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| number = ML17229B294
| number = ML17229B294
| issue date = 08/22/2017
| issue date = 08/22/2017
| title = 08/22/2017, Meeting Slide Regarding Partially Closed Pre-submittal Public Meeting with Duke Energy for a License Amendment Request for Brunswick Steam Electric Plant
| title = Meeting Slide Regarding Partially Closed Pre-submittal Public Meeting with Duke Energy for a License Amendment Request for Brunswick Steam Electric Plant
| author name = Murray W R
| author name = Murray W
| author affiliation = Duke Energy Progress, Inc
| author affiliation = Duke Energy Progress, Inc
| addressee name = Hon A
| addressee name = Hon A
Line 9: Line 9:
| docket = 05000325, 05000324
| docket = 05000325, 05000324
| license number = DPR-062, DPR-071
| license number = DPR-062, DPR-071
| contact person = Hon A L, NRR/DORL/LPL2-2, 415-8480
| contact person = Hon A, NRR/DORL/LPL2-2, 415-8480
| document type = Meeting Briefing Package/Handouts, Slides and Viewgraphs
| document type = Meeting Briefing Package/Handouts, Slides and Viewgraphs
| page count = 20
| page count = 20
| project =
| stage = Meeting
}}
}}


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{{#Wiki_filter:Brunswick Advanced AREVA Methods LAR NRC Pre-Application Meeting 8/22/17
{{#Wiki_filter:Brunswick Advanced AREVA Methods LAR NRC Pre-Application Meeting 8/22/17


===
===Background===
Background===
On a 6/15/17 teleconference, Duke Energy and the NRC discussed our intent to submit an LAR to adopt Advanced AREVA Methods Advanced AREVA Methods are needed to support ATRIUM 11 deployment Advanced AREVA Methods LAR approval needed by Feb 2020 to support first reload of ATRIUM 11 2
On a 6/15/17 teleconference, Duke Energy and the NRC discussed our intent to submit an LAR to adopt Advanced AREVA Methods Advanced AREVA Methods are needed to support ATRIUM 11 deployment Advanced AREVA Methods LAR approval needed by Feb 2020 to support first reload of ATRIUM 11   2 Background (cont) Based upon 6/15 NRC feedback additional information will be presented on, Motivation for LAR Proposed Milestones/Schedule LAR Content Staged submittal for some cycle specific items for first reload of ATRIUM 11 LAR Methodologies Generic Advanced AREVA Methods Plant specific methodologies Other Technical Considerations Challenges, Risk Reduction Prioritization of NRC reviews Relationship to MELLLA+
 
3 Motivation for LAR Eight Brunswick Unit 2 ATRIUM 11 LUAs operating since 2015 remaining fuel is ATRIUM 10XM in both units Duke Energy desires to deploy ATRIUM 11 fuel in reload quantities 11x11 array reduces LHGR (~19%) and fuel duty improving safety margin Improved debris protection features (fuel failure risk reduction)
Background (cont)
Improved channel performance Improved fuel cycle economics First ATRIUM 11 reloads Unit 1 Cycle 23  
Based upon 6/15 NRC feedback additional information will be presented on, Motivation for LAR Proposed Milestones/Schedule LAR Content Staged submittal for some cycle specific items for first reload of ATRIUM 11 LAR Methodologies Generic Advanced AREVA Methods Plant specific methodologies Other Technical Considerations Challenges, Risk Reduction Prioritization of NRC reviews Relationship to MELLLA+
- Startup April 2020 Unit 2 Cycle 25  
3
- Startup April 2021 4 Proposed Milestones Date for LAR submittal September 2018 After MELLLA+ LAR approval SER need date February 2020 17 months available for review of Advanced AREVA Methods LAR 5
 
Motivation for LAR Eight Brunswick Unit 2 ATRIUM 11 LUAs operating since 2015 remaining fuel is ATRIUM 10XM in both units Duke Energy desires to deploy ATRIUM 11 fuel in reload quantities 11x11 array reduces LHGR (~19%) and fuel duty improving safety margin Improved debris protection features (fuel failure risk reduction)
Improved channel performance Improved fuel cycle economics First ATRIUM 11 reloads Unit 1 Cycle 23 - Startup April 2020 Unit 2 Cycle 25 - Startup April 2021 4
 
