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{{#Wiki_filter:OFFICIAL USE ONLY PROPRIETARY INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 2, 2018 Mr. Robert S. Bement Executive Vice President Nuclear/Chief Nuclear Officer Arizona Public Service Company P.O. Box 52034, Mail Station 7602 Phoenix, AZ 85072-2034  
{{#Wiki_filter:OFFICIAL USE ONLY         PROPRIETARY INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 2, 2018 Mr. Robert S. Bement Executive Vice President Nuclear/Chief Nuclear Officer Arizona Public Service Company P.O. Box 52034, Mail Station 7602 Phoenix, AZ 85072-2034


==SUBJECT:==
==SUBJECT:==
PALO VERDE NUCLEAR GENERA TING STATION, UNITS 1, 2, AND 3 -SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSE AMENDMENTS AND EXEMPTIONS RE: IMPLEMENTATION OF FRAMATOME HIGH THERMAL PERFORMANCE FUEL (EPID L-2018-LLA-0194 AND EPID L-2018-LLE-0010)  
PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 -
SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSE AMENDMENTS AND EXEMPTIONS RE:
IMPLEMENTATION OF FRAMATOME HIGH THERMAL PERFORMANCE FUEL (EPID L-2018-LLA-0194 AND EPID L-2018-LLE-0010)


==Dear Mr. Bement:==
==Dear Mr. Bement:==
By letter dated July 6, 2018, Arizona Public Service Company (APS) submitted license amendment and exemption requests for Palo Verde Nuclear Generating Station, Units 1, 2, and 3. The proposed amendments and exemptions would support the implementation of Framatome High Thermal Performance Fuel. The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of these amendment and exemption requests.
 
The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the license amendment and exemption applications have any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant. Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an amendment to the license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications.
By letter dated July 6, 2018, Arizona Public Service Company (APS) submitted license amendment and exemption requests for Palo Verde Nuclear Generating Station, Units 1, 2, and 3. The proposed amendments and exemptions would support the implementation of Framatome High Thermal Performance Fuel.
Section 50.34 of 10 CFR addresses the content of technical information required.
The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of these amendment and exemption requests. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the license amendment and exemption applications have any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an amendment to the license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required.
This section stipulates that the submittal address the design and operating characteristics unusual or novel design features, and principal safety considerations.
This section stipulates that the submittal address the design and operating characteristics unusual or novel design features, and principal safety considerations.
Enclosure 1 to this document contains Proprietary Information.
Enclosure 1 to this document contains Proprietary Information. When separated from Enclosure 1, this letter is DECONTROLLED.
When separated from Enclosure 1, this letter is DECONTROLLED.
OFFICIAL USE ONLY         PROPRIETARY INFORMATION
OFFICIAL USE ONLY PROPRIETARY INFORMATION R. Bement OFFICIAL USE ONLY PROPRIETARY INFORMATION Consistent with Section 50.12 of 10 CFR, the Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of the regulations of this part, which are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security.
 
The Commission will not consider granting an exemption unless special circumstances are present, as specified in Section 50.12(a)(2).
OFFICIAL USE ONLY         PROPRIETARY INFORMATION R. Bement                                        Consistent with Section 50.12 of 10 CFR, the Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of the regulations of this part, which are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. The Commission will not consider granting an exemption unless special circumstances are present, as specified in Section 50.12(a)(2).
The NRC staff has reviewed your license amendment and exemption applications and concluded that the information delineated in the enclosure  
The NRC staff has reviewed your license amendment and exemption applications and concluded that the information delineated in the enclosure 'to this letter is necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed amendments and exemptions in terms of regulatory requirements and the protection of public health and safety and the environment.
'to this letter is necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed amendments and exemptions in terms of regulatory requirements and the protection of public health and safety and the environment.
In order to make the license amendment and exemption applications complete, the NRC staff requests that APS supplement the application to address the information requested in the enclosure by October 22, 2018. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff's request is not received by the above date, the license amendment and exemption applications will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the applications. If the applications are subsequently accepted for review, you will be advised of any further information needed to support the NRC staff's detailed technical review by separate correspondence.
In order to make the license amendment and exemption applications complete, the NRC staff requests that APS supplement the application to address the information requested in the enclosure by October 22, 2018. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff's request is not received by the above date, the license amendment and exemption applications will not be accepted for review pursuant to 1 O CFR 2.101, and the NRC will cease its review activities associated with the applications.
The information requested and associated timeframe in this letter were discussed with Mr. Tom Weber of your staff on September 27, 2018.
If the applications are subsequently accepted for review, you will be advised of any further information needed to support the NRC staff's detailed technical review by separate correspondence.
If you have any questions, please contact me at (301) 415-3229 or via e-mail at Michael. Orenak@nrc.gov.
The information requested and associated timeframe in this letter were discussed with Mr. Tom Weber of your staff on September 27, 2018. If you have any questions, please contact me at (301) 415-3229 or via e-mail at Michael. Orenak@nrc.gov.
Sincerely, IRA Margaret W. O'Banion for/
Docket Nos. STN 50-528, STN 50-529, and STN 50-530  
Michael D. Orenak, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, and STN 50-530


