ML15356A185

ANP-3456NP, Revision 0, Response to SLU2 NRC Snpb RAI-9, Licensing Report.

ML15356A185
Person / Time
Site:	Saint Lucie
Issue date:	12/31/2015
From:	AREVA
To:	Office of Nuclear Reactor Regulation
Shared Package
ML15356A251	List: L-2015-300, ANP-3352NP, Revision 1, Transition License Amendment Request, Technical Report. ML15356A184 ML15356A185
References
L-2015-300, TAC MF5494, TAC MF5495 ANP-3456NP, Rev. 0
Download: ML15356A185 (35)

Text

L-2015-300 Attachment 3 ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensing Report Following 31 pages III kJU~U LJ~JL~UI I~I IL A RE EVA Response to SLU2 NRC SNPB RAI-9 Licensing Report AN P-3456N P Revision 0 December 2015 AREVA Inc.(c) 2015 AREVA Inc.

'.,LJI ILl UI[~U L/LJUUI I I~I IL ANP-3456NP Revision 0 Copyright

© 2015 AREVA Inc.All Rights Reserved

~~IJI [LI L/lI~U LJUL'UI I I~I IL AREVA Inc.AN P-3456N P Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensina Reoort Paae i Nature of Changes Item 1 Section(s) or Page(s)All Description and Justification Initial Issue

.;L,.U 1 IIl U.fiI t~i L.JUL,.7L.AI.i I I1.AREVA Inc. ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAi-9 Licensing Report Page ii Contents Page

1.0 INTRODUCTION

......................................................................

1-1 2.0 RESPONSES TO NRC QUESTION ................................................

2-1 2.1 NRC SNPB RAI-9.............................................................

2-1

3.0 REFERENCES

........................................................................

3-1

'AJ1 U!

I IL AREVA Inc. ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensinqi Report Paqie iii List of Tables Table 2-1 Seismic and LOCA Loadings...................................................

2-3 Table 2-2 Maximum Seismic and LOCA Impact Loads by Row Pattern................

2-4 Table 2-3 Maximum Vertical Impact Loads..............................................

2-21 AREVA Inc.Response to SLU2 NRC SNPB RAI-9 Line~nsina Renort: ANP-3456NP Revision 0 Paae iv Figure 2-1 Figure 2-2 Figure 2-3 Figure 2-4 Figure 2-5 Figure 2-6 Figure 2-7 List of Figures 17 Assembly Row Reactor Core Reload Pattern ............................

2-6 15 Assembly Row Reactor Core Reload Pattern ............................

2-7 13 Assembly Row Reactor Core Reload Pattern ............................

2-8 11 Assembly Row Reactor Core Reload Pattern ............................

2-9 9 Assembly Row Reactor Core Reload Pattern ............................

2-10 4 Assembly Row Reactor Core Reload Pattern ............................

2-11 Fuel Assembly Vertical Model Schematic...................................

2-22

~..jIjI III ~JII~U LJLJLUI I I~I IL AREVA Inc. ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensinqi Report Paqe 1-1

1.0 INTRODUCTION

This document contains the response to NRC SNPB RAI Question 9. The request is as follows: "The following questions are related to the seismic and seismic/LOCA evaluations of AREVA CE 16x16, HTP, co-resident CE 16x16 and mixed core at SLU-2 associated with its request for introduction of the new fuel. They are based on the relevant sections of ANP-3352P and ANP-3396P that were submitted to the NRC.a. ANP-3396P, Section 3.2 indicates that "for St. Lucie Unit 2, the events were analyzed for a full core of the current fuel design, a full core of the AREVA CE 16x16 HTP fuel, and for a wide range of mixed core configurations, in order to verify that the limiting loads and deflections remain within acceptable fuel design limits." Provide a summary of the results from the above-mentioned analyses for the three different configurations of the SL-2 core.b. TR BAW-10133(P)(A) originally modeled a Mark-C fuel assembly for seismic and LOCA analyses.