Proposed Milestones Date for LAR submittal September 2018 After MELLLA+ LAR approval SER need date February 2020 17 months available for review of Advanced AREVA Methods LAR 5
 
LAR Content Reports submitted with LAR based upon BNP equilibrium ATRIUM 11 Design:
LAR Content Reports submitted with LAR based upon BNP equilibrium ATRIUM 11 Design:
Assembly Mechanical Design reports Methods Applicability Supplement Document Thermal Hydraulic Design Report LOCA/MAPLHGR Report BWR Licensing Methodology Compendium Updated for new methods (AURORA
Assembly Mechanical Design reports Methods Applicability Supplement Document Thermal Hydraulic Design Report LOCA/MAPLHGR Report BWR Licensing Methodology Compendium Updated for new methods (AURORA-B [LOCA / Transients and Accidents / CRDA], ACE / ATRIUM 11, and Cr-Doped fuel)
-B [LOCA / Transients and Accidents / CRDA], ACE / ATRIUM 11, and Cr-Doped fuel)
ATWSi Plant Specific Methodology Analysis Report Fuel Cycle Design Report Nuclear Fuel Bundle Design Report Fuel Rod Design Report AURORA-B Limiting Transient Analysis Uncertainty Demonstration DSS-CD Qualification for ATRIUM 11 6
ATWSi Plant Specific Methodology Analysis Report Fuel Cycle Design Report Nuclear Fuel Bundle Design Report Fuel Rod Design Report AURORA-B Limiting Transient Analysis Uncertainty Demonstration DSS-CD Qualification for ATRIUM 11 6
LAR Content (cont) Implementation cycle reports will be submitted post LAR for information:
 
Fuel Cycle Design Report  
LAR Content (cont)
- March 2019 Nuclear Fuel Bundle Design Report - March 2019 Safety Limit MCPR Report - May 2019 Fuel Rod Design Report - October 2019 Reload Safety Analysis Report
Implementation cycle reports will be submitted post LAR for information:
- October 2019 (dates represent a 3 month acceleration compared to a normal reload schedule)
Fuel Cycle Design Report - March 2019 Nuclear Fuel Bundle Design Report - March 2019 Safety Limit MCPR Report - May 2019 Fuel Rod Design Report - October 2019 Reload Safety Analysis Report - October 2019 (dates represent a 3 month acceleration compared to a normal reload schedule)
Submittal strategy and timeline based upon successful BNP LAR submittals used to implement AREVA methods in 2007 and 2010.
Submittal strategy and timeline based upon successful BNP LAR submittals used to implement AREVA methods in 2007 and 2010.
7 LAR Content: TS 5.6.5 Additions AREVA Thermal
7
-mechanical methodologies BAW-10247P-A, Supplement 2P, Revision 0, "Realistic Thermal
 
-Mechanical Fuel Rod Methodology for Boiling Water Reactors Supplement 2: Mechanical Methods
LAR Content: TS 5.6.5 Additions AREVA Thermal-mechanical methodologies BAW-10247P-A, Supplement 2P, Revision 0, Realistic Thermal-Mechanical Fuel Rod Methodology for Boiling Water Reactors Supplement 2: Mechanical Methods - Submitted April 2016 ANP-10340P Revision 0, Incorporation of Chromium-Doped Fuel in AREVA Approved Methods - Submitted April 2016 Plant specific Brunswick DSS-CD Qualification for ATRIUM 11 8
" - Submitted April 2016 ANP-10340P Revision 0, "Incorporation of Chromium
 
