2012/11/27 Areva EPR DC - DRAFT Response to U.S. EPR ...August 30, 2012 Resolution Meeting to...

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ArevaEPRDCPEm Resource

From: WILLIFORD Dennis (AREVA) [[email protected]]Sent: Tuesday, November 27, 2012 4:54 PMTo: Snyder, AmyCc: BENNETT Kathy (AREVA); DELANO Karen (AREVA); LEIGHLITER John (AREVA);

ROMINE Judy (AREVA); RYAN Tom (AREVA); TOLLEY Tracey (AREVA); VANCE Brian (AREVA); WELLS Russell (AREVA); NOXON David (AREVA); RITCHEY Calvin (AREVA); SAWYER Ogden (AREVA); Ford, Tanya

Subject: DRAFT Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Question 19-335

Attachments: RAI 349 Question 19-335 Response US EPR DC - DRAFT.pdf

Amy, Attached is a DRAFT response for RAI No. 349, FSAR Ch 19, Question 19-335 in advance of the January 31, 2013 final date. The attached file is a revision to the draft response sent for this question on June 14, 2010. The revised question response was discussed during the August 30, 2012 PRA closure meeting. Let me know if the staff has questions or if the response can be sent as final. Thanks, Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected]

From: WILLIFORD Dennis (RS/NB) Sent: Tuesday, November 27, 2012 4:36 PM To: [email protected] Cc: BENNETT Kathy (RS/NB); DELANO Karen (RS/NB); LEIGHLITER John (RS/NB); ROMINE Judy (RS/NB); RYAN Tom (RS/NB); TOLLEY Tracey (RS/NB); VANCE Brian (RS/NB); WELLS Russell (RS/NB); NOXON David (RS/NB); RITCHEY Calvin (EP/PE); SAWYER Ogden (EP/PE); [email protected] Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 20 Amy, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010, Supplement 4 on June 14, 2010, Supplement 5 on July 20, 2010 and Supplement 6 on August 20, 2010 providing an updated schedule for the responses. AREVA NP submitted Supplement 7 to the response on September 24, 2010 providing technically correct and complete responses to 2 of the 4 remaining questions and a revised schedule for the 2 remaining questions. Supplement 8 on October 26, 2010, Supplement 9 on December 6, 2010, Supplement 10 on January 14, 2011, Supplement 11 on February 21, 2011, Supplement 12 on March 22, 2011, 2011, Supplement 13 on April 21, 2011, Supplement 14 on June 24, 2011, Supplement 15 on October 18, 2011, Supplement 16 on November 17, 2011, Supplement 17 on December 13, 2011, Supplement 18 on

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January 24, 2012, and Supplement 19 on February 26, 2012 provided a revised schedule for the two remaining questions. The schedule for a technically correct and complete responses to the remaining 2 questions has been changed as provided below. These changes to the final response dates were discussed with NRC staff during the August 30, 2012 Resolution Meeting to Discuss PRA Path Forward for Closure of Open Items for the U.S. EPR Design Certification. Question # Response Date RAI 349 — 19-334 January 31, 2013 RAI 349 — 19-335 January 31, 2013 Sincerely, Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected]

From: WILLIFORD Dennis (RS/NB) Sent: Sunday, February 26, 2012 5:17 PM To: [email protected] Cc: BENNETT Kathy (RS/NB); DELANO Karen (RS/NB); ROMINE Judy (RS/NB); RYAN Tom (RS/NB); NOXON David (RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 19 Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010, Supplement 4 on June 14, 2010, Supplement 5 on July 20, 2010 and Supplement 6 on August 20, 2010 providing an updated schedule for the responses. AREVA NP submitted Supplement 7 to the response on September 24, 2010 providing technically correct and complete responses to 2 of the 4 remaining questions and a revised schedule for the 2 remaining questions. Supplement 8 on October 26, 2010, Supplement 9 on December 6, 2010, Supplement 10 on January 14, 2011, Supplement 11 on February 21, 2011, Supplement 12 on March 22, 2011, 2011, Supplement 13 on April 21, 2011, Supplement 14 on June 24, 2011, Supplement 15 on October 18, 2011, Supplement 16 on November 17, 2011, Supplement 17 on December 13, 2011, and Supplement 18 on January 24, 2012 provided a revised schedule for the two remaining questions. The schedule for technically correct and complete responses to the remaining 2 questions has been changed as provided below. This schedule was transmitted to the NRC in AREVA NP letter NRC:12:008 dated February 21, 2012. Question # Response Date RAI 349 — 19-334 June 28, 2013 RAI 349 — 19-335 June 28, 2013

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Sincerely, Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected]

From: WILLIFORD Dennis (RS/NB) Sent: Tuesday, January 24, 2012 5:13 PM To: [email protected] Cc: BENNETT Kathy (RS/NB); DELANO Karen (RS/NB); ROMINE Judy (RS/NB); RYAN Tom (RS/NB); NOXON David (RS/NB); [email protected]; [email protected] Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 18 Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010, Supplement 4 on June 14, 2010, Supplement 5 on July 20, 2010 and Supplement 6 on August 20, 2010 providing an updated schedule for the responses. AREVA NP submitted Supplement 7 to the response on September 24, 2010 providing technically correct and complete responses to 2 of the 4 remaining questions and a revised schedule for the 2 remaining questions. Supplement 8 sent on October 26, 2010, Supplement 9 on December 6, 2010, Supplement 10 on January 14, 2011, Supplement 11 on February 21, 2011, Supplement 12 on March 22, 2011, 2011, Supplement 13 on April 21, 2011, Supplement 14 on June 24, 2011, Supplement 15 on October 18, 2011, Supplement 16 on November 17, 2011, and Supplement 17 on December 13, 2011 provided a revised schedule for the two remaining questions. A preliminary revised schedule for technically correct and complete responses to the remaining 2 questions is provided below. This schedule is being reevaluated and a new supplement with a revised schedule will be transmitted by February 21, 2012. Question # Response Date RAI 349 — 19-334 February 21, 2012 RAI 349 — 19-335 February 21, 2012 Sincerely, Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected]

From: WILLIFORD Dennis (RS/NB) Sent: Tuesday, December 13, 2011 4:37 PM To: [email protected]

