ML18193B024
| ML18193B024 | |
| Person / Time | |
|---|---|
| Issue date: | 06/19/2018 |
| From: | Charles Brown Advisory Committee on Reactor Safeguards |
| To: | |
| Brown C | |
| References | |
| NRC-3783 | |
| Download: ML18193B024 (169) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards APR 1400 Subcommittee Docket Number: (n/a)
Location: Rockville, Maryland Date: Tuesday, June 19, 2018 Work Order No.: NRC-3783 Pages 1-169 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +
7 APR1400 SUBCOMMITTEE 8 + + + + +
9 TUESDAY 10 JUNE 19, 2018 11 + + + + +
12 ROCKVILLE, MARYLAND 13 + + + + +
14 The Subcommittee met at the Nuclear 15 Regulatory Commission, Two White Flint North, Room 16 T2B1, 11545 Rockville Pike, at 1:00 p.m., Matthew 17 Sunseri, Chairman, presiding.
18 COMMITTEE MEMBERS:
19 MATTHEW SUNSERI, Chairman 20 RONALD G. BALLINGER, Member 21 CHARLES H. BROWN, JR. Member 22 MARGARET SZE-TAI Y. CHU, Member 23 MICHAEL L. CORRADINI, Member*
24 JOSE MARCH-LEUBA, Member 25 JOY L. REMPE, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 PETER RICCARDELLA, Member*
2 GORDON R. SKILLMAN, Member 3 DESIGNATED FEDERAL OFFICIAL:
4 CHRISTOPHER BROWN 5 ALSO PRESENT:
6 DAEGUEN AHN, WDCC/KHNP 7 TONY AHN, KHNP 8 NAN CHIEN, NRO 9 HYEONGSEOK EUN, KEPCO E&C 10 JAMES GILMER, NRO 11 RAJ GOEL, NRO 12 NICHOLAS HANSING, NRO 13 RAUL HERNANDEZ, NRO 14 DIANE JACKSON, NRO 15 REBECCA KARAS, NRO 16 JUNGHO KIM, KHNP 17 YEONG SU KIM, KEPCO E&C 18 YOUNGKI KIM, KEPCO E&C 19 THOMAS KOSHY, NRR 20 OLIVIER LAREYNIE, NRO 21 TUAN LE, NRO 22 JOOHEE LEE, KEPCO E&C 23 SANGWON LEE, KHNP and KEPCO E&C 24 SEUNG WOOK LEE, KEPCO E&C 25 MARK LINTZ, NRO NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 SHANLAI LU, NRO 2 TIM LUPOLD, NRO 3 GREGORY MAKAR, NRO 4 JILL MONAHAN, Westinghouse 5 WARREN ODESS-GILLETT, Westinghouse*
6 SHEILA RAY, NRR 7 CAYETANO (TANNY) SANTOS, NRO 8 THOMAS SCARBROUGH, NRO 9 ROB SISK, Westinghouse 10 MATTHEW SMITH, Westinghouse 11 JEUNGHYO SONG, KHNP 12 ANGELO STUBBS, NRO 13 ED STUTZCAGE, NRO 14 ROBERT SWEENEY, WDCC/AECOM 15 GETACHEW TESFAYE, NRO 16 MATT THOMAS, NRO 17 BOYCE TRAVIS, NRO 18 JESSICA UMANA, NRO 19 ANDREA D. VEIL, Executive Director, ACRS 20 HANRY WAGAGE, NRO 21 WILLIAM WARD, NRO 22 ANDREW YESHNIK, NRO 23 SUNGHO YOU, KEPCO E&C 24 DEANNA ZHANG, NRO 25 *Present via telephone NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 C-O-N-T-E-N-T-S 2 Opening Remarks and Objectives 3 by Matthew Sunseri . . . . . . . . . . . . 5 4 Chapter 13, Conduct of Operation 5 by Jungho Kim, KHNP . . . . . . . . . . . . 9 6 Chapter 13, Conduct of Operation 7 by NRC . . . . . . . . . . . . . . . . . . 12 8 Chapter 14, Section 14.3 ITAAC 9 by Sangwon Lee, KHNP . . . . . . . . . . . 18 10 Chapter 14, Section 14.3, ITAAC 11 by NRC . . . . . . . . . . . . . . . . . . 28 12 Chapter 6, Engineered Safety Features 13 by Jeunghyo Song, KHNP . . . . . . . . . . 58 14 Chapter 6, Engineered Safety Features 15 by NRC . . . . . . . . . . . . . . . . . . 64 16 RAI Table Discussion 17 by Bill Ward . . . . . . . . . . . . . . . 87 18 Adjourn . . . . . . . . . . . . . . . . . . . . 101 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 P R O C E E D I N G S 2 (12:59 p.m.)
3 CHAIR SUNSERI: Good afternoon. Let's 4 call the meeting to order. This is a meeting of the 5 APR1400 Subcommittee of the Advisory Committee on 6 Reactor Safeguards.
7 I am Matt Sunseri, Co-Chairman of the 8 APR1400 Subcommittee. ACRS Members in attendance, 9 they are Ron Ballinger, Joy Rempe, Jose March-Leuba, 10 Dick Skillman, Margaret Chu and I guess that's it.
11 We have Pete Riccardella on the phone line 12 as well as Mike Corradini. Christopher Brown is the 13 Designated Federal Official for this meeting.
14 The purpose of today's meeting is for the 15 Subcommittee to receive an information briefing from 16 Korea Electric Power Corporation, Korea Hydro and 17 Nuclear Power Corporation and the NRC staff regarding 18 the design certification application for the APR1400, 19 mainly Chapter 6: Engineered Safety Features, Chapter 20 13: Conduct of Operations, Chapter 14.3:
21 Inspections, Tests, Analyses and Acceptance Criteria.
22 The ACRS was established by statute and is 23 governed by the Federal Advisory Committee Act. That 24 means that the Committee can only speak through its 25 published letter reports.
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6 1 Since this is a Subcommittee meeting any 2 feedback that you receive today is that of individual 3 members and not reflective of the ACRS as a full body.
4 We hold the meeting to gather information to support 5 our deliberations.
6 Interested parties who wish to provide 7 comments can contact our offices requesting time after 8 the meeting announcement is published in the Federal 9 Register. That said, we set aside ten minute for spur 10 of the moment comments from members of the public 11 attending or listening in on our meetings.
12 Written comments are also welcome. And we 13 have not received any requests to make a statement 14 from the public for this part of the meeting.
15 The ACRS section of the U.S. NRC public 16 website providers our charter, bylaws, letter reports 17 and full transcripts of all full and Subcommittee 18 meetings including slides and presentations. The 19 rules for today's participation, for participation in 20 today's meeting, excuse me, were announced in the 21 Federal Register on Monday, June 18, 2018.
22 The meeting was announced as open and 23 closed to the public meeting. This means that the 24 Chairman can close the meeting as needed to protect 25 proprietary information of KHNP or its vendors.
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7 1 Now it's my understanding we do not have 2 any proprietary information planned to be presented as 3 the final agenda came together, as the final 4 presentations came together. However, if our 5 questions lead to such information we ask that the 6 staff or the applicant advise us and we can close the 7 meeting to deal with the question.
8 A transcript of the meeting is being kept 9 and will be made available as stated in the Federal 10 Register notice. Therefore, we request that 11 participants in this meeting use the microphone 12 located throughout the meeting room when addressing 13 the Subcommittee.
14 Participants should first identify 15 themselves and speak with sufficient clarity and 16 volume so that they can be readily heard. We have a 17 bridge line established for interested members of the 18 public to listen in.
19 To minimize disturbance the public line 20 will be kept in a listen in only mode. The public 21 will have the opportunity to make a statement or 22 provide comments at a designated time toward the end 23 of the meeting.
24 At this point I request that meeting 25 attendees and participants silence their cell phones NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 and other electronic devices. As it's anticipated 2 that this is the last Subcommittee prior to a full 3 Committee review of the APR1400 application for design 4 certification, which is scheduled, which that full 5 Committee is scheduled on July 11th from 1:00 to 4:00 6 p.m. local time, we look forward to wrapping up any of 7 our Subcommittee comments and questions that we may 8 have open.
9 So without any additional preliminary 10 comments I asked Bill Ward, NRO Senior Project Manager 11 to introduce the presenters and any remarks you want 12 to make, Bill.
13 MR. WARD: Thank you, yes. I know that 14 the NRC staff and KHNP are pleased to be here again 15 for what is the last scheduled Subcommittee meeting.
16 We believe our presentations and answering your 17 questions today will satisfy all the need for any more 18 Subcommittee meetings.
19 And we appreciate the Committee's 20 flexibility in all the scheduling we've had going on 21 this summer as we work to meet the 42 month goal we 22 have for the project, Rob.
23 MR. SISK: Rob Sisk, Westinghouse. I'll 24 echo Bill's comments. We certainly are excited and 25 look forward to the presentation of the last three NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 chapters, 6, 13, 14.3 to the Subcommittee and 2 appreciate the staff's or the ACRS flexibility over 3 the last few months to get these chapter reviews.
4 So we do thank you on that. As mentioned 5 earlier, our presentations are listed as non-6 proprietary. But we will be monitoring carefully or 7 paying close attention to questions and if any 8 proprietary information comes up we'll request that we 9 hold that until the closed session.
10 But other than that we can proceed, I 11 think, as planned. And without further ado I would 12 introduce Jungho Kim to begin Chapter 13.
13 CHAIR SUNSERI: And let me just jump in 14 here. We were joined by Charles Brown as a Member.
15 So that completes the attendance. Please go ahead, 16 sir.
17 MR. KIM: Yes, good afternoon, everybody.
18 I'm Jungho Kim from KHNP working for APR1400 design 19 certification licensing project management team.
20 Sitting left to me is Sangwon Lee from KHNP 21 responsible for Chapter 13 and 14.
22 She will help answer any questions ACRS 23 members may ask. Okay, I make presentation about 24 Chapter 13, Conduct of Operation. Now in this 25 presentation I talk about overview of Chapter 13 and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 current status.
2 Acronyms is attached to the back of the 3 slide for your information, next. With regard to 4 conduct of operation KHNP submitted two documents.
5 One is they issued a Tier 2 Chapter 13, Conduct of 6 Operations. And the other one is in addition to Tier 7 2.
8 Besides them there are a lot of, there are 9 several other chapters and technical report which have 10 information supporting the conduct of operation. KHNP 11 listed the 52 RAI questions from the staff for the 12 chapter review and responded to all of the questions.
13 Those responses have been accepted by, I'm 14 sorry, excuse me. KHNP responded to all RAI response 15 during Page 2 and previous pages and those responses 16 have been accepted by NRC staff. So now there are no 17 more open items left.
18 Chapter 13 consists of seven sections. I 19 briefly explain about major contents in each section.
20 13.1, Organizational Structure of the Applicant. KHNP 21 provided 11 COL items. Accordingly COL items COL 22 applicant will develop specific management, technical 23 support, operating organization and qualification of 24 nuclear power plant personnel.