-Doped Fuel in AREVA Approved Methods" - Submitted April 2016 Plant specific Brunswick DSS
LAR Content: TS 5.6.5 Additions (cont)
-CD Qualification for ATRIUM 11 8
AREVA Licensing methodologies ANP-10335P Revision 0, ACE/ATRIUM 11 Critical Power Correlation - Submitted Feb 2015, SE Pending ANP-10300P Revision 0, AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Transient and Accident Scenarios - Submitted December 2009, Draft SE July 2017 ANP-10332P Revision 0, AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Loss of Coolant Accident Scenarios - Submitted March 2014 ANP-10333P Revision 0, AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Control Rod Drop Accident Scenarios - Submitted March 2014 9
LAR Content: TS 5.6.5 Additions (cont) AREVA Licensing methodologies ANP-10335P Revision 0, "ACE/ATRIUM 11 Critical Power Correlation
 
" - Submitted Feb 2015, SE Pending ANP-10300P Revision 0, "AURORA
LAR Methodologies: AREVA Generic 6 AREVA generic methodologies There is good potential for all AREVA generic methodologies to be approved by the time of submittal Estimated            Estimated Methodology Draft SE Date        Final SE Date AURORA-B AOO            Complete            11/30/2017 AURORA-B CRDA            9/1/2017            4/30/2018 AURORA-B LOCA            6/30/2018        After LAR Submittal ACE ATRIUM 11 Critical Imminent            4th Quarter 2017 Power Correlation Cr-doped Extension to 1/31/2018            4/30/2018 RODEX4 BWR Mechanical Methods      9/31/2017            12/31/2017 10
-B: An Evaluation Model for Boiling Water Reactors; Application to Transient and Accident Scenarios
 
" - Submitted December 2009, Draft SE July 2017 ANP-10332P Revision 0, "AURORA
LAR Methodologies: AREVA Generic Current AREVA Advanced Methods Generic Methodology approval status 11
-B: An Evaluation Model for Boiling Water Reactors; Application to Loss of Coolant Accident Scenarios"
 
- Submitted March 2014 ANP-10333P Revision 0, "AURORA
LAR Methodologies: Plant Specific - Stability Upon Approval of MELLLA+ Brunswick will use GEH DSS-CD for stability monitoring DSS-CD LAR requires qualification on a fuel type specific basis Plant specific approach required to qualify for ATRIUM 11 AREVA will submit their generic BEO-III methodology topical for review in 4Q2017 Includes previously approved RAMONA5-FA (other generic BEO-III elements not needed by this LAR)
-B: An Evaluation Model for Boiling Water Reactors; Application to Control Rod Drop Accident Scenarios
Draft SE unlikely by September 2018 Plant Specific Approach: evaluate Brunswick equilibrium ATRIUM 11 core with AREVA generic RAMONA5-FA Approved RAMONA5-FA use will be extended to generate time dependent LPRM signals and critical power response for the limiting stability events Feed GEH DSS-CD algorithm with RAMONA5-FA results to confirm margin to the SLMCPR at time of SCRAM Duke to provide any needed translation between RAMONA5-FA output and GEH DSS-CD algorithm LAR to include description and details of plant specific DSS-CD qualification for ATRIUM 11 12
" - Submitted March 2014 9
LAR Methodologies: AREVA Generic 6 AREVA generic methodologies There is good potential for all AREVA generic methodologies to be approved by the time of submittal


10 Methodology Estimated Draft SE Date Estimated Final SE Date AURORA-B AOO Complete 11/30/2017 AURORA-B CRDA 9/1/2017 4/30/2018 AURORA-B LOCA 6/30/2018 After LAR Submittal ACE ATRIUM 11 Critical Power Correlation Imminent 4 th Quarter 2017 Cr-doped Extension to RODEX4 1/31/2018 4/30/2018 BWR Mechanical Methods 9/31/2017 12/31/2017
LAR Methodologies: Plant Specific - ATWSi AREVA Generic ATWSi, ANP-10345P, to be submitted in late 2017 Brunswick will be used as a sample problem for the AREVA generic topical report Intent is to provide extensive overlap between the AREVA generic submittal in 2017 and the plant-specific submittal in 2018 Given the timeline, a plant-specific submittal will be required to support ATRIUM 11 introduction at Brunswick Plan to submit a plant specific version of the AREVA generic topical report which will minimize the differences to editorial Allows for efficiencies as AREVA generic review will remain directly applicable to the plant-specific submittal 13


