affidavit commonwealth of virginia city of …

AFFIDAVIT

COMMONWEALTH OF VIRGINIA )) ss.

CITY OF LYNCHBURG )

1. My name is Gayle F. Elliott. I am Manager, Product Licensing, for AREVA NP

Inc. (AREVA NP) and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA NP to determine whether

certain AREVA NP information is proprietary. I am familiar with the policies established by

AREVA NP to ensure the proper application of these criteria.

3. I am familiar with the AREVA NP information contained in the document titled

"NRC Pre-Submittal FA Mechanical Analysis External Loads," dated May 29, 2013, and referred

to nerein as Document. Iinf-ormation contained in this Document has been classified by

AREVA NP as proprietary in accordance with the policies established by AREVA NP 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 NP 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 the 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

requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial

information":

6. The following criteria are customarily applied by AREVA NP to determine

whether information should be classified as proprietary:

(a) The information reveals details of AREVA NP'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 similar 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 NP.

(d) The information reveals certain distinguishing aspects of a process,

methodology, or component, the exclusive use of which provides a

competitive advantage for AREVA NP in product optimization or marketability.

(e) The information is vital to a competitive advantage held by AREVA NP, would

be helpful to competitors to AREVA NP, and would likely cause substantial

harm to the competitive position of AREVA NP.

The information in the Document is considered proprietary for the reasons set forth in

paragraphs 6(c) and 6(d) above.

7. In accordance with AREVA NP'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 AREVA NP only as required and under suitable agreement

providing for nondisclosure and limited use of the information.

8. AREVA NP policy requires that proprietary information be kept in a secured

file or area and distributed on a need-to-know basis.

9. The foregoing statements are true and correct to the best of my knowledge,

information, and belief.

SUBSCRIBED before me this n2r!L.

day of WISO 2013.

Sherry L. MoFadenNOTARY PUBLIC, COMMONWEALTH OF VIRGINIAMY COMMISSION EXPIRES: 10/31/2014Reg.#70791 29

NRC FORM 8C(7-94)NRCMD 3.57

COVER SHEET FOR CORRESPONDENCE

USE THIS COVER SHEET TO PROTECT ORIGINALS OFMULTI-PAGE CORRESPONDENCE

NRC Pre-Submittal meeting:Topical Report for FuelAssembly MechanicalAnalysis for External Loads

AREVA/NRC MeetingMay 29, 2013

APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 A R E V A

AgendaOo Objectives

lo Summary of changes to currently approved method

lo Overview of topical reportApplicabilityRegulatory requirements

<" Acceptance CriteriaInputsHorizontal Load AnalysisVertical Load Analysis

N Fuel Assembly Structural AnalysisSample problems

00 Summarylo Next Steps

APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 2 A R E VA

Objectives

Oo Provide an overview of the revised fuel assemblymechanical analysis of external loadsmethodology

Summary of entire method

Highlight changes

Oo Provide a schedule summary

lo Obtain NRC feedback


Planned Schedule

Po Pre-submittal meeting (strategy and scope) - today

Po Pre-submittal meeting (content) - 3rd Quarter 2013

Oo Topical submittal to NRC - 4th Quarter 2013

OP Post-submittal meeting - 1 st Quarter 2014

PoAdditional meetings/technical audits as needed

Oo Requested NRC approval - 4th Quarter 2015

NRC approval is requested by 4th Quarter 2015

APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 4 A R EVA

NRC's Prioritization Factors

Po Classification0 Emergent NRC technical Issue

IN2012-09<New method that improves safety

OP ApplicabilityPotentially all PWRs

11 Implementation CertaintyDocketed intent by Bellefonte [TVA/NRC meeting in April 2013]

Oo Tie to License Amendment Request (LAR)Support Bellefonte FSAR submittal

>'" NRC approval is requested by 4th Quarter 2015 to

support TVA's Bellefonte FSAR submittal A

Pre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 5 A R E VA

Start of Proprietary Information

OoProprietary meeting will begin with nextslide

Pre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013A

6 AREVA

Methodology Comparison (1/3)