25 Second, training. According to KHNP COL NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 item KHNP provided plant staff training program will 2 be developed in accordance with the NEI 06-13A 3 "Template for an Industry Training Program 4 Description" by COL applicant.
5 Next, emergency planning. KHNP provided 6 emergency plan pictures considered in design basis 7 such as technical support center, operations support 8 center, emergency operations facility. COL applicant 9 based on those emergency planning pictures, COL 10 applicant will develop site specific emergency 11 planning.
12 13.4, Operational Program Implementation.
13 According to COL item the COL applicant will implement 14 operational program per SECY 05-197. 13.5, Plant 15 Procedure. KHNP provided APR1400 Emergency Operating 16 Guidelines to support plant specific guidelines.
17 So COL applicant will develop their own 18 plant specific guidelines based on the KHNP, APR1400 19 Emergency Operating Guidelines. Next, physical 20 security.
21 I'm not going to talk about this for 22 security reason. And lastly, Fitness for Duty.
23 Fitness for Duty program will be developed by COL 24 applicant.
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12 1 with no open items. So KHNP continues to monitor 2 Chapter 13 to assure any component changes are 3 addressed. This concludes my presentation. Any 4 questions?
5 CHAIR SUNSERI: Any questions from 6 Members? All right, thank you. And I guess we now 7 transition over to staff.
8 (Off the record comments.)
9 CHAIR SUNSERI: Go ahead, Bill.
10 MR. WARD: Thank you. My name is William 11 Ward. I'm the lead project manager for this. But I 12 was also the Chapter 13 project manager about halfway 13 through the project.
14 So I will be giving the presentation here.
15 A couple of notes real quick. First of all the, as 16 noted in KHNP's presentation it mentioned chapters or 17 sections 13.6 and 13.7.
18 But those sections were not reviewed by 19 ACRS so they're not presented as part of my 20 presentation. Also there were quite a number of RAI 21 questions in 13.6. So the count of RAI questions may 22 not be the same as what you saw because they counted 23 13.6 as well.
24 So in, also before I get started I'll say 25 that in, diverging slightly from our approach to a lot NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 of the other chapters I kept a lot of the stuff from 2 the Phase 3 ACRS meeting in here because I noticed in 3 various discussions there were times where things came 4 up where people were talking about operational 5 programs or other thing in emergency planning.
6 And so I left it all in here in case the 7 Committee had any questions that they had deferred 8 from prior Subcommittee meetings related to those 9 topics. So this is the opportunity if they're still 10 out there.
11 CHAIR SUNSERI: You're a risk taker, 12 aren't you?
13 MR. WARD: I'm not asking. I'm just 14 saying, so Sorindra Rora (phonetic) would be in the 15 audience but he's out of town this week. That's the 16 way it's scheduled. Eddie Robinson is in the audience 17 to help answer any questions on 13.3 which is 18 Emergency Planning.
19 And these are the five sections that we 20 cover for ACRS. A little bit more description than 21 what KHNP gave a minute ago. The first one, 22 organizational structure, I'm not going to read the 23 entire slide.
24 But this one is the overall structure and 25 organization of the applicant's or the COL's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 1 management and technical support organizations. As is 2 the case with most of Chapter 13, it's really the DC 3 applicant passing on what the expectations are to the 4 COL.
5 So the key to Chapter 13 in a lot of cases 6 are the COL items clear and do they cover the 7 requirements that we have for what needs to be passed 8 on to the COL applicant? So in this case we were 9 Section 13.1.
10 There were 11 COL items and we found that 11 they were appropriately identified and sufficiently 12 addressed the required information. 13.2 is 13 specifically about training discussing the size, 14 ability and technical competence of the staff to 15 operate the facility.
16 In this case there were six COL items.
17 The COL items do reference some NEI guidance for how 18 to set up a training program and they appropriately 19 reference that. There were some issues early on about 20 how it was referenced.
21 But those were resolved and there's no 22 open items on that. So we had no issue with the six 23 COL items in this area.
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15 1 emergency planning, a lot of it is up to the COL 2 applicant. The requirements are that they provide the 3 facilities that only a DC can design like the 4 technical support center and the operational support 5 center.
6 Those are things that are best designed by 7 the DC and not left up to the COL to do. Beyond that 8 most of it is left to the COL to handle the emergency 9 planning, everything else about the structure, any 10 other structures they need are up to the COL to 11 design.
12 So there were six COL items that covered 13 this area. And the review found that the TSC provided 14 adequate space, data retrieval capabilities and 15 dedicated communications equipment.
16 The same was found with the operational 17 support center. We also list in here SRP interface 18 areas because there are other areas which address 19 aspects of emergency planning but are not covered in 20 Chapter 13.
21 So we provided a list here. The MCR 22 personnel in emergency, section 6.4. Data retrieval 23 is in the digital I&C chapter. The PASS system, Post 24 Accident Sampling System is addressed in Chapter 9.
25 Communications is addressed in Chapter 9, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 decontamination in Chapter 12 which is radiological 2 protection. Dose analysis is covered in Chapter 15 3 which is the severe accidents analysis. And then 4 beyond design basis external events is 19.3 and there 5 was discussion about, you know, the Fukushima support 6 that type of accident.
7 That's covered in 19.3. It's not covered 8 in Chapter 13.3.
9 CHAIR SUNSERI: So before you start the 10 next topic I know that the Members have a lot of 11 questions about the TSC access times, things like 12 that. So I would just like to pause and ask the 13 Members if all your questions have been resolved.
14 Do you have any other thoughts about this 15 topic, this chapter or this section, I'm sorry? All 16 right, good. All right, Bill, go ahead.
17 MR. WARD: You realize there's a typo in 18 the conclusion. It should have been 13.3. So again, 19 there were six COL items. We found those adequate.
20 13.4, Operational Programs. Again, this 21 one is just COL items. And they provided the required 22 COL items in accordance with the NUREG and other 23 requirements.
24 13.5 is on the creation of plant 25 procedures. I rewrote this one a little bit to follow NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 1 the format that we had. Again, the responsibility 2 resides with the COL application referencing the 3 design.
4 And it's up to the design certification to 5 provide necessary information to support the COL in 6 designing things. Among those are the generic 7 technical guidelines otherwise referred to as EOGs.
8 And they're used by the COL to develop 9 plant specific technical guidelines. We reviewed the 10 EOGs and found they were satisfactory. The COL items 11 were found to be satisfactory.
12 The findings are provided here about the 13 EOGs that, they're based on the Combustion Engineering 14 Owners' Group GTGs. They have the right format.
15 The final finding errors about the 16 transient analysis, those were provided in a KEPCO 17 report and we reviewed those and found those 18 acceptable for use for the development of the APR1400 19 EOGs.
20 In the conclusion we have six of the seven 21 COL items in 13.5 are acceptable. The last COL item 22 there seems to have been a printing issue. There were 23 some extraneous information that was put in there.
24 There was also a COL item that was deleted 25 that got left behind. So we grouped it in with 13.57.
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18 1 13.58 was created and then deleted in the process of 2 editing in DCD. So we're waiting for that aspect to 3 be cleared up in Rev 3.
4 So we actually have a pair of confirmatory 5 actions related to this. So that's all we have left 6 in 13.5.
7 CHAIR SUNSERI: So I'll jump in once again 8 and remind us that Members had fairly substantial 9 comments on the EOGs, in particular the translation 10 from a kind of what I'll call an analog-based plant to 11 a digital-based plant and was there sufficient 12 information going to be provided for those EOGs to 13 facilitate that kind of transition in human 14 performance.
15 So, Members, any additional questions or 16 comments at this stage? All right, thank you.
17 MR. WARD: That concludes the 18 presentation. Thank you.
19 CHAIR SUNSERI: All right, any other 20 questions for the staff regarding conduct of 21 operations? All right. We'll transition back to 22 KEPCO KHNP for Chapter 14.3. Great, whenever you're 23 ready.
24 MR. LEE: Good afternoon, everyone. My 25 name is SangWon Lee and I work for Korea Hydro and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 Nuclear Power Corporation as a technical manager for 2 primary system design.
3 Today I will talk about Chapter 14.3, 4 Inspections, Tests, Analyses and Acceptance Criteria.
5 Next please. This is an outline. I will briefly 6 introduce Chapter 14.3 and a summary of the major 7 responses and finalized with the current status.
8 Chapter 14 has three sections. 14.1 and 9 14.2, initial plant test program is already presented 10 in earlier this year. And today I will focus on the 11 14.3 ITAAC.
12 As you can see in the slide there are six 13 subsections. Most of the content is Subsection 2, 14 design description and ITAACs. Next please.
15 A list of submitted documents is all the 16 Tier 2 material and the Tier 1 materials. Tier 1 17 material is very closely related to all of the Tier 2 18 materials.
19 There are 91 RAI questions was issued.
20 And as you can see in here the big chapter is in 21 instrumentations and control and radiation protection 22 and electric systems and physical securities.
23 As of now current APR1400 ITAAC has put 24 out 13 sections and 1,202 individual ITAAC is 25 identified as of right now. And most of the portion NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 1 is the reactor systems and I&C and electric power and 2 plant systems and containment system.
3 Next please. From this slide I will 4 briefly discuss the major responses for the RAI. The 5 first one is ITAAC wording changes. ITAAC wording 6 change is based on the NRC guidance and to resolve the 7 discrepancy and provide a technical clarification.
8 We revised applicable section based on the 9 suggested ITAAC word changes or alternative language 10 here. So we think that the discrepancies were 11 corrected to ensure overall consistency.
12 Next please. This slide shows the 13 structural information on seismic activity structure.
14 NRC requested more, additional information such as the 15 principal codes and standards with addition of key 16 dimensions and tolerance and critical section and 17 design attribute.
18 And the seismic analysis method and in-19 structure response spectra for our key location. All 20 of these things is added to the current ITAAC. Also 21 in key material and also in Q.03.08 is newly added for 22 tolerance acceptance criteria. I missed it.
23 The issue is the dedication of the 24 communication independence in as-built ESF-CCS. So 25 true to that independence are achieved using key NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 1 communication features for three listed below.
2 Use of dual port memory and separation 3 between functional and communication processor and the 4 pre-defined data set and protocol and error checking 5 code. And related interfaces the PPS and ESF-CCS for 6 safety division.
7 ESCM and IFPD for safety and non-safety 8 interface. And the issue is priority logic for manual 9 control and automatic safety systems for the ESF-CCS 10 loop controller. There are three different signals 11 exist.
12 We make a high priority as ESF actuation 13 signal from PPS and low priority is ESCM manual 14 command signal and minimum inventory switch manual 15 command signals. CPU load restriction in CPCS. This 16 needs to be in the ITAAC.
17 So we add 15 restrictions in the ITAAC 18 2.5.1.1 for CPC load to make it lower than the 75 19 percent of processor load. And this issue --
20 MEMBER BROWN: Excuse me, could you go 21 backwards one? Just for the Committee's understanding 22 this was a major issue during the discussions. And 23 these were discussed in those previous meetings and 24 they have, since they've been incorporated it seems to 25 me it's a reasonable resolution for this.