LAR Methodologies: AREVA Generic 11 Current  AREVA Advanced Methods Generic Methodology approval status
Other Technical Considerations AREVA to generate generic ATRIUM 11 fuel-specific one-time document ANF-89-98(P)(A), Generic Mechanical Design Criteria for BWR Fuel Designs ATRIUM 11 compliance document provided by AREVA to NRC for information only TN-B1 License for ATRIUM 11 Shipments Updated SAR submitted - NRC Approval Expected by Spring 2019 14


LAR Methodologies: Plant Specific - Stability Upon Approval of MELLLA+ Brunswick will use GEH DSS
Challenges, Risk Reduction Coordination of LAR submittal predecessors and successors NRC approval of AREVA generic methodologies will minimize plant specific methodology submittals MELLLA+ must be approved 2018 Advanced AREVA Methods LAR Requesting 17 month review cycle 6 AREVA generic methodologies, one plant specific methodology added to TS 5.6.5.b for ATRIUM 11 Initial LAR will provide examples of application of the AREVA methodologies to BNP Thermal Hydraulic, LOCA, Fuel Cycle Design, Assembly Mechanical, ATWSi, Nuclear Fuel Bundle Design, Fuel Rod Mechanical, AURORA-B Limiting Transient Analysis, Stability 2007 AREVA Methods LAR - 14 month review supporting fuel vendor change 2010 AREVA Methods LAR - 11.5 month review supporting A10XM transition 15
-CD for stability monitoring DSS-CD LAR requires qualification on a fuel type specific basis Plant specific approach required to qualify for ATRIUM 11 AREVA will submit their  generic BEO
 
-III methodology topical for review in 4Q2017 Includes previously approved RAMONA5
Prioritization of NRC Reviews Current schedule shows only the AREVA Generic LOCA methodology schedule may become limiting Other AREVA generic methodology reviews are near completion or have good margin Focus should remain on completing the AREVA Generic LOCA methodology draft SE on the current schedule to support submittal ATWSI - AREVA will submit generic methodology 4Q2017 Review of the generic methodology will be directly applicable to the BNP LAR Review of the generic methodology would expedite the BNP plant specific application Stability AREVA will submit generic BEO-III stability methodology 4Q2017 LAR will utilize only the RAMONA5-FA portion of BEO-III as part of the qualification of DSS-CD for ATRIUM 11 NRC review focus on the RAMONA5-FA portion prior to the BNP submittal would expedite review of BNP plant specific application submitted with LAR 16
-FA (other generic BEO
 