The licensee claims that the Addenda I and 2 of this TR has demonstrated its acceptability for other generic pressurized-water reactor fuel assembly designs, including the CE 16x16 HTP fuel design. Table 3.1 of ANP-3396P for Nominal Beginning of Life (BOL) Mechanical Design Data Comparison indicates significant differences in several listed parameters for CE I16x1 6 HTP and Mark-C fuel designs. Therefore, explain in detail how the differences are accounted for in the components testing." c. ANP-3396P states that additional testing and evaluations are included in the analyses to address this NRC Information Notice (IN) 2012-09. Provide detailed information on testing performed in response to IN 2012-09.d. Provide a detailed description of both the L] that are mentioned in the ANP-3396P report. Provide the results from the analysis that used the [] and explain in detail."

L.#IJI ILl ~JEI~U LJULiUI I I~I IL AREVA Inc.Response to SLU2 NRC SNPB RAI-9 Licensinq Report Note: ANP-3456NP Revision 0 Paqe 1-2]The information provided in ANP-3396P remains unchanged.

However, the new analyses affect some of the information in ANP-3352P, Revision 0, as identified in the revised report ANP-3352P, Revision 1, which has been revised to show the revised results. The analytical methods described and the conclusions of ANP-3352P, Revision o are unchanged.

The AREVA design continues to meet the design requirements for both the transition cores and the full cores. The responses presented in this RAI response, particularly part (a), also reflect the updated analysis.

After resolution of this issue, it was determined that ANP-3396P

[2] was unaffected.

'~.jLJE IL! LJII~U LJULUI I I~I IL AREVA Inc. ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 LicensinIq Report Paqe 2-1 2.0 RESPONSES TO NRC QUESTION 2.1 NRC SNPB RAI-9 Question # SNPB RAI-9 (a):."ANP-3396P, Section 3.2 indicates that "for St. Lucie Unit 2, the events were analyzed for a full core of the current fuel design, a full core of the AREVA CE 16x16 HTP fuel, and for a wide range of mixed core configurations, in order to verify that the limiting loads and deflections remain within acceptable fuel design limits." Provide a summary of the results from the above-mentioned analyses for the three different configurations of the SL-2 core." Response: The purpose of the analyses performed by AREVA is to evaluate the AREVA fuel against the safety criteria required for licensing.

As such, the analyses not only consider the eventual scenario in which the core is fully loaded with AREVA fuel, but also considers those transition (or mixed) cores as AREVA fuel is introduced.

The representation of the co-resident fuel in AREVA's mixed core analyses is made using inputs (e.g. fuel assembly dynamic characteristics and spacer grid impact characteristics) provided by the fuel vendor via the Licensee.

This representation of the co-resident fuel is adequate to assess the performance of AREVA's fuel design.

'..AJI ILl LJlI~U LJLJL'UI I I~I IL AREVA Inc. ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 LicensinQ Report Paae 2-2 Six row models were established to represent the different row lengths present in the St.Lucie Unit 2 core: 4-, 9-, 11-, 13-, 15-, and 17-assembly rows. Each row model was analyzed considering a full row of AREVA fuel in addition to various patterns of mixed rows with both AREVA and co-resident fuel. The various patterns provide the behavior trends due to the positions of the different fuel types. For the mixed core configuration at St. Lucie 2, the limiting load condition for either the AREVA or co-resident fuel [] The results of the various loading patterns in each row provide the basis for identifying the most limiting conditions.

For the St. Lucie Unit 2 analyses, a total of [ ] fuel assembly core patterns were ultimately analyzed and these are shown in Figures 2-1 through 2-6. These row patterns are sensitivity studies addressing the different assembly types in various core locations.

Note that the letters "A" and 'LWr' in these figures represent the locations of the AREVA CE 1 6x1 6 and co-resident fuel assemblies, respectively.

Each row model was subjected to the full set of seismic and LOCA loadings required for St. Lucie Unit 2.The analytical methodology used for the analyses is based on the methods described in BAW-10133PA, Rev. 1, including Addenda 1 and 2 [3].The maximum grid impact forces on the AREVA fuel for both LOCA and seismic accidents occur [] The results of these limiting cases are summarized below. Based on the evaluations performed, for both seismic (OBE and SSE) and LOCA events, the AREVA fuel assemblies meet design limits for both mixed core and full core conditions.

