,Cj.__+h_

day of t\/ove,,,m bex: ,2018.

~m*t!J~

Hailey M Siekawitch NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 9/28/2020

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