HITACHI GE Hitachi Nuclear Energy

• HITACHI

Proprietary Notice

This letter transmits proprietary information in accordance with 10 CFR 2.390. Upon the removal of Enclosures 1 and 4, the balance of the letter may be considered non-proprietary.

M180204

November 26, 2018

U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001

GE Hitachi Nuclear Energy

Lisa K. Schichlein

GE-Hitachi Nuclear Energy Americas LLC Senior Project Manager, Regulatory Affairs P.O. Box 780, M/C A-70 Wilmington, NC 28401 USA

T 910.819.4815 [email protected] C/6(902- 0 2 +

7(0DJ01 JD

Subject: Response to Request for Additional Information NEDC-33173P-A, "Applicability of GE Methods to Expanded Operating Domains" Supplement 5, "Supplement for GNF3 Fuel" (EPID No. L-2017-TOP-0033)

This letter transmits the GE Hitachi Nuclear Energy (GEH) responses to the Nuclear Regulatory Commission (NRC) Requests for Additional Information (RAis) for NEDC-33173P Supplement 5. In addition, a copy of the calculated and measured Traversing In-Core Probe (TIP) data that is cited in the response to RAI-3 has been included.

Please note that :Enclosure 1 contains proprietary information of the type that GEH maintains in confidence and withholds from public disclosure. The affidavit contained within Enclosure 3 identifies that the information contained in Enclosure 1 has been handled and classified as proprietary to GEH. GEH hereby requests that the information in Enclosure 1 be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390 and 9.17. Enclosure 2 is the non-proprietary version of Enclosure 1.

Enclosure 4 contains a copy of calculated and measured TIP data, which is deemed proprietary in its entirety. Thus, a non-proprietary version of Enclosure 4 has not been provided in accordance with NRC Information Notice 2009-07, Requirements for Submittals, (2), which states: "In instances in which a nonproprietary version would be of no value to the public because of the extent of the proprietary information, the agency does not expect a nonproprietary version to be submitted."

WJD1

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Ml80204 Page 2 of2

If you have questions regarding the enclosed references, please contact me or Lukas Trosman at 910-547-1263.

Sincerely,

Lisa K. Schichlein Senior Project Manager Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC

Docket No. 99902024 Project No. 710

No commitments are made in this letter beyond those specifically made in the RAI responses.

Enclosures:

1. Response to Requests for Additional Information - GEH Proprietary Information - Non-Public

2. Response to Requests for Additional Information- Non-Proprietary Information

3. Affidavit for Enclosure 1 dated November 2018

4. Calculated and Measured TIP· Data - CD-ROM - GEH Proprietary Information - Non-Public

5. Affidavit for Enclosure 4 dated November 2018

cc: J Golla, US NRC M Catts, GER/Wilmington L Trosman, GER/Wilmington PLM Specification 003N625.6 Rl

ENCLOSURE3

M180204

Affidavit for Enclosure 1

GE-Hitachi Nuclear Energy Americas, LLC

AFFIDAVIT

I, Lisa K. Schichlein, state as follows:

(1) I am a Senior Project Manager, NPP/Services Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC (GEH), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in Enclosure 1 of GEH letter, Ml 80204, L. K. Schichlein (GEH) to Document Control Desk (USNRC), Subject: Response to Request for Additional Information NEDC-33 l 73P-A, "Applicability of GE Methods to Expanded Operating Domains" Supplement 5, "Supplement for GNF3 Fuel" (EPID No. L-2017-TOP-0033), dated November 26, 2018. The proprietary information in Enclosure 1, entitled "Response to Requests for Additional Information", is identified by a dotted underline· within double square brackets. [[This _sentence _is _an_ example. {3 }_]] Figures and large objects containing GEH proprietary information are identified with double square brackets before and after the object. In all cases, the superscript notation {3l refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Infonnation Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.l 7(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F2.d 871 (DC Cir. 1992), and Public

, Citizen Health Research Group v. FDA, 704 F2.d 1280 (DC Cir. 1983).

( 4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's competitors without license from GEH constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c. Information which reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;

Ml 80204 Enclosure 1 Affidavit Page 1 of 3


d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information i;iought to be withheld is considered to be proprietary foi; the reasons set forth in paragraphs (4)a and (4)b above.