Table 2-1 provides the results for the limiting cases and Table 2-2 shows the loads for all the row configurations analyzed.

AREVA Inc.Response to SLU2 NRC SNPB RAI-9 Licensincq Report ANP-3456NP Revision 0 Paqie 2-3 Table 2-1 Limiting Seismic and LOCA Loadings Load !Allowable IMargin Ro Layout....................

ii F 1* ' 9 &1 5 assem bly Full BLL J 8 o CoeI New AA A EOL 7 1[°/°1%* 1 assembly row4 Coe[O ] [ 37 CoLe[L]' [ ] 7o0 11 assembly row___I..I IAWW...WWA CoeV EOL r 1 1 [ 1 043%* 17 assembly row_ ___J L IL JAWAW...WAWAA

• This allowable limit has been updated from the value initially reported in Revision 0 of ANP-3352P based on the inclusion of additional crush test data for the St. Lucie 2 specific grid type.** This margin (14%) is based on the simulation of an unrealistic core loading pattern in which fresh AREVA fuel is placed directly on the baffle while the rest of the core is populated by non-AREVA fuel. This row configuration, while unrealistic, was analyzed for conservatism.

Without this row configuration, the next limiting mixed core configuration yields 60% margin (Case 170 in Figure 2-1).**In general, the mixed core cases indicate significantly lower margins than the full core cases. These margins are reduced because of additional conservatisms included in the mixed core cases to assure uniform treatment of different assembly types. In particular, all fuel assembly damping values for the mixed core cases were conservatively set to match the co-resident fuel. Using this damping for the AREVA fuel is very restrictive and is less than half of the damping that is approved for use in BAW-10133P-01, Addendum 2. The impact of this additional conservatism can be seen in the order of magnitude difference between full core and mixed core margins.

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I I~I ~L AREVA Inc.ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensina Renort P~ri_ 2-4 Table 2-2 Maximum Seismic and LOCA Impact Loads by Row Pattern*,**

Notes:* SSE + LOCA loads are calculated by performing a square root sum of squares (SRSS) combination of the individual SSE and LOCA loads shown here.**[I

~..#LJI III LJII~U LJULiUI I I~I IL AREVA Inc. ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensingq Report Paqe 2-5 Co-Resident Fuel Evaluation To support the evaluation of the co-resident fuel, AREVA's analyses also provided input on the relative effect that AREVA fuel has on the response of the co-resident fuel. For this evaluation, AREVA first analyzed row models consisting entirely of co-resident fuel.The analysis of these row models provided a baseline against which to provide a comparison.

The impact loads in the co-resident fuel assemblies in the mixed core configurations, in comparison to the baseline impact loads, provided a relative assessment of the effect of AREVA fuel on the co-resident fuel. [J This information was provided to FPL for their evaluation of the co-resident fuel.The evaluation performed by Westinghouse for the Westinghouse co-resident fuel assemblies under the seismic/LOCA loadings associated with mixed core configurations of AREVA and Westinghouse fuel, using the above load increase, demonstrated that the Westinghouse fuel assemblies would continue to satisfy the applicable seismic/LOCA design criteria consistent with the licensed methodology of CENPD-1 78 and its associated SER [6].