==Enclosure:==
==Enclosure:==
: 1. Supplemental Information Needed (Proprietary version) 2. Supplemental Information Needed (Non Proprietary version) cc: w/o Enclosure 1: Listerv Sincerely, IRA Margaret W. O'Banion for/ Michael D. Orenak, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation OFFICIAL USE ONLY PROPRIETARY INFORMATION Enclosure 2 REQUESTED SUPPLEMENTAL INFORMATION LICENSE AMENDMENT AND EXEMPTION REQUESTS REGARDING IMPLEMENTATION OF FRAMATOME HIGH THERMAL PERFORMANCE FUEL ARIZONA PUBLIC SERVICE COMPANY PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530 (NON-PROPRIETARY)
: 1. Supplemental Information Needed (Proprietary version)
Proprietary information pursuant to Section 2.390 of Title 1 O of the Code of Federal Regulations has been redacted from this document.
: 2. Supplemental Information Needed (Non Proprietary version) cc: w/o Enclosure 1: Listerv OFFICIAL USE ONLY         PROPRIETARY INFORMATION
 
Enclosure 2 REQUESTED SUPPLEMENTAL INFORMATION LICENSE AMENDMENT AND EXEMPTION REQUESTS REGARDING IMPLEMENTATION OF FRAMATOME HIGH THERMAL PERFORMANCE FUEL ARIZONA PUBLIC SERVICE COMPANY PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530 (NON-PROPRIETARY)
Proprietary information pursuant to Section 2.390 of Title 1O of the Code of Federal Regulations has been redacted from this document.
Redacted information is identified by blank space enclosed within double brackets.
Redacted information is identified by blank space enclosed within double brackets.
OFFICIAL USE ONLY PROPRIETARY INFORMATION SUPPLEMENTAL INFORMATION NEEDED LICENSE AMENDMENT AND EXEMPTION REQUESTS REGARDING IMPLEMENTATION OF FRAMATOME HIGH THERMAL PERFORMANCE FUEL ARIZONA PUBLIC SERVICE COMPANY PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530 By letter dated July 6, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18187A417), Arizona Public Service Company (APS, the licensee) submitted license amendment and exemption requests for Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Palo Verde). The proposed amendments and exemptions would support the implementation of Framatome High Thermal Performance Fuel. During the acceptance review of the license amendment and exemption applications (together, the application), the U.S. Nuclear Regulatory Commission (NRC) staff identified the following information needed before the application can be accepted by the NRC for review. 1. In Section 5.4.1.1, of Attachment 10 of the application, APS discusses its use of the VIPRE-01 computer code. VIPRE-01 has been previously reviewed and approved by the NRC staff. However, as noted by the NRC staff in its safety evaluation, "Each organization using VIPRE-01 for licensing calculations should submit separate documentation describing how they intend to use VIPRE-01 and providing justification for their specific modeling assumptions, choice of particular two-phase flow models and correlations, heat transfer correlations, CHF [critical heat flux] correlation and DNBR [departure from nucleate boiling ratio] limit, input values of plant specific data such as turbulent mixing coefficient, slip ratio, grid loss coefficient, etc., including defaults." In Section 5 of Enclosure 10 of the application, APS did not provide the details necessary for the NRC staff to approve the use of VIPRE-01.
 
