ML19204A055
| ML19204A055 | |
| Person / Time | |
|---|---|
| Site: | PROJ0728, 99902041 |
| Issue date: | 09/24/2019 |
| From: | Jeremy Dean NRC/NRR/DSS/SNPB |
| To: | Peters G Framatome |
| Rowley J, NRR/DLP, 415-4053 | |
| Shared Package | |
| ML19204A048 | List: |
| References | |
| CAC No. MF9078/EPID: L02016-TOP-0016 ANP-10342P, Rev. 0 | |
| Download: ML19204A055 (3) | |
Text
RESOLUTION OF COMMENTS BY THE OFFICE OF NUCLEAR REACTOR REGULATION ON DRAFT SAFETY EVALUATION FOR TOPICAL REPORT ANP-10342P, REVISION 0, GAIA FUEL ASSEMBLY MECHANICAL DESIGN FRAMATOME, INC.
PROJECT NO. 728/DOCKET NO. 99902041 This attachment provides the U.S. Nuclear Regulatory Commission (NRC) staffs review and disposition of the comments made by Framatome Inc. (Framatome) on the draft safety evaluation (SE) for Topical Report (TR) ANP-10342P, Revision 0, GAIA Fuel Assembly Mechanical Design. Framatome provided the comments by letter dated December 20, 2018 (Agencywide Documents Access and Management System Accession No. ML18360A171).
Reference 2 in this attachment refers to Reference 2 of that letter.
NRC Resolution of Page Line Proposed Change/Comment Proposed Change/Comment 1 19-20 Replace this TR extends the use of the fuel The NRC staff accepts design change process with this TR the proposed change.
implements a fuel design change process The change was made similar to the one ANP-10342P is not accordingly in the final dependent upon EMF-92-116. SE.
2 23, 25- Replace This TR extends the use of the fuel The additional 28 design change process with This TR information provided implements a fuel design change process justification of the similar to the one and delete the second independence. The sentence of this paragraph. The GAIA change NRC staff accepts the process is self-contained and does not use proposed change. The methods and criteria from EMF-92-116. The change was made independence from EMF-92-116 is reinforced accordingly in the final by the additional information provided in SE.
Reference 2 of this letter.
6 7-9 Framatome proposed a re-wording of the The staff agrees and will internal pressure criteria in Reference 2 of this confirm the write up in letter that is consistent with SRP Section 4.2 the -A version of the TR.
and current practice, including the analysis supporting ANP-10342P. The SE should be updated to reflect the markups in Reference 2, which will be included in the approved version of the topical report.
Attachment
NRC Resolution of Page Line Proposed Change/Comment Proposed Change/Comment 7 43 Framatome proposed in Reference 2 of this Staff acknowledges that 8 34 letter to add specific sections in ANP-10342P the criteria are evaluated 9 4, 19 for the following evaluation areas: overheating outside of this TR.
10 15 of cladding, excessive fuel enthalpy, bursting, Some changes were cladding embrittlement, violent expulsion of made to state this but fuel, and fuel rod ballooning. These new acceptance criteria for sections identify that the criteria are included in GAIA were added for the NRC-approved methodology topical reports. use those outside These criteria are not evaluated as part of the methods as they apply to generic topical report but will be evaluated in GAIA.
plant-specific analyses using NRC-approved methods. This SE should be updated to reflect only the information in Reference 2 for these criteria.
11 37-38 Framatome interprets Section 3.4 to mean that The design update minor changes require discussion or process evaluation notification per clarification #3, but this section was completely discussion / notification can occur after rewritten for clarity and implementation of the change. Therefore, to establish the NRCs stated right to declare that a change is notification requirement subject to review and approval could occur for minor and major after implementation of the change. No changes.
change to the SE is required.
12 1-2 Framatome understands the request for The NRC staff accepts notification of minor changes. For clarification, the suggested Framatome recommends: Should Framatome clarification. The final decide that the fuel update meetings are no SE was changed longer going to be held then a report of all the accordingly. L&C minor mechanical design changes shall be reworded.
made within a year after first implementation of the change in a GAIA reload. This wording will also remove the obligation to submit an annual report when no changes have been made.
12 1-2 The requirement to discuss minor changes at The requirement to the fuel performance meeting or submit a discuss changes at fuel report of changes should be identified in performance meeting Section 4.0, Limitations and Conditions, has been removed.
because the requirement is not stated in Alternate reporting has ANP-10342P. placed in SE. L&C reworded
NRC Resolution of Page Line Proposed Change/Comment Proposed Change/Comment 12 17-20 Limitation and condition #4 can be removed. Framatome provided The use of approved CHF correlations and adequate information to mixed core methods has been added to convince the NRC staff ANP-10342P in Reference 2 of this letter. that limitation and condition #4 should be removed. The final SE was modified accordingly. There are no additional restrictions on the use of CHF correlations that have approved for the use with GAIA fuel.
12 22-29 Framatome does not object to using a modern Discussion of the use of control rod ejection methodology. However, DG-1327 has largely because reactivity initiated accidents are been removed. L&C outside the scope of ANP-10342P, Framatome condition on RIA has be believes it is not appropriate to include this re-written to state that limitation here. The implementation provisions plants LAR to adopt in the final Regulatory Guide resulting from GAIA must include DG-1327 will dictate when the guidance should evaluation of RIA be back fit or forward fit on a licensee. including a justifiable acceptance criteria.
12 39-41 The highlighted statement should be deleted. Statement removed with Per LIC-500, additional restrictions to the additional rewording topical report imposed by the NRC staff should be clearly stated as limitations and conditions.
In the absence of specific limitations and conditions, the SE approves use of the topical report as written, including information not explicitly addressed in the SE. If the NRC staff does not agree with this comment, then additional information must be added to the SE.
12 46 This statement can be removed. In Statement has been Reference 2, Framatome has added a removed statement to ANP-10342P about each additional criterion in SRP Section 4.2 that is not evaluated generically in the topical report.