(5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GEH, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GEH, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

( 6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GEH.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist, or other equivalent authority for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2) is classified as proprietary because it contains detailed results and conclusions regarding GEH methods supporting evaluations of the safety-significant changes necessary to demonstrate the· regulatory acceptability for the expanded power/flow operating domains including Extended Power Uprates, Constant Pressure Power Uprates, and the MELLLA+ domain for a GE BWR, utilizing analytical models and methods, including computer codes, which GEH has developed, obtained NRC approval of, and applied to perform evaluations of transient and accident events in the GEH Boiling Water Reactor ("BWR"). The development and approval of these system, component, and thermal hydraulic models and computer codes was achieved at a significant cost to GEH.

The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset.



(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profitmaking opportunities. The information is part of GEH's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical and NRC review costs compnse a substantial investment of time and money by GEH.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on this 26th day of November 2018.

Ml 80204 Enclosure 1

Lisa K. Schichlein Senior Project Manager NPP/Services Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas, LLC 3901 Castle Hayne Road Wilmington, NC 28401 [email protected]

Affidavit Page 3 of 3

ENCLOSURE 5

Ml80204

Affidavit for Enclosure 4


AFFIDAVIT

I, Lisa K. Schichlein, state as follows:

(1) I am a Senior Project Manager, NPP/Services Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC (GEH), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in Enclosure 4 of GEH letter, Ml 80204, L. K. Schichlein (GEH) to Document Control Desk (USNRC), Subject: Respon~e to Request for Additional Information NEDC-33173P-A, "Applicability of GE Methods to Expanded Operating Domains" Supplement 5, "Supplement for GNF3 Fuel" (EPID No. L-2017-TOP-0033), dated November 26, 2018. The content of Enclosure 4, which is a CDROM entitled "Calculated and Measured TIP Data," is proprietary in its entirety. The label on the CD-ROM carries the notation "GEH Proprietary Information - Non-Public{3} ." The superscript notation {3} refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.l 7(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F2.d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2.d 1280 (DC Cir. 1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's competitors without license from GEH constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c. Information which reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;

Ml 80204 Enclpsure 4 Affidavit Page 1 of 3

GE-Hitachi Nuclear Energy Americas, J;.LC

d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be prqprietary for the reasons set forth in paragraphs (4)a and (4)b above.

(5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GEH, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GEH, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

( 6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GEH.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist, or other equivalent authority for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees., and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2) is classified as proprietary because it contains detailed results and conclusions regarding GEH methods supporting evaluations of the safety-significant changes necessary to demonstrate the regulatory acceptability for the expanded power/flow operating domains including Extended Power Uprates, Constant Pressure Power Uprates, and the MELLLA+ domain for a GE BWR, utilizing analytical models and methods, including computer codes, which GEH has developed, obtained NRC approval of, and applied to perform evaluations of transient and accident events in the GEH Boiling Water Reactor ("BWR"). The development and approval of these system, component, and thermal hydraulic models and computer codes was achieved at a significant cost to GEH.

The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset.



(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profitmaking opportunities. The information is part of GEH's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and

analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage

. to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on this 26th day of November 2018.

M180204 Enclosure 4

Lisa K. Schichlein Senior Project Manager NPP/Services Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas, LLC 3901 Castle Hayne Road Wilmington, NC 28401 [email protected]

Affidavit Page 3 of 3

ENCLOSURE2

M180204

Response to Requests for Additional Information

Non-Proprietary Information

IMPORTANT NOTICE

This is a non-proprietary version of Enclosure 1, from which the proprietary information has been removed. Portions of the enclosure that have been removed are indicated by an open and closed bracket as shown here [[ ]].

M180204 Enclosure 2

RAI-1

Non-Proprietary Information Page 1 of22

Figures 2-1 and 2-2 illustrate the results of fission density benchmarks for GNF3 lattice designs. The spread of similar benchmarks for prior fuel designs is indicated using the standard deviation of similar benchmarking data from the prior design. Please provide data for GNF3 and GNF2 in tabular format to facilitate a more detailed comparative evaluation.

GEH Response

Table 1-1 through Table 1-5 provide the fission density differences for GNF2 fuel with a void, exposure and lattice averaged value of [[ ]]. Table 1-6 through Table 1-10 provide the corresponding fission density differences for GNF3 fuel with a void, exposure averaged value of

[[ ]].