Please submit the information that describes how APS intends to use VIPRE-01.
OFFICIAL USE ONLY           PROPRIETARY INFORMATION SUPPLEMENTAL INFORMATION NEEDED LICENSE AMENDMENT AND EXEMPTION REQUESTS REGARDING IMPLEMENTATION OF FRAMATOME HIGH THERMAL PERFORMANCE FUEL ARIZONA PUBLIC SERVICE COMPANY PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530 By letter dated July 6, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18187A417), Arizona Public Service Company (APS, the licensee) submitted license amendment and exemption requests for Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Palo Verde). The proposed amendments and exemptions would support the implementation of Framatome High Thermal Performance Fuel.
: 2. Since the publication of Regulatory Guide (RG) 1. 77, "Assumptions Used for Evaluating a Control Rod Ejection Accident for Pressurized Water Reactors" (ADAMS Accession No. ML003740279), the acceptance criteria of 280 calories per gram of deposited enthalpy has been found inadequate to ensure fuel rod geometry and long-term coolability.
During the acceptance review of the license amendment and exemption applications (together, the application), the U.S. Nuclear Regulatory Commission (NRC) staff identified the following information needed before the application can be accepted by the NRC for review.
The NRC staff documented its position on RG 1. 77 in a letter dated April 3, 2015, "Results of Periodic Review of Regulatory Guide 1.77" (ADAMS Accession No. ML15075A311  
: 1.     In Section 5.4.1.1, of Attachment 10 of the application, APS discusses its use of the VIPRE-01 computer code. VIPRE-01 has been previously reviewed and approved by the NRC staff. However, as noted by the NRC staff in its safety evaluation, "Each organization using VIPRE-01 for licensing calculations should submit separate documentation describing how they intend to use VIPRE-01 and providing justification for their specific modeling assumptions, choice of particular two-phase flow models and correlations, heat transfer correlations, CHF [critical heat flux] correlation and DNBR
). The position is supported by a guidance document dated January 19, 2007, titled "Technical and Regulatory Basis for the Reactivity-Initiated Accident Interim Acceptance Criteria and Guidance" (ADAMS Accession No. ML070220400).
[departure from nucleate boiling ratio] limit, input values of plant specific data such as turbulent mixing coefficient, slip ratio, grid loss coefficient, etc., including defaults."
Please demonstrate that the control element assembly ejection transient analysis results meet General Design Criterion 28, "Reactivity Limits," of Title 10 of the Code of Federal OFFICIAL USE ONLY PROPRIETARY INFORMATION OFFICIAL USE ONLY PROPRIETARY INFORMATION Regulations Part 50, Appendix A, by showing that fuel rod geometry and long-term coolability is maintained and that the effects of burn-up are considered in the analysis.
In Section 5 of Enclosure 10 of the application, APS did not provide the details necessary for the NRC staff to approve the use of VIPRE-01. Please submit the information that describes how APS intends to use VIPRE-01.
: 2.     Since the publication of Regulatory Guide (RG) 1. 77, "Assumptions Used for Evaluating a Control Rod Ejection Accident for Pressurized Water Reactors" (ADAMS Accession No. ML003740279), the acceptance criteria of 280 calories per gram of deposited enthalpy has been found inadequate to ensure fuel rod geometry and long-term coolability. The NRC staff documented its position on RG 1. 77 in a letter dated April 3, 2015, "Results of Periodic Review of Regulatory Guide 1.77" (ADAMS Accession No. ML15075A311 ). The position is supported by a guidance document dated January 19, 2007, titled "Technical and Regulatory Basis for the Reactivity-Initiated Accident Interim Acceptance Criteria and Guidance" (ADAMS Accession No. ML070220400).
Please demonstrate that the control element assembly ejection transient analysis results meet General Design Criterion 28, "Reactivity Limits," of Title 10 of the Code of Federal OFFICIAL USE ONLY           PROPRIETARY INFORMATION
 
