W3F1-2007-0045, Supplement to the ECCS Performance Analysis Submittal in Support of Next Generation Fuel - 1999 EM Optional Steam Cooling Model Justification

Supplement to the ECCS Performance Analysis Submittal in Support of Next Generation Fuel - 1999 EM Optional Steam Cooling Model Justification

ML072820400
Person / Time
Site:	Waterford
Issue date:	10/04/2007
From:	Murillo R Entergy Nuclear South, Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2007-0045
Download: ML072820400 (19)

Text

I4 -i Entergy Nuclear South Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 vEntergy Tel 504-739-6715 Fax 504-739-6698 rnllUri IITcntergv. coin Robert J. Murillo Licensing Manager Waterford 3 W3F1-2007-0045 October 4, 2007 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Supplement to the ECCS Performance Analysis Submittal In Support of Next Generation Fuel in Waterford 3 -

1999 EM Optional Steam Cooling Model Justification Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

REFERENCES:

1. Entergy letter to the NRC "License Amendment Request NPF-38-271 to Support Next Generation Fuel," dated August 2, 2007 (W3F1-2007-0037)

2. Entergy letter to the NRC "Emergency Core Cooling System Performance Analysis," dated August 9, 2007 (W3F1-2007-0038)

Dear Sir or Madam:

Entergy Operations, Inc. (Entergy) committed by letter (Reference 1) to provide an addendum to the Emergency Core Cooling System (ECCS) Performance Analysis (Reference 2) to address a limitation and condition in the final NRC Safety Evaluation (SE) for the Westinghouse topical report (TR) CENPD-1 32, Supplement 4-P-A, Addendum 1-P, "Calculative Methods for the CE Nuclear Power Large Break LOCA Evaluation Model -

Improvement to 1999 Large Break LOCA EM Steam Cooling Model for Less Than 1 in/sec Core Reflood." The addendum is included in Attachment 1 and provides supplementary information on the application of the optional spacer grid steam cooling heat transfer model in the 1999 EM Large Break Loss-of-Coolant Accident (LBLOCA) ECCS Performance Analysis for the implementation of Combustion Engineering (CE) 16x1 6 Next Generation Fuel (NGF)

Assemblies in Waterford 3. In addition, the addendum contains supplementary analyses and graphical results that are provided in response to the NRC Staff request to confirm the A=m

W3F1-2007-0045 Page 2 of 2 acceptability of the use of the 1999 EM optional steam cooling model for implementation of NGF into Waterford 3.

As previously requested in Reference 2, Entergy requests approval of the revised analysis by March 14, 2008 in order to support the spring 2008 refueling outage. Once the licensing basis change is approved and following startup from the spring 2008 refueling outage, the analysis shall become the analysis of record. Although this request is neither exigent nor emergency, your prompt review is requested.

This letter contains no commitments. If you have any questions or require additional information, please contact Ron Williams at 504-739-6255.

Sincerely, RJM/RLW

Attachment:

1. Supplement to the ECCS Performance Analysis Submittal In Support of Next Generation Fuel in Waterford 3 -1999 EM Optional Steam Cooling Model Justification cc: Mr. Elmo E. Collins, Jr.

Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U.S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS O-7D1 Washington, DC 20555-0001 Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division P. O. Box 4312 Baton Rouge, LA 70821-4312

Attachment I W3F1-2007-0045 Supplement to the ECCS Performance Analysis Submittal in Support of Next Generation Fuel in Waterford 3 -

1999 EM Optional Steam Cooling Model Justification to W3F1-2007-0045 Page 1 of 16 Supplement to the ECCS Performance Analysis Submittal In Support of Next Generation Fuel in Waterford 3 1999 EM Optional Steam Cooling Model Justification 1.0 Purpose The purpose of this submittal is to provide requested supplementary information on the application of the optional spacer grid steam cooling heat transfer model in the 1999 EM Large Break Loss-of-Coolant Accident (LBLOCA) ECCS Performance Analysis for the implementation of Combustion Engineering (CE) 16x16 Next Generation Fuel (NGF) Assemblies in Waterford 3.

This submittal also contains supplementary analyses and graphical results that are provided in response to the NRC staff request to confirm the acceptability of the use of the 1999 EM optional steam cooling model for implementation of NGF into Waterford 3.