Table 1-1: GNF2 BASE Fission Density Differences ''

,,

' [[

]]

Table 1-2: GNF2 PLEl Fission Density Differences

]]

Table 1-3: GNF2 VANl Fission Density Differences

]]

Ml80204 Enclosure 2


Table 1-4: GNF2 PLE2 Fission Density Differences

]]

Table 1-5: GNF2 V AN2 Fission Density Differences

]]

Table 1-6: GNF3 BASE Fission Density Differences

]]

Table 1-7: GNF3 PLEl Fission Density Differences

]]

Table 1-8: GNF3 MID Fission Density Differences

]]

M180204 Enclosure 2


Table 1-9: GNF3 PLE2 Fission Density Differences

'~;:;, :',,«

[[

]]

Table 1-10: GNF3 VAN Fission Density Differences

]]

M180204 Enclosure 2

RAI-2


Provide a description of the GNF3 lattice designs used to perform TGBLA06-MCNP fission density comparisons in sufficient detail to confirm that the designs are reflective, in terms of design features like gadolinia loading and enrichment, of fuel designs used in expanded operating domains. Also, provide information to confirm that the lattice designs are reasonably equivalent, in terms of uranium enrichment and gadolinia loading, to the GE14 and GNF2 designs against which the TGBLA06-MCNP differences are compared.

GEH Response

Given the close geometrical similarities, the existing population of GNF2 lattices were used as an indicator of the future population of GNF3 lattices. The BASE lattices from the GNF2 population were analyzed to generate a representative sample of bundles that span the range of enrichments and Gad concentrations. This sample also represented the variation in plant types, channel thickness and fuel pellet stack densities.

The resulting GNF2 BASE, VANl, VAN2, PLEl and PLE2 lattices from these bundles were used as the basis for the corresponding GNF3 BASE, MID, VAN, PLEI and PLE2 lattice designs. Figure 2-1 illustrates the average enrichments and Gad concentrations of the GNF2 BASE lattice population. The lattices used in extended operating designs are shown in green, while the GNF3, GNF2 and GEI4 lattices used as in this analysis are shown in red, yellow and blue. This plot shows that the GNF3 lattices are representative of the enrichment and Gad cqncentration in the GNF2 population, and that the extended operating domain (EOD) designs are indistinguishable from the non-EOD GNF2 population.

M180204 Enclosure 2

[[


]]

Figure 2-1: BASE Lattice Average Enrichment and Gad Concentrations

M180204 Enclosure 2

RAI-3


Page 2-8 of NEDC-33173P Supplement 5 asserts that traversing in-core probe (TIP) comparisons for GNF3 lead use assemblies (LUAs) "demonstrate no unusual or adverse trends ... which would be indicative of a method issue for the new fuel type." Provide additional information, including data in tabular format, to support this statement. Specifically, for instances where GNF3 TIP information is available, provide a TIP statistics summary, TIP measurements for the LUA, LUA bundle power and exposure, and integrated TIP string radial errors. For each quantity included, provide a brief description. Lastly, provide a figure that shows the TIP string location and surrounding bundle fuel designs.

GEH Response

Traversing in-core probe (TIP) data measurements and statistics are provided from two plants in which LUAs were loaded: LaSalle Unit 2 Cycle 16 and River Bend Unit 1 Cycle 19.

LaSalle Unit 2 Background Information

LaSalle Unit 2 is a 764 bundle BWR/5. In Cycle 16, the rated power was 3,546.0 MWt, and the rated flow was 108.5 Mlbm/hr. The original rated power was 3,323.0 MWt, so the plant operated at 106.7% of the original rated power. The fuel loading is summarized in TableJ-1. The majority of the fuel is GNF2 (74.3% of the core loading), with ATRMlO fuel comprising 25.1 % of the core, and the remaining 0.5% composed of GNF3 fuel. The bundle type (IAT) array is provided as Figure 3-1.

M180204 Enclosure 2


Table 3-1: Fuel Loading for Cycle 16 of LaSalle Unit 2 s,;1;xt·.:; 1.,i'l:£i'f'l . ii..i-~~:i ,,;:::~:f:i?t''£·t,\:/':,~!ff,li~ih ?~,, 1;'¥:V:,,,z t>·,~:t 1&?,i'.~f.J;,i¥~'::i.W· ">'..~ -•. --' ,,,J, liJft2': , 'l,,;,;~,~~ll~l!f/c·<t()JJ,,~/1(~"~~//, <;:,:;yf;'.·~<(_;;~;~':et{~~'-t'.'!'.f?:·~J,::'.;.:::;'1t~J/::,;1~t",.{;'~·<,\,;,/');f:,·:;.