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22 1 So I just wanted to make sure we were 2 paying attention. If you could go back one more slide 3 also I would appreciate it.
4 This was not my comment. This was John's 5 comment during the meeting. I can't speak for him 6 obviously since he's not here anymore. But and when 7 you look at, I didn't have any problem with the 8 priority logic.
9 And so they've incorporated this from this 10 standpoint and I think that's satisfactory also.
11 CHAIR SUNSERI: All right. Thank you, 12 Charlie.
13 MEMBER BROWN: Okay, sorry to backtrack.
14 My brain was about three slides behind you guys. You 15 can go on, thank you.
16 CHAIR SUNSERI: So were you processing 17 between 70 and 75 percent?
18 MEMBER BROWN: I'm not even sure I was at 19 70 percent much less, I'm probably still down at 20 around 50. But I'm working on that. I'm awake.
21 That's the high point to this whole meeting. Thank 22 you.
23 CHAIR SUNSERI: Please continue.
24 MR. LEE: This issue to clarify the 25 diversity between the diverse actuation system and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 PPS/ESF-CCS. The resolution is that ITAAC is revised 2 to confirm the below three items as to how we use the 3 PRC versus PGA.
4 And the software diversity will be made by 5 different programming tool used. And the human 6 diversity we used, we have different independent 7 development design team for the design group.
8 MEMBER BROWN: I have a comment here just 9 go backwards. That is okay. I had a question back 10 during the meeting. I'm trying to recall it and I 11 couldn't find my notes so I apologize for that.
12 But it was in terms of your final 13 verification of independence most everything worked 14 just fine but there was no explicit statement of 15 ensuring that the design actually complied with the no 16 communications up to the voting (phonetic) units.
17 There was no, the architecture is very, very clear.
18 No problem with the architecture, very 19 defensive. Not a problem. But I did ask the question 20 relative to in one of the meetings and it was in the 21 Tier 1, Section 2.5 question I think. It might have 22 been a Chapter, whatever chapter this is, 14 question.
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24 1 division to division. I don't know if anything was 2 done with that comment or not.
3 That was a comment I had and I didn't see 4 any, didn't see that addressed anywhere. So I suspect 5 everything is okay.
6 It's just it was a question of did 7 somebody confirm that the actual wiring there is no, 8 there are no physical connections division to 9 division, you know, as you go through everything prior 10 to the feeds to the voting units.
11 That's the way it's supposed to be. It's 12 an eyeball check, nothing technical about it. Just an 13 eyeball check, okay. Thank you.
14 MR. SISK: This is Rob Sisk. I'm trying 15 to reflect back and remember those discussions as 16 well. And of course the I&C expert that you discussed 17 with is not here today.
18 But I recall something on that and do 19 recall taking some notes. But I so appreciate the 20 comment. It's something we have captured. Thank you.
21 MEMBER BALLINGER: I think I'm operating 22 at 50 percent as well. But I do remember this. And 23 I remember a KHNP person going up to the microphone 24 and confirming what you said.
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25 1 were going to check it?
2 MEMBER BALLINGER: Yes.
3 MEMBER BROWN: It's just not, it was not 4 explicitly stated amongst the ITAAC or the, whatever 5 the test. I think it was a Section 2, I think the 6 comment was that's a Tier 1, Section 2 thing not a 7 Chapter 14 thing or something like that.
8 And I, and we kind of dropped it at that 9 point. And I didn't follow up. So now I'm following 10 up.
11 MR. SISK: And we've captured the comment, 12 so thank you.
13 MEMBER BROWN: Okay, thank you.
14 CHAIR SUNSERI: So let me just ask a 15 clarifying question because I'm confused a little bit.
16 So are you talking about the hardware module itself or 17 are you talking about the interconnection to the plant 18 which can also create an independence?
19 MEMBER BROWN: If you look at the 20 architecture there's a division one detectors 21 conversion to digital. Each division processes 22 through the microprocessors, calculates a trip or a 23 no-trip.
24 That signal then is sent to all four 25 voting units. There is supposed to be no NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 1 communications between division to division to 2 division to division.
3 There should be, it's really an easy 4 thought process just to make sure in the process of 5 the design there weren't some compromises made where 6 there's some interconnections just to confirm that it 7 conforms with the architecture.
8 CHAIR SUNSERI: Okay, I'm with you now.
9 MEMBER BROWN: Voting units, you've got to 10 have wires going into the voting units otherwise it 11 doesn't work. And what slide are we on, 12? I 12 thought there was something about watchdog timers in 13 here also.
14 But that might be in the staff slides.
15 Okay, go ahead. I interrupted you. That's my only 16 comment there.
17 MR. LEE: I will finalize it. Section 14 18 all RAI responses were submitted and most of the 19 response has been resolved with adequate and 20 sufficient discussion with the staff.
21 But right now changing the response to the 22 RAI was incorporated into the DCD Rev. 2 and the 23 remaining will be reflected upcoming DCD Rev. 3.
24 Thank you for your attention.
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27 1 one of the general comments I remember from a lot of 2 the discussion on these various ITAACs was since this 3 is essentially, for lack of better words, I call it a 4 handoff from the design to the operator, was there 5 sufficient clarity in the statements so that the 6 operator could understand what they needed to do and 7 what acceptance criteria they had to achieve.
8 So I'm, this is a question for the 9 Members. Are you happy that these things have all 10 turned out the way you anticipated them in your 11 questions previously?
12 We just heard a lot from Charlie and it 13 seems like the job of --
14 MEMBER BROWN: I'm done, other than what 15 I stated I'm done.
16 CHAIR SUNSERI: Okay. So I take it from 17 other if you don't have, if you had a question you 18 would speak up. No comments, thank you guys.
19 MR. SISK: Mr. Chairman, with regard to 20 that question I would comment that one of the RAIs 21 that we received, Rob Sisk, Westinghouse. One of the 22 RAIs that we received was basically from OGC, that 23 data review to make sure that the RAIs for the ITAACs 24 or I should say the ITAACs were readable, 25 understandable and hopefully will benefit the COL NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 1 clearly in an unambiguous way at that point in time.
2 So I think we've tried to take an effort 3 to make sure we've addressed that issue in the ITAACs.
4 CHAIR SUNSERI: Great, thanks for that 5 feedback, Rob. All right, so that concludes you all's 6 presentation. Let's go on transition to the staff 7 now.
8 (Off the record comments.)
9 MR. SANTOS: So this part of the 10 presentation is --
11 CHAIR SUNSERI: Is your microphone on, 12 Tanny?
13 MR. SANTOS: That better? Okay, so this 14 part of the presentation the staff will discuss the 15 SER Section 14.3. As KHNP mentioned earlier 14.1 and 16 14.2 were presented in January of this year.
17 So my name is Cayetano Santos. I'm the 18 Chapter 14 PM. You already heard from Bill Ward, the 19 lead project manager.
20 As far as the technical staff that worked 21 on 14.3 it was numerous staff not just from NRO but 22 NRR as well as NSIR because ITAAC covered the whole 23 design certification concept or breadth of the design.
24 So a lot of different staff worked on it.
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29 1 14.35 and in Chapter 7. She will cover part of the 2 presentation.
3 But I didn't have enough room to try to 4 list every staff member who participated in the 5 review.
6 MEMBER SKILLMAN: Can I interrupt you for 7 a minute?
8 MR. SANTOS: Please.
9 MEMBER SKILLMAN: Just to clarify my 10 previous statements on Chapter 14, I have now found my 11 comment and it was in Table 2.5.1-5, Page 3 of 12 12 relative to Item 3C.
13 And my comment was no tests or inspection 14 verifies that no communications between divisions 15 exists other than trip data to other division voting 16 processors.
17 So I think I phrased it properly. And 18 that was the context of my comment during the, and it 19 was during the Chapter 14 meeting. I'm pretty sure 20 that's when it occurred.
21 So anyway, I wasn't making this up out of 22 thin air. That's it. Just to confirm that, okay, 23 thank you.
24 MR. SANTOS: Okay. So an outline of the 25 presentation today. First topic is just a general NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 overview of the SER Section 14.3. And then go over a 2 few of the RAIs.
3 The RAIs that are listed here are ones in 4 which the staff asked KHNP, requested that KHNP 5 designate some of the Tier 2 information as Tier 1 6 information. So the first RAI listed here is one that 7 KHNP discussed earlier from Chapter 3 about the 8 structure.
9 So I don't have any additional information 10 or discussion about this since it was already 11 discussed. But there are staff here that can answer 12 questions if you have any.
13 The second RAI listed here from Chapter 6, 14 again I don't have an additional slide or any details 15 on it. But basically at this particular RAI what the 16 staff was asking for was information from Tier 2 to be 17 moved to Tier 1.
18 And that information was the location and 19 containment of the passive autocatalytic recombiners 20 and hydrogen igniters. That was Tier 2 information so 21 the staff just asked KHNP to move that to Tier 1.
22 They did and there's an ITAAC to verify 23 those locations. So staff found that acceptable. The 24 next two questions from Chapter 7 Deanna will cover 25 shortly after this.
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31 1 And in the final RAI listed here is from 2 Chapter 18, Human Factors Engineering. And I will 3 come back and discuss a little bit more about that at 4 the end of the presentation.
5 MEMBER SKILLMAN: Hey, Tanny, just as a 6 general question.
7 MR. SANTOS: Sure.
8 MEMBER SKILLMAN: What is the trigger that 9 causes the staff to request information be moved from 10 Tier 2 to Tier 1?
11 MR. SANTOS: Well some of that is, there's 12 a SECY that comes up later that was issued last year 13 about, what was the title of that, talking about 14 planned improvements to the design certification 15 tiered information designations.
16 And that SECY paper basically said that 17 Tier 2 Star information is Tier 1 information that the 18 applicant has requested have additional flexibility.
19 So what should be moved up from Tier 2 to Tier 1 is 20 the safety significant issues that should be certified 21 and codified as a part of the design in the rule.
22 And fortunately the staff is still going 23 to try to develop some additional guidance on what 24 exactly that is. But with the issuance of that SECY 25 paper outlining that new concept we don't have any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1 additional specific guidance yet for the staff.
2 So KHNP and APR 1400 was, the applications 3 since they had already started we tried to review that 4 given the guidance in that SECY without any specific, 5 like the new SRP information or anything like that.
6 So it was on a case by case basis for each issue that 7 the staff raised whether it's structural, fuel, human 8 factors engineering, I&C.
9 So that's what resulted in the different 10 RAIs from the different chapters, the issuance of that 11 statement.
12 MEMBER SKILLMAN: I understand the 13 construction of the design cert and I understand the 14 difference between Tier 1, Tier 2 Star and Tier 2.
15 But I'm really curious what would initiate a request 16 or guidance to move Tier 2 Star up to Tier 1 other 17 than just a gut feel that the Tier 2 Star information 18 is so important it really needs to be considered in 19 Tier 1.