1.1 Background A Licensing Amendment Request (LAR) for the implementation of CE 16x16 NGF assemblies in Waterford 3 was submitted in Reference 1-1. In addition, a revised ECCS Performance Analysis for the implementation of NGF assemblies in Waterford 3 was submitted in Reference 1-2. Upon approval of these submittals and implementation of NGF assemblies, this revised ECCS Performance Analysis will constitute the new Analysis-of-Record (AOR) and baseline for which future changes to the ECCS performance analysis of Waterford 3 will be measured against in accordance with 10 CFR 50.46(a)(3) (Reference 1-5).

The Waterford 3 NGF Analysis for LBLOCAs utilized a new optional steam cooling model improvement in the Westinghouse ECCS Performance Evaluation Model for CE plants (1999 EM) that was submitted for approval in Reference 1-3. The final Safety Evaluation Report (SER) for this optional steam cooling model (Reference 1-4) was received by Westinghouse after the revised LBLOCA ECCS Performance Analysis for Waterford 3 NGF was completed.

The final SER called for minor changes to the proposed model and added several Limitations and Conditions on the acceptability of the optional steam cooling model. In view of this background, this submittal (1) documents the performance of the optional steam cooling model in its final approved form for the implementation of CE 16x16 NGF at Waterford 3 and (2) demonstrates compliance with the final SER Limitations and Conditions through required supplementary documentation.

1.2 Regulatory Basis As required by 10 CFR 50.46(a)(1)(i), the ECCS performance analysis must conform to the ECCS acceptance criteria (Reference 1-5). Additionally, the ECCS performance must be calculated in accordance with an acceptable evaluation model and must be calculated for a number of postulated LOCAs of different sizes, locations, and other properties sufficient to provide assurance that the most severe postulated LOCAs are calculated. The evaluation model may either be a realistic evaluation model as described in 10 CFR 50.46(a)(1)(i) or must conform to the required and acceptable features of Appendix K ECCS Evaluation Models (Reference 1-6). The evaluation models used to perform the ECCS performance analyses for Waterford 3 are Appendix K evaluation models.

The regulatory basis for this submittal comes from the SER Limitations and Conditions for the optional steam cooling model contained in Reference 1-4. Condition 4 of the SER stated that

"...the licensee should provide the results of the evaluation with and without the optional steam to W3F1-2007-0045 Page 2 of 16 cooling model, in a format similar to the graphical results provided in the reference calculations presented in the supplemental TR. The peak cladding temperature, local oxidation, and steam cooling flow rates should be included in the submittal. These comparisons will enable the NRC staff to confirm the acceptability of the use of the optional steam cooling model." This report contains supplementary material on the analyses and comparison graphical results that will enable the NRC staff to confirm the acceptability of the use of the optional steam cooling model for Waterford 3 NGF assemblies, as requested in SER Condition 4.

1.3 Contents of Submittal Section 2.0 of this submittal includes a supplementary description of the ECCS performance method of analysis including the recently approved Topical Reports and Supplements pertaining to the implementation of CE 16x16 NGF assemblies at Waterford 3.

Section 3.0 of this submittal presents both tabular and graphical results of the application of the optional steam cooling model to the implementation of CE 16x16 NGF at Waterford 3. These results provide comparisons of the ECCS performance both with and without the optional steam cooling model. These results provide the means for demonstrating the acceptability of the use of the optional steam cooling model to analyze LBLOCA ECCS performance for the implementation of CE 16x16 NGF at Waterford 3.

Section 4.0 presents the conclusions of this submittal.

2.0 Method of Analysis 2.1 1999 EM (CENPD-132, Supplement 4-P-A)

The Westinghouse Appendix K Evaluation Model for ECCS Performance in CE plants is the 1999 Evaluation Model (1999 EM) for LBLOCA (Reference 1-7). The 1999 EM for LBLOCA is augmented by CENPD-404-P-A for analysis of ZIRLOTM cladding (Reference 1-8), and by Addendum 1 to CENPD-404-P-A for analysis of Optimized ZIRLOTM cladding (Reference 1-9).

Also, the 1999 EM is supplemented by WCAP-16072-P-A (Reference 1-10) for implementation of ZrB 2 IFBA fuel assembly designs. The 1999 EM now includes an optional steam cooling heat transfer component model for less than 1 in/sec core reflood that includes spacer grid heat transfer effects as documented in Reference 1-3. The implementation of CE 16x16 NGF into the 1999 EM methodology is documented in Reference 1-11.