OFFICIAL USE ONLY         PROPRIETARY INFORMATION Regulations Part 50, Appendix A, by showing that fuel rod geometry and long-term coolability is maintained and that the effects of burn-up are considered in the analysis.
: 3. Attachment 4 of the application, Insert "A" to 8.2.1.1, indicates that there will be three fuel types which will be used at Palo Verde (CE16STD, CE16NGF and CE16HTP).
: 3. Attachment 4 of the application, Insert "A" to 8.2.1.1, indicates that there will be three fuel types which will be used at Palo Verde (CE16STD, CE16NGF and CE16HTP).
However, in Section 5.5 of Attachment 10 of the application, APS seems to limit the mixed core assessment to (1) the inlet flow distribution, and (2) crossflow velocity analysis for mechanical calculations.
However, in Section 5.5 of Attachment 10 of the application, APS seems to limit the mixed core assessment to (1) the inlet flow distribution, and (2) crossflow velocity analysis for mechanical calculations. Provide a summary of the analysis that describes how mixed cores are treated from a thermal-hydraulic standpoint, especially noting any DNBR penalties which are needed due to the different fuel types. This should be provided for both the VIPRE-W and VIPRE-01 methodologies.
Provide a summary of the analysis that describes how mixed cores are treated from a thermal-hydraulic standpoint, especially noting any DNBR penalties which are needed due to the different fuel types. This should be provided for both the VIPRE-W and VIPRE-01 methodologies.
: 4. Pages 12 and 13 of Attachment 5 of the application discuss the use of Topical Report CENPD-183-A, "C-E methods for Loss of Flow Analysis" (ADAMS Accession No. ML16224A358) for loss of flow analysis using several codes, such as COAST, QUIX, COSMO/W3, TORC/CE1 and CESEC. The methodology and codes are approved for Combustion Engineering (CE) or Westinghouse type of fuels. Please provide a detailed justification as to how these codes can be applied to the Palo Verde mixed core with Framatome CE 16x16 high thermal performance (HTP) fuel design.
: 4. Pages 12 and 13 of Attachment 5 of the application discuss the use of Topical Report CENPD-183-A, "C-E methods for Loss of Flow Analysis" (ADAMS Accession No. ML16224A358) for loss of flow analysis using several codes, such as COAST, QUIX, COSMO/W3, TORC/CE1 and CESEC. The methodology and codes are approved for Combustion Engineering (CE) or Westinghouse type of fuels. Please provide a detailed justification as to how these codes can be applied to the Palo Verde mixed core with Framatome CE 16x16 high thermal performance (HTP) fuel design. 5. Section 5.4.3 of Attachment 10 of the application discusses the proposed implementation of the BHTP (designation for a Framatome CHF Correlation)
: 5. Section 5.4.3 of Attachment 10 of the application discusses the proposed implementation of the BHTP (designation for a Framatome CHF Correlation) CHF correlation with the VIPRE-01 and VIPRE-W thermal-hydraulic codes and with several other thermal-hydraulics codes at Palo Verde. The examples cited are:
CHF correlation with the VIPRE-01 and VIPRE-W thermal-hydraulic codes and with several other thermal-hydraulics codes at Palo Verde. The examples cited are:
* Implementing the ABB-NV or WSSV CHF correlations, which the NRC has previously approved for use with the VIPRE-W code, for use with the VIPRE-01 code;
* Implementing the ABB-NV or WSSV CHF correlations, which the NRC has previously approved for use with the VIPRE-W code, for use with the VIPRE-01 code;
* Implementing the CE-1 CHF correlation, which the NRC has previously approved for use with the VIPRE-W, CETOP-D, and TORC codes, for use with the VIPRE-01 code;
* Implementing the CE-1 CHF correlation, which the NRC has previously approved for use with the VIPRE-W, CETOP-D, and TORC codes, for use with the VIPRE-01 code;
* Implementing the BHTP CHF correlation, which is anticipated to be approved for use with the VIPRE-01 and VIPRE-W code as described in this license amendment request, with the CETOP-D code and/or the TORC code. Please provide detailed explanations for inserting the different correlations into the above codes with respect to validation, verification, and sensitivity studies. 6. Section 1.3 of Attachment 10 of the application states, in part, The current APS Core Thermal Hydraulic Analysis scope will be modified to the extent that [[ ]) for compliance with Technical Specification limits on DNBR.
* Implementing the BHTP CHF correlation, which is anticipated to be approved for use with the VIPRE-01 and VIPRE-W code as described in this license amendment request, with the CETOP-D code and/or the TORC code.
OFFICIAL USE ONLY PROPRIETARY INFORMATION The specifics of this modification process in Section 5 of Attachment 1 O do not appear to be provided.
Please provide detailed explanations for inserting the different correlations into the above codes with respect to validation, verification, and sensitivity studies.
Please provide a detailed explanation of which computer codes were needed to be modified by the addition of BHTP and how that modification took place. 7. Section 11 of Attachment 10 provides a short summary of Core Operating Limits Supervisory System/Core Protection Calculator System (COLSS/CPCS) setpoints analysis that is unique for some CE plants. This section provides a very limited description of the setpoints analysis for Palo Verde cores which use Framatome CE 16x16 HTP fuel. a. Please provide justification for the CE setpoints methodology applicability to Framatome fuel. b. Please provide details of how the CE setpoints methodology is applied to the cores with Framatome fuel design.
: 6. Section 1.3 of Attachment 10 of the application states, in part, The current APS Core Thermal Hydraulic Analysis scope will be modified to the extent that ((
OFFICIAL USE ONLY PROPRIETARY INFORMATION R. Bement
                                                            ]) for compliance with Technical Specification limits on DNBR.