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Cc: BENNETT Kathy (RS/NB); DELANO Karen (RS/NB); ROMINE Judy (RS/NB); RYAN Tom (RS/NB); NOXON David (RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 17 Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010, Supplement 4 on June 14, 2010, Supplement 5 on July 20, 2010 and Supplement 6 on August 20, 2010 providing an updated schedule for the responses. AREVA NP submitted Supplement 7 to the response on September 24, 2010 providing technically correct and complete responses to 2 of the 4 remaining questions and a revised schedule for the 2 remaining questions. Supplement 8 sent on October 26, 2010, Supplement 9 on December 6, 2010, Supplement 10 on January 14, 2011, Supplement 11 on February 21, 2011, Supplement 12 on March 22, 2011, 2011, Supplement 13 on April 21, 2011, Supplement 14 on June 24, 2011, Supplement 15 on October 18, 2011, and Supplement 16 on November 17, 2011 provided a revised schedule for the two remaining questions. A preliminary revised schedule for technically correct and complete responses to the remaining 2 questions is provided below. This schedule is being reevaluated and a new supplement with a revised schedule will be transmitted by January 25, 2012. Question # Response Date RAI 349 — 19-334 January 25, 2012 RAI 349 — 19-335 January 25, 2012 Sincerely, Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected]

From: WILLIFORD Dennis (RS/NB) Sent: Thursday, November 17, 2011 6:23 PM To: [email protected] Cc: BENNETT Kathy (RS/NB); DELANO Karen (RS/NB); ROMINE Judy (RS/NB); RYAN Tom (RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 16 Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010, Supplement 4 on June 14, 2010, Supplement 5 on July 20, 2010 and Supplement 6 on August 20, 2010 providing an updated schedule for the responses. AREVA NP submitted Supplement 7 to the response on September 24, 2010 providing technically correct and complete responses to 2 of the 4 remaining questions and a revised schedule

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for the 2 remaining questions. Supplement 8 sent on October 26, 2010, Supplement 9 on December 6, 2010, Supplement 10 on January 14, 2011, Supplement 11 on February 21, 2011, Supplement 12 on March 22, 2011, 2011, Supplement 13 on April 21, 2011, Supplement 14 on June 24, 2011, and Supplement 15 on October 18, 2011 provided a revised schedule for the two remaining questions. A preliminary revised schedule for technically correct and complete responses to the remaining 2 questions is provided below. This schedule is being reevaluated and a new supplement with a revised schedule will be transmitted by December 14, 2011. Question # Response Date RAI 349 — 19-334 December 14, 2011 RAI 349 — 19-335 December 14, 2011 Sincerely, Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected]

From: WILLIFORD Dennis (RS/NB) Sent: Tuesday, October 18, 2011 4:57 PM To: [email protected] Cc: BENNETT Kathy (RS/NB); DELANO Karen (RS/NB); ROMINE Judy (RS/NB); RYAN Tom (RS/NB); NOXON David (RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 15 Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010, Supplement 4 on June 14, 2010, Supplement 5 on July 20, 2010 and Supplement 6 on August 20, 2010 providing an updated schedule for the responses. AREVA NP submitted Supplement 7 to the response on September 24, 2010 providing technically correct and complete responses to 2 of the 4 remaining questions and a revised schedule for the 2 remaining questions. Supplement 8 on October 26, 2010, Supplement 9 on December 6, 2010, Supplement 10 on January 14, 2011, Supplement 11 on February 21, 2011, Supplement 12 on March 22, 2011, Supplement 13 on April 21, 2011, and Supplement 14 on June 24, 2011 provided revised schedules for the two remaining questions. A preliminary revised schedule for technically correct and complete responses to the remaining 2 questions is provided below. This schedule is being reevaluated and a new supplement with a revised schedule will be transmitted by November 17, 2011. Question # Response Date RAI 349 — 19-334 November 17, 2011 RAI 349 — 19-335 November 17, 2011

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Sincerely, Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected]

From: WILLIFORD Dennis (RS/NB) Sent: Friday, June 24, 2011 11:32 AM To: 'Tesfaye, Getachew' Cc: BENNETT Kathy (RS/NB); DELANO Karen (RS/NB); ROMINE Judy (RS/NB); RYAN Tom (RS/NB); NOXON David (RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 14 Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010, Supplement 4 on June 14, 2010, Supplement 5 on July 20, 2010 and Supplement 6 on August 20, 2010 providing an updated schedule for the responses. AREVA NP submitted Supplement 7 to the response on September 24, 2010 providing technically correct and complete responses to 2 of the 4 remaining questions and a revised schedule for the 2 remaining questions. Supplement 8 on October 26, 2010, Supplement 9 on December 6, 2010, Supplement 10 on January 14, 2011, Supplement 11 on February 21, 2011, Supplement 12 on March 22, 2011, and Supplement 13 on April 21, 2011 provided revised schedules for the two remaining questions. The schedule for providing technically correct and complete responses to the 2 remaining questions has been changed as provided below: Question # Response Date RAI 349 — 19-334 October 19, 2011 RAI 349 — 19-335 October 19, 2011 Sincerely, Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected]

From: WELLS Russell (RS/NB) Sent: Thursday, April 21, 2011 3:46 PM To: 'Tesfaye, Getachew' Cc: NOXON David (RS/NB); BENNETT Kathy (RS/NB); DELANO Karen (RS/NB); ROMINE Judy (RS/NB); RYAN Tom

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(RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 13 Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010, Supplement 4 on June 14, 2010, Supplement 5 on July 20, 2010 and Supplement 6 on August 20, 2010 providing an updated schedule for the responses. AREVA NP submitted Supplement 7 to the response on September 24, 2010 providing technically correct and complete responses to 2 of the 4 remaining questions and a revised schedule for the 2 remaining questions. Supplement 8 on October 26, 2010, Supplement 9 on December 6, 2010, Supplement 10 on January 14, 2011, Supplement 11 on February 21, 2011, and Supplement 12 on March 22, 2011 provided revised schedules for the two remaining questions. The schedule for the remaining two questions is being changed to allow more time for resolution of NRC comments. The revised schedule for technically correct and complete responses to the 2 remaining questions is provided below: Question # Response Date RAI 349 — 19-334 June 24, 2011 RAI 349 — 19-335 June 24, 2011 Sincerely, Russ Wells U.S. EPR Design Certification Licensing Manager AREVA NP, Inc. 3315 Old Forest Road, P.O. Box 10935 Mail Stop OF-57 Lynchburg, VA 24506-0935 Phone: 434-832-3884 (work) 434-942-6375 (cell) Fax: 434-382-3884 [email protected]