[[

]]

M180204 Enclosure 2


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11 11 13 11 22 17 22 18 17 18 18 17 18 22 17 22 11 13 11 12

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Figure 3-1: Bundle Type (IAT) Array for LaSalle Unit 2 Cycle 16

11 11

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The LaSalle Unit 2 plant has a gamma TIP system with 43 TIP strings. Of the four GNF3 LUA fuel assemblies, one is adjacent to a TIP string (String 39) which is on the line of diagonal symmetry. The locations of the four GNF3 fuel assemblies are given in Table 3-2, while the location of the TIP strings and the line of diagonal symmetry are provided in Figure 3-2.

Table 3-2: Location of GNF3 Fuel Assemblies in LaSalle Unit 2 Cycle 16

I J

6 7

25 7

6 24

25 24

M l80204 Non-Proprietary Information Enclosure 2 Page 9 of22

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Figure 3-2: TIP String Locations fo r LaSalle Unit 2 and Locations of GNF3 Fuel Assemblies

River Bend Uni t 1 Background Info rmation

River Bend Unit 1 is a 624 bund le BWRJ6. In Cycle 19, the rated power was 3,091.0 MWt, and the rated flow was 84.5 Mlbm/hr. The original rated power was 2,894.0 MWt, so the p lant operated at 106.8% of the original rated power. The fue l loading is summarized in Table 3-3. The majority of the fue l is GNF2 (99.4% of the core loading) with the remaining 0.6% composed of GNF3 fue l. The bundle type (IAT) array is provided as Figure 3-3.

Ml80204 Enclosure 2

Note:


Table 3-3: Fuel Loading for Cycle 19 of River Bend Unit 1 1

IAT # Name [[

]]

1. There were multiple mid-cycle outages. This is the latest fuel loading for River Bend Unit 1.

Ml80204 Enclosure 2

Non-Proprietary Information Page 11 of 22

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8 5 16 13 3 12 3 12 4 14 4 11 4 4 11 4 11 4 12 3 12 3 13 16 6 16 12 3 12 3 5 4 3 4 11 4 11 11 4 11 4 3 4 5 3 12 3 12

5 16 3 12 4 11 4 11 4 14 4 11 3 3 11 4 14 4 11 4 11 4 12 3 3 16 3 12 4 11 4 11 4 14 4 11 3 3 11 4 14 4 11 4 11 4 12 3

6 16 12 3 12 3 5 4 3 4 11 4 11 11 4 11 4 3 4 3 3 12 3 12 8 5 16 13 3 12 3 12 4 11 4 11 4 4 11 4 11 4 12 3 12 3 13 16

6 3 16 3 12 3 12 4 11 4 14 4 14 14 4 14 4 11 4 12 3 12 3 16 6 6 13 13 3 5 3 12 4 14 4 3 4 4 3 4 14 4 12 3 5 3 13 13

9 7 5 13 12 3 12 3 12 4 12 4 11 J1 4 12 4 12 3 12 3 12 13 5 10 6 5 3 13 15 3 15 3 12 3 5 4 4 5 3 12 3 15 3 15 13 3 3

6 9 9 17 3 12 3 5 3 12 3 11 11 3 12 3 5 3 12 3 17 6 8 8 8 3 16 13 12 3 12 3 12 4 4 12 3 12 3 12 13 16 3 10 6

8 8 9 3 13 13 3 13 3 12 12 3 13 3 13 13 3 9 8 8 8 9 5 5 13 13 13 12 3 3 12 13 13 13 5 5 6 8

8 8 7 6 3 5 16 13 13 16 5 3 7 7 9 8 10 9 6 6 8 6 3 3 6 8 9 8 9 10

8661010668

Figure 3-3: Bundle Type (IAT) Array for River Bend Unit 1 Cycle 19

8 9 7

6 3 5

16

16 16 16 5 3 6 9 8

6

6 9 6 6 8 6

3 5

6 8 6 6 9 10

7

6

8

10 6

7

6

7

The River Bend Unit 1 plant has a thermal TIP system with 33 TIP strings. Of the four GNF3 LUA fuel assemblies, one is adjacent to a TIP string (String 10). The locations of the four GNF3 fuel assemblies are given in Table 3-4, while the location of the TIP strings and the line of diagonal symmetry are provided in Figure 3-4.

Table 3-4: Location of GNF3 Fuel Assemblies in River Bend Unit 1 Cycle 19

I J 6 7

23 7 6 22

23 22

Ml80204 Enclosure 2


2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

2 3 4 5 ~--· .... -1--+---;·-· ... --1--+---;· -· ... . -1--+---;--- .... -1--+--;,,-3-3° ~ . , 29 , , 30 , 31 , 32 ~ !