==SUBJECT:==
OFFICIAL USE ONLY          PROPRIETARY INFORMATION The specifics of this modification process in Section 5 of Attachment 1O do not appear to be provided. Please provide a detailed explanation of which computer codes were needed to be modified by the addition of BHTP and how that modification took place.
PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3-SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSE AMENDMENTS AND EXEMPTIONS RE: IMPLEMENTATION OF FRAMATOME HIGH THERMAL PERFORMANCE FUEL (EPID L-2018-LLA-0194AND EPID L-2018-LLE-0010)
: 7. Section 11 of Attachment 10 provides a short summary of Core Operating Limits Supervisory System/Core Protection Calculator System (COLSS/CPCS) setpoints analysis that is unique for some CE plants. This section provides a very limited description of the setpoints analysis for Palo Verde cores which use Framatome CE 16x16 HTP fuel.
DATED OCTOBER 2, 2018 DISTRIBUTION:
: a. Please provide justification for the CE setpoints methodology applicability to Framatome fuel.
PUBLIC PM Reading File RidsACRS_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrPMPaloVerde Resource RidsNrrLAPBlechman Resource RidsRgn4Mai1Center Resource MBales, NRR MPanicker, NRR JKaizer, NRR JLehning, NRR JBorromeo, NRR ADAMS Accession Nos: PKG ML18271A037 Proprietary ML18271A035 Non-Proprietary ML18271A039 OFFICE NRR/DORL/LPL4/PM NAME MOrenak DATE 9/28/18 OFFICE NRR/DSS/SRXB/BC NAME JWhitman DATE 8/24/18 NRR/DORL/LPL4/LA NRR/DSS/SNPB/BC PBlechman Rlukes 9/28/18 8/31/18 NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM RPascarelli MOrenak (MO'Banion for) 10/01/18 10/2/18 OFFICIAL RECORD COPY OFFICIAL USE ONLY PROPRIETARY INFORMATION}}
: b. Please provide details of how the CE setpoints methodology is applied to the cores with Framatome fuel design.
 
PKG ML18271A037 Proprietary ML18271A035 Non-Proprietary ML18271A039 OFFICE   NRR/DORL/LPL4/PM     NRR/DORL/LPL4/LA     NRR/DSS/SNPB/BC NAME      MOrenak              PBlechman           Rlukes DATE      9/28/18              9/28/18             8/31/18 OFFICE    NRR/DSS/SRXB/BC      NRR/DORL/LPL4/BC     NRR/DORL/LPL4/PM NAME      JWhitman              RPascarelli         MOrenak (MO'Banion for)
DATE      8/24/18              10/01/18             10/2/18}}

Latest revision as of 05:12, 17 March 2020

Non Proprietary - Supplemental Information Needed for Acceptance of Requested License Amendments and Exemptions Implementation of Framatome High Thermal Performance Fuel (Epids L-2018-LLA-0194 and L-2018-LLE-0010)
ML18271A039
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 10/02/2018
From: Michael Orenak
Plant Licensing Branch IV
To: Bement R
Arizona Public Service Co
Orenak M
References
EPID L-2018-LLA-0194, EPID L-2018-LLE-0010
Download: ML18271A039 (7)
v • d • e


Text

OFFICIAL USE ONLY PROPRIETARY INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 2, 2018 Mr. Robert S. Bement Executive Vice President Nuclear/Chief Nuclear Officer Arizona Public Service Company P.O. Box 52034, Mail Station 7602 Phoenix, AZ 85072-2034

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 -

SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSE AMENDMENTS AND EXEMPTIONS RE:

IMPLEMENTATION OF FRAMATOME HIGH THERMAL PERFORMANCE FUEL (EPID L-2018-LLA-0194 AND EPID L-2018-LLE-0010)

Dear Mr. Bement:

By letter dated July 6, 2018, Arizona Public Service Company (APS) submitted license amendment and exemption requests for Palo Verde Nuclear Generating Station, Units 1, 2, and 3. The proposed amendments and exemptions would support the implementation of Framatome High Thermal Performance Fuel.

