Text

Supplemental Information in Support of Request for License Amendment Regarding Transition to Areva Fuel
	ML16117A187
Person / Time
Site:	Dresden, Quad Cities
Issue date:	04/26/2016
From:	Simpson P; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RS-16-105
	Download: ML16117A187 (10)
	v • d • e

'1300 W111f1clcl <o cf l/v,ir 'iv II IL r>O r. >

Exelon Generation RS-16-105 10 CFR 50.90 April 26, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Supplemental Information in Support of Request for License Amendment Regarding Transition to AREVA Fuel

References:

( 1) Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Request for License Amendment Regarding Transition to AREVA Fuel," dated February 6, 2015 (2) Letter from U.S. NRC to Bryan Hanson (Exelon Generation Company, LLC), "Dresden Nuclear Power Station, Units 2 and 3 and Quad Cities Nuclear Power Station, Units 1 and 2 - Request for Additional Information Related to the License Amendment Request to Transition to AREVA Fuel (CAC Nos. MF5736, MF5737, MF5738, and MF5739)," dated January 19, 2016 (3) Letter from Patrick R. Simpson {Exelon Generation Company, LLC) to U.S. NRC, "Response to Request for Additional Information Regarding Request for License Amendment Regarding Transition to AREVA Fuel,"

dated January 28, 2016 (4) Email from Timothy A Byam (Exelon Generation Company, LLC) to Russell Haskell (U.S. NRC), "Clarification of Dresden and Quad Cities Fuel Transition RAls," dated March 31, 2016 In Reference 1, Exelon Generation Company, LLC {EGC) requested an amendment to Renewed Facility Operating License Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station {DNPS) Units 2 and 3, and Renewed Facility Operating License Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station {QCNPS) Units 1 and 2. The proposed change supports the transition from Westinghouse SVEA-96 Optima2 (Optima2} fuel to AREVA

April 26, 2016 Nuclear Regulatory Commission Page2 ATRIUM 10XM fuel at DNPS and QCNPS. Specifically, EGG proposes to revise Technical Specification (TS) 5.6.5, "Core Operating Limits Report (COLA)," paragraph b, to delete no longer used methodologies and to add the AREVA analysis methodologies to the list of approved methods to be used in determining the core operating limits in the COLA. Also, in support of the planned transition to AREVA ATRIUM 10XM fuel, EGG proposes to revise DNPS and QCNPS TS 3.2.3, "Linear Heat Generation Rate (LHGR)," and TS 3.7.7, "The Main Turbine Bypass System."

In Reference 2, the NRG requested that EGG provide additional information to support their review of the subject amendment request (i.e., Reference 1). The requested information was provided in the attachments to Reference 3.

Following their review of the RAI responses provided in Reference 3, the NRG contacted EGG and requested a conference call to obtain clarification on several of the RAI responses provided.

Specifically, the reviewers were looking for clarification on the EGG responses to the following four RAls:

RAI 16 RAI 17 RAI 18a and b RAI 21b The conference call was conducted on March 2, 2016 and included participants from EGG, AREVA, and the NRG. It was agreed during the call that the requested clarifications for RAls 17, 18 (partial) and 21 b would be provided by email to Russell Haskell (NRG PM). These clarifications were provided in Reference 4. It was also agreed during the March 2, 2016 teleconference call that EGG would provide the remaining RAI response clarifications in a supplement to Reference 1. The requested clarifications are provided in the attachment to this letter.

EGG has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRG in Attachment 1 of Reference 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. Timothy A. Byam at (630) 657-2818.

April 26, 2016 Nuclear Regulatory Commission Page3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 26th day of April 2016.

