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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
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 3 A R E VA
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
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 9 A R E VA
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
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 10 A R EVA
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
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 11 A R E VA
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)
Pre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013A
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
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 13 A R EVA
Acceptance Criteria:Regulatory Guidance
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
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 14 A R EVA
Acceptance Criteria:Regulatory Guidance
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
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 15 A R EVA
Acceptance Criteria:Regulatory Guidance
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
AREVA's Grid Strength Criteria
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 18AREVA
AREVA's Grid Strength Criteria
A19AREVAPre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013
AREVA's Grid Strength Criteria
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 2o AR EVA
AREVA's Grid Strength Criteria
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...
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 23 A R E VA
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
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 25 A R EVA
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]
Pre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013A
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
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 27 A R E VA
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
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 29 A R EVA
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
Pre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013A
32 AR EVA
Horizontal Analysis - Row model
_ _pperCore Plate_ _
00 ---
Lower Core PlateLOWER CORE PLATE
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 33 AR EVA
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)
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 36 A R EVA
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
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 37 A R E VA
Vertical Analysis
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 38 AR EVA
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.
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 41 A R EVA
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
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 42 AR EVA
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
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 43 A R EVA
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
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 44 A R EVA
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
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 45 A R EVA
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
APre-submittal meeting: Fuel Assembly Mechanical Analysis for External Loads - May 29, 2013 46 A R EVA
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