20 MR. SANTOS: I think what would happen was 21 that the initial concept for Tier 2 Star was initially 22 that it was essentially Tier 1 information, right.
23 But I think over the years and the process has evolved 24 to such that it essentially became Tier 2 information 25 that the staff wanted to make sure that it had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 1 opportunity to review and approve before any changes 2 were made.
3 So the concept change was basically 4 changing from an elevation of Tier 2 information to 5 Tier 2 Star versus a change of Tier 1 information to 6 Tier 2 Star information is what basically the essence 7 of the SECY paper is trying to communicate.
8 MEMBER SKILLMAN: Thanks, Tanny. That's 9 fine, thank you.
10 MR. SANTOS: Okay. So overview of Section 11 14.3. So 14.3.1 describes the staff's review of the 12 Tier 1 information which includes the principal 13 performance characteristics, safety functions, ITAAC, 14 design descriptions.
15 And that includes definitions of terms and 16 general provisions that apply to the ITAAC in the 17 design descriptions. Now for an ITAAC to be 18 sufficient they must meet some, you know, certain 19 criteria.
20 One, they need to clearly identify the 21 activities that are needed to satisfy the acceptance 22 criteria. The acceptance criteria must have clear 23 objectives.
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34 1 consistent with one another. And the ITAAC of course 2 must be capable of being performed before you load the 3 fuel.
4 So as a result of, you know, this 5 evaluation the staff basically issued an RAI to KHNP 6 which I think as mentioned earlier, RAI 558-9456 that 7 asked KHNP to make wording changes, text changes to 8 the Tier 1 information and ITAAC to try to obtain the 9 clarity and accuracy that was mentioned, Matt 10 mentioned earlier.
11 So this particular RAI was based on the 12 ITAAC that was provided in DCD Revision 1 as well as 13 some RAI responses that were submitted as of about 14 September 2017. The significance of that is that some 15 of these RAI added ITAAC or deleted ITAAC.
16 So that was a more up to date, current 17 version of the ITAAC at the time the staff started 18 doing this review. And to give you a frame of 19 reference, Rev. 2 was submitted in March 2018.
20 So this is kind of in between a Rev. 1 and 21 a Rev. 2 version of ITAAC that the staff reviewed.
22 And as was mentioned earlier I think that the staff 23 found the response to this particular RAI acceptable 24 because KHNP either agreed to the requested wording 25 changes the staff asked for, provided the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 1 clarification needed or then corrected any 2 discrepancies that were identified.
3 So next, so the remaining sections of 4 14.3, 14.3.2 through 14.3.13 document the staff's 5 review of the ITAAC in the corresponding sections of 6 the DCD. So they either contain the evaluation in 7 14.3 or they point to another SER chapter that 8 contains the evaluation of the ITAAC.
9 So as the staff was finalizing its SER for 10 14.3 we saw that some of the ITAAC evaluations in 11 these other chapters outside of 14.3 needed to be 12 revised. A lot of these revisions were needed mainly 13 just to ensure that all of the ITAAC in that table 14 were evaluated and appropriately evaluated.
15 Sometimes they may have only mentioned a 16 few of the ITAAC but not all of the ones in the table.
17 So to ensure we had a comprehensive review we needed 18 to go back and revise the text in those other 19 sections.
20 Now since many of these other chapters 21 were already provided to the Committee as part of the 22 Phase 4 SER and Phase 5 reviews previously, the staff 23 has prepared what we've called an ITAAC evaluation 24 cross reference table which we transmitted.
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36 1 chance to look at it. But we've transmitted it over 2 to the Committee. And what that table contains is a 3 listing for each ITAAC table.
4 It identifies the SER sections that 5 contain the ITAAC evaluation. Now if it's 14.3 the 6 last column of the table is blank. But if it's a 7 section other than 14.3 it includes the revised text 8 from those SER sections that have the ITAAC 9 evaluation.
10 So this cross reference table is basically 11 some supplementary information that, you know, we 12 provided to the Committee for 14.3 to ensure that you 13 had the most up to date, complete evaluation of all of 14 the ITAAC because if you look at what you were 15 provided in Phase 4 the ITAAC evaluations there may 16 not have been as complete as we would have originally 17 liked.
18 Any questions on that? Okay. Then I'll 19 turn it over to Deanna for the next couple of slides.
20 MS. ZHANG: Hi, my name is Deanna Zhang.
21 I'm a I&C technical reviewer. Can you hear me, okay.
22 CHAIR SUNSERI: Put it pretty close to you 23 since you're --
24 MS. ZHANG: I'm an I&C technical reviewer 25 and I led the review for Section 14.3.5 which is on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 I&C ITAAC in the APR1400 design certification. So 2 before I begin I want to go back to Charlie's question 3 about the communications independence between 4 redundant safety divisions.
5 So I know you pointed to ITAAC item 3.c in 6 Table 2.5.1-5. And that's what the staff relied on 7 for our review of ITAAC, an acceptable ITAAC. And for 8 the information that's only shared among redundant 9 divisions the acceptance criteria that we looked at 10 was that it only received defined messages.
11 And those defined messages are the ones in 12 Tier 2 that are what's allowed to be communicated 13 across core protection redundant divisions of the core 14 protection calculator system, between the processors, 15 the bistable processors and the voting processors and 16 then between the integrated test panels for the 17 display of the containment isolation valve status.
18 So a specific list of those data doesn't 19 exist in Tier 1. But we relied upon the information 20 in Tier 2 as a basis for the acceptance criteria 21 that's stated here and defined data.
22 MEMBER BROWN: I wasn't referring, I 23 understand that part about obviously at each stage you 24 have a communication process or even in the function 25 process. And some of that information is sent out to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 1 the, we call it the integrated test, there's some type 2 of a test panel.
3 I've forgotten what it's called. And then 4 there's also data sent for monitoring purposes. But 5 it's not shared into other divisions.
6 My question was relative to only 7 intradivision not data sent for monitoring purposes to 8 the main control room or to the test panels. So 9 looking at would you call it the data field?
10 MS. ZHANG: Yes.
11 MEMBER BROWN: In itself where they go 12 it's a matter of is it since they go to, some of these 13 go through a network as well. My question was 14 something gets sidetracked and I end up with some 15 other data going between communication process, or 16 division to division for some other reason or some 17 other connection between them.
18 The voting processors, I mean you're list 19 of stuff it talks about making sure stuff trips, that 20 the stuff in the table or in the 2.5. So what I was 21 referring to is not necessarily, I recognize you've 22 got to send the output of data to the main control 23 room to monitoring stuff.
24 That is not a compromising or a loss of 25 independence. My concern was were there any other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 1 data that don't show up in those basic, you know, one 2 line diagrams that we've got that the communication 3 processors talk to each other in some circumstance 4 division to division before you get to the voting 5 units?
6 MS. ZHANG: So that's what the list says 7 defined data. So anything that's not defined will 8 not, cannot be communicated or should be verified to 9 have not been communicated across those links.
10 MEMBER BROWN: I don't quite understand 11 how you would do that just by defining the 12 communication data itself. Although that's an 13 address.
14 It's got to go to a certain place and I 15 presume that the other divisions have a different 16 address and therefore it won't go there. Is that, did 17 phrase that correctly?
18 MS. ZHANG: Well part of it is the links 19 themselves are point to point. So for, let's say from 20 the bistables to the voters it's only a point to point 21 link.
22 MEMBER BROWN: That's easy. That's within 23 the division.
24 MS. ZHANG: And then same thing with the 25 core protection calculator systems. So Division A of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 1 the core protection --
2 MEMBER BROWN: So it only gets, I 3 understand.
4 MS. ZHANG: -- it will only connect to 5 Division B of the or Division C, they are all point to 6 point links.
7 MEMBER BROWN: That's right. So they 8 don't, they are unique point to point links.
9 MS. ZHANG: Yes.
10 MEMBER BROWN: That part I understand.
11 And my consideration rightly or wrongly was are there, 12 were there any other ended up that somebody verify 13 that no other links ended up because they were buried 14 somewhere in the overall design that information got 15 moved from one communication processor to another 16 ahead of the voting units. That's all I was looking 17 for.
18 MS. ZHANG: So I don't think there is a 19 proof of the negative. I think they just do a, you 20 know, is this, do we have the communications and the 21 link necessary to perform the function necessary and 22 are, what is communicated is that what we had 23 approved, the messages that are sent.
24 I don't think we do a negative of well are 25 there, you know, are there links there that was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 1 accidentally added that don't belong there. I think 2 that's part of the implementation process, part of the 3 verifying that, you know, when you install it in the 4 plant that you do wire checks to make sure everything 5 is connected properly.
6 But I don't think we have anything 7 specifically going to look at.
8 MR. SISK: This is Rob Sisk, Westinghouse.
9 We happen to have one of the experts available online 10 and I think we might be able to add some additional 11 light to that question. Warren, are you on the line?
12 CHAIR SUNSERI: Rob, can we open the line 13 for the comment?
14 MR. SISK: Warren, are you on the line?
15 MEMBER BROWN: He's going to check the 16 line.
17 MR. SISK: I'm just waiting to see if he 18 calls in.
19 MEMBER BROWN: Direct links are fairly 20 easy. Those I understand. Some of this data that 21 goes back to places goes into the network.
22 MS. ZHANG: So the only network it goes to 23 is the one way out from the plant to the plant. And 24 there is ITAAC for verifying those one way outs.
25 MEMBER BROWN: I'm not talking about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 1 extra.
2 MR. SISK: Can you hear us, Warren?
3 MEMBER BROWN: Still working on it.
4 CHAIR SUNSERI: Warren, if you're there 5 unmute your phone.
6 MR. ODESS-GILLETT: It's unmuted.
7 MR. SISK: You are now online, Warren.
8 MR. ODESS-GILLETT: Okay, great.
9 MR. SISK: Go ahead.
10 MR. ODESS-GILLETT: Hi, Charlie. This is 11 Warren Odess-Gillett from Westinghouse.
12 MEMBER BROWN: Yes.
13 MR. ODESS-GILLETT: So just for three way 14 communication you're wanting to make sure that all of 15 the interdivisional data links are defined in the 16 architecture and there aren't any interdivisional data 17 links not identified in the architecture?
18 MEMBER BROWN: No.
19 MR. ODESS-GILLETT: Okay.
20 MEMBER BROWN: My brain, I'm not very 21 smart so you have to simplify your brain. We reviewed 22 and we based our approval or our agreement, not 23 approval, our agreement on an architecture that showed 24 no communications of any kind division to division 25 from the input from the sensors clear down to where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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43 1 the output of the bistable from the function 2 processors go to the voting units.
3 That's the only common link division to 4 division. Any one division feeds a voting yes or no 5 to all four voting units. That's what the 6 architecture shows.
7 Then there are obviously outputs from each 8 function processor that feed back to the main control 9 room and others to tell them, hey, what are the 10 pressures, temperatures, flows, et cetera that are 11 being done, you know, within the plant that we have.