'~JLJI ILl UU~U LJUL'U[ I C~I IL AREVA Inc.Response to SLU2 NRC SNPB RAI-9 Licensino Reoort ANP-3456N P Revision 0 Pacie 2-6 Figure 2-1 17 Assembly Row Reactor Core Reload Pattern

'..iUi ILl !JlE~U LJU~.jUI I I~I IL AREVA Inc.AN P-3456N P Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensina Renoart PRaR 2-7 Figure 2-2 15 Assembly Row Reactor Core Reload Pattern

'...#LJI ILl LJII~U LJUL~UI I I~I IL AREVA Inc.Response to SLU2 NRC SNPB RAI-9 Licensina Renort ANP-3456NP Revision 0 Paqie 2-8 Figure 2-3 13 Assembly Row Reactor Core Reload Pattern

'~LII III ~JII~U L/'JLUI I l~I ii ARE VA Inc.AN P-3456N P Revision 0 Response to SLU2 NRC SNPB RAI-9 Sicn~nsina1 Rennrt PRn~ 2-9 Figure 2-4 11 Assembly Row Reactor Core Reload Pattern

'.j~.JI ILl 1JII~U LJIJLUI I I~I IL AREVA Inc.AN P-3456N P Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensinq Report P~nri 2-1O Figure 2-5 9 Assembly Row Reactor Core Reload Pattern

~..jLJI III LJ1I~U LJLJL~U! I I~I IL AREVA Inc.Response to SLU2 NRC SNPB RAI-9 Sir.ens~inr Report AN P-3456N P Revision 0 Paae 2-11 Figure 2-6 4 Assembly Row Reactor Core Reload Pattern AREVA Inc. ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensingq Report Paqe 2-12 Question # SNPB RAI-9 (b): "TR BAW-10133(P)(A) originally modeled a Mark-C fuel assembly for seismic and LOCA analyses.

The licensee claims that the Addenda 1 and 2 of this TR has demonstrated its acceptability for other generic pressurized-water reactor fuel assembly designs, including the CE 16x16 HTP fuel design. Table 3.1 of ANP-3396P for Nominal Beginning of Life (BOL) Mechanical Design Data Comparison indicates significant differences in several listed parameters for CE 16x16 HTP and Mark-C fuel designs.Therefore, explain in detail how the differences are accounted for in the components testing." Response: The BAW-10133(P) (A) topical report, although referencing the Mark-C design in the title, describes the general methodology, which is structured to be generically applicable to PWR fuel designs. The generic methodology requires that the specific fuel assembly be tested to determine the dynamic behavior.

A finite element model is then created and benchmarked to these design specific test results. Thus a design specific fuel assembly model is established.

Plant specific time histories are used with this benchmarked finite element model to determine the fuel assembly displacements and impact loads. These calculated loads are then compared to the design limits to determine the acceptability of the design. The applicability to the different PWR fuel designs is provided by the design specific fuel assembly test results, and the plant specific applicability is provided by the plant specific time histories.

The generic applicability is captured in the Safety Evaluation Report (SER) for BAW-10133(P) (A), Rev. 1 in which it is noted that the methodology is acceptable for the "Mark C fuel design and similar designs".

The methodology was modified in Addendum 1 where it is stated that "the application of this method is for generic use". Addendum 2 introduces the damping values to apply in this analysis and is noted to be "justified for all FCF (AREVA) PWR fuel designs based on the supporting test data".

'..jUI iLl LJll~U LJULUI I I~l IL AREVA Inc. ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensincq Report Paqie 2-13 Consistent with the stated intent of the method given in TR BAW-10133PA (with Addenda 1 and 2) [3] to be generic, the described methods given in ANP-3396P

[2] and ANP-3352P

[1] are appropriate to the CE 16x16 HTP design being analyzed.

BAW-10133PA (with Addenda 1 and 2) defines generic finite element model architecture and testing protocols that can represent the structure of any PWR fuel assembly.

Design specificity is introduced in the characterization of the fuel through testing and the definition of model parameters that define assembly behavior, such as bundle stiffness, frequency, etc. Plant specificity is introduced in the geometry of the model boundary conditions (core dimensions, fuel assembly pitch, etc.) and inputs (e.g., core plate seismic and LOCA time histories).

The application of BAW-10133PA (with Addenda 1 and 2) is thus justified for CE 16x16 fuel when fuel design specific bundle/component testing and model benchmarking is performed and the model parameters are derived from those tests. AREVA conducted full fuel bundle assembly tests and component tests of the St. Lucie 2 AREVA design. FPL provided the St. Lucie Unit 2 time histories.