6 7

t--+-~IHll'__,al: __ _ ,__ : : ___ ,__ : :.-.,- . ..,:_.._..,:._.,-. : I..,..~ ·-+-8 H·-· -· 9 , 23 __ _.,. - · .... --- ... ------ ... . -1--+--1·-· ... ··,.afC-t....,"+--i·-. - . --'-----1 : 24 : :· fs" . : : 26 , : 27 ..,.. , , 28 : 10 ri·-· -· 11

:.,-,· - ..... ----- . ... . . - ..... -1--+1_,"7111 .... -.... . . - . - . -1,--+--I

12 W---13 -· , 17 -1--+--1'· - ..... -1--+--I· - ..... -1--+--I ... ,::,l-':.....+---4· - • - • -1--+---i· - . - . -j'--+--1 , 18 , 19 :20·1; , , 21 , 22

14 H ·-· -· 15 ~

-+--+---1• - • I-.---· -. I-. -+--+"-711 .. - ..... ----- . - . -t--+----1· - • - .... ,----....

16 W--· -· 17 • 11 18 H·-· -· : 19

: __ • I-• :.,,,,, : : __ • I-• : : ___ -· : : ___ -· :

-+--+---1 +--+-, -1'-, -· ... ---- -+--+---1 -+--+---i -1,--+--I

20 LJ ___ -· 21 ; 5 ; _ __ _., , ·-· ___ ] ____ ....

··5· r:;,., ;·T'"'" ; ;" ii ·'"'· ; ;·g· -· ; · 10 ;

22 '·-· i -· 23 -+--+-~...,,.~ .... ..,i __ _,i. -· ... ..... if--+--_,i. -· .... ..,i __ _,i __ . - . -1i,__ ...... ~•-NF'I .... +-

24 25 26 27 '· -..... -;·---;·--· .... -;·~--;·--· .... -;•---;·--. -. +-28

Figure 3-4: TIP String Locations for River Bend Unit 1 and Locations of GNF3 Fuel Assemblies

EVALUATION

Comparisons of calculated power distributions to TIP measurements were made for LUA adjacent TIP strings. TIP statistics are calculated as described in the GE response to Nuclear Regulatory Commission (NRC) RAI 21-2, SLMCPR, in MFN 05-022 (Reference 3-1). Underlying calculated (CAL TIP) and measured (PCTIP) TIP data, as output by PANACl 1, is provided in the Excel file in Enclosure 4.

LaSalle Unit 2 Cycle 16

A TIP statistics summary for LaSalle Unit 2 Cycle 16 is provided in Tab le 3-5. There are seven TIP comparisons provided.

Calculated and measured TIP readings for the TIP string adjacent to a GNF3 bundle are provided in Table 3-6.

The "Axial LUA TIP RMS Error" of Table 3-6 is the LUA adjacent TIP string component of the core average "Axial RMS" in Table 3-5 . The "Radial Integrated LUA TIP Absolute Error" of Table 3-6 is the LUA adjacent TIP string component of the core average "Bundle RMS" in Table 3-5. Using the notation from the GE response to NRC RAI 21-2 in MFN 05-022 (Reference 3-1) and the normalization of C and P described therein (normalization factors

M180204 Enclosure 2


provided in the Excel file in Enclosure 4), for TIP string j (LUA), these two components are, respectively:

/:J.j,axial=

L ( K · C(k,j) K · P(k,j) )2

k Lkr C(k',j) - Lkr P(k',j)

K

Ik( C(k,j) - P(k,j)) /:J.j,rad= K

The relative GNF3 bundle power is provided along with GNF3 bundle exposure in Table 3-7.

Over a range of exposures it is observed that the axial power distribution predictions are unaffected by the presence of the GNF3 assemblies, including_those cases where the GNF3 bundle power was relatively high compared to the remaining three bundles.