12 Then there's also some data that goes to 13 you all's maintenance unit or processor, you know, 14 maintenance cabinet or whatever it was. I can't 15 remember that.
16 My only concern was, was there part of the 17 overall design that ended up with, I view it as I take 18 each division I should be able to put a steel plate 19 between everything from the sensor clear out to the 20 voting unit and there's no wires that cross that 21 boundary.
22 That's, or links of any kind. That's what 23 I was looking for and I didn't see any verification 24 that there weren't some other paths that weren't 25 necessarily viewed as relevant to the one line of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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44 1 fundamental architecture.
2 MR. ODESS-GILLETT: Right. So what you're 3 referring to probably would be a possible data link 4 that exists from the bistable processors to the other 5 bistable processors in other divisions.
6 MEMBER BROWN: Exactly.
7 MR. ODESS-GILLETT: Right. So that you 8 would see in the architecture that there's no such 9 links between bistable processors in one division 10 connecting to a bistable processor in another division 11 sharing data in order to make a signal or an actuation 12 signal.
13 MEMBER BROWN: Okay. That includes even, 14 I mean the bistable processors also have a 15 communication module. I mean --
16 MR. ODESS-GILLETT: Yes, because they have 17 to go down to the voter.
18 MEMBER BROWN: Right. And so that's the 19 only connection from the communication units goes to 20 the voters and it doesn't, there are no other links to 21 any other place?
22 MR. ODESS-GILLETT: Right. They don't 23 like divert then back to the bistable processor in the 24 other division or anything.
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45 1 will send data to the main control room. You 2 obviously have to have read outs of your parameters.
3 Okay, all right. I guess I'll fold on this one. How 4 about that, just like a cheap suit.
5 MS. ZHANG: Thank you, Charlie.
6 MEMBER BROWN: Thank you, Warren.
7 CHAIR SUNSERI: Thanks. Deanna, please 8 continue on.
9 MS. ZHANG: Thank you, Warren. So again 10 the staff reviewed the ITAAC provided for the reactor 11 trip system, the ESF system, the diverse actuation 12 system, the qualified indication alarm system and the 13 engineer's safety feature component control system as 14 well as control systems not required for safety.
15 The staff found that the design 16 descriptions and corresponding ITAAC for these systems 17 are acceptable and provide reasonable assurance that 18 the as-built system will meet the design commitments 19 for those systems.
20 But we just want to highlight a couple 21 questions the staff had. And the first one is related 22 to the central processing unit or CPU load 23 restrictions for the core protection calculator system 24 or CPCS.
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46 1 systems are based on the Common Q platform. And 2 because of the multitasking nature of the Common Q 3 platform there is a 70 percent restriction of the CPU 4 load for any application that uses this platform.
5 However, for the CPCS system the applicant 6 needed to increase the load limit to 75 percent in 7 order to acquire all the required computations for two 8 particular reactor trip functions. That's the 9 departure from nuclear boiling ratio, trip and the 10 high linear high LOCA density power trip.
11 As such the platform vendor specified a 12 number of restrictions in order for the load limit to 13 be increased to 75 percent and still have 14 deterministic performance.
15 The staff requested the applicant in the 16 RAI 7.2-18 for the applicant to provide this list of 17 15 restrictions in Tier 1 as well as an ITAAC to 18 verify that these restrictions have been properly 19 implemented in the as-built CPCS.
20 The applicant followed through and 21 provided that design description. This is Item 28 in 22 Section 2.5.1.1 as well as a corresponding ITAAC in 23 Table 2.5.1-5.
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47 1 core protection calculator system will have those 2 restrictions implemented. Next slide.
3 So in July of last year Westinghouse sent 4 a Nuclear Safety Advisory Letter informing the NRC 5 that the software --
6 MEMBER BROWN: Deanna.
7 MS. ZHANG: Yes.
8 MEMBER BROWN: Backtrack a minute. Maybe 9 I misunderstood what you said. Your last sentence 10 said they verified that the core protection calculator 11 system or did you mean, we also have the same type of 12 restrictions on the processing units and everything.
13 Core protection calculator is a separate 14 device that feeds the data into each division.
15 MS. ZHANG: So the, these special 16 restrictions are only for the core protection 17 calculator system because those processors in that 18 system are the only ones that required this bump in, 19 to 75 percent.
20 MEMBER BROWN: I think I vaguely remember 21 that now. I'm sorry.
22 MS. ZHANG: Yes, all the other ones --
23 MEMBER BROWN: I forgot that detail.
24 Thank you for reminding me.
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48 1 Westinghouse submitted a Nuclear Safety Advisory 2 Letter to inform the NRC that the software stall 3 timers which is part of their watchdog timer sets, was 4 in the Common Q platform, were not activated due to an 5 error in configuring the system's software.
6 And the staff presented on this issue 7 during the ACRS meeting for Chapter 7 with extensive 8 detail. So I won't go over the specific details for 9 this meeting.
10 But to resolve the issues related to this 11 letter, the staff issued a new RAI to the applicant.
12 And in response to this RAI the applicant stated that 13 the watchdog timers, referencing the FSAR Tier 2 and 14 the safety I&C system technical report are all Windows 15 watchdog timers which are strictly hardware devices.
16 And they provided a definition for what 17 that means. And they do not employ a programmable 18 hardware device like FPGAs or contain any software and 19 does not rely on software for activation.
20 These will be simple transistor devices 21 that will be used to achieve the watchdog timer 22 functions. The applicant also clarified that they 23 will remain with the current licensing basis which is 24 that the stall timers will be activated and the 25 additional design descriptions will be added in Tier NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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49 1 1 as well as Tier 2, as well as a proposed ITAAC to 2 clarify the application of the Common Q Window 3 watchdog timer.
4 This includes an ITAAC to verify that the 5 watchdog timer will be hardware and its time out will 6 result in a trip condition for that division in a 7 built as is for the SFAS functions.
8 The staff finds that the fail safe design 9 is acceptable due to the hardware design of the 10 Windows watchdog timer and that the resulting trip 11 condition caused by the Window watchdog timeout and 12 the ITAAC verified the implementation in the as-built 13 systems are adequate.
14 MEMBER BROWN: Can I ask you to refresh my 15 memory?
16 MS. ZHANG: Yes.
17 MEMBER BROWN: One of the timers, if I 18 recall reading all this stuff the Windows watchdog 19 timer triggers the reactor trip for that division 20 based on it timing out.
21 Doesn't one of the timers in there also 22 reset the processor if it doesn't? Was that the stall 23 timer or was that --
24 MS. ZHANG: That was the stall timer.
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50 1 activated so that the processors reset and will begin 2 their entire processing cycle?
3 MS. ZHANG: Yes.
4 MEMBER BROWN: Do you know how long it 5 takes for them reboot? And I remember one of the 6 meetings somebody said five to ten minutes and I can't 7 --
8 MS. ZHANG: I don't recall it being that 9 long. I thought it was shorter.
10 MEMBER MARCH-LEUBA: I remember you saying 11 it took too long.
12 MEMBER BROWN: Took too long to. The 13 reason I ask is in the program I was in ours reset in 14 250 milliseconds so that even if it triggered you just 15 kept on trucking.
16 MEMBER MARCH-LEUBA: Yes, but this is an 17 FPGA system.
18 MEMBER BROWN: I understand that. So, no, 19 the Common Q system is not an FPGA system.
20 MS. ZHANG: No, but this one --
21 MEMBER BROWN: It's a microprocessor based 22 system.
23 MS. ZHANG: Yes, it would definitely be 24 longer than --
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51 1 was not milliseconds. Okay, you don't remember that's 2 fine. That's not critical to this discussion.
3 MS. ZHANG: I don't know if Warren 4 remembers.
5 MEMBER BROWN: You can go on.
6 MS. ZHANG: Okay, but that's all I have.
7 MEMBER BROWN: Okay, Deanna, thank you.
8 MR. SANTOS: Okay. So the last RAI 9 discusses the Chapter 18 RAI on human factors 10 engineering. That's, this is discussed in Section 11 14.3.9 of the SER.
12 So there are two HFE ITAAC. And as a 13 result of this RAI there was no change to the ITAAC 14 themselves. But what was added was a lot of 15 additional information to Tier 1 to provide a means to 16 constrain the changes that can be made to Tier 2 17 information.
18 This Tier 2 information are the human 19 factors engineering implementation plans. They're 20 currently in various technical reports that are 21 incorporated by reference into Tier 2.
22 These implementation plans describe the 23 HFE design process and the methods that will be used 24 to develop the APR1400 human system interface. So the 25 staff relied on the information in this report to make NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 1 its safety finding in Chapter 18 of the SER.
2 So what the staff additionally planned to 3 do was to designate this Tier 2 information in these 4 reports as Tier 2 Star as was done in previous 5 designs. But because of the second paper I cited 6 earlier that concept changed.
7 So the information is going to remain as 8 Tier 2. KHNP has not identified any information that 9 it would like to make Tier 2 Star.
10 So given the fact that these 11 implementation plans are not to be Tier 2 Star or 12 still to remain Tier 2, the staff couldn't rely on the 13 50.59 like change control process for Tier 2 14 information to ensure that any changes made to these 15 implementation plans would not invalidate the safety 16 findings that it made in the Chapter 18 SER.
17 Okay. So the staff issued RAI 18-134 to 18 address this issue. So in response to this question 19 what the applicant provided was additional information 20 in Tier 1 that constrains the information that can be 21 changed in Tier 2.
22 So these changes to the, the result of 23 this addition was that changes to these implementation 24 plans can be made without staff approval as long as 25 the information continues to conform to the review NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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53 1 criteria in NUREG-0711 which is the human factors 2 engineering program review model and they continue to 3 comply with the, in Tier 1 information related to 4 integrated system validation testing which was also 5 added to Tier 1 information.
6 So therefore the staff found the response 7 to this RAI acceptable because the findings on the HFE 8 program are based on conformance with NUREG-0711 Rev.
9 3 and the information in the integrated systems 10 validation test that is now in Tier 1 information. So 11 no change to the ITAAC was needed.
12 And finally, the overall conclusion for 13 the, all of 14.3 was basically the finding in 14 regulation 10 CFR 5247(b)(1) upon incorporation of the 15 confirmatory items and to the subsequent DCD revision 16 of Rev. 3, well you can read. It's basically a 17 recitation of the 5247(b)(1) finding in the 18 regulations.
19 So that concludes the staff's 20 presentation.
21 CHAIR SUNSERI: All right, thank you. We 22 have, it looks like we have some update here.
23 MR. SISK: Rob Sisk, Westinghouse again 24 just a little bit of feedback from the subject matter 25 expert, Warren Odess-Gillett. Rather than going NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 1 through the effort of trying to open up the lines I'm 2 going to try to relay the information.
3 It does take a few minutes to reboot and 4 you have to recall that during that reboot performs 5 many diagnostics as part of the start up process. So 6 if we need a little bit detail than that we have to 7 open the line up.