Space grid buckin alowd iLOCA Space grid buckling is not a~llowed,!i~evaluationamxiu teortia deformation limited to less tha

Un-irradiate adIrrdae pcrgi

Un-irradiated spacer grid strength

Un-irrait.d d.ampin. g

Fuel assembly frequency defined by [I

Un-irradiated and irradiated spacer gridstrength

Un-irradiated and irradiated damping

Fuel assembly frequency defined by [

Arnal Loads - May 29, 2013 7 AR EVAPre-submittal meeting: Fuel Assembly Mechanical Analysis for Exte

Methodology Comparison (213)

Current Method Updated/Future Method

Guide tube stress allowables based on [ Guide tube stress allowables based on [I I

Unclear expectatins regardingcombination ~of loads in two- or tre

dime~nsions

Define combination of loads that reflects [I

- A8AREVAPre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013

Methodology Comparison (313)

Current Method Updated/Future Method

Generically applicable to all PWl~s Generically applicable to all PWRs

No assumption of loss of offsite power No assumption of loss of offsite power

No assumption of 400 during 4 hour No assumption of AO duin• 4 hourperiodI followin~g eatquk alowd o period Iofolloing earthquakealowed to

evaluate erth~quak sevriy, shutdown evaluate earthq~uake severity, shutdownrequired if above OBE required if above OBE


Topical Report OutlineOo Introduction

'' Compliance to regulatory requirements

• ApplicabilityPWR Generic

P Acceptance CriteriaOBE, SSE, LOCA, SSE+LOCAGrids, Non-grid components

l Inputs0 Fuel Characteristics / Tests0 Time History Inputs

Oo Horizontal Load AnalysisSingle Fuel Assembly Model

I Row Model• Horizontal Analysis Method

Po Vertical Load AnalysisFuel Assembly ModelVertical Analysis Method

00 Fuel Assembly Structural Analysis, Load Combination


Event DescriptionOi Operating Basis Earthquake (OBE)

Unrestricted operation following an OBE•> Reactor shut-down at motions above OBE

9 4hrs typically allowed for evaluationEvent not considered if OBE severity is 1/3 or less of the SSE severity(Appendix S of 10 CFR 50, OBE Ground Motion)

Oo Safe Shutdown Earthquake (SSE)Treated independently as a design basis accidentNot coupled with normal operating or AOO eventsDemonstrate ability to shut down reactor and maintain it in a safe-shutdown condition (Appendix S of 10 CFR 50)Prevent or mitigate consequences of accidents that could result inoffsite exposures (Appendix S of 10 CFR 50)

Il Loss of Coolant Accident (LOCA)Treated as a postulated design basis accident

, Combined with SSE as limiting design basis accident


Acceptance Criteria:Regulatory General Design Criteria

Oo Basic design criteria to be addressed fuel assemblymechanical accident analysis methodology topical

GDC 2: Appropriate combination of loads from naturalphenomenon and accident conditions

GDC 10: Maintain normal operability of the fuel assemblyduring and after an OBE

0 GDC 27: Maintainduring and after a

control rod insertability (reactivitySSE, LOCA, or combined SSE and

control)LOCA

GDC 35: Prevent fuelcoolability during and

rod fragmentation and maintain ECCSafter LOCA, or combined SSE and LOCA

0.3 10 CFR Part 100: Fission product release for postulatedaccidents (i.e. fuel rod fracturing under external loads)


12 AREVA

Acceptance Criteria:Regulatory Guidance

lo Appendix A of Chapter 4.2 of NUREG-0800 (Standard ReviewPlan)