From: WELLS Russell (RS/NB) Sent: Tuesday, March 22, 2011 1:42 PM To: 'Tesfaye, Getachew' Cc: NOXON David (RS/NB); BENNETT Kathy (RS/NB); DELANO Karen (RS/NB); ROMINE Judy (RS/NB); RYAN Tom (RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 12 Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010, Supplement 4 on June 14, 2010, Supplement 5 on July 20, 2010 and Supplement 6 on August 20, 2010 providing an

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updated schedule for the responses. AREVA NP submitted Supplement 7 to the response on September 24, 2010 providing technically correct and complete responses to 2 of the 4 remaining questions and a revised schedule for the 2 remaining questions. Supplement 8 on October 26, 2010, Supplement 9 on December 6, 2010, Supplement 10 on January 14, 2011 and Supplement 11 on February 21, 2011 provided revised schedules for the two remaining questions. The schedule for the remaining two questions is being changed to allow more time for resolution of NRC comments. The revised schedule for technically correct and complete responses to the 2 remaining questions is provided below: Question # Response Date RAI 349 — 19-334 April 25, 2011 RAI 349 — 19-335 April 25, 2011 Sincerely, Russ Wells U.S. EPR Design Certification Licensing Manager AREVA NP, Inc. 3315 Old Forest Road, P.O. Box 10935 Mail Stop OF-57 Lynchburg, VA 24506-0935 Phone: 434-832-3884 (work) 434-942-6375 (cell) Fax: 434-382-3884 [email protected]

From: BRYAN Martin (External RS/NB) Sent: Monday, February 21, 2011 9:41 AM To: Tesfaye, Getachew Cc: DELANO Karen (RS/NB); ROMINE Judy (RS/NB); BENNETT Kathy (RS/NB); NOXON David (RS/NB); WELLS Russell (RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 11 Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010, Supplement 4 on June 14, 2010, Supplement 5 on July 20, 2010 and Supplement 6 on August 20, 2010 providing an updated schedule for the responses. AREVA NP submitted Supplement 7 to the response on September 24, 2010 providing technically correct and complete responses to 2 of the 4 remaining questions and a revised schedule for the 2 remaining questions. Supplement 8 on October 26, 2010, Supplement 9 on December 6, 2010 and Supplement 10 on January 14, 2011 provided revised schedules for the two remaining questions. The schedule for the remaining two questions is being changed to allow more time for resolution of NRC comments. The revised schedule for technically correct and complete responses to the 2 remaining questions is provided below: Question # Response Date

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RAI 349 — 19-334 March 23, 2011 RAI 349 — 19-335 March 23, 2011 Sincerely, Martin (Marty) C. Bryan U.S. EPR Design Certification Licensing Manager AREVA NP Inc. Tel: (434) 832-3016 702 561-3528 cell [email protected]

From: BRYAN Martin (External RS/NB) Sent: Friday, January 14, 2011 10:51 AM To: 'Tesfaye, Getachew' Cc: DELANO Karen (RS/NB); ROMINE Judy (RS/NB); BENNETT Kathy (RS/NB); NOXON David (RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 10

Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010, Supplement 4 on June 14, 2010, Supplement 5 on July 20, 2010 and Supplement 6 on August 20, 2010 providing an updated schedule for the responses. AREVA NP submitted Supplement 7 to the response on September 24, 2010 providing technically correct and complete responses to 2 of the 4 remaining questions and a revised schedule for the 2 remaining questions. Supplement 8 on October 26, 2010 and Supplement 9 on December 6, 2010 provided revised schedules for the two remaining questions. The schedule for the remaining two questions is being changed to allow more time for resolution of NRC comments. The revised schedule for technically correct and complete responses to the 2 remaining questions is provided below: Question # Response Date RAI 349 — 19-334 February 21, 2011 RAI 349 — 19-335 February 21, 2011 Sincerely, Martin (Marty) C. Bryan U.S. EPR Design Certification Licensing Manager AREVA NP Inc. Tel: (434) 832-3016 702 561-3528 cell [email protected]

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From: BRYAN Martin (External RS/NB) Sent: Monday, December 06, 2010 11:53 AM To: 'Tesfaye, Getachew' Cc: DELANO Karen (RS/NB); ROMINE Judy (RS/NB); BENNETT Kathy (RS/NB); NOXON David (RS/NB); RYAN Tom (RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 9

Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010, Supplement 4 on June 14, 2010, Supplement 5 on July 20, 2010 and Supplement 6 on August 20, 2010 providing an updated schedule for the responses. AREVA NP submitted Supplement 7 to the response on September 24, 2010 providing technically correct and complete responses to 2 of the 4 remaining questions and a revised schedule for the 2 remaining questions. Supplement 8 on October 26, 2010 provided a revised schedule for the two remaining questions. The schedule for the remaining two questions is being changed to allow more time for resolution of NRC comments. The revised schedule for technically correct and complete responses to the 2 remaining questions is provided below: Question # Response Date RAI 349 — 19-334 January 17, 2011 RAI 349 — 19-335 January 17, 2011 Sincerely, Martin (Marty) C. Bryan U.S. EPR Design Certification Licensing Manager AREVA NP Inc. Tel: (434) 832-3016 702 561-3528 cell [email protected]

From: BRYAN Martin (External RS/NB) Sent: Tuesday, October 26, 2010 7:30 AM To: 'Tesfaye, Getachew' Cc: DELANO Karen (RS/NB); ROMINE Judy (RS/NB); BENNETT Kathy (RS/NB); NOXON David (RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 8

Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010, Supplement 4

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on June 14, 2010, Supplement 5 on July 20, 2010 and Supplement 6 on August 20, 2010 providing an updated schedule for the responses. AREVA NP submitted Supplement 7 to the response on September 24, 2010 providing technically correct and complete responses to 2 of the 4 remaining questions and a revised schedule for the 2 remaining questions The schedule for the remaining two questions is being changed to allow more time for resolution of NRC comments. The revised schedule for technically correct and complete responses to the 2 remaining questions is provided below: Question # Response Date RAI 349 — 19-334 December 6, 2010 RAI 349 — 19-335 December 6, 2010 Sincerely, Martin (Marty) C. Bryan U.S. EPR Design Certification Licensing Manager AREVA NP Inc. Tel: (434) 832-3016 702 561-3528 cell [email protected]