8 But it's a few minutes and it includes the 9 diagnostic process in that reboot period.
10 MEMBER BROWN: That's what my memory from 11 the discussion was. But I, like I say, I think I had 12 a brain freeze or a loss of data some place along the 13 line. That's why I asked the question again. Thank 14 you very much.
15 CHAIR SUNSERI: All right, thank you. Any 16 other questions on this chapter for the staff from the 17 Members? All right, so we're at a point in the agenda 18 where we had intended to close the meeting at this 19 point.
20 But since we know there are, it's our 21 intention to leave the meeting open I do want to 22 respect the agenda as it was published and ask for any 23 public comments for people that may be waiting on the 24 line for this particular point in time since they 25 thought this was their last opportunity.
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55 1 So while we're waiting to get the line 2 open I'll ask any Members or anybody in the room that 3 would like to make a public comment please come up to 4 the microphone. All right.
5 So now we'll turn to the phone line. Any 6 members of the public that have been listening in, 7 would you like to make a comment?
8 MEMBER RICCARDELLA: Matt, this is Pete.
9 I'm not a member of the public. But I am on the phone 10 line and it seems like I've been muted and I just 11 thought I would announce that I am on the line.
12 MEMBER CORRADINI: This is Corradini, the 13 same here.
14 CHAIR SUNSERI: Okay. So do you all have 15 any comments regarding any of the material that you've 16 heard?
17 MEMBER RICCARDELLA: Not me.
18 MEMBER CORRADINI: Not me.
19 CHAIR SUNSERI: Okay, all right. Very 20 good then. So I guess if, since we're keeping that 21 public line closed I guess you can email Joy or text 22 me if you need to break in at any time during the 23 meeting, okay.
24 MEMBER RICCARDELLA: Okay.
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56 1 up at the end of the discussion here.
2 MEMBER REMPE: But the public line will 3 continue to be visible even though it was planned to 4 have a closed meeting?
5 CHAIR SUNSERI: Yes.
6 (Off the record comments.)
7 CHAIR SUNSERI: But so we do, since we're 8 going to continue in an open format then we want to 9 leave the public line open. I understand. It will be 10 active but muted.
11 MEMBER RICCARDELLA: Okay.
12 CHAIR SUNSERI: All right. And, Pete and 13 Mike, it's my understanding I just was advised that 14 you are on a separate line and it should be open. So 15 we're going to make sure that happens.
16 You should be able to just break in any 17 time.
18 MEMBER RICCARDELLA: Okay.
19 MEMBER CORRADINI: Okay.
20 CHAIR SUNSERI: All right. So now having 21 been through that part of the meeting this calls for 22 our break. But I'd like to keep the momentum going 23 here and avoid the break because I think we can push 24 on through with Chapter 6 right now.
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57 1 get up to take a bio break go ahead and quietly do so.
2 But we're going to push on with the agenda.
3 And if any Members at the table need to, 4 I'll make sure we keep a quorum here, all right, which 5 isn't hard. We only need two.
6 So let me ask KHNP, are you all ready to 7 advance the agenda by doing Chapter 6 now?
8 MR. SISK: We're bringing the people up 9 right now.
10 CHAIR SUNSERI: Okay, thank you. Now I 11 guess this is an early warning to the staff be on 12 deck.
13 MEMBER CORRADINI: Hey, Matt, can you hear 14 us?
15 CHAIR SUNSERI: Yes, yes.
16 MEMBER CORRADINI: Okay. We are on a 17 separate line, thank you.
18 CHAIR SUNSERI: Perfect. Actually, Mike, 19 your line is quite clear.
20 MEMBER BALLINGER: Not even cracking.
21 MR. SISK: This is Bob Sisk, Westinghouse.
22 KHNP is ready to go when the Committee is ready to go.
23 CHAIR SUNSERI: Okay. I'm just looking 24 here. We had a few Members take advantage of the 25 transition and took a break. But we do have a quorum NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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58 1 so let's go forward.
2 MR. SISK: Mr. Song will be doing Chapter 3 6. Please begin.
4 MR. SONG: Good afternoon. I am Jeunghyo 5 Song working in --
6 CHAIR SUNSERI: I don't think it's on. Is 7 the green light on? There we go, thank you.
8 MR. SONG: Good afternoon. I'm Jeunghyo 9 Song working in Enterprise Division at KEPCO E&C.
10 This presentation provides open item discussions in 11 Chapter 6 of the APR1400 DCD Tier 2.
12 I'm sorry. The contents consist of a 13 review over Chapter 6 and the summary of open items 14 and current status and the attachments which includes 15 an acronym list.
16 The sections I will review of Chapter 6 is 17 shown in this table which includes seven sections.
18 KHNP has submitted three documents DCD Tier 1 and DCD 19 Tier 2 and the technical report on LOCA mass and 20 energy release methodology.
21 The open items for Chapter 6 are as 22 follows, next. The summary of open items provide, 23 will provide the discussions for each open item. The 24 staff tracks the RAI 296-8342, Question 06.02.01.01.A-25 2 as an open item.
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59 1 There are two issues with this RAI and the 2 both of them regarding passive heat sink modeling.
3 The first issue is about the discrepancy of the heat 4 structures numbers in DCD and GOTHIC deck.
5 And the second one is regarding the heat 6 structure modeling. The staff requested how KHNP 7 determined the thickness of the passive heat sink 8 having arbitrary shapes.
9 To solve the first issue KHNP clarified 10 the description and the number of passive heat sink 11 relied upon in the analysis. For the second issue, 12 sorry, for the second issues KHNP clarified how it 13 modeled passive heat sink thickness and updated the 14 passive heat sink modeling description.
15 In the heat structure modeling the 16 thickness is calculated from dividing the structure's 17 volumetric size by the structure's surface area 18 exposed to the atmosphere. The staff tracks two RAIs 19 as a combined open item.
20 RAI 296-8342, Question 06.02.01.01.A-3 and 21 the RAI 378-8442, Question 06.02.01.01.A-9 for the 22 GOTHIC containment model. There are two issues with 23 this GOTHIC model.
24 The first one is about condensing model 25 applied it to the containment passive heat sinks. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 1 the second one is regarding the inertial lengths. To 2 resolve the first issue the Tagami/Uchida empirical 3 correlation was used for work on the station which was 4 previously accepted by the NRC.
5 To resolve the second issue the effect of 6 the junctions inertial links on the containment 7 pressure was estimated. From the sensitivity study of 8 the inertial lengths we knew that the longer inertial 9 lengths the junction has the higher pressure the 10 containment has.
11 Thus we updated the GOTHIC model to have 12 increased inertial links resulting in a peak 13 containment pressure increasing by 0.4 psia. However, 14 the containment back pressure is well within the 15 design limit.
16 MEMBER CORRADINI: Can I have a quick, can 17 ask a question here?
18 MR. SONG: Yes.
19 MEMBER CORRADINI: So you changed both 20 things simultaneously. You applied Tagami/Uchida as 21 well as increased the inertial lengths at the same 22 time?
23 MR. EUN: Yes, that's right.
24 MEMBER CORRADINI: Okay. You didn't see 25 which direction either of them had. I can see where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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61 1 the inertial length would increase the pressure. I'm 2 not so sure about switching to Tagami/Uchida.
3 MR. EUN: The effect of the condensing 4 model that is changed to the Tagami/Uchida from the 5 Direct/DLM. Impact on the containment pressure by 0.3 6 psi.
7 MEMBER CORRADINI: So in increased the 8 pressure by 0.3 psi?
9 MR. EUN: Yes, by the, by changing the 10 condensing model.
11 MEMBER CORRADINI: And then the additional 12 increase is 0.1 by inertial length?
13 MR. EUN: 0.4 by the inertial length.
14 MEMBER CORRADINI: So the combination was 15 0.7 psi?
16 MR. EUN: Yes, that's right.
17 MEMBER CORRADINI: Okay, thank you. I 18 missed that. Thank you.
19 MR. EUN: Yes.
20 MR. SONG: Next, this slide is, shows the 21 open item for the basis of the back pressure 22 assumption during the reflood phase. The related RAI 23 is 327-8354, Question 06.02.01.01.A-6.
24 The staff requested to justify the back 25 pressure assumption of a 58 psia and to explain NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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62 1 whether an even lower variable for containment back 2 pressure would be more conservative for the M&E 3 release during the reflood phase.
4 The staff needs to establish that the 5 applicant's analysis covered a sufficient DBA analysis 6 domain for the containment peak pressure analysis 7 using two different computer codes in order to accept 8 the assumed value of 58 psia of containment back 9 pressure.
10 To resolve these issues KHNP provided the 11 calculated containment pressure between the EOB and 12 the peak pressure time for LOCA cases which shows that 13 the assumed back pressure of 58 psia is lower than 14 most of the calculated containment pressures.
15 Therefore, the assumed containment back pressure is 16 considered conservative.
17 The minimum calculated containment 18 pressure of 57.157 psia would not significantly affect 19 the conservatism of the back pressure assumption. A 20 lower value for containment back pressure may result 21 in more conservative output as compared to the output 22 when 58 psia is used.
23 However, since using 58 psia as the input 24 is already conservative as mentioned about the 25 additional conservatism is not considered to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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63 1 necessary. This item is now resolved and closed.
2 Next, the staff tracked the RAI 378-8442, 3 Question 06.02.01.01.A-10 as an open item. The NRC 4 staff requested to provide the justification of how 5 the pressure ratio after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is calculated.
6 This RAI is a question about which value 7 should be used between gauge pressure and absolute 8 pressure in calculating the pressure ratio. In the 9 Reg Guide 1.206 Table 6-1 the pressure ratio is 10 justified as the ratio of the containment pressure at 11 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the calculated peak pressure.
12 And the pressure unit used in this 13 calculation is the British pressure gauge units, psig.
14 In APR1400 the percent of the pressure at 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is 15 estimated to be 37.1 percent of the peak pressure.
16 The staff noted that in DCD Tier 2, 17 Section 934 the CPCS provides for the capability of 18 recycling boron. If the boron recycling is to be used 19 the applicant shall provide the discussion in DCD 20 about how the current proposal the technical 21 specification and the surveillance requirements 22 ensures a minimum Boron-10 atom percent when the water 23 is recycled or provide an additional technical 24 specification and the surveillance requirement.
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64 1 additional clarification to ensure a minimum Boron-10 2 atom percent by adding surveillance requirement and 3 existing technical specification and their 4 corresponding basis.
5 All items in Chapter 6 is completed. Five 6 open items that were identified in Phase 2 and Phase 7 3 has been satisfactorily resolved with the staff.
8 Conforming changes in Chapter 6 are as reviewed and 9 marked up in the response to the RAIs that have been 10 incorporated into DCD Revision 2.
11 Thank you for hearing the presentation.
12 Is there a question?
13 CHAIR SUNSERI: Members, any questions?
14 I remember lively discussions about containment during 15 our previous presentations. All right, thank you.
16 And now we will exchange the table for the staff to 17 come up.
18 MS. UMANA: Good afternoon. I'm Jessica 19 Umana. I am now the former project manager for 20 Chapter 6. But I'm finishing up my duties with this 21 presentation.