Pp LOCA"fuel rod fragmentation must not occur as a direct result of blowdown loads"- Satisfied if combined loads on fuel rods and components other than spacer

grids remain below acceptable loads"10 CFR 50.46 temperature and oxidation limits must not be exceeded"- Satisfied by an ECCS analysis- If grid loads are below P(crit), the usual ECCS analysis is sufficient- If grid loads are above P(crit), then grid deformation must be assumed in ECCS

analysisAn assumption of maximum credible deformation may be made (i.e. fully collapsedgrid)

Control rod insertability must be demonstrated for combined load of worst-case LOCA plus SSE- If grid loads are below P(crit), then significant deformation would not be present

to interfere with control rod insertion- If grid loads are above P(crit), then additional analysis required to demonstrate

that deformation does not prevent control rod insertion



Po SSE"fuel rod fragmentation must not occur as a result of the seismicloads"

Same criteria as LOCA

Control rod insertability must be assuredSame criteria as LOCASatisfied by SSE + LOCA evaluation, unless licensing basis does notrequire combined loads

SRP acceptance criteria for SSE are consistent withAppendix S of 10 CFR 50



0 Grid StrengthP(crit) = critical load of the spacer grid

" Consequences of grid deformation are small

* Gross deformation in many PWR assemblies need to interfere withcontrol rod insertion

e Gross deformation of hot channel would only result in small increasesin peak cladding temperature

* Therefore, average values are appropriate

" P(crit) should be the 95% confidence limit on the true mean of asample of grids at or corrected to operating temperature

<" NUREG/CR-1 018 "Review of LWR fuel system mechanicalresponse with recommendations for component acceptancecriteria" provides background on grid strength definition for SRP4.2 Appendix A



10 Components other than gridsStrengths may be deduced from fundamental material propertiesor experimentation

0 Protect against structural failure

Acceptable loads may follow ASME Code guidance

Acceptable loads should consider buckling and fatigue effects

APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 16 AR EVA

AREVA's Grid Strength Criteria

APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 17AREVA


APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 18AREVA


A19AREVAPre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013


APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 2o AR EVA


APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 21. A REVA

Summary of AREVA's GridStrength Criteria

WOMMMMMEMPA

22 AREVAPre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013

AREVA's Criteria for ComponentsOther than Grids

In general,...

for SSE and/or LOCA, component allowables are based onService Level D limits from the ASME BPV Code

* Reference: ASME BPVC Section III, Division 1, Appendix F

* Consistent with SRP to apply ASME guidance to protect againststructural failure

Or derived from ultimate strength testinge.g. welded connections, nozzles, etc.

But, there are exceptions...


AREVA's Criteria for ComponentsOther than Grids

ENMEMMMMOA

24 AR EVAPre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013

PWR Tests & Numerical ModelsApplicability

l- The proposed methodology is applicable to all fuelassembly designs for Pressurized Water Reactors

Oo-All PWR fuel designs share a similar geometry andstructure

OoArchitecture of the numerical models defined inthis methodology is appropriate and generic to allPWR fuel designs

Oo-Testing establishes design specificity by definingthe numerical parameters of the model


PWR Tests & Numerical ModelsAnalysis

- Seismic and LOCA time histories from Reactor System

Analysis4

Vertical

Mechanical characterization of Fuel

assembly from tests anddevelopment of numerical model

for vertical analysis

Mechanical characterization of fuelassembly from tests and development

of numerical model for horizontalanalysis

Combine Horizontal and Vertical loads

I Stress analysis for fuel assembly components I4

Redesign

No

I Compare to allowable limits I

Yes

Design Approval]


26 AR EVA

PWR Tests & Numerical ModelsHorizontal Analysis

Oo Single fuelassembly model

lo Constructed usingbeam, spring, gap,and damperelements

lo The fuel assemblymodel is linear


PWR Tests & Numerical ModelsVertical Analysis

Ag: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 28 A R E VAPre-submittal meetinc