Patrick R. Simpson Manager - Licensing

Attachment:

RAI Response Clarification for Dresden and Quad Cities Nuclear Power Stations cc: Regional Administrator- NRC Region Ill NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector- Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT RAI Response Clarification for Dresden and Quad Cities Nuclear Power Stations

IDENTIFICATION REVISION I

FS1-0026562 11 1.0 I AREVA Front End BG Fuel BL A

AREVA TOTAL NUMBER OF PAGES: 6 RAI Response Clarification for Dresden and Quad Cities Nuclear Power Stations ADDITIONAL INFORMATION:

ATRIUM 10XM, Exelon, Dresden, Quad Cities PROJECT DISTRIBUTION TO PURPOSE OF DISTRIBUTION Darrell Carr Tony Will Kevin Elliott HANDLING None Tom Galioto Jeff Morris Sharon Artz EIR - Engineering Ralph Grummer Robert Schnapp Katherine Kerr CATEGORY Information Report Earl Riley CurtisJohnson Susan McCoy Scott Adair Dan Jordheim Alan Meginnis STATUS Mike Anderson Pat McQuade This document is electronically approved. Records regarding the signatures are stored in the Fuel BU Document Database. Any attempt to modify this file may subject employees to civil and crimi 1penalties. ED Object Id: 0901216780Bb9fb2 - Release date (YYYY/MMIOD} : 201 /04114 18:45:31 [Western European Time)

Bol!! Name Dal!! IYYYY£MMIQQl 0!'.lll!!Ji~!iO!J Writer CARR Darr II 2016/04/14 02:31 :49 AREVA Inc.

Writer ELLIOTI Kevin 20 16/04/14 01:45:01 AREVA Inc.

Reviewer ADAIR Scott 2016/04/14 07:11:58 AREVA Inc.

Reviewer GRUMMER Ralph 2016/04/14 17:44:18 AREVA Inc.

Reviewer MEGINNIS Alan 2016104/14 16:45:51 AREVA Inc.

Reviewer JOHNSON Curtis 2016/04/14 18:06:52 AREVA Inc.

Approver MCQUADE Patrick 2016/04114 18:45:24 AREVA Inc.

Approver SCHNEPP Robert 2016/04/14 18:09:32 AREVA Inc.

9aGlll!d!Usm lil!l!O!I AL: OE001 ECCN: OE001 RELEASE DATA: Los marchandlsea portanl la dl!slgnaUon *AL ln6gal N" aonl aoumlsas 6 la rilglemonlaUon ourop6onne ou allemande on maU6re de conlr61e des oxportallons ou seln ou honi de ruE. Los marchandlsas portanl la dlalgnallon *ECCN ln6gal N" 1onl soumlses 6 lo -'glemenlallon amllricalne. Los marchandlsos portanl lea d6slgnatlons *AL:N* OU "ECCN:N" peuvant, selon la deatinallon OU ruUllsatlon flnalea du prodult, ilgalement llnS soumlses 6 autottsatlon.

lil!I!!!!! i:!iaaiftcall2a AL: OE001 ECCN:OE001 Goods labeled with 'AL nol equal to N" era subject to European or German export authortzatlon when being exported within or out of the EU. Goods labeled with "ECCN not equal to N" ara subject to US raaxport authortzatlon. Even without a label, or with label *AL: N" or "ECCN: N", authortzatlon may ba required due to tho SAFETY RELATED DOCUMENT: y flnal wtieraabouts and purpose for which the gooda ara to be used.

E.xoortlct!!QD51!nl!!lg AL: OE001 ECCN: OE001 CHANGE CONTROL RECORDS: France: N Ole mil *AL ungletch N" galconnzolchnalen GOiar untarllegan bat der Ausfuhr aus dar EU biw.

This document, when revised, must be USA: y lnnergemaln1challllchen Verbrtngung der europ!lschan biw. daullchan Ausfuhrgenehmlgung1plllchl. Ole mlt "ECCN unglalch N" gekennzalchnetan GDter unterllegan der US-Raexportganahmlgungspfllchl. Auch ohna reviewed or approved by following regions: Germany: N Kennzelchen, biw. bel Kennzalchen *AL: N" oder "ECCN: N", kann llch elne Genehmlgungspffich~ unter anderam dutch den Endvarblalb und Varwendunasiweck der GOiar """""'"*

CWDll Rov. 4.4 -10#12115

N" FS 1-0026562 Rev. 1.0 RAI Response Clarification for Dresden and Quad Cities Nuclear Power Stations A

Handling: None Page 2/6 AREVA REVISIONS REVISION DATE EXPLANATORY NOTES 1.0 See 151 page New document release date AREVA - Fuel BL Thia document is sub eel to the restrictions set forth on the first or title a e