The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of these amendment and exemption requests. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the license amendment and exemption applications have any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.

Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an amendment to the license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required.

This section stipulates that the submittal address the design and operating characteristics unusual or novel design features, and principal safety considerations.

Enclosure 1 to this document contains Proprietary Information. When separated from Enclosure 1, this letter is DECONTROLLED.

OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION R. Bement Consistent with Section 50.12 of 10 CFR, the Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of the regulations of this part, which are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. The Commission will not consider granting an exemption unless special circumstances are present, as specified in Section 50.12(a)(2).

The NRC staff has reviewed your license amendment and exemption applications and concluded that the information delineated in the enclosure 'to this letter is necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed amendments and exemptions in terms of regulatory requirements and the protection of public health and safety and the environment.

In order to make the license amendment and exemption applications complete, the NRC staff requests that APS supplement the application to address the information requested in the enclosure by October 22, 2018. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff's request is not received by the above date, the license amendment and exemption applications will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the applications. If the applications are subsequently accepted for review, you will be advised of any further information needed to support the NRC staff's detailed technical review by separate correspondence.

The information requested and associated timeframe in this letter were discussed with Mr. Tom Weber of your staff on September 27, 2018.

If you have any questions, please contact me at (301) 415-3229 or via e-mail at Michael. Orenak@nrc.gov.

Sincerely, IRA Margaret W. O'Banion for/

Michael D. Orenak, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, and STN 50-530

Enclosure:

1. Supplemental Information Needed (Proprietary version)
2. Supplemental Information Needed (Non Proprietary version) cc: w/o Enclosure 1: Listerv OFFICIAL USE ONLY PROPRIETARY INFORMATION

Enclosure 2 REQUESTED SUPPLEMENTAL INFORMATION LICENSE AMENDMENT AND EXEMPTION REQUESTS REGARDING IMPLEMENTATION OF FRAMATOME HIGH THERMAL PERFORMANCE FUEL ARIZONA PUBLIC SERVICE COMPANY PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530 (NON-PROPRIETARY)

Proprietary information pursuant to Section 2.390 of Title 1O of the Code of Federal Regulations has been redacted from this document.

Redacted information is identified by blank space enclosed within double brackets.

OFFICIAL USE ONLY PROPRIETARY INFORMATION SUPPLEMENTAL INFORMATION NEEDED LICENSE AMENDMENT AND EXEMPTION REQUESTS REGARDING IMPLEMENTATION OF FRAMATOME HIGH THERMAL PERFORMANCE FUEL ARIZONA PUBLIC SERVICE COMPANY PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530 By letter dated July 6, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18187A417), Arizona Public Service Company (APS, the licensee) submitted license amendment and exemption requests for Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Palo Verde). The proposed amendments and exemptions would support the implementation of Framatome High Thermal Performance Fuel.

During the acceptance review of the license amendment and exemption applications (together, the application), the U.S. Nuclear Regulatory Commission (NRC) staff identified the following information needed before the application can be accepted by the NRC for review.

1. In Section 5.4.1.1, of Attachment 10 of the application, APS discusses its use of the VIPRE-01 computer code. VIPRE-01 has been previously reviewed and approved by the NRC staff. However, as noted by the NRC staff in its safety evaluation, "Each organization using VIPRE-01 for licensing calculations should submit separate documentation describing how they intend to use VIPRE-01 and providing justification for their specific modeling assumptions, choice of particular two-phase flow models and correlations, heat transfer correlations, CHF [critical heat flux] correlation and DNBR

[departure from nucleate boiling ratio] limit, input values of plant specific data such as turbulent mixing coefficient, slip ratio, grid loss coefficient, etc., including defaults."

In Section 5 of Enclosure 10 of the application, APS did not provide the details necessary for the NRC staff to approve the use of VIPRE-01. Please submit the information that describes how APS intends to use VIPRE-01.