2.2 CE 16x16 NGF (WCAP-16500-P)

The methodologies for licensing CE 16x16 NGF assemblies are documented in Westinghouse Topical Report WCAP-16500-P, titled "CE 16 x 16 Next Generation Fuel Core Reference Report," Reference 1-11. WCAP-1 6500-P was approved by the NRC in Reference 1-12.

Section 5.2 of Reference 1-11 documents the ECCS performance methods suitable for use to analyze the implementation of NGF. The final SER for WCAP-1 6500-P contains 10 Limitations and Conditions. Compliance with these Limitations and Conditions for implementation of NGF in Waterford 3 was documented in Reference 1-1.

to W3F11-2007-0045 Page 3 of 16 2.3 Optimized ZIRLOTM (CENPD-404-P-A Addendum 1)

The CE 16x16 NGF design utilizes Optimized ZIRLO TM , an advanced cladding alloy. The implementation of Optimized ZIRLOTM in CE plants is documented in Reference 1-9 and approved by the NRC in Reference 1-13. As required by the SER Limitations and Conditions in Reference 1-13, the ECCS performance analysis computer codes have been updated to include the Optimized ZIRLOTM cladding property changes detailed in the topical report. The use of Optimized ZIRLO TM cladding in the NGF assemblies requires a cladding exemption from the requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix K, which has been submitted to the NRC in Reference 1-14.:

2.4 1999 EM Optional Steam Cooling Model (CENPD-132 Supplement 4-P-A Addendum 1-P)

"Calculative Methods for the CE Nuclear Power Large Break LOCA Evaluation Model, Improvement to 1999 Large Break LOCA EM Steam Cooling Model for Less Than 1 in/sec Core Reflood," CENPD-1 32, Supplement 4-P-A, Addendum 1-P was approved by the NRC in Reference 1-4.

The conclusion of the SER stated that Limitations and Conditions 3, 4, and 5 are applicable to CE 16 x 16 NGF design fuel assemblies. The first two Limitations and Conditions included in the SER for CENPD-132, Supplement 4-P-A, Addendum 1-P are for fuel designs other than CE 16 x 16 NGF. This report contains supplementary material on the analyses and comparison graphical results that will enable the NRC staff to confirm the acceptability of the use of the optional steam cooling model for Waterford 3 NGF assemblies, which was requested in SER Condition 4. The applicable Limitations and Conditions and the means of satisfying them were documented in Reference 1-1.

3.0 Results To provide the required comparison of results for the use of the optional steam cooling model, the limiting local cladding oxidation percentage case from the Reference 1-2 AOR is utilized.

This case is the 1.0 Double-Ended Guillotine break in the reactor coolant Pump Discharge leg (DEG/PD), The most limiting case for peak local cladding oxidation of the hot rod was for the UO2 fuel type with Optimized ZIRLOTM cladding at a burnup of 0.5 GWD/MTU. This case includes the worst single failure of an ECCS component, which is no failure, Safety Injection Tank (SIT) initial conditions, and refueling water storage tank initial conditions that lead to the most limiting ECCS performance results.

Comparisons are made with and without the optional steam cooling model to quantify the performance of the model and show its impact on the calculated results. Use of the optional steam cooling model has no impact on the calculated peak cladding temperature for the implementation of CE 16x1 6 NGF at Waterford 3, which occurs below the rupture node and is not subjected to any steam cooling heat transfer limitation. The primary purpose of utilizing the optional steam cooling model for the implementation of CE 16x16 NGF at Waterford 3 is to improve the heat transfer coefficient on the fuel rod rupture node, which provides margin to the peak local oxidation criterion.

The calculations presented in this submittal were prepared using the 1999 EM computer code versions that contain the approved optional steam cooling heat transfer model. In particular, the to W3F1-2007-0045 Page 4 of 16 PARCH module of the STRIKIN-1I computer code that was utilized in these calculations contains the following required features based on the final model approved in the SER (Reference 1-4):

(1) the approved spacer grid rewet temperature criterion required by the final SER, (2) final formulation of calculated parameters required by the SER, (3) code logic to ensure that SER imposed limitations on the calculated heat transfer coefficients are satisfied, and (4) computational constraints to confirm that the calculations were within the allowed range of applicability for flow blockage and Reynolds number.