-III elements not needed by this LAR)
Relationship to MELLLA+
Draft SE unlikely by September 2018 Plant Specific Approach: evaluate Brunswick equilibrium ATRIUM 11 core with AREVA generic RAMONA5-FA Approved RAMONA5
-FA use will be extended to generate time dependent LPRM signals and critical power response for the limiting stability events Feed GEH DSS
-CD algorithm with RAMONA5
-FA results to confirm margin to the SLMCPR at time of SCRAM Duke to provide any needed translation between RAMONA5
-FA output and GEH DSS
-CD algorithm LAR to include description and details of plant specific DSS
-CD qualification for ATRIUM 11 12 LAR Methodologies: Plant Specific
- ATWSi AREVA Generic ATWSi, ANP-10345P, to be submitted in late 2017 Brunswick will be used as a sample problem for the AREVA generic topical report Intent is to provide extensive overlap between the AREVA generic submittal in 2017 and the plant
-specific submittal in 2018 Given the timeline, a plant
-specific submittal will be required to support ATRIUM 11 introduction at Brunswick Plan to submit a plant specific version of the AREVA generic topical report which will minimize the differences to editorial Allows for efficiencies as AREVA generic review will remain directly applicable to the plant-specific submittal  13 Other Technical Considerations AREVA to generate generic ATRIUM 11 fuel
-specific one-time document ANF-89-98(P)(A), Generic Mechanical Design Criteria for BWR Fuel Designs ATRIUM 11 compliance document provided by AREVA to NRC for information only TN-B1 License for ATRIUM 11 Shipments Updated SAR submitted
- NRC Approval Expected by Spring 2019 14 Challenges, Risk Reduction Coordination of LAR submittal predecessors and successors NRC approval of AREVA generic methodologies will minimize plant specific methodology submittals MELLLA+ must be approved 2018 Advanced AREVA Methods LAR Requesting 17 month review cycle 6 AREVA generic methodologies, one plant specific methodology added to TS 5.6.5.b for ATRIUM 11 Initial LAR will provide examples of application of the AREVA methodologies to BNP Thermal Hydraulic, LOCA, Fuel Cycle Design, Assembly Mechanical, ATWSi, Nuclear Fuel Bundle Design, Fuel Rod Mechanical, AURORA
-B Limiting Transient Analysis, Stability 2007 AREVA Methods LAR  
- 14 month review supporting fuel vendor change 2010 AREVA Methods LAR  
- 11.5 month review supporting A10XM transition 15 Prioritization of NRC Reviews Current schedule shows only the AREVA Generic LOCA methodology schedule may become limiting Other AREVA generic methodology reviews are near completion or have good margin Focus should remain on completing the AREVA Generic LOCA methodology draft SE on the current schedule to support submittal ATWSI - AREVA will submit generic methodology 4Q2017 Review of the generic methodology will be directly applicable to the BNP LAR Review of the generic methodology would expedite the BNP plant specific application Stability AREVA will submit generic BEO
-III stability methodology 4Q2017 LAR will utilize only the RAMONA5
-FA portion of BEO
-III as part of the qualification of DSS
-CD for ATRIUM 11 NRC review focus on the RAMONA5
-FA portion prior to the BNP submittal would expedite review of BNP plant specific application submitted with LAR 16 Relationship to MELLLA+
Advanced AREVA Methods LAR will not be submitted until MELLLA+ LAR approved BNP MELLLA+ LAR with ATRIUM 10XM fuel submitted September 2016 Draft SE expected Spring 2018 with approval September 2018 The LAR will demonstrate advanced AREVA methods applicability to an Expanded Flow Window (EFW)/MELLLA+ ATRIUM 11 equilibrium cycle To support ATRIUM 11 Reloads:
Advanced AREVA Methods LAR will not be submitted until MELLLA+ LAR approved BNP MELLLA+ LAR with ATRIUM 10XM fuel submitted September 2016 Draft SE expected Spring 2018 with approval September 2018 The LAR will demonstrate advanced AREVA methods applicability to an Expanded Flow Window (EFW)/MELLLA+ ATRIUM 11 equilibrium cycle To support ATRIUM 11 Reloads:
Application of AREVA ATWSi methodology to Brunswick DSS-CD will continue to be used for stability protection for ATRIUM 11 17 Summary Proposed date for LAR submittal  
Application of AREVA ATWSi methodology to Brunswick DSS-CD will continue to be used for stability protection for ATRIUM 11 17
- September 2018 SER need date - February 2020 17 month LAR review LAR will request the use of many advanced AREVA methodologies that are currently under NRC review Two plant specific methodologies will be used to support the LAR Risk/Challenges identified and addressed along with review prioritization Critical NRC actions are approval of MELLLA+ and AURORA
 
-B LOCA Proposed schedule/plan is challenging but achievable 18 19 Backup Slide  
Summary Proposed date for LAR submittal - September 2018 SER need date - February 2020 17 month LAR review LAR will request the use of many advanced AREVA methodologies that are currently under NRC review Two plant specific methodologies will be used to support the LAR Risk/Challenges identified and addressed along with review prioritization Critical NRC actions are approval of MELLLA+ and AURORA-B LOCA Proposed schedule/plan is challenging but achievable 18
- Past LAR Experience 2007 AREVA Methods LAR Approval obtained one month prior to startup after a 14 month review 18 generic methodologies added to TS 5.6.5.b to introduce AREVA fuel (ATRIUM
 