A description of the CE 16x16 HTP design, along with other designs where BAW-10133(P) (A) has been applied, is presented in Table 3.1 of ANP-3396P.

The building block of the lateral model is a simplified single column fuel assembly model. The single fuel assembly model is benchmarked against dynamic vibration test results in both BOL and EOL conditions.

This process of benchmarking of the single fuel assembly model is the same regardless of the type of the PWR fuel design. The single fuel assembly model is benchmarked to [J After a single fuel assembly beam model is benchmarked against the results of design-specific fuel assembly characterization tests, it is available for use in licensing analyses of the core. The characterization tests and the model parameters derived from those tests are the same as described in TR BAW-10133PA (with Addenda 1 and 2) regardless of the type of the PWR design. Small design differences such as guide tube, fuel rod and the instrument tube cross section properties, number of grids, grid span length, number of grids, number of guide tubes and fuel rods, material, etc. are ultimately homogenized

'~.iUI III ~J~I~U LJ'..J~iUI I I~I IL AREVA Inc. ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensincq Report Paqie 2-14 in the overall dynamic characterization of the fuel bundle, based on full-scale bundle testing. All models used in the fuel assembly seismic and LOCA analyses are benchmarked to these overall, design-specific characteristics that are defined through testing and as such, they are appropriate for representation of the fuel assembly.

It is noted in Table 3.1 of ANP-3396P that there are only small differences in the fuel assembly 1 st mode natural frequencies between the Mark-C and the CE 16x16 fuel assembly [ ]The spacer grid dynamic properties, needed to simulate the grid response under impacts during seismic and LOCA events, are also obtained from design specific tests.These tests are generically defined in BAW-10133PA, Rev. 1, Addendum 11[3]. This testing also establishes a design-specific definition of grid allowable load limits. The spacer grid properties used in the lateral core model are benchmarked to design-specific test data and as such, they are appropriate for representation of this fuel design.

~...AJI ILl UII~U L.JUL,'LII I I~I IL AREVA inc. ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensingq Rep~ort Paqe 2-15 Question # SNPB RAI-9 ('c)"ANP-3396P states that additional testing and evaluations are included in the analyses to address this NRC Information Notice (IN) 2012-09. Provide detailed information on testing performed in response to IN 2012-09." Response: In response to IN 2012-09, additional testing and analyses were performed to evaluate the SLU2 fuel design. In particular, characterization tests (free and forced vibration) done on full scale fuel assemblies were performed for two St. Lucie Unit 2 design specific test assemblies, one representing the non-irradiated, or beginning-of-life, condition and the other representing the irradiated, or end-of-life, condition.

Similarly, characterization testing of individual spacer grids was performed on grids in both the non-irradiated and a simulated-irradiated condition.

This test data was used to develop separate models that represent the fuel in both non-irradiated and irradiated conditions.

Likewise, analyses were performed to consider the fuel response in both the non-irradiated and irradiated conditions.

To simulate the effects of irradiation on overall fuel assembly characteristics during dynamic characterization testing, (] The dynamic characterization testing is performed following the same protocol for both non-irradiated and simulated-irradiated fuel assemblies.

In comparison to the tests performed on the non-irradiated fuel assembly, ['

~.jIJI ILK LJII~U LJU~iL~I I I~I IL AREVA Inc. ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensinq Report Paqe 2-16 The effects of irradiation are also simulated in the spacer grid impact testing. The general methodology for the spacer grid dynamic impact testing is established and defined in Addendum 1 of BAW-10133PA.

The spacer grid dynamic impact testing was performed for both non-irradiated and simulated-irradiated configurations using this testing protocol, but L J to simulate the effects of irradiation.

J It has been demonstrated based on testing conducted in a hot cell on actual irradiated grids, that []

IU ~ ~ I P AREVA Inc.Response to SLU2 NRC SNPB RAI-9 LicensinQ Repjort ANP-3456NP Revision 0 Page 2-17 II] This protocol has been shown to demonstrate a good, conservative agreement with the results of the tests performed on irradiated grids in the hot cell.