Sections 3.1, 3.2, and 3.3 provide results for the case with the most limiting peak local cladding oxidation, both with and without the optional steam cooling model, and using the final version of STRIKIN-II described above. Section 3.4 provides results for the case with the most limiting peak cladding temperature with the final version of STRIKIN-II. Since the approval of the optional steam cooling model was received by Westinghouse after the Reference 1-2 AOR was completed, which used a proposed version of the steam cooling model, the results produced by the final version of STRIKIN-II described above are slightly different than the results in the AOR.

However, use of the approved methodology shows no change in the peak cladding temperature and a negligible change in the final maximum local cladding oxidation percentage results for the implementation of CE 16x16 NGF in Waterford 3 compared to those results presented in Reference 1-2. The results in this report do not replace the results reported in the Reference 1-2 AOR.

3.1 Results for the Limiting Peak Local Cladding Oxidation Case Without the Optional Steam Cooling Model The following table lists key results that characterize the performance of the 1999 EM for the case with the limiting peak local cladding oxidation without the optional steam cooling model.

The list of parameters includes (1) results from the blowdown analysis with CEFLASH-4A/FII, (2) results from the reflood analysis with COMPERC-II/LB, (3) results from the hot rod heatup analysis with STRIKIN-II, and (4) the COMZIRC calculated core-wide oxidation. The hot rod peak cladding temperature and local cladding oxidation percentage are given by the STRIKIN-II results and are highlighted with a bold font. The core-wide oxidation percentage given by the COMZIRC results is also highlighted with a bold font.

As the results in Table 3.1-1 indicate, the peak local cladding oxidation case without the steam cooling model exceeds the ECCS acceptance criterion of 17%. Also, the core-wide oxidation percentage exceeds the ECCS acceptance criterion of 1%. It is noted, that this non-licensing case was terminated before the maximum oxidation was calculated. The end time of this case was selected to be consistent with the end time of the AOR cases. This is acceptable for purposes of providing the requested graphical comparisons to follow.

to W3F1-2007-0045 Page 5 of 16 Table 3.1-1 Peak Local Oxidation Case Run Without the Optional Steam Cooling Model CEFLASH-4A Blowdown PCT (deg F) 1485.4 Time of Blowdown PCT (sec) 5.55 Blowdown PCT Node 14 Time of Annulus Downflow (TAD) (sec) 23.99 COMPERC-1i Contact Time (sec) 41.00 SITs Empty Time (sec) 99.87 Time of 1 inch/sec Core Reflood (sec) 100.23 First Reflood Rate (in/sec) 1.5433 Second Reflood Rate (in/sec) 1.1449 Third Reflood Rate (in/sec) 0.6636 STRIKIN-Il Reflood PCT (deg F) 2154.7 Time of Reflood PCT (sec) 240.42 Reflood PCT Node 12 Rupture Node 13 Rupture Time (sec) 47.37 Rupture Temperature (deg F) 1591.2 Rupture Strain (%) 40.93 Blockage (%) 30.26 Peak Local Oxidation (PLO) (%) 18.0 PLO Node 13 Hot Rod Peak Fuel Avg Temp at TAD (deg F) 1209.1 Node of Peak Fuel Avg Temp at TAD 13 COMZIRC Max Core Wide Oxidation (%) 1.009 3.2 Results for the Limiting Peak Local Cladding Oxidation Case With the Optional Steam Cooling Model Table 3.2-1 shows the results of the same case as described in the previous section with the optional steam cooling model activated. In this case, the limiting local cladding oxidation percentage is below the ECCS acceptance criterion of 17%. There was no change to the calculated peak cladding temperature and the core-wide oxidation percentage was below its ECCS acceptance criterion of 1%. Table 3.2-1 and its comparison to Table 3.1-1 demonstrate the magnitude of the impact of the optional steam cooling model on the calculated results for the implementation of CE 16x16 NGF at Waterford 3. These calculated results with the optional steam cooling model conform to the general range and order of magnitude of the effect described to the NRC during the approval process for the improved methodology.