-10) Initial LAR did not provide examples of application of the AREVA methodologies to BNP Thermal Hydraulic, LOCA, Fuel Cycle Design, and Reload Safety Analysis reports were provided in supplemental transmittals 2010 AREVA Methods LAR Approved a few days prior to startup after a 11.5 month review Two additional generic methodologies added to TS 5.6.5.b to introduce ATRIUM 10XM Initial LAR did not provide examples of application of the AREVA methodologies to BNP Thermal Hydraulic, LOCA, Fuel Cycle Design, Fuel Rod Thermal Mechanical Evaluation, Mechanical Design Report, and Reload Safety Analysis reports were provided in supplemental transmittals 20}}
19 Backup Slide - Past LAR Experience 2007 AREVA Methods LAR Approval obtained one month prior to startup after a 14 month review 18 generic methodologies added to TS 5.6.5.b to introduce AREVA fuel (ATRIUM-10)
Initial LAR did not provide examples of application of the AREVA methodologies to BNP Thermal Hydraulic, LOCA, Fuel Cycle Design, and Reload Safety Analysis reports were provided in supplemental transmittals 2010 AREVA Methods LAR Approved a few days prior to startup after a 11.5 month review Two additional generic methodologies added to TS 5.6.5.b to introduce ATRIUM 10XM Initial LAR did not provide examples of application of the AREVA methodologies to BNP Thermal Hydraulic, LOCA, Fuel Cycle Design, Fuel Rod Thermal Mechanical Evaluation, Mechanical Design Report, and Reload Safety Analysis reports were provided in supplemental transmittals 20}}

Latest revision as of 06:27, 4 December 2019

Meeting Slide Regarding Partially Closed Pre-submittal Public Meeting with Duke Energy for a License Amendment Request for Brunswick Steam Electric Plant
ML17229B294
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 08/22/2017
From: Murray W
Duke Energy Progress
To: Andrew Hon
Plant Licensing Branch II
Hon A, NRR/DORL/LPL2-2, 415-8480
References
Download: ML17229B294 (20)


Text

Brunswick Advanced AREVA Methods LAR NRC Pre-Application Meeting 8/22/17

Background

On a 6/15/17 teleconference, Duke Energy and the NRC discussed our intent to submit an LAR to adopt Advanced AREVA Methods Advanced AREVA Methods are needed to support ATRIUM 11 deployment Advanced AREVA Methods LAR approval needed by Feb 2020 to support first reload of ATRIUM 11 2

Background (cont)

Based upon 6/15 NRC feedback additional information will be presented on, Motivation for LAR Proposed Milestones/Schedule LAR Content Staged submittal for some cycle specific items for first reload of ATRIUM 11 LAR Methodologies Generic Advanced AREVA Methods Plant specific methodologies Other Technical Considerations Challenges, Risk Reduction Prioritization of NRC reviews Relationship to MELLLA+

3

Motivation for LAR Eight Brunswick Unit 2 ATRIUM 11 LUAs operating since 2015 remaining fuel is ATRIUM 10XM in both units Duke Energy desires to deploy ATRIUM 11 fuel in reload quantities 11x11 array reduces LHGR (~19%) and fuel duty improving safety margin Improved debris protection features (fuel failure risk reduction)

Improved channel performance Improved fuel cycle economics First ATRIUM 11 reloads Unit 1 Cycle 23 - Startup April 2020 Unit 2 Cycle 25 - Startup April 2021 4

Proposed Milestones Date for LAR submittal September 2018 After MELLLA+ LAR approval SER need date February 2020 17 months available for review of Advanced AREVA Methods LAR 5

LAR Content Reports submitted with LAR based upon BNP equilibrium ATRIUM 11 Design:

Assembly Mechanical Design reports Methods Applicability Supplement Document Thermal Hydraulic Design Report LOCA/MAPLHGR Report BWR Licensing Methodology Compendium Updated for new methods (AURORA-B [LOCA / Transients and Accidents / CRDA], ACE / ATRIUM 11, and Cr-Doped fuel)