22 Today you will hear from the technical 23 staff with regards to the resolutions that they 24 brought to open items including a question we got from 25 ACRS regarding the swing panels back in March of last NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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65 1 year.
2 So now if we turn it over, we're going to 3 start with Andrew Yeshnik with the first open that we 4 identified in Chapter 6.
5 MR. YESHNIK: Good afternoon, everyone.
6 My name is Andrew Yeshnik. I am materials engineer in 7 the Materials and Chemical Engineering Branch. And 8 I'm going to update you on two open items that have 9 been closed in Phase 4 of this review.
10 The first open item came about when the 11 applicant stated that the IRWST liner would only meet 12 a portion of Section III, Division 2, Subsection CC-13 2511 with the exception of the quality assurance 14 requirements.
15 And the question came up what were the 16 quality assurance requirements for this component.
17 This item was resolved when the applicant revised the 18 SR to state that the IRWST liner will meet ASME NQA-1 19 and 10 CFR Appendix B, QA requirements. So the staff 20 considers this item closed, next.
21 And the next open item the staff noted 22 that the process controls for type 304 stainless steel 23 were not consistent with the staff guidance in Reg 24 Guide 1.44. So the staff requested information on how 25 sensitization of material was prevented.
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66 1 The applicant committed to verifying that 2 weld processes do not produce sensitization as 3 demonstrated by meeting ASTM A262, Practices A&E.
4 This is in accordance with Reg Guide 1.44.
5 So the applicant meets staff guidance and 6 is acceptable.
7 MEMBER BALLINGER: So it's wrapped as A&D.
8 MR. YESHNIK: A&E.
9 MEMBER BALLINGER: A&E, okay.
10 MR. YESHNIK: So that's all I have. Next 11 will be Boyce.
12 MR. TRAVIS: Good afternoon, everyone. My 13 name is Boyce Travis. I'm a technical reviewer in the 14 Containment and Ventilation Branch. I am not the 15 leader here on the sections I will be presenting on.
16 I am filling in today for the lead reviewer.
17 I will be focusing on three sections, 18 06.02.01-1, 06.02.02-3 and 06.02.02-4. The first 19 relates to containment structural integrity and peak 20 containment pressure and temperature analysis.
21 06.02.02-3 is containment mass and energy 22 release for a LOCA and 06.02.02-4 is mass energy 23 release for an ACMI break inside containment. I'll be 24 focusing on three items that were open in the Phase 2 25 SER of the March 23rd Subcommittee meeting.
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67 1 And as a result of the interactions with 2 KHNP we've had since then and updated RAI responses 3 the staff has been able to close all of the open items 4 in these sections. So for the first open item it 5 pertains to peak pressure and temperature for a LOCA.
6 The regulation requires sufficient margin.
7 As defined in the guidance for ECD that's ten percent 8 from the calculated peak containment pressure. In 9 performing confirmatory analysis for these, for this 10 set of calculations there was a fairly large 11 discrepancy between the staff's calculation and the 12 applicant's calculation.
13 And so the RAIs that we'll be discussing 14 today were motivated by that discrepancy.
15 MEMBER CORRADINI: Can I ask --
16 MR. TRAVIS: Go ahead.
17 MEMBER CORRADINI: -- a question, Boyce?
18 MR. TRAVIS: Absolutely, Mike.
19 MEMBER CORRADINI: What did you use on the 20 staff side that alerted you to the discrepancy?
21 MR. TRAVIS: Sure. So the staff's code is 22 MELCOR. The applicant used GOTHIC. And I will 23 hopefully by the end of the next three slides be able 24 to explain why we came up with such a large 25 discrepancy.
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68 1 MEMBER CORRADINI: Okay.
2 MR. TRAVIS: So, yes, in the DCD the 3 applicant has reported a greater than ten percent 4 margin to the peak containment pressure. When the 5 staff used MELCOR we got a calculated peak pressure of 6 on the order of five percent.
7 And in order to understand that 8 discrepancy we asked a number of RAIs and requested 9 sensitivity studies be performed by the applicant. We 10 also reviewed the GOTHIC deck in detail for both the 11 limiting LOCA and MSLB cases and identified three, 12 what will be termed non-conservatisms for the 13 remainder of this slide.
14 But that may or may not be the correct 15 terminology here with regard to containment peak 16 pressure. The first was the use of the correlation 17 for modeling heat transfer or condensation on services 18 inside the containment.
19 In NUREG 00588 suggests that Tagami/Uchida 20 heat transfer correlation should be used. The 21 applicant used the Direct/DLM model and we asked the 22 applicant to perform a sensitivity study to determine 23 the effect of using the suggested Tagami/Uchida 24 correlation.
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69 1 less than half a psi difference in the peak 2 containment pressure. The second non-conservatism was 3 the use of an inertial link of one foot in the GOTHIC 4 calculations.
5 That struck the staff as being perhaps not 6 representative of the conditions that would exist 7 inside containment following a LOCA blow down. And so 8 they increased the containment inertial length and 9 that was shown to be more conservative.
10 And then finally, the third issue related 11 to the thermal conductivity degradation which I 12 believe has been discussed in a number of Subcommittee 13 meetings separately to this, but as part of the mass 14 and energy release for these calculations the 15 applicant included the additional effect of thermal 16 conductivity degradation which is, as thermal 17 conductivity decreases it will result in a higher core 18 stored energy and raw temperatures and therefore a 19 higher mass and energy release.
20 I'll note that all three of these non-21 conservatisms were a little less than a psi which did 22 not account for the full discrepancy between the 23 staff's confirmatory calc and what the applicant 24 performed. And so --
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70 1 in. What was the discrepancy because I asked this 2 question earlier and one was, I can't remember which 3 was which. One was .4 psia. One was .3 psia and the 4 TCD I can't remember if anybody mentioned that.
5 But those don't make up the discrepancy 6 that you observed, right?
7 MR. TRAVIS: I'm just going to skip ahead 8 to Slide 6 so I can answer your question. So as part 9 of the RAIs the staff asked we looked at the GOTHIC 10 deck and the heat sink table as specified in the DCD.
11 We were trying to understand, there was a 12 fairly large discrepancy in the volume and area of 13 heat sinks that were employed in the GOTHIC deck 14 versus the MELCOR deck. And so our interpretation of 15 what was specified in the, basically because of how 16 heat structures are input into GOTHIC the heat sink 17 data in the DCD tables were subject to some 18 interpretation.
19 It looks a little like the previous DCD 20 tables were extracted from GOTHIC. And so because of 21 how GOTHIC, so the GOTHIC heat structure values were 22 correct and the DCD interpretation that we took from 23 it was incorrect.
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71 1 what was actually supposed to be present in the 2 calculation.
3 And so as a result of this RAI the 4 applicant updated the DCD tables to clarify exactly 5 what constituted the area and thickness of all the 6 heat sinks in containment to better reflect what was 7 actually going to be present inside the containment.
8 MEMBER CORRADINI: Okay. But to put it 9 succinctly you guys misinterpreted what was a somewhat 10 cloudy table.
11 MR. TRAVIS: Yes, I would say that's fair.
12 I would say the table was reflective of the input 13 conditions for the way GOTHIC takes its heat 14 structures in whereas that was not exactly how the 15 table could, it could be construed in a way that 16 resulted in what we got of half the heat sink value, 17 roughly half the heat sink value that would exist.
18 MEMBER CORRADINI: Okay. So let me ask, 19 I'm sorry that I'm dwelling on this stuff. But 20 unfortunately this is interesting to me so I 21 apologize.
22 MR. TRAVIS: That's all right. I 23 understand.
24 MEMBER CORRADINI: The MELCOR model uses 25 the Direct/DLM model unless you guys short circuited NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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72 1 and put it into Tagami/Uchida. Is that what was done 2 by staff?
3 MR. TRAVIS: That is correct, yes.
4 MEMBER CORRADINI: Okay, because from a 5 physics standpoint the Direct/DLM model was correct.
6 MR. TRAVIS: So I guess I'll reiterate the 7 comment I made earlier. I'm not the lead reviewer on 8 this section.
9 I don't, I do agree that and I think from 10 the staff's perspective the sensitivity was asked so 11 that we could better understand where the discrepancy 12 lied before we got access to the GOTHIC deck.
13 MEMBER CORRADINI: Okay.
14 MR. TRAVIS: I think the staff in general 15 agrees that the DLM model could be used appropriately 16 in certain cases. In this case it was just, we were 17 trying to reconcile a difference and we noted that was 18 a potential source of difference.
19 Obviously it didn't account for a large 20 increase in containment pressure but it was an 21 increase in the containment pressure.
22 MEMBER CORRADINI: Okay, all right. Thank 23 you very much. I appreciate it.
24 MR. TRAVIS: No problem.
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73 1 we have spent a lot of time talking about thermal 2 conductivity. It is on. We spent a lot of time 3 talking about thermal conductivity degradation.
4 And I believe you said all three of these 5 sensitivities led to less than a psi. So if I take 6 one psi minus .03 or .04 does that --
7 MR. TRAVIS: Each of them is less than a 8 psi. I'm sorry. I believe TCD was on the order of 9 something like .7. But I can't --
10 MEMBER REMPE: So it was a lot more than 11 the heat transfer coefficient or the --
12 MR. TRAVIS: Yes.
13 MEMBER REMPE: -- inertial length?
14 MR. TRAVIS: Absolutely.
15 MEMBER REMPE: That's interesting just out 16 of curiosity. It is idle curiosity though.
17 MR. TRAVIS: Functionally, yes, that's 18 just a result of the initial stored energy in the core 19 going up by a couple of percent.
20 MEMBER REMPE: Thanks.
21 MR. TRAVIS: So I guess I'll step back to 22 Slide 5 briefly. Slide 5 talks about the RAI. As 23 part of this process to recalculate the peak 24 containment pressure and temperature the staff also 25 asked RAI regarding the temperature or the peak NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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74 1 pressure, sorry, excuse me, the calculated pressure at 2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following the transient.
3 The regulations require that it be reduced 4 sufficiently and the guidance interprets that it's 5 less than 50 percent of the peak calculated pressure 6 following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the accident. There was some 7 confusion as to whether that would be the case 8 following, before the, our understanding of the 9 discrepancy in the two models.
10 As a result of the recalculated values 11 that have been put in the DCD it's well below 50 12 percent and therefore is acceptable. And then we'll 13 skip to Slide 7. Go ahead, Mike.
14 MEMBER CORRADINI: So if I might just, the 15 reason I guess I'm asking about the transfer and all 16 these sort of things is there are other applicants 17 that will be coming or you already have them in front 18 of you where passive heat rejection to a cool surface 19 is important.
20 And it isn't, for want of a better term, 21 necessarily in the empirical database at 22 Tagami/Uchida. So using something that is physics 23 based might be more logical.
24 MR. TRAVIS: I think as a staff we agree 25 with that 100 percent. I think a physics-based NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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75 1 correlation would provide an appropriate starting 2 point.