2. Since the publication of Regulatory Guide (RG) 1. 77, "Assumptions Used for Evaluating a Control Rod Ejection Accident for Pressurized Water Reactors" (ADAMS Accession No. ML003740279), the acceptance criteria of 280 calories per gram of deposited enthalpy has been found inadequate to ensure fuel rod geometry and long-term coolability. The NRC staff documented its position on RG 1. 77 in a letter dated April 3, 2015, "Results of Periodic Review of Regulatory Guide 1.77" (ADAMS Accession No. ML15075A311 ). The position is supported by a guidance document dated January 19, 2007, titled "Technical and Regulatory Basis for the Reactivity-Initiated Accident Interim Acceptance Criteria and Guidance" (ADAMS Accession No. ML070220400).

Please demonstrate that the control element assembly ejection transient analysis results meet General Design Criterion 28, "Reactivity Limits," of Title 10 of the Code of Federal OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION Regulations Part 50, Appendix A, by showing that fuel rod geometry and long-term coolability is maintained and that the effects of burn-up are considered in the analysis.

3. Attachment 4 of the application, Insert "A" to 8.2.1.1, indicates that there will be three fuel types which will be used at Palo Verde (CE16STD, CE16NGF and CE16HTP).

However, in Section 5.5 of Attachment 10 of the application, APS seems to limit the mixed core assessment to (1) the inlet flow distribution, and (2) crossflow velocity analysis for mechanical calculations. Provide a summary of the analysis that describes how mixed cores are treated from a thermal-hydraulic standpoint, especially noting any DNBR penalties which are needed due to the different fuel types. This should be provided for both the VIPRE-W and VIPRE-01 methodologies.

4. Pages 12 and 13 of Attachment 5 of the application discuss the use of Topical Report CENPD-183-A, "C-E methods for Loss of Flow Analysis" (ADAMS Accession No. ML16224A358) for loss of flow analysis using several codes, such as COAST, QUIX, COSMO/W3, TORC/CE1 and CESEC. The methodology and codes are approved for Combustion Engineering (CE) or Westinghouse type of fuels. Please provide a detailed justification as to how these codes can be applied to the Palo Verde mixed core with Framatome CE 16x16 high thermal performance (HTP) fuel design.
5. Section 5.4.3 of Attachment 10 of the application discusses the proposed implementation of the BHTP (designation for a Framatome CHF Correlation) CHF correlation with the VIPRE-01 and VIPRE-W thermal-hydraulic codes and with several other thermal-hydraulics codes at Palo Verde. The examples cited are:
  • Implementing the ABB-NV or WSSV CHF correlations, which the NRC has previously approved for use with the VIPRE-W code, for use with the VIPRE-01 code;
  • Implementing the CE-1 CHF correlation, which the NRC has previously approved for use with the VIPRE-W, CETOP-D, and TORC codes, for use with the VIPRE-01 code;
  • Implementing the BHTP CHF correlation, which is anticipated to be approved for use with the VIPRE-01 and VIPRE-W code as described in this license amendment request, with the CETOP-D code and/or the TORC code.

Please provide detailed explanations for inserting the different correlations into the above codes with respect to validation, verification, and sensitivity studies.

6. Section 1.3 of Attachment 10 of the application states, in part, The current APS Core Thermal Hydraulic Analysis scope will be modified to the extent that ((

]) for compliance with Technical Specification limits on DNBR.

OFFICIAL USE ONLY PROPRIETARY INFORMATION The specifics of this modification process in Section 5 of Attachment 1O do not appear to be provided. Please provide a detailed explanation of which computer codes were needed to be modified by the addition of BHTP and how that modification took place.

7. Section 11 of Attachment 10 provides a short summary of Core Operating Limits Supervisory System/Core Protection Calculator System (COLSS/CPCS) setpoints analysis that is unique for some CE plants. This section provides a very limited description of the setpoints analysis for Palo Verde cores which use Framatome CE 16x16 HTP fuel.
a. Please provide justification for the CE setpoints methodology applicability to Framatome fuel.
b. Please provide details of how the CE setpoints methodology is applied to the cores with Framatome fuel design.

PKG ML18271A037 Proprietary ML18271A035 Non-Proprietary ML18271A039 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DSS/SNPB/BC NAME MOrenak PBlechman Rlukes DATE 9/28/18 9/28/18 8/31/18 OFFICE NRR/DSS/SRXB/BC NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME JWhitman RPascarelli MOrenak (MO'Banion for)

DATE 8/24/18 10/01/18 10/2/18

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