~JIJI III '...JII~U LJIJL~UI I I~E IL AREVA Inc.Response to SLU2 NRC SNPB RAI-9 Licensingq Report Question # SNPB RAI-9 (d): ANP-3456NP Revision 0 Paqe 2-18"Provide a detailed description of both the [] that are mentioned in the ANP-3396P report. Provide the results from the analysis that used the [ ] and explain in detail." Response: The vertical response of the AREVA St. Lucie Unit 2 fuel assembly due to the vertical LOCA loads was determined using I" ]. This [] approach is a which a [modification to the method described in BAW-1 01 33(P)(A), in J is described.

The [I In contrast, the [I

'~.AjI ILl ~JCl~U LJULjUE I C~E IL AREVA Inc. ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensinq Rep~ort Paqe 2-19[I A [ ] uses two columns representing the guide tubes and the fuel rods. These columns are modeled as linear translational springs. All nodal degrees of freedom (DOFs) in the lateral and rotational directions are constrained and hence, no extraneous reaction forces or moments are produced.

Furthermore, a third column is added to the model to represent an instrument tube. The spring element characteristics are directly derived from geometric and material considerations except for the tie plates whose stiffnesses are derived from design-specific component testing. The hold-down spring force is accounted for by using a linear translational spring element. In addition, the nonlinear capabilities of the model consist of a number of gap-springs, gap dampers, and slider elements, as shown in Figure 2-7. A brief discussion of these elements follows:*The non-linear gap-spring-damper element representing the lower tie plate: The stiffness of this element is used to account for the stiffness of the load-path between the guide tube connections and the lower core plate for the Beginning of Life (BOL)case, and from the lower tie plate upper face and the lower core plate for the End of Life (EOL) case. In the EOL case, the load is distributed on the upper face of the lower tie plate, since the fuel rods are resting against this surface. This element has damping capability, which is necessary to accurately capture the fuel assembly rebound height in the case of an impact. The input parameters for this element are benchmarked using results from an axial drop test performed on the SLU-2 CE

'~~AJI IL! ~JII~U LJLJLUI I I~I IL AREVA Inc. ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensincq Report Paqie 2-20 16x16 fuel assembly design.*The non-linear gap-spring-damper element between the fuel rod lower end and the top face of the lower tie plate: The element gap is a function of the fuel design and BOL or EOL condition.

In the BOL condition the gap is open for the CE 16x16 HTP design. In the EOL condition the gap is closed due to the subsequent seating of the rods on the upper face of the lower tie plate and the impact load is carried through the stiffness of the lower tie plate grillage.

The input parameters for this element are benchmarked using results from an axial drop test performed on the SLU-2 CE 16x16 fuel assembly design.*The non-linear gap-spring-damper element between the top of the fuel rods and the upper tie plate: The characteristics of this spring are similar to the element above, with the gap being different.

This gap is designed to remain open over the service life of the fuel assembly under normal operating conditions (including irradiation growth), but could close due to impacts produced by seismic or LOCA loading. The input parameters for this element are benchmarked using results from an axial drop test performed on the SLU-2 CE 16x16 fuel assembly design.*The non-linear slider elements between the fuel rod nodes and the corresponding spacer grid nodes on the guide tube column: These elements are characterized by stiffness (or slope) and a saturation force at which the fuel rods begin to slip within the spacer grids (i.e. the grid slip load). The input parameters for this element are benchmarked using the slip loads measured from tests performed on SLU-2 CE 1 6x1 6 HTP spacer grids and test results from axial stiffness tests performed on the SLU-2 CE 16x16 fuel assembly.The vertical load analysis is performed on a single fuel assembly model by applying the seismic or LOCA loads in the vertical (axial) direction.

The vertical fuel assembly model calculates the axial loads primarily arising from fuel assembly impacts with the upper and lower core plate during seismic and LOCA excitations.

From the vertical faulted condition analyses for CE 16x16 HTP fuel at St. Lucie Unit 2, the maximum impact loads are reported in Table 2-3.