AREVA PWR Test Programs

lo The program is divided into two sections:' 1. Fuel assembly test program

0 2. Fuel assembly component test program

Oo Results from tests are used to characterize thebehavior of the fuel assembly assisting in thedevelopment of numerical models and to compareagainst values from acceptance criteria


PWR Fuel Assembly Tests

Pre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 3o AREVA

PWR Fuel Assembly Tests

-- A3o AR EVAPre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013

Spacer Grid Test Protocol

AMlechanical Analysis for External Loads - May 29, 2013 31 AR EVAPre-submittal meeting: Fuel Assembly I

Horizontal Analysis


32 AR EVA

Horizontal Analysis - Row model

_ _pperCore Plate_ _

00 ---

Lower Core PlateLOWER CORE PLATE


Horizontal Analysis Methodology

A34 AR EVAPre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013

Horizontal Analysis - Frequency

Pre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013CA-R

35 AR EVA

Horizontal Analysis - Damping

lo Structural and flow induced damping0 Structural damping - Regulatory Guide 1.61

Flow induced damping" BAW-10133PA, Rev. 1, Addendum 2 defines flow-induced damping in

unirradiated condition based on experimental results

" New topical will expand flow-induced damping definition to addressirradiated condition based on updated testing

Oo Damping - numerical modelsRayleigh damping, modal damping or scalar dampers (dashpot)


Vertical Analysis

Generate vertical fuel assemblymodel using component properties

IBenchmark to axial

stiffness and vertical drop

Adapt model to reflectin-core conditions

Apply Vertical seismic Apply vertical LOCAdisplacements loads

Extract componentloads


Vertical Analysis


Fuel Assembly componentanalysis

Pre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 39 AR EVA

Fuel Assembly componentanalysis

NEENNOMMMEr

A4o AR EVAPre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013

Sample Problems I

Purpose:

lThe sample problems will demonstrate themodeling techniques and features outlined inthe Topical Report.

llThe analytical methods that are used to makeperformance predictions are structurallyrepresentative of the fuel assembly design.

lLateral and Vertical sample problems will beincluded in the Topical Report.


Sample Problems

loModel of an AREVA 17xl 7 PWR fuelassembly.

loA typical core geometry from a 4-loop 17 X 17plant (193 assembly plant) and an actual plantloading time-history will

loA homogeneous row ofmodeled.

be analyzed.

fuel assemblies will be


Sample Problems

OoThe plant loading time-history will be scaled bya factor and applied to the core model.

0 This is not to show conservatism, but rather to analyze asevere loading time-history to reveal potential technicalconcerns, if any.

OoCASAC, an AREVA in-house finite elementcode will be used to perform the lateralanalysis

OoANSYS finite element code will be used toperform the vertical analysis


Summary/Conclusions

loMethodology overview provided2 No spacer grid buckling allowed - increased

conservatism

< Un-irradiated and irradiated spacer grid strengthaddressed

Criteria is consistent with 10 CFR 50 Appendix S

</ SSE and loss of offsite power are decoupled

loNRC feedback desired.

PoNRC approval is requested by 4th Quarter2015


Next Steps

Po Pre-submittal meeting (content) - 3 rd Quarter 2013

lo Submittal to NRC - 4th Quarter 2013

OP Post-submittal meeting - 1 st Quarter 2014

OoAdditional meetingsltechnical audits as needed

Ol Requested NRC approval - 4th Quarter 2015


Abbreviations

AOO - Anticipated Operational Occurrence

ASME BVP Code - American Society of Mechanical Engineers Boiler & PressureVessel Code

CFR - Code of Federal Regulations

ECCS - Emergency Core Cooling Systems

FSAR - Final Safety Analysis Report

GDC - General Design Criteria

LAR - License Amendment Request

LOCA - Loss of Coolant Accident

NRC- Nuclear Regulatory Commission

OBE - Operating Basis Earthquake

PWR - Pressurized Water Reactor

SRP - Standard Review Plan

SSE - Safe Shutdown Earthquake

TVA - Tennessee Valley Authority


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