to W3F1-2007-0045 Page 6 of 16 Table 3.2-1 Peak Local Oxidation Case Run With the Optional Steam Cooling Model CEFLASH-4A Blowdown PCT (deg F) 1485.4 Time of Blowdown PCT (sec) 5.55 Blowdown PCT Node 14 Time of Annulus Downflow (TAD) (sec) 23.99 COMPERC-I1 Contact Time (sec) 41.00 SITs Empty Time (sec) 99.87 Time of 1 inch/sec Core Reflood (sec) 100.23 First Reflood Rate (in/sec) 1.5433 Second Reflood Rate (in/sec) 1.1449 Third Reflood Rate (in/sec) 0.6636 STRIKIN-1i Reflood PCT (deg F) 2154.7 Time of Reflood PCT (sec) 240.42 Reflood PCT Node 12 Rupture Node 13 Rupture Time (sec) 47.37 Rupture Temperature (deg F) 1591.2 Rupture Strain (%) 40.93 Blockage (%) 30.26 Peak Local Oxidation (PLO) (%) 16.9 PLO Node 13 Hot Rod Peak Fuel Avg Temp at TAD (deg F) 1209.1 Node of Peak Fuel Avg Temp at TAD 13 COMZIRC Max Core Wide Oxidation (%) 0.988 3.3 Graphical Results for the Limiting Peak Local Cladding Oxidation Case Supplementary graphical results are provided as required by the Reference 1-4 SER for evaluation of the use of the optional steam cooling model for the implementation of CE 16x1 6 NGF at Waterford 3. In particular, results of the cases with and without the optional steam cooling model are shown in a format similar to the graphical results provided in the information presented to NRC in support of the Topical Report (Reference 1-3).

The peak cladding temperature, local oxidation, and steam cooling flow rates are shown with and without the optional steam cooling model as required by the SER Limitations and Conditions. In addition, comparisons of the calculated spacer grid temperatures and fuel rod heat transfer coefficients are shown with and without the optional steam cooling model. For convenience, the graphs are labeled "with and without grids," which is synonymous to "with and without the optional steam cooling model."

These graphical comparisons further confirm the acceptability of the use of the optional steam cooling model regarding both the performance of the model and its impact on the calculated results. These graphical results with the optional steam cooling model conform to the general to W3F1-2007-0045 Page 7 of 16 range and order of magnitude of the effect described to the NRC during the approval process for the improved methodology.

These results demonstrate that the use of the optional steam cooling model for the implementation of CE 16x1 6 NGF at Waterford 3 is appropriate for this application.

2400 2000 /,"\

/V 1600 //"

I/ \

1200 800 w// ds PCT Regulatory Limit 400 0 0 100 200 300 400 500 TiME, SECONDS Peak Cladding Temperature Node 12 (Below Rupture Node)

For the implementation of CE 16x16 NGF at Waterford 3, peak cladding temperature is calculated to occur on the node just below the rupture elevation, which is a region on the hot rod not impacted by the optional steam cooling heat transfer model. Therefore, Figure 3.3-1 shows that use of the optional steam cooling model has no impact on the calculated peak cladding temperature for this case with the most limiting peak local cladding oxidation percentage.

to W3F1-2007-0045 Page 8 of 16 These conditions and the conclusion are the same for the case with the most limiting peak cladding temperature; that is, there is no impact on the calculated peak cladding temperature results with and without the optional steam cooling model for the most limiting peak cladding temperature case.

18

/

15 I

/

12

//

i 0.

9

//

6

--- --- w/o *kds PLO Regulatory Limit 3

0 0 100 200 300 400 500 TIME, SECONDS Peak Local Oxidation Node 13 (Rupture Node)

For the implementation of CE 16x16 NGF at Waterford 3, the primary purpose of utilizing the optional steam cooling model is to improve the peak local oxidation percentage, which occurs on the hot rod rupture node. Figure 3.3-2 shows the margin to criterion produced by the optional steam cooling model for the case with the most limiting peak local cladding oxidation percentage. Figure 3.3-7 shows that the cladding temperature on this node at 500 seconds to W3F1-2007-0045 Page 9 of 16 using the optional steam cooling model is below 16001F, where no further significant oxidation is calculated.

Figure 3.3-3 shows spacer grid temperatures calculated with the optional steam cooling model that are below the rupture node elevation and above the core two-phase mixture level. If these spacer grids have a temperature below the rewet criterion then they are assumed to have a liquid film available for evaporation from the grid surface to augment the calculated steam flow rate. At roughly 340 seconds, Grid 6 becomes covered by the core mixture level only to be uncovered briefly at roughly 380 seconds.

to W3F1-2007-0045 Page 10 of 16 180 150 120 J.,.