ILl LJII~U LJLJLUI I I~I IL AREVA Inc.ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensino Report Paae 2-21 Table 2-3 Maximum Vertical Impact Loads Maximum Impact Load [N] BOL EOL LOCA [ ][ J The resulting axial loads are combined with loads from the normal operating and horizontal load analyses for subsequent component stress and structural integrity analysis, as reported in ANP-3352P

[1]. These combined loads are then evaluated using the ASME derived limits. The St. Lucie 2 design has margin to these ASME derived limits.

III LJhI~U LJLJLLH I I~I IL AREVA Inc.ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensinq Reoort Paae 2-22 Figure 2-7 Fuel Assembly Vertical Model Schematic Height 2 0 U-(28 K27 K26 C 2.5 U I-03 C 03 U K25 K24 m K23 rn K22 KG4 = Preloaded Hold-Down

+ UTP Spring: KG3 = UTP to FR UEPK2o SK17 ml.3 SK15 FS6l m3K1613 rns n K125 4:K2=FR LEP to LTP KG1 =LTP to Core Support Plate K21 .m26 26 C 2 x I-0)C YS K2 Node Number Linear Spring Element Number K1 Lumped Mass Elements Slider Friction Elements Non-Linear Spring Element Number 1 T Lower Core Support Plate

~..iUi ELI ~JII~U LJLJLiUI I I~I IL AREVA Inc. ANP-3456NP Revision 0 Response to SLU2 NRC SNPB RAI-9 Licensinqi Report Paqe 3-1

3.0 REFERENCES

1. ANP-3352P, Revision 1, St. Lucie Unit 2 Fuel Transition License Amendment Request Technical Report, November 2015.2. ANP-3396P, Revision 0, St. Lucie Unit 2 Fuel Transition Supplemental Information to Support the LAR, March 2015.3. Topical Report, BAW-10133PA, Rev. 1, Addenda 1 and 2, 43-10133PA-00, 04/99.4. ANP-10337P, Revision 0, PWR Fuel Assembly Structural Response to Externally Applied Dynamic Excitations Topical Report, August 2015.5. BAW-10172(P)(A), Revision 0, "Mark-BW Mechanical Design Report" 6. Topical Report CENPD-178-P, Revision l-P, "Structural Analysis of Fuel Assemblies for Seismic and Loss of Coolant Accident Loading" and associated SER letter from H. Bernard (NRC) to A. E. Scherer (C-E),"Acceptance for Referencing of Licensing Topical Report CENPD-1 78" L-2015-300 Attachment 4 Page 1 of 3 A FF1 DAVIT COMMONW1EALTH OF VIRGINIA )) SS, CITY OF LYNCHBURG) 1f. My name is Nathan E. Hottie. I am Manager, Product Licensing, for AREVA Inc. (AREVA) and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.

I am familiar with the policies established by AREVA to ensure the proper application of these criteria.3. I am familiar with the AREVA information contained in the following document: "ANP-3352P Rev. 1, St. Lucie Unit 2 Fuel Transition License Amendment Request," referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA Inc. for the control and protection of proprietary and confidential information.

4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5. This Document has been made available to thie U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure.

The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is L-2015-300 Attachment 4 Page 2 of 3 requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information." 6. The foillowing criteria are customarily applied by AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA's research and development plans and programs or their results.(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a simfiar product or service.(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which, results in a competitive advantage for AREVA.(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitve advantage for AREVA in product optimization or marketability.(e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA.The Information in this Document is considered proprietary for the reasons set forth in paragraphs 6(c), 6(d), and 6(e) above.7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside ARE VA only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. .AREVA policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

L-2015-300 Attachment 4 Page 3 of 3 9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.SUBSCRIBED before me this____Sherry L. MoFaden*NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10131118 Reg. # 7079129 , a, AA A A-- ......It SHERRY L MCFADEN NOIMVPUbk Comn~~unIU~

of WginIa 707912~omm~uh1oe

~xofrus Oct 31, 20%S