From: BRYAN Martin (External RS/NB) Sent: Thursday, September 23, 2010 8:40 PM To: 'Tesfaye, Getachew' Cc: DELANO Karen (RS/NB); ROMINE Judy (RS/NB); BENNETT Kathy (RS/NB); NOXON David (RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 7

Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010,Supplement 4 on June 14, 2010, Supplement 5 on July 20, 2010 and Supplement 6 on August 20, 2010 providing an updated schedule for the responses. Proprietary and Non-proprietary versions of the response to RAI 349, Supplement 7 are provided via letter NRC 10:87. An affidavit to support withholding of information from public disclosure, per 10CFR2.390(b), is provided as an enclosure to that letter. The following table indicates the respective pages in the response document, that contain AREVA NP’s response to the subject questions. Question # Start Page End Page RAI 349 — 19-332 2 57 RAI 349 — 19-333 58 65 The schedule for technically correct and complete responses to the 2 remaining questions has been changed and is provided below:

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RAI 349 — 19-334 October 27, 2010 RAI 349 — 19-335 October 27, 2010 Sincerely, Martin (Marty) C. Bryan U.S. EPR Design Certification Licensing Manager AREVA NP Inc. Tel: (434) 832-3016 702 561-3528 cell [email protected]

From: BRYAN Martin (External RS/NB) Sent: Friday, August 20, 2010 12:34 PM To: 'Tesfaye, Getachew' Cc: DELANO Karen (RS/NB); ROMINE Judy (RS/NB); BENNETT Kathy (RS/NB); NOXON David (RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 6

Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010,Supplement 4 on June 14, 2010, and Supplement 5 on July 20, 2010 providing an updated schedule for the responses. AREVA NP Inc. provided draft responses for the four remaining questions on June 14, 2010. The schedule for the four remaining questions is being revised to allow more time to interact with the NRC on review of the draft responses. The schedule for technically correct and complete responses to the 4 remaining questions has been changed and is provided below: Question # Response Date RAI 349 — 19-332 September 23, 2010 RAI 349 — 19-333 September 23, 2010 RAI 349 — 19-334 September 23, 2010 RAI 349 — 19-335 September 23, 2010 Sincerely, Martin (Marty) C. Bryan U.S. EPR Design Certification Licensing Manager AREVA NP Inc. Tel: (434) 832-3016 702 561-3528 cell [email protected]

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From: BRYAN Martin (EXT) Sent: Tuesday, July 20, 2010 4:45 PM To: 'Tesfaye, Getachew' Cc: DELANO Karen V (AREVA NP INC); ROMINE Judy (AREVA NP INC); BENNETT Kathy A (OFR) (AREVA NP INC); NOXON David B (AREVA NP INC) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 5

Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010, and Supplement 4 on June 14, 2010, providing an updated schedule for the responses. AREVA NP Inc. provided draft responses to the for the four remaining questions on June 14, 2010. Let me know if these responses can be submitted as final. The schedule for the four remaining questions is being revised to allow more time for NRC review of the draft responses. The schedule for technically correct and complete responses to the 4 remaining questions has been changed and is provided below: Question # Response Date RAI 349 — 19-332 August 23, 2010 RAI 349 — 19-333 August 23, 2010 RAI 349 — 19-334 August 23, 2010 RAI 349 — 19-335 August 23, 2010 Sincerely, Martin (Marty) C. Bryan U.S. EPR Design Certification Licensing Manager AREVA NP Inc. Tel: (434) 832-3016 702 561-3528 cell [email protected]

From: BRYAN Martin (EXT) Sent: Monday, June 14, 2010 3:41 PM To: 'Tesfaye, Getachew' Cc: DELANO Karen V (AREVA NP INC); ROMINE Judy (AREVA NP INC); BENNETT Kathy A (OFR) (AREVA NP INC); NOXON David B (AREVA NP INC) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 4

Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing an updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010,

14

to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. AREVA NP submitted Supplement 3 to the response on May 24, 2010, providing an updated schedule for the responses. The schedule for the four remaining questions is being revised to allow time to interact with the NRC on the responses. The schedule for technically correct and complete responses to the 4 remaining questions has been changed and is provided below: Question # Response DateRAI 349 — 19-332 July 21, 2010 RAI 349 — 19-333 July 21, 2010 RAI 349 — 19-334 July 21, 2010 RAI 349 — 19-335 July 21, 2010 Sincerely, Martin (Marty) C. Bryan U.S. EPR Design Certification Licensing Manager AREVA NP Inc. Tel: (434) 832-3016 702 561-3528 cell [email protected]

From: BRYAN Martin (EXT) Sent: Monday, May 24, 2010 4:36 PM To: 'Tesfaye, Getachew' Cc: DELANO Karen V (AREVA NP INC); ROMINE Judy (AREVA NP INC); BENNETT Kathy A (OFR) (AREVA NP INC); NOXON David B (AREVA NP INC) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 3

Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing updated schedule for the responses. AREVA NP submitted Supplement 2 to the response on April 30, 2010, to provide technically correct and complete responses to 2 of the 6 questions and a revised schedule for the remaining 4 questions. As agreed with the NRC, the schedule for the four remaining questions is being revised to allow time to discuss the proposed response with the NRC. A telecon was originally scheduled for May 19th to discuss the proposed responses but had to be rescheduled. The schedule for technically correct and complete responses to the 4 remaining questions has been changed and is provided below: Question # Response DateRAI 349 — 19-332 June 21, 2010 RAI 349 — 19-333 June 21, 2010

15

RAI 349 — 19-334 June 21, 2010 RAI 349 — 19-335 June 21, 2010 Sincerely, Martin (Marty) C. Bryan U.S. EPR Design Certification Licensing Manager AREVA NP Inc. Tel: (434) 832-3016 702 561-3528 cell [email protected]

From: BRYAN Martin (EXT) Sent: Friday, April 30, 2010 4:21 PM To: 'Tesfaye, Getachew' Cc: DELANO Karen V (AREVA NP INC); ROMINE Judy (AREVA NP INC); BENNETT Kathy A (OFR) (AREVA NP INC); NOXON David B (AREVA NP INC) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 2

Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. AREVA NP submitted Supplement 1 to the response on March 31, 2010, providing updated schedule for the responses. The attached file, “RAI 349 Supplement 2 Response US EPR DC” provides technically correct and complete responses to 2 of the 6 questions, as committed. Appended to this file are affected pages of the U.S. EPR Final Safety Analysis Report in redline-strikeout format which support the response to RAI 349 Questions 19-330 and 19-331. The following table indicates the respective pages in the response document, “RAI 349 Supplement 2 Response US EPR DC,” that contain AREVA NP’s response to the subject questions. Question # Start Page End Page RAI 349 — 19-330 2 3 RAI 349 — 19-331 4 10 As agreed with NRC, the schedule for Question 19-333 is being revised to address NRC comments during the review of the draft response. The schedule for technically correct and complete responses to the 4 remaining questions has been changed and is provided below: Question # Response DateRAI 349 — 19-332 May 24, 2010 RAI 349 — 19-333 May 24, 2010 RAI 349 — 19-334 May 24, 2010 RAI 349 — 19-335 May 24, 2010 Sincerely,

16

Martin (Marty) C. Bryan U.S. EPR Design Certification Licensing Manager AREVA NP Inc. Tel: (434) 832-3016 702 561-3528 cell [email protected]

From: BRYAN Martin (EXT) Sent: Wednesday, March 31, 2010 3:56 PM To: 'Tesfaye, Getachew' Cc: DELANO Karen V (AREVA NP INC); ROMINE Judy (AREVA NP INC); BENNETT Kathy A (OFR) (AREVA NP INC); NOXON David B (AREVA NP INC) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Supplement 1

Getachew, AREVA NP Inc. provided a schedule for a technically correct and complete response to RAI No. 349 on February 17, 2010. The schedule for Questions 19-330 and 19-331 is being revised to April 30, 2010 to allow for an opportunity to discuss the responses with the NRC. The schedule for technically correct and complete responses to the 6 questions has been changed and provided below: Question # Response Date RAI 349 — 19-330 April 30, 2010RAI 349 — 19-331 April 30, 2010 RAI 349 — 19-332 May 24, 2010 RAI 349 — 19-333 April 30, 2010 RAI 349 — 19-334 May 24, 2010 RAI 349 — 19-335 May 24, 2010 Sincerely, Martin (Marty) C. Bryan Licensing Advisory Engineer AREVA NP Inc. Tel: (434) 832-3016 [email protected]

From: DUNCAN Leslie E (AREVA NP INC) Sent: Wednesday, February 17, 2010 3:15 PM To: 'Tesfaye, Getachew' Cc: DELANO Karen V (AREVA NP INC); BENNETT Kathy A (OFR) (AREVA NP INC); ROMINE Judy (AREVA NP INC); NOXON David B (AREVA NP INC) Subject: Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM

Getachew,

17

Attached please find AREVA NP Inc.’s response to the subject request for additional information (RAI). The attached file, “RAI 349 Response US EPR DC.pdf,” provides the schedule for technically correct and complete responses to these questions. The following table indicates the respective pages in the response document, “RAI 349 Response US EPR DC.pdf,” that contain AREVA NP’s response to the subject questions. Question # Start Page End Page RAI 349 — 19-330 2 2 RAI 349 — 19-331 3 3 RAI 349 — 19-332 4 5 RAI 349 — 19-333 6 6 RAI 349 — 19-334 7 7 RAI 349 — 19-335 8 8 The schedule for technically correct and complete responses to these questions is provided below. Question # Response Date RAI 349 — 19-330 March 31, 2010 RAI 349 — 19-331 March 31, 2010 RAI 349 — 19-332 May 24, 2010 RAI 349 — 19-333 April 30, 2010 RAI 349 — 19-334 May 24, 2010 RAI 349 — 19-335 May 24, 2010 Sincerely, Les Duncan Licensing Engineer AREVA NP Inc. An AREVA and Siemens Company Tel: (434) 832-2849 [email protected]

From: Tesfaye, Getachew [mailto:[email protected]] Sent: Tuesday, January 26, 2010 3:33 PM To: ZZ-DL-A-USEPR-DL Cc: Phan, Hanh; Fuller, Edward; Clark, Theresa; Mrowca, Lynn; Chowdhury, Prosanta; Colaccino, Joseph; ArevaEPRDCPEm Resource Subject: U.S. EPR Design Certification Application RAI No. 349 (4164, 4165),FSAR Ch. 19 OPEN ITEM

Attached please find the subject requests for additional information (RAI). A draft of the RAI was provided to you on December 18, 2009, and discussed with your staff on January 19, 2010. Draft RAI Questions 19-333 and 19-335 were modified as a result of that discussion. The questions in this RAI are OPEN ITEMS in the safety evaluation report for Chapter 19 for Phases 2 and 3 reviews. As such, the schedule we have established for your application assumes technically correct and complete responses prior to the start of Phase 4 review. For any RAI that cannot be answered prior to the start of Phase 4 review, it is expected that a date for receipt of this information will be provided so that the staff can assess how this information will impact the published schedule.

Thanks,

18

Thanks, Getachew Tesfaye Sr. Project Manager NRO/DNRL/NARP (301) 415-3361

Hearing Identifier: AREVA_EPR_DC_RAIs Email Number: 4109 Mail Envelope Properties (2FBE1051AEB2E748A0F98DF9EEE5A5D4F25A96) Subject: DRAFT Response to U.S. EPR Design Certification Application RAI No. 349, FSAR Ch. 19 OPEN ITEM, Question 19-335 Sent Date: 11/27/2012 4:53:56 PM Received Date: 11/27/2012 4:54:24 PM From: WILLIFORD Dennis (AREVA) Created By: [email protected] Recipients: "BENNETT Kathy (AREVA)" <[email protected]> Tracking Status: None "DELANO Karen (AREVA)" <[email protected]> Tracking Status: None "LEIGHLITER John (AREVA)" <[email protected]> Tracking Status: None "ROMINE Judy (AREVA)" <[email protected]> Tracking Status: None "RYAN Tom (AREVA)" <[email protected]> Tracking Status: None "TOLLEY Tracey (AREVA)" <[email protected]> Tracking Status: None "VANCE Brian (AREVA)" <[email protected]> Tracking Status: None "WELLS Russell (AREVA)" <[email protected]> Tracking Status: None "NOXON David (AREVA)" <[email protected]> Tracking Status: None "RITCHEY Calvin (AREVA)" <[email protected]> Tracking Status: None "SAWYER Ogden (AREVA)" <[email protected]> Tracking Status: None "Ford, Tanya" <[email protected]> Tracking Status: None "Snyder, Amy" <[email protected]> Tracking Status: None Post Office: auscharmx02.adom.ad.corp Files Size Date & Time MESSAGE 43903 11/27/2012 4:54:24 PM RAI 349 Question 19-335 Response US EPR DC - DRAFT.pdf 2924901 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

Response to

Request for Additional Information No. 349, Question 19-335

01/26/2010

U. S. EPR Standard Design Certification AREVA NP Inc.

Docket No. 52-020 SRP Section: 19 - Probabilistic Risk Assessment and Severe Accident Evaluation

Application Section: FSAR Chapter 19

QUESTIONS for PRA Licensing, Operations Support and Maintenance Branch 2 (ESBWR/ABWR Projects) (SPLB)

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ndndSPLB) SPL

AREVA NP Inc.