ATWSi Plant Specific Methodology Analysis Report Fuel Cycle Design Report Nuclear Fuel Bundle Design Report Fuel Rod Design Report AURORA-B Limiting Transient Analysis Uncertainty Demonstration DSS-CD Qualification for ATRIUM 11 6

LAR Content (cont)

Implementation cycle reports will be submitted post LAR for information:

Fuel Cycle Design Report - March 2019 Nuclear Fuel Bundle Design Report - March 2019 Safety Limit MCPR Report - May 2019 Fuel Rod Design Report - October 2019 Reload Safety Analysis Report - October 2019 (dates represent a 3 month acceleration compared to a normal reload schedule)

Submittal strategy and timeline based upon successful BNP LAR submittals used to implement AREVA methods in 2007 and 2010.

7

LAR Content: TS 5.6.5 Additions AREVA Thermal-mechanical methodologies BAW-10247P-A, Supplement 2P, Revision 0, Realistic Thermal-Mechanical Fuel Rod Methodology for Boiling Water Reactors Supplement 2: Mechanical Methods - Submitted April 2016 ANP-10340P Revision 0, Incorporation of Chromium-Doped Fuel in AREVA Approved Methods - Submitted April 2016 Plant specific Brunswick DSS-CD Qualification for ATRIUM 11 8

LAR Content: TS 5.6.5 Additions (cont)

AREVA Licensing methodologies ANP-10335P Revision 0, ACE/ATRIUM 11 Critical Power Correlation - Submitted Feb 2015, SE Pending ANP-10300P Revision 0, AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Transient and Accident Scenarios - Submitted December 2009, Draft SE July 2017 ANP-10332P Revision 0, AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Loss of Coolant Accident Scenarios - Submitted March 2014 ANP-10333P Revision 0, AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Control Rod Drop Accident Scenarios - Submitted March 2014 9

LAR Methodologies: AREVA Generic 6 AREVA generic methodologies There is good potential for all AREVA generic methodologies to be approved by the time of submittal Estimated Estimated Methodology Draft SE Date Final SE Date AURORA-B AOO Complete 11/30/2017 AURORA-B CRDA 9/1/2017 4/30/2018 AURORA-B LOCA 6/30/2018 After LAR Submittal ACE ATRIUM 11 Critical Imminent 4th Quarter 2017 Power Correlation Cr-doped Extension to 1/31/2018 4/30/2018 RODEX4 BWR Mechanical Methods 9/31/2017 12/31/2017 10

LAR Methodologies: AREVA Generic Current AREVA Advanced Methods Generic Methodology approval status 11

LAR Methodologies: Plant Specific - Stability Upon Approval of MELLLA+ Brunswick will use GEH DSS-CD for stability monitoring DSS-CD LAR requires qualification on a fuel type specific basis Plant specific approach required to qualify for ATRIUM 11 AREVA will submit their generic BEO-III methodology topical for review in 4Q2017 Includes previously approved RAMONA5-FA (other generic BEO-III elements not needed by this LAR)

Draft SE unlikely by September 2018 Plant Specific Approach: evaluate Brunswick equilibrium ATRIUM 11 core with AREVA generic RAMONA5-FA Approved RAMONA5-FA use will be extended to generate time dependent LPRM signals and critical power response for the limiting stability events Feed GEH DSS-CD algorithm with RAMONA5-FA results to confirm margin to the SLMCPR at time of SCRAM Duke to provide any needed translation between RAMONA5-FA output and GEH DSS-CD algorithm LAR to include description and details of plant specific DSS-CD qualification for ATRIUM 11 12

LAR Methodologies: Plant Specific - ATWSi AREVA Generic ATWSi, ANP-10345P, to be submitted in late 2017 Brunswick will be used as a sample problem for the AREVA generic topical report Intent is to provide extensive overlap between the AREVA generic submittal in 2017 and the plant-specific submittal in 2018 Given the timeline, a plant-specific submittal will be required to support ATRIUM 11 introduction at Brunswick Plan to submit a plant specific version of the AREVA generic topical report which will minimize the differences to editorial Allows for efficiencies as AREVA generic review will remain directly applicable to the plant-specific submittal 13