No FS 1-0026562 Rev. 1.0 RAI Response Clarification for Dresden and Quad Cities Nuclear Power Stations A

Handling: None Page 3/6 AREVA TABLE OF CONTENTS

1. INTRODUCTION .............................................................................................................................. 4

2. RAIS AND RESPONSES ....................*.........*.................................................................................. 4 2.1. RAl-16 ...................................................................................................................................................... 4 2.1.1. CLARIFICATION .........................................................................................................................4 2.1.2. AREVA RESPONSE ................................................................................................................... 4 2.2. RAl-18 ...................................................................................................................................................... 6 2.2.1. CLARIFICATION .........................................................................................................................6 2.2.2. AREVA RESPONSE ................................................................................................................... 6 LIST OF TABLES Table 1: Control Rod and In-Core Instrumentation Interface Compatibility ............................................ 5 REFERENCES

1. ANF-89-98(P)(A), Revision 1 and Supplement 1, "Generic Mechanical Design Criteria for BWR Fuel Designs," Advanced Nuclear Fuels Corporation, May 1995

2. EMF-93-177(P)(A), Revision 1, "Mechanical Design for BWR Fuel Channels," Framatome ANP, August 2005

3. ANP-3305P Revision 1, "Mechanical Design Report for Quad Cities and Dresden ATRIUM 10XM Fuel Assemblies," AREVA Inc., August 2015

4. EMF-2209(P)(A) Revision 3, "SPCB Critical Power Correlation," AREVA NP, September 2009

5. ANP-10298(P)(A) Revision 1, "ACE/ATRIUM 10XM Critical Power Correlation," AREVA, March 2014 AREVA- Fuel BL This document Is sub eel to the restrictions set forth on the flrst or ~tie a e

No FS 1-0026562 Rev. 1.0 RAI Response Clarification for Dresden and Quad Cities Nuclear Power Stations A

Handling: None Page 4/6 AREVA

1. INTRODUCTION The following Clarification of RAI responses provided in the January 28, 2016 letter from Exelon generation Company, LLC (EGC) are provided in response to the NRC request as discussed during the March 2, 2016 teleconference between the U.S. NRC and Exelon. It was agreed that the following clarifications would be provided as a supplement to the license amendment request. The remaining clarifications were provided in an email from Timothy A. Byam (Exelon Generation Company) to Russell Haskell (U.S. NRC), "Clarification of Dresden and Quad Cities Fuel Transition RAls," dated March 31, 2016.

2. RAIS AND RESPONSES 2.1. RAl-16 2.1.1. CLARIFICATION The NRG reviewer requested additional detail concerning the mechanical design analyses. A recent AREVA document supporting another US utility customer was provided as an example of the desired level of detail.

2.1.2. AREVA RESPONSE The AREVA ATRIUM 10XM fuel assembly design has been evaluated by AREVA Inc. and EGC to ensure that the mechanical compatibility with the Dresden Nuclear Power Station (DNPS), Units 2 & 3 and Quad Cities Nuclear Power Station (QCNPS), Units 1 & 2 control blades and in-core instrumentation is in compliance with AREVA's generic mechanical design criteria documents for boiling water reactor (BWR) fuel designs (Reference 1) and fuel channels (Reference 2). Page 1-5 of Reference 2 describes the application of channel deformation in mechanical compatibility evaluations. Analyses are used to verify the mechanical compatibility based on specific bounding physical features and attributes of the fuel assembly as defined in the AREVA detailed design drawings and the dimensional data of the reactor core internals and co-resident fuel assemblies officially transmitted by EGC.

The specific evaluations for the control blade and in-core instrumentation compatibility are provided in the following Table 1. These evaluations are discussed for the applicable fuel component and the corresponding interface on the co-resident fuel assembly and/or in-core component. The conclusion of each evaluation is also provided. Mechanical compatibility and corresponding analyses are further discussed in Reference 3.