Response to Request for Additional Information No. 349, Question 19-335 U.S. EPR Design Certification Application Page 2 of 12

Question 19-335:

OPEN ITEM Follow-up to RAI 133, Question 19-233 This was a follow-up to Question 19-84e. The response shows a calculation of likelihood of multiple Steam Generator Tube Rupture (SGTR) using a Poisson distribution due to random flaws in the tubes under creep-induced conditions. The analysis does not treat/consider the potential implication of failure propagation due to the continued heat-up of the steam generator tubes, after the initial tube failure. Natural circulation and steam generator tube heat-up is expected to continue well beyond the failure of a single tube. Therefore, the analysis of the calculated failure likelihoods is incomplete.

The calculated fission product releases to the environment for the single and multiple tube failure based on MAAP results are low. In comparison to the recent NRC MELCOR calculations for a single double-ended induced-SGTR scenario, the MAAP results cited in AREVA response, are about 50% too low. One reason is the termination of MAAP calculations after 24 hours, thus limiting the releases due to revaporization. These differences are significant and need to be reconciled.

a. Please revise the analysis to reflect the potential impact of continued heatup of the steam generator tubes, and determine at what level of failure (number of tubes), RCS depressurization occurs, terminating additional tube failures.

b. Please extend the present source term calculations to at least 48 hours, and report the impact on fission product releases and severe accident risk for U.S. EPR.

Response to Question 19-335

Response to Question 19-335(a):

The analysis presented in RAI 133, Supplement 2, Response to Question 19-233 has been extended to investigate the continued heatup of the steam generator (SG) tubes following the initial rupture. This analysis focuses on the potential for multiple tube failures as a result of this heatup.

An SG experiencing creep induced tube rupture will continue to heat up after the initial rupture, with a sustained high differential pressure across the tubes. The heat up of the tubes is driven by the enhanced flow of hot gases through the existing SG break.

A number of modular accident analysis program (MAAP) runs have been performed with an increased number of SG tube failures. Figure 19-335-1 shows the primary system pressure for a single and multiple SGTRs; 1, 10, 20, 30, 50 and 100. Figure 19-335-2 shows the maximum wall temperature for SG tubes as a function of time after a given number of tube ruptures.

After the initial heat up, the drop in the wall temperature of the tubes is immediate and significant for greater than or equal to 20 ruptured tubes, indicating that the tubes are adequately cooled down, therefore precluding additional ruptures.

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AREVA NP Inc.


Figures 19-335-1 and 19-335-2 show that adequate depressurization and cooldown of the SG tubes is reached with a break area equivalent to the rupture of a maximum of 20 tubes, assuming that no induced hot leg rupture (IHLR) occurs. If IHLR occurs at any time after the initial tube rupture, additional SGTRs will be precluded due to the rapid and complete depressurization of the primary system leading to a stress relief across the tubes and their cool down.

Evaluation of Multiple Steam Generator Tube Failures Timings:

A cascade of multiple SG tube failures could be arrested as a result of:

� The occurrence of IHLR at anytime during the transient scenario.

� A rapid rupture of a sufficient number of SG tubes to achieve adequate cool down and pressure relief across the tubes.

For high pressure accident scenarios, the likelihood of the creep IHLR occurrence is significantly higher than the creep induced steam generator tube rupture. The phenomenon of IHLR has been extensively discussed in RAI 6, Supplement 1, Response to Question 19-079 and the probabilities of piping failure due to creep induced ruptures have been summarized in Table 19-79-6. The occurrence of IHLR leads to an immediate depressurization of the primary system, subsequently precluding any further steam generator tube ruptures.

The timing of IHLR relative to additional SG tube ruptures has been analyzed for 1, 10 and 20 tube ruptures. These cases have been selected based on the earlier conclusion that multiple SGTRs involving more than 20 tubes were not credible because of the rapid cooldown of the tubes.

The analysis is focused on the timeframe following the first tube rupture. Using the temperature and pressure histories after the initial failure from MAAP and the Larson-Miller correlation (Equations 1 and 2), the timing of additional steam SGTRs was evaluated.

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AREVA NP Inc.


P� : pressure difference across the SG tube wall (Pa)

r : SG tube radius (m)

x : SG wall thickness (m)

fitfit bm , are fitting parameters for Inconel 690 and they are -0.1777 and 25.4198 respectively

The rupture times calculated and shown in Figure 19-335-3 are from the point where the first rupture is predicted forward. The X-axis represents the real time in hours while the Y-axis represents the theoretical time of tube ruptures (initial and subsequent ruptures) calculated using the Larson Miller correlation. Note that a linear plot indicating that the calculated rupture time is equal to the real time is shown in Figure 19-335-3. The intersection of this linear plot and the calculated rupture time indicates the occurrence of a predicted rupture. The times of hot leg ruptures predicted by MAAP are also shown in the same figure. They are indicated by dots along the linear plot and their values shall be read on the X-axis since they represent real events. The following was concluded from the plots:

� Case of one induced SGTR (Green plot on Figure 19-335-3): Additional failures are predicted within a few minutes of the initial tube failure. The hot leg rupture is predicted to occur much later than the next tube failures; therefore, it cannot be credited to stop further tube ruptures.

� Case of 10 induced SGTR (Blue plot on Figure 19-335-3): No additional failure time is calculated prior to the occurrence of hot leg rupture. The pressure and temperature values at any given time after the initial rupture are not sufficient to sustain a cascade of additional tube failures.

� Case of 20 induced SGTR (Magenta plot on Figure 19-335-3): In this case, the hot leg rupture is predicted to occur before any additional tube rupture thus terminating the cascade of tube ruptures.

Note that the additional tube rupture shown in Figure 19-335-3 for the case of 20 induced SGTR is a result of not modeling the IHLR when predicted by MAAP. If the IHLR was modeled, the pressure and temperature profiles would have been lower and thus no additional ruptures would have been calculated. The purpose of preventing the IHLR was to model harsher conditions on the SG tubes.