Other Technical Considerations AREVA to generate generic ATRIUM 11 fuel-specific one-time document ANF-89-98(P)(A), Generic Mechanical Design Criteria for BWR Fuel Designs ATRIUM 11 compliance document provided by AREVA to NRC for information only TN-B1 License for ATRIUM 11 Shipments Updated SAR submitted - NRC Approval Expected by Spring 2019 14

Challenges, Risk Reduction Coordination of LAR submittal predecessors and successors NRC approval of AREVA generic methodologies will minimize plant specific methodology submittals MELLLA+ must be approved 2018 Advanced AREVA Methods LAR Requesting 17 month review cycle 6 AREVA generic methodologies, one plant specific methodology added to TS 5.6.5.b for ATRIUM 11 Initial LAR will provide examples of application of the AREVA methodologies to BNP Thermal Hydraulic, LOCA, Fuel Cycle Design, Assembly Mechanical, ATWSi, Nuclear Fuel Bundle Design, Fuel Rod Mechanical, AURORA-B Limiting Transient Analysis, Stability 2007 AREVA Methods LAR - 14 month review supporting fuel vendor change 2010 AREVA Methods LAR - 11.5 month review supporting A10XM transition 15

Prioritization of NRC Reviews Current schedule shows only the AREVA Generic LOCA methodology schedule may become limiting Other AREVA generic methodology reviews are near completion or have good margin Focus should remain on completing the AREVA Generic LOCA methodology draft SE on the current schedule to support submittal ATWSI - AREVA will submit generic methodology 4Q2017 Review of the generic methodology will be directly applicable to the BNP LAR Review of the generic methodology would expedite the BNP plant specific application Stability AREVA will submit generic BEO-III stability methodology 4Q2017 LAR will utilize only the RAMONA5-FA portion of BEO-III as part of the qualification of DSS-CD for ATRIUM 11 NRC review focus on the RAMONA5-FA portion prior to the BNP submittal would expedite review of BNP plant specific application submitted with LAR 16

Relationship to MELLLA+

Advanced AREVA Methods LAR will not be submitted until MELLLA+ LAR approved BNP MELLLA+ LAR with ATRIUM 10XM fuel submitted September 2016 Draft SE expected Spring 2018 with approval September 2018 The LAR will demonstrate advanced AREVA methods applicability to an Expanded Flow Window (EFW)/MELLLA+ ATRIUM 11 equilibrium cycle To support ATRIUM 11 Reloads:

Application of AREVA ATWSi methodology to Brunswick DSS-CD will continue to be used for stability protection for ATRIUM 11 17

Summary Proposed date for LAR submittal - September 2018 SER need date - February 2020 17 month LAR review LAR will request the use of many advanced AREVA methodologies that are currently under NRC review Two plant specific methodologies will be used to support the LAR Risk/Challenges identified and addressed along with review prioritization Critical NRC actions are approval of MELLLA+ and AURORA-B LOCA Proposed schedule/plan is challenging but achievable 18

19 Backup Slide - Past LAR Experience 2007 AREVA Methods LAR Approval obtained one month prior to startup after a 14 month review 18 generic methodologies added to TS 5.6.5.b to introduce AREVA fuel (ATRIUM-10)

Initial LAR did not provide examples of application of the AREVA methodologies to BNP Thermal Hydraulic, LOCA, Fuel Cycle Design, and Reload Safety Analysis reports were provided in supplemental transmittals 2010 AREVA Methods LAR Approved a few days prior to startup after a 11.5 month review Two additional generic methodologies added to TS 5.6.5.b to introduce ATRIUM 10XM Initial LAR did not provide examples of application of the AREVA methodologies to BNP Thermal Hydraulic, LOCA, Fuel Cycle Design, Fuel Rod Thermal Mechanical Evaluation, Mechanical Design Report, and Reload Safety Analysis reports were provided in supplemental transmittals 20