Table 3-5: LaSalle Unit 2 TIP Statistics Suminary

C. yc_le Reactor ·Core. Bundle ; ·,Exoosure Power ; !?low. , . ~· ..

· Axial , , ·-Nod1d PCTIP CALTiP Core Avg: ¥x._1!:xi( ',_;-- < -''" '., --"

:CaS:e::, fMWd/ST) . AMWt) ; XMlbm/Iir) ,.::· RMS.; RMS<, : .RMS rr

11 Root Mean Square (RMS) rr Mean Standard Deviation Minimum Maximum 11

Table 3-6: LaSalle Unit 2 TIP Measurements for GNF3 Lead Use Assemblies

·cy~l~ Exposure":.: .TiP. . AjfalLUA TIP' ·. Jtidialintegrat~d LUA (MWd/ST) $trio~ R,l\'.IS Error, •• :TiP Absolute Error ;

rr

11

M180204 Enclosure 2

rr


Table 3-7: GNF3 Bundle Power and Exposure for LaSalle Unit 2

]]

River Bend Unit 1 Cycle 19

A TIP statistics summary for the current River Bend Unit 1 Cycle 19 is provided in Table 3-8. There are seven TIP comparisons provided.

Calculated and measured TIP readings for the TIP strings adjacent to a GNF3 bundle are provided in Table 3-9. Over a range of exposures, it is observed that the axial power distribution predictions are unaffected by the presence of the GNF3 assemblies.

The relative GNF3 bundle power is provided along with GNF3 bundle exposure in Table 3-10.

Over a range of exposures it is observed that the axial power distribution predictions are unaffected by the presence ?f the GNF3 assemblies.

Table 3-8: River Bend.Unit 1 TIP Statistics Summary

Case. <MWil/S'f.) / -(MW1:Y ,. <Mli:nn/hrL RMS RMS : RMS:. ·svmmetn:: Symmetry :Ex;,V oid i , , Void , . ,:

rr

11 RMS rr Mean Standard Deviation Minimum Maximum 11

M180204 Enclosure 2


Table 3-9: River Bend Unit 1 TIP Measurements for GNF3 Lead Use Assemblies

. C ~.~, :cy~Je Exrr,6S,J!r~ .; j\T~~:,'.:1:i , ~:xi~l ; UA;,;rl,P , ~fa~ial Iµiegr:aled ·;~.f' Y · (MWd/ST) . Strmg, RMS Error.· · TIP Absolute Error rr

11

Table 3-10: GNF3 Bundle Power and Exposure for River Bend Unit 1

Reference

3-1 Letter, George Stramback (GE Energy) to NRC Document Control Desk, "Responses to · RAis - Methods Interim Process (TAC No. MC5780)," MFN 05-022, March 31, 2005.

M180204 Enclosure 2

RAI-4

Non-Proprietary Information Page-16 of22

On Page 2.:9 ofIMLTR Supplement 5,· [[ ]] is described for the purpose of generating code-to.,code comparisons between MCNP and P ANAC 11. Provide more detail about the bundle designs used to demonstrate that they reflect fuel and core designs in use for plants with expanded operating domains.

GEH Response

[[ . ]] equilibrium core designs of high

power density expanded operating domain (EOD) plants, as discussed in the response to RAI-5.

These equilibrium cycles are typically used in cycle-independent safety evaluations to provide

repres~ntative operational information for a given plant, operational strategy, and fuel type combination. The core and bundle designs represent an ·idealized steady-state loading pattern

(i.e., same bundle designs. in the same location in every cycle) that could be achieved if all design

requirements ( e.g., cycle. energy plan, target eigenvalue) and plant operational performance. were held constant for all future reloads. fa this way, the long-term safety and economic impact of a

new fuel type and/or a new operational strategy can be assessed with a single cycle design.

[[

]]

[[ ]]

M180204 Enclosure 2

[[

Figure 4-1: [[ ]]


]]

M180204 Enclosure 2

[[

Figure 4-2: [[ ]]


]]

M180204 Enclosure 2

[[

Figure 4-3: [[ ]]


]]

M180204 Enclosure 2

RAl-5


IMLTR Supplement 5 presents power distribution comparisons of a PANACll core region to a 3D core modeled in MCNP, to demonstrate that the power prediction capability of PANACl 1 for

GNF3 is consistent with that for previous fuel designs (e.g., GE14 and GNF2). However, the

approach used to develop the input for both codes is not described in sufficient detail in

Supplement 5 to allow for a reasonable assessment that both models are appropriate for comparison. Provide a descriptive summary of the various steps involved in the analysis approach

to assure that the power distribution predictions compare meaningfully between MCNP and

PANACll.

GEH Response

The steps used to generate models is further described in the numbered list below. These same

steps are also presented as a flow diagram in Figure 5-1 in an attempt to make the data flow easier

to understand.

[[ ]] benchmarking steps:

1) [[

M180204 Enclosure 2

]]


MI80204 Enclosure 2

[[

Figure 5-1: [[


]]

]]

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