It can be concluded from these results that the maximum number of SGTRs from the heatup initiated by the first rupture will be no greater than 10 tubes.

Table 19-335-1 summarizes the source term resulting from a single tube rupture and 10 tube ruptures at 48 hours. Based on the conclusions of this analysis, these two cases are considered to adequately bound the range of expected multiple SGTRs.

It is noted that the MAAP runs used in this analysis are based on the latest revision of the U.S. EPR MAAP model and the results are slightly different from those presented in the RAI 133 Supplement 2, Response to Question 19-233.

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Response to Question 19-335(b):

Figure 19-335-4 shows the original MAAP4 results of fission product releases for the single induced-SGTR scenario extended out to 48 hours. These releases are approximately half of the values determined by the NRC MELCOR analysis with no appreciable change in the time period from 24 to 48 hours for the volatile fission products, data provided in Table 19-335-2.

For the first 24 hours, the differences in the releases were traced to the timing of the occurrence of the steam generator tube rupture. For MELCOR (based on the NRC provided information for the MELCOR analysis), the rupture occurs prior to significant core degradation (release of fission products into the RCS). In other words, the SGTR was assumed to be the initiating event.

In the reported MAAP analysis, the SGTR is assumed to occur after significant core degradation (after significant release of fission products to the RCS), allowing for time for significant plate-out of fission products on the walls of the RCS to occur. This delay in SGTR in the MAAP analysis allows for a reduction in the availability of fission products to be released (i.e., in the MAAP analysis, the SGTR occurs when there is less airborne fission products in the RCS). It should be noted that we are in the process of revising the source term documentation including a revision to the MAAP model. Preliminary results of the new analysis show substantial earlier SGTR failure, i.e., prior to major fission product release from the fuel. We are also incorporating the provision for SGTR to occur as an initiating event, in addition to previous scenario of only a thermal-induced SGTR.

For the response to this particular question, and to mimic the MELCOR analysis as close as possible, an early SGTR failure was modeled in MAAP by a forcing function to create a steam generator tube rupture at 3000 seconds. For at least the first 24 hours, the revised MAAP4 model predicted fission product releases are well within the NRC MELCOR calculated values; see Table 19-335-3. For the next 24 hours, out to 48 hours, only the noble gases continued to agree, confirming that the volume versus break flow is similar between the MELCOR and MAAP4 models. For the MAAP4 model, no appreciable change in volatile fission product release was noted for the subsequent time period (24 to 48 hours); see Figure 19-335-5.

This lack of subsequent release can be traced to the relocation of the deposited fission products out of the primary circuit apparent in the MAAP4 calculation (see Figure 19-335-6), resulting in a relatively low concentration of volatile fission products (e.g., cesium and iodine) in the primary system; and, ultimately, a lower decay heat.

A similar reduction can be noted in the MELCOR calculations for CsI and Te, see Figure 19-335-7, but not for Cs, a species that can be either in the form of CsOH or Cs2MoO4. Assuming that the gas flow through the failed tube is similar (based on the noble gas release) between MAAP and MELCOR, the differences for Iodine and Te (which have similar vapor pressure calculations) are most probably the result of higher gas temperatures being predicted by MAAP within the RCS, relocating these fission products to the containment via the small break.

Further review of the NRC MELCOR’s result for RCS retention during the first 24 hours, Figure 19-335-7, reveals that the Cs within the RCS deposits extremely rapidly and remains on the RCS surfaces as opposed to either Iodine or Te, as noted by the lack of a dip in the fission product fraction. Again, this trend is significantly different than that predicted by MAAP4 (see

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Figure 19-335-6). Within MAAP4, approximately 30% of the Cs is retained within the Primary System with almost 60% being predicted to be retained by MELCOR. This predication agrees well with those discussed in (Reference 1) Jason Schaperow’s paper “Investigation of a Steam Generator Tube Rupture Sequence Using VICTORIA,” which shows MELCOR having approximately 80% retention of Cs in the RCS as opposed to MAAP’s 32 % retention for Cs.

For both MAAP and MELCOR after the initial spike of fission products in the primary circuit, the RCS continues to depressurize, transferring fission products from the RCS to the containment via the 2” line break and to the environment via the steam generator tube rupture. This removal is from two sources – suspended (airborne) and vaporization of deposited fission products on the RCS walls (including the steam generator tubes). For suspended fission products, the removal is via the typical flow paradigm. For deposited material, the removal involves the vaporization and subsequent transport of fission products from the primary system.

For MELCOR, the condensation and evaporation from the heat structures (RCS Surfaces) are controlled by the vapor pressure of the individual fission product classes. This is based on the statement in Section 2.5.2 of the MELCOR’s RN Package Reference Manual:

In addition to being used to determine the amount of each material class present as aerosol and as fission product vapor, the vapor pressure is used in the model for condensation and evaporation to determine the saturation concentrations, Ci

S, calculated from the perfect gas law,…

An analogous paradigm also exists within MAAP. Therefore the rate of vaporization off of the primary system heat structure calculated by MAAP4 and MELCOR is dependent upon the vapor pressure algorithm within the two codes, which is based on the temperature of the surrounding gas and structure. In general, MELCOR and MAAP share almost the exact parameters for the algorithm used in determining the vapor pressure, specifically for Class 16 (CsI) in MELCOR and Class 2 (iodine) in MAAP. The most significant difference is that MELCOR contains a new class, Cs2MoO4, which is not available in MAAP. This is a new class developed post release of MELCOR 1.8.6 and has much lower vapor pressure than CsOH. This new class is modeled via the input file for MELCOR. This input file was not available for review, and thus could not be compared to the values of vapor pressure for CsOH used in the MAAP cases supporting the US EPR SGTR analysis.

In retrospect, the lack of additional release after 24 hours in the MAAP4 models was traced to the small amount of fission product plate-out that MAAP4 is predicting for the primary circuit; see Figure 19-335-6. For Cs, the values shown in Figure 19-335-6 are less than a quarter of the values predicted by MELCOR, Figure 19-335-7. For Te, the values are only a fraction of the values reported by MELCOR. In general, it appears the MELCOR is predicting sufficiently less revaporization of material within the primary circuit than MAAP4 (and associated decay heat) during the initial 24 hours.