' 'I 90

• 2 60 Steam Flow w/ Grids Steam Flow w/o Grid 30 0

0 100 200 300 400 500 TIME, SECONDS Waford 3 Core Average Steam Flow At and Above Rupture Node Elevation Figure 3.3-4 Figure 3.3-4 shows the improvement in the calculated core average steam flow rate at and above the hot rod rupture node elevation by utilizing the optional steam cooling heat transfer model including the impact of the wetted spacer grids below the rupture node.

to W3F17-2007-0045 Page 11 of 16 Figure 3.3-5 shows the improvement in the hot rod heat transfer coefficient at the rupture node elevation by utilizing the optional steam cooling heat transfer model along with the improved steam flow rate shown in Figure 3.3-4. The graphs show that the heat transfer coefficient calculated using the FLECHT correlation represents an upper bound on the calculated steam cooling heat transfer.

to W3F1-2007-0045 Page 12 of 16 Figure 3.3-6 shows the improvement in the hot rod heat transfer coefficient on the node just above the rupture elevation by utilizing the optional steam cooling heat transfer model along with the improved steam flow rate shown in Figure 3.3-4. The graphs show that the heat transfer coefficient calculated using the FLECHT correlation represents an upper bound on the calculated steam cooling heat transfer.

to W3F1-2007-0045 Page 13 of 16 2400 2000

/ G --

1600 1200

,wI d, 800

--- --- w/o 4k ds PCT Regulatoty Limit 400 V0 100 200 300 400 500 TIME, SECONDS Cladding Temperature Node 13 (Rupture Node)

Figure 3.3-7 shows the improvement in the calculated hot rod cladding temperature at the rupture node elevation by utilizing the optional steam cooling heat transfer model along with the improved heat transfer coefficients shown in Figure 3.3-5. Reduced cladding temperature late in the transient leads to reduced local oxidation percentage, as shown in Figure 3.3-2.

to W3F1-2007-0045 Page 14 of 16 3.4 Results for the Limiting Peak Cladding Temperature Case With the Final Approved Optional Steam Cooling Model The limiting peak cladding temperature case from the Reference 1-2 AOR results is the 1.0 DEG/PD. The most limiting case for peak cladding temperature of the hot rod was for the U0 2 fuel type with Optimized ZIRLOTM cladding at a burnup of 32 GWD/MTU. This case includes the worst single failure of an ECCS component, which is no failure, SIT initial conditions, and refueling water storage tank initial conditions that lead to the most limiting ECCS performance results.

Table 3.4-1 provides a comparison of results between the limiting peak cladding temperature case from the AOR and a case utilizing the final approved optional steam cooling model. Use of the final approved optional steam cooling model has no impact on the calculated peak cladding temperature for the implementation of CE 16x1 6 NGF at Waterford 3 compared to the AOR case using an earlier version of the optional steam cooling model for this case with the most limiting peak cladding temperature. The results in this report do not replace the results reported in the Reference 1-2 AOR.

Table 3.4-1 Peak Cladding Temperature Case Comparison Between the AOR and the Final Optional Steam Cooling Model CASE AOR Final CEFLASH-4A Blowdown PCT (deg F) 1375.9 1375.9 Time of Blowdown PCT (sec) 5.53 5.53 Blowdown PCT Node 14 14 Time of Annulus Downflow (TAD) (sec) 24.02 24.02 COMPERC-II Contact Time (sec) 41.04 41.04 SITs Empty Time (sec) 99.88 99.88 Time of 1 inch/sec Core Reflood (sec) 100.27 100.27 First Reflood Rate (in/sec) 1.541 1.541 Second Reflood Rate (in/sec) 1.1439 1.1439 Third Reflood Rate (in/sec) 0.6636 0.6636 STRIKIN-II Reflood PCT (deg F) 2166.1 2166.1 Time of Reflood PCT (sec) 239.08 239.08 Reflood PCT Node 12 12 Rupture Node 13 13 Rupture Time (sec) 39.03 39.03 Rupture Temperature (deg F) 1493.2 1493.2 Rupture Strain (%) 33.38 33.38 Blockage (%) 24.2 24.2 Peak Local Oxidation (PLO) (%) 16.8 16.8 PLO Node 13 13 Hot Rod.Peak Fuel Avg Temp at TAD (deg F) 1292.8 1292.8 Node of Peak Fuel Avg Temp at TAD 13 13 COMZIRC Max Core Wide Oxidation.(%) 0.923 0.923 to W3F1-2007-0045 Page 15 of 16 4.0 Conclusions This supplement to the ECCS Performance Analysis submittal for the implementation of CE 16x16 NGF in Waterford 3 (Reference 1-2) (1) documents the performance of the optional steam cooling model in its final approved form and (2) demonstrates compliance with the final SER Limitations and Conditions through required supplementary documentation. The NGF Analysis-of-Record results for Waterford 3 presented in Reference 1-2, which demonstrate conformance to the ECCS acceptance criteria using a proposed version of the optional steam cooling model, are unchanged by the supplementary results contained in this report using the NRC approved version of the model as given in the following table:

NGF Current Parameter Criterion AOR Supplementary Results Results Peak Cladding Temperature <2200OF 2166OF 2166OF Maximum Cladding Oxidation _<17% 16.9% 16.9%

Maximum Core-Wide Oxidation _<1% <1% <1%

Coolable Geometry Yes Yes Yes The results are applicable to Waterford 3 for a rated core power of 3716 MWt (3735 MWt including a 0.5% power measurement uncertainty) for the implementation of CE 16x16 NGF.

These results support a Peak Linear Heat Generation Rate (PLHGR) of 12.9 kW/ft.

The supplementary results contained in this report provide the technical justification that confirms the acceptability of the use of the 1999 EM optional steam cooling model for implementation of NGF into Waterford 3.

5.0 References 1-1 Entergy letter to the NRC "License Amendment Request NPF-38-271 to Support Next Generation Fuel" dated August 2, 2007 (W3F1-2007-0037).

1-2 Entergy letter to the NRC "Emergency Core Cooling System Performance Analysis" dated August 9, 2007 (W3F1-2007-0038).

1-3 CENPD-132, Supplement 4-P-A, Addendum 1-P, "Calculative Methods for the CE Nuclear Power Large Break LOCA Evaluation Model, Improvement to 1999 Large Break LOCA EM Steam Cooling Model for Less Than 1 in/sec Core Reflood," May 2006.

1-4 NRC Letter to Westinghouse dated June 27, 2007, "Final Safety Evaluation for Westinghouse Electric Company (Westinghouse) Topical Report (TR) CENPD-132 Supplement 4-P-A, Addendum 1-P, 'Calculative Methods for the CE [Combustion Engineering] Nuclear Power Large Break LOCA Evaluation Model - Improvement to 1999 Large Break LOCA EM Steam Cooling Model for Less than 1 in/sec Core Reflood' 1-5 Code of Federal Regulations, Title 10, Part 50, Section 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light Water Nuclear Power Reactors."

1-6 Code of Federal Regulations, Title 10, Part 50, Appendix K, "ECCS Evaluation Models."

1-7 CENPD-1 32, Supplement 4-P-A, "Calculative Methods for the CE Nuclear Power Large Break LOCA Evaluation Model," March 2001.

to W3F1-2007-0045 Page 16 of 16 1-8 CENPD-404-P-A, Rev. 0, "Implementation of ZIRLOTM Cladding Material in CE Nuclear Power Fuel Assembly Designs," November 2001.

1-9 WCAP-1 261 0-P-A & CENPD-404-P-A Addendum 1-A, "Optimized ZIRLOTM, July 2006.

1-10 WCAP-16072-P-A, Rev. 0, "Implementation of Zirconium Diboride Burnable Absorber Coatings in CE Nuclear Power Fuel Assembly Designs," August 2004.

1-11 WCAP-16500-P, Rev. 0, "CE 16x16 Next Generation Fuel Core Reference Report,"

February 2006.

1-12 Letter from H. K. Nieh (NRC) to J. A. Gresham (Westinghouse), "Final Safety Evaluation for Westinghouse Electric Company Topical Report WCAP-1 6500-P, Revision 0, 'CE 16x16 Next Generation Fuel Core Reference Report' (TAC No. MD0560)," July 30, 2007.

1-13 Letter from H. N. Berkow (NRC) to J. A. Gresham (Westinghouse), "Final Safety Evaluation for Addendum 1 to Topical Report WCAP-1 2610-P-A and CENPD-404-P-A,

'Optimized ZIRLOTM' (TAC No. MB8041)," June 10, 2005.

1-14 Entergy letter to the NRC dated April 24, 2007, "License Amendment Request to Allow the Use of Optimized ZIRLOTM Fuel Rod Cladding" (W3F1-2007-0020).