AREVA - Fuel BL Thia document is sub eel to the reatrictlona set forth on the first or tlUe a e

N" FS 1-0026562 Rev. 1.0 RAI Response Clarification for Dresden and Quad Cities Nuclear Power Stations A

AREVA Handling: None Page 5/6 Table 1: Control Rod and In-Core Instrumentation Interface Compatibility AREVA Fuel Assembly In-Core Interface Component Evaluated Conclusion Fuel channel spacers Axial and lateral interface with The overlap between the fuel co-resident fuel channel channel spacers is maintained spacers throughout the design throughout the design life to life provide clearance between channels for control rods Control rod handle elevation, Clearance exists between the including scram over-travel fuel channel spacer and the control blade handle at full insertion Fuel channel fastener Axial, lateral and radial The fuel channel fastener interface with co-resident fuel springs remain in compression channel fastener springs and in contact throughout the throughout the design life design life to maintain fuel assemblies in the cell against the upper core guides and to maintain clearance between channels for control rods, including when a fresh AREVA fuel assembly is adjacent to an EOL co-resident fuel assembly Control rod handle elevation, Clearance exists between the including scram over-travel fuel channel fastener and the control blade handle at full insertion Fuel channel reduced Control rod roller or pad The control rod rollers and pads thickness wall section elevation, including scram remain within the thinned wall over-travel section of the Advanced Fuel Channel for maximum control Lateral interface with control rod clearance rod roller or pad Control rod roller or pad Clearance exists throughout the thickness travel of the control blade between fuel channels at BOL and margin to stuck control rod due to channel bow and bulge remains positive throughout the design life Fuel channel corners In-core instrumentation tube Clearance exists throughout the travel of the instrumentation tube between the fuel channel comers AREVA- Fuel BL This document Is sub ect to the rastriclions set forth on the finit or UUe e

No FS 1-0026562 Rev. 1.0 RAI Response Clarification for Dresden and Quad Cities Nuclear Power Stations A

Handling: None Page 6/6 AREVA 2.2. RAl-18 2.2.1. CLARIFICATION Table 18.1 of the response shows that the OPTIMA2 and ATRIUM 10XM assemblies have very different flow characteristics (as shown by the differences in pressure and inlet subcooling). The NRG reviewer asked the following clarifying questions:

1. How will Exelon manage and track flow dynamics and Critical Heat Flux in the mixed cores?

2. Please highlight/elaborate on the guidance used in defining the impact on the safety limit minimum CPR determination.

2.2.2. AREVA RESPONSE Clarifying Question #1 Table 18.1 shows that the ranges of applicability are different for critical power correlations used for OPTIMA2 and ATRIUM 10XM fuel; particularly for the pressure and inlet subcooling. For all cores (including mixed core configurations), inputs to the codes used to design, license and monitor the core identify the correlation to use in critical power calculations for each fuel assembly. As a result, the critical power correlations are applied on an assembly by assembly basis. This includes checks on the application of the range of applicability of the specific correlation.

Clarifying Question #2 For mixed core configurations of OPTIMA2 and ATRIUM 1OXM fuel, two different critical power correlations are used. The SPCB correlation (Reference 4) will be used for the OPTIMA2 fuel and the ACE/ATRIUM 1OXM correlation (Reference 5) for the ATRIUM 1OXM fuel. The critical power correlations are applied on an assembly by assembly basis in the safety limit minimum CPR analysis. As a result, the ranges of applicability for the critical power correlations are also applied on an assembly by assembly basis.

The core simulator code MICROBURN-82 is used to model the steady state CPR performance of all the assemblies in the core. Code input identifies the CPR power correlation to use for each assembly. As previously noted, the SPCB correlation will be used for the OPTIMA2 fuel and the ACE/ATRIUM 1OXM correlation for the ATRIUM 1OXM fuel. The ranges of applicability for the correlations are programmed into the code and checks against the ranges of applicability are made on an assembly by assembly basis.

Should a parameter such as mass flux, inlet subcooling, or pressure, fall outside the range of applicability of the correlation for a given assembly, the code is programmed to follow the procedures outlined in Reference 4 Section 2.6 for the SPCB correlation, and Reference 5 Section 5.13 for the ACE/ATRIUM 10XM correlation. The same application and coding of the SPCB and ACE/ATRIUM 10XM correlations are also included in the POWERPLEX core monitoring system. Therefore, the critical power correlations and the associated ranges of applicability are applied on an assembly by assembly basis in the core wide calculations and the core monitoring system.

AREVA- Fuel BL This document is sub eel ta the restrictions set forth an the first or UUe a e