Subsequent to 24 hours, it is these deposited volatile fission products with their increased decay heat that constitute the principle increase in the non-Noble Gas source terms through the failed steam generator tubes as a result of revaporization of deposited material on the RCS surfaces as predicted by MELCOR.

The revaporization phenomenon of Cs including the high concentration of Cs2MoO4 is driven by high temperatures described in Reference 2, coming from the decay heat of the deposited

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AREVA NP Inc.


fission products on the RCS surfaces. From the MAAP input deck, CsOH contains about 3 % of the decay energy; therefore, MAAP predicts only about 0.9% (30% retention of the Cs in the primary system multiplied by 3% power fraction) of decay power is associated with the CsOH remaining on the RCS surfaces after the initial release. Within MELCOR, this percentage increases to almost 2% (assuming the same power fraction with an 80% retention) of the decay power, a factor of more than twice. Thus, MAAP4 does not predict the high temperatures in the RCS necessary for revaporization of Cs (i.e., 400 to 500oC per Reference 2) after the initial 24 hours as a result of lower mass of fission products (and associated decay heat) remaining on the RCS surfaces.

In addition, the area over reach the deposition occurred may be dramatically different between the two codes. MAAP inherently allows for natural circulation within the hot leg; however, MELCOR does not. Therefore, to allow for natural circulation, the MELCOR user must divide the RCS piping (top half and bottom of the hot leg) in half with one half being the flow to the steam generator and the other half being the return. The end result is that the deposition area associated with the MELCOR model may be significantly smaller than that available in the MAAP model, concentrating the deposited material in a smaller area.

Additionally, plant operators for beyond 24 hours will be responding to event consequences through Severe Accident Management Guidelines (SAMG) as outlined in Section 3.10 of the Technical Report, “The Operating Strategies for Severe Accident Methodology for the U.S. EPR,” and should have recovered at least partial operation of the plant (including containment cooling, which was conservatively neglected in these analyses). Several strategies for controlling the release of fission products through a failed steam generator tube can be envisioned and will be evaluated through AREVA’s Operating Strategies for Severe Accidents (OSSA), used in the development of U.S. EPR SAMGs.

Given that the results from the revised MAAP4 analysis are in strong agreement with MELCOR for the first 24 hours (assuming the early MELCOR predicted time of SGTR) and the uncertainty regarding the event progression beyond 24 hours, specifically with regards to the deposition, and the revaporization of Cs and I in the RCS piping and steam generators (which occurs at relatively high temperatures within the primary circuit); it is concluded that MAAP4 is providing adequate release estimates for the postulated SGTR.

RAI References:

1. Bixler, N. E., C. M. Erickson, and J. H. Schaperow, “Investigation of a Steam Generator Tube Rupture Sequence using VICTORIA”

2. Herranz, L. E., et.al., “Progress in Understanding Key Aerosol Issues”

3. ANP-10314 R0, “The Operating Strategies for Severe Accidents Methodology for the U.S. EPR”, Technical Report.

FSAR Impact:

The U.S. EPR FSAR will not be changed as a result of this question.

DRAFT

ne hne hresult is tresu

maller than thamaller thsmaller area. smaller area.

ll be responding to evell be responding to evs (SAMG) as outlined i(SAMG) as

or Severe Accident Metere Accpartial operation of the ppartial operation o

cted in these analyses).d in these analysescts through a failed steough a failed ste

rough AREVA’s Operatrough AREVA’s Operatt of U.S. EPR SAMGs. t of U.S. EPR SA

he revised MAAP4 revised MAAP4 anaanauming the early MELCuming the ear OO

ogression beyond 24 hoogression beyond 2on of Cs and I in the RCon of Cs and I in the Reratures within the preratures within th

mates for the pomates for the p

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Table 19-335-1—Source Term from a Single and Multiple Steam Generator Tube Ruptures

Source Term

(at 48 hours)

XE/KR

Group 1

I

Group 2

Cs

Group 6

Te (Sb)

Group 10

Sr

Group 4

Ru

Group 5

La

Group 8

Ce

Group 9

Ba

Group 7

1 induced SGTR 16.3% 8.4% 8.6% 13.5% 1.3% 10% 0.05% 0.2% 6%

10 induced SGTR 69.5% 40.4% 44.1% 70.3% 9.7% 47% 0.3% 1.4% 28.3%

Average source term

(1, 10) induced SGTR

43% 24.4% 26.35% 41.9% 5.5% 28.5% 0.2% 0.8% 17.15%

Increase factor

compared

to 1 induced SGTR

2.6 2.9 3.1 3.1 4.2 2.9 4.0 4.0 2.9

Table 19-335-2—NRC MELCOR Radionuclide Release Results:

MELCOR 24 hours 48 hours

Noble Gases 23.0% 27.0% I 17.0% 27.0%

Cs 13.0% 17.0% Te 18.0% 24.5% Mo 0.6% 0.7% Ba 0.2% 0.2% Ru 0.2% 0.2%

Table 19-335-3—MAAP4 Predicted Fission Product Releases For NRC MELCOR Emulation Model

TIME Noble Gases Iodine Cs Te

Hours 24. 21.5% 16.8% 14.8% 14.5% 48. 27.6% 16.9% 14.8% 14.5%

DRAFT28.5% 028.5

FTT3.1 4.4.2 2.9 2 FTFTRARARAAFAFTT

—NRC MELCOR Rad—NRC MELCOR Ra

ME

Noble GasesGasI

CsCs

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Figure 19-335-1—Primary System Pressure for Multiple Steam Generator Tube Ruptures

Figure 19-335-2—Maximum Wall Temperature of Steam Generator Tube for Multiple Ruptures

DRAWall Temperature of SWall Temperatu

Ruptures ture

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Figure 19-335-3—Calculated Times of Additional ISGTR following; 1, 10, and 20 Tubes

Figure 19-335-4—Fission Product Releases for 48 Hours Following a

Single Induced-SGTR

DRA—Fission Product ReFission Product Re

Single InduSingle Indu

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Figure 19-335-5—MAAP4 Revised Fission Product Releases based on NRC MELCOR Emulation Model

Figure 19-335-6—MAAP4 Revised Primary Circuit Fission Product Fractions based on NRC MELCOR Emulation Model

DRAFMAAP4 Revised PrimaMAAP4 Revised P

based on NRC MELCbased on NRC MEL

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Figure 19-335-7—NRC MELCOR Primary Circuit Fission Product Fractions

DRAF

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