3 I think we would expect for there to be 4 some testing in whatever regime if it does not exist 5 already to be backed up by some tested data in 6 whatever regime that said hypothetical future 7 applicant would be using for their condensation 8 surface.
9 MEMBER CORRADINI: Well said.
10 CHAIR SUNSERI: I just want to do a check 11 here to make sure that we're not encroaching on 12 propriety information in any of this.
13 MR. TRAVIS: I don't believe any of what's 14 been said thus far has been proprietary. I'll look 15 over to the applicant to make sure that's the case.
16 But I didn't, I specifically didn't use numbers as 17 part of my presentation but they did. So I'm --
18 MS. UMANA: We also, I'm sorry, we also 19 extended them a courtesy copy of the presentation to 20 confirm that there isn't proprietary information.
21 CHAIR SUNSERI: Yes, but I'm just worried 22 about the discussion.
23 MS. UMANA: Let's not get into specific 24 numbers.
25 CHAIR SUNSERI: It was just a check.
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76 1 MR. TRAVIS: Understood. With regards to 2 the correlations that's, yes, there should be no 3 problem there. So to close out the three open items 4 that were discussed here really they were all part of 5 one large item to reperform the analysis.
6 The applicant clarified that the 7 additional passive heat sinks in GOTHIC were, that 8 were identified during the staff's review were 9 conservatively excluded from the GOTHIC analysis and 10 then updated the table to better reflect the heat sink 11 parameters and conditions that were used.
12 The applicant addressed the three non-13 conservatisms that the staff identified in GOTHIC 14 model and also made other improvements listed on the 15 slide here. They modified the break flow model to 16 better reflect the conditions that are expected during 17 the break.
18 They created water trap conditions in the 19 containment. And they corrected the decay heat curve.
20 Each of these are smaller impacts than what we 21 discussed before and I believe the total impact of all 22 three of these corrections is less than a half a psi.
23 And so the updated, after all of these 24 RAIs the staff updated their confirmatory calculation 25 and it conforms fairly well with the applicant's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 1 licensing basis calculation. They are in much better 2 agreement than they were before.
3 Taken as a whole, the staff concludes that 4 GDCs 16, 50 and 38 have been satisfied. As part of 5 this set of RAI responses the applicant has submitted 6 their revised limiting GOTHIC analysis and deck for 7 the LOCA and MSLB analysis and updated the DCD and 8 technical reports appropriately to reflect the 9 necessary revisions and therefore these items are 10 closed.
11 I believe that's it for my presentation.
12 Are there any more questions on this? I would be 13 happy to address.
14 CHAIR SUNSERI: Members, anything, Mike, 15 you good?
16 MEMBER CORRADINI: Yes, sir.
17 MS. UMANA: Actually I have --
18 MR. TRAVIS: Sorry, apologies.
19 MS. UMANA: So I'm presenting, I'm not the 20 reviewer for this but I will be presenting this slide.
21 And this one is an open item we had for 06.02.04-11 22 having to do with the containment isolation valves and 23 an ITAAC issue that we had come up.
24 And this particular RAI was concerned with 25 the compliance of the as-built plant with the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 1 requirements of 10 CFR Appendix A, GDC 55, 56, and 57 2 which require that the isolation valves outside 3 containment should be located as close as possible to 4 the, as close as practical to the containment.
5 The staff asked the applicant to explain 6 how this ITAAC would ensure that the supplied as-built 7 piping distances from the outer containment isolation 8 valves to the containment would be such that the 9 valves are located as close as practical. The 10 applicant was requested to provide an ITAAC to meet 11 the requirements of GDCs 55, 56 and 57.
12 The staff reviewed a revised response that 13 came in where the applicant proposed an additional 14 ITAAC to be added to Tier 1 of the DCD which is in 15 Table 2.11.3-2. And that particular ITAAC is 16 evaluated in Section 14.3.11 of the SE.
17 The staff reviewed the proposed DCD mark 18 ups and found that the proposed ITAAC is acceptable 19 for meeting the requirements of GDC 55, 56 and 57.
20 And this is now being tracked as a confirmatory item 21 so we hope to see that in Revision 3 of the DCD.
22 MEMBER BROWN: Question, as close as 23 practical. Well it's an ITAAC. So what does somebody 24 expect if they tell you it's close as it can be does 25 that mean it's okay or is it supposed to be closer NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 1 than one foot or --
2 MS. UMANA: That's a good question so I 3 actually underlined that term in the slide. I'm going 4 to either defer to the technical reviewer if he's 5 here, Raj. Would you be able to answer the question 6 or, Bill, you look like you're ready to jump in?
7 MEMBER BROWN: It seems to me there ought 8 to be a criteria. I mean just saying --
9 MS. UMANA: We had extensive discussions 10 about this.
11 MEMBER BROWN: -- if the guy goes to 12 inspect it this looks pretty close to me and everybody 13 is happy and walks away. So I'm being a little 14 cynical but, no, I'm being very cynical as a matter of 15 fact.
16 MS. UMANA: No, this is the exact 17 conversation we had internally.
18 MR. WARD: Yes, I'll add into this. Bill 19 Ward, Lead PM. The question was because initially 20 there's a design and there's an expectation in the DCD 21 about how far away the valves would be.
22 And it allows for, during construction for 23 some of those valves to be adjusted because other 24 things may get in the way and there's going to be some 25 sort of process to determine if they need to move it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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80 1 out a foot further because the valve is bigger than 2 they thought it was, whatever they procured, whatever.
3 It may move a little bit. So the as-built 4 plant may not be exactly as they imagined in the DCD 5 even though they may say, you know, this type of valve 6 procurement and things like that the valve might be a 7 little different, the locations might be different, 8 hangers might be different.
9 So the valve might not be exactly where 10 they thought it would be in the DCD. So the analysis 11 in the DCD gave an idea of where they would be. But 12 in the as-built we needed to make sure that somebody 13 went around and verified they didn't get moved out 20 14 feet.
15 So the idea was that for any valve that 16 wasn't essentially where they thought it would be in 17 the DCD they would do an evaluation and just like we 18 do an evaluation on the DCD there would be an 19 evaluation done. There would be a report stating that 20 the valve was not significantly changed, the position 21 was not significantly changed so it was still as close 22 as practical.
23 And we would evaluate that report and 24 verify that through the ITAAC.
25 MEMBER BROWN: Who does that evaluation?
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81 1 MR. WARD: Initially it would be the COL 2 or the applicant.
3 MEMBER BROWN: Is it evaluated before the 4 actual installation is complete or after it's all done 5 and welded and it's an uphill battle after that?
6 MR. WARD: I think that's up to the COL 7 and for us to work out in the construction section.
8 MEMBER BROWN: So there's no standard by 9 which you all would determine whether, I mean if you 10 walked in and saw it was ten feet away and if that's 11 the way they built it was okay, I'm just raising the 12 point about, I'm sorry. I apologize for that.
13 MR. WARD: Yes, no, the idea was that it 14 would be determined, you know, or evaluated by the COL 15 if they had to put it in a location that was slightly 16 different than originally planned. And we would 17 review the evaluation.
18 MEMBER BROWN: It's kind of an after the 19 fact type thing and it's got to be acceptable 20 regardless of where it is, is what I'm hearing. I 21 mean --
22 MR. WARD: I think if they were proposing 23 something radically different they would talk to us 24 first.
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82 1 common practice. 55 is reactor coolant system 2 penetrating containment. 56 is closed system 3 penetrating containment and 57 is open system.
4 And this allows, for instance a large 5 bulky valve like the main steam line to be out ten 6 feet with the structure for seismic whereas the two 7 and a half to three inch injection line would be 8 closer but there are some weld requirements on the 9 outer skin of containment.
10 So this is common practice. But like Bill 11 said, as long as it's not outrageous 50 feet away 12 hiding in a bunker with no penetration cut off, I mean 13 this is common practice. So this is --
14 MEMBER BROWN: I understand common 15 practice, Dick. It just seemed it was so open that it 16 could end up wherever you wanted to it to be and after 17 the fact you're not going to go change it even if it 18 was 50 feet away.
19 MEMBER SKILLMAN: Yes. But the openness 20 allows there to be discussion between the, what would 21 be the licensee and the regulator as they look at the 22 ITAAC. So I appreciate your concern and I think 23 you're right on target.
24 But this flexibility allows the designers 25 to do a very good job.
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83 1 MEMBER BROWN: I have no problem with the 2 flexibility issue although we did have an inspector 3 walk down through a submarine. He walked through a 4 hatch and hit his head, not his head but his helmet.
5 He said I normally don't do that in this 6 design submarine. I walk through here and I don't hit 7 my head. It turns out the entire main propulsion unit 8 was off by, in its alignment relative to the gears 9 going out the back end of the submarine ended up 10 having to rip everything apart and put it all back.
11 So it was an interesting question about 12 how close is good enough. As practical seems kind of 13 open. We can't design something, this gives you 14 flexibility. I understand that.
15 MR. WARD: The ITAAC as written states 16 that it has to provide consideration for the following 17 which are access for inspection to welds, containment 18 leaking testing and replacement and valve maintenance.
19 MEMBER BROWN: Okay, thank you.
20 MS. UMANA: Okay. If there are no more 21 questions. Rob, did you want to add anything or you 22 are good?
23 MEMBER BROWN: I'm happy.
24 MS. UMANA: Okay. Well now I'm going to 25 turn it over to Matt Thomas.
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84 1 MR. THOMAS: Good afternoon. I'm Matt 2 Thomas. I'm a technical reviews in the Reactor 3 Systems Branch. I was the lead reviewer for Section 4 6.3, the emergency core cooling section or system.
5 And we had a couple of issues come out of 6 the Phase 3 meeting. One of those open items was 7 related to the Boron-10 and boric acid recycling 8 capability and the APR1400 design.
9 The staff questioned the applicant on how 10 it maintains the Boron-10 isotopic concentration 11 within the specification that's assumed in the safety 12 analysis. Unfortunately there wasn't any information 13 on the DCD on that.
14 So an RAI was asked. And the resolution 15 of it was the applicant adding a tech spec and 16 surveillance requirement for periodic verification of 17 the Boron-10 atom concentration in the IRWST safety 18 injection tanks.
19 And they even threw it into the spent fuel 20 pool as well as they showed earlier. So the staff 21 found that was acceptable on the basis that, you know, 22 it's periodically verified that the concentration is 23 within the specs and the safety analysis.
24 MEMBER MARCH-LEUBA: Matt, out of 25 curiosity how do they measure the Boron-10? What I'm NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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85 1 thinking is what typically to calculate isotopic 2 concentration you would use a mass spectrometer which 3 is a very complex, expensive, difficult device.
4 If, boron is such a low mass material that 5 maybe you don't need that.
6 MR. THOMAS: It's a what material?
7 MEMBER MARCH-LEUBA: Boron is a low mass 8 material, z, like in zebra. I'm wondering if we're 9 putting a requirement there that will add tremendous 10 complexity to the plant.
11 Obviously KHNP did not complain. So they 12 must have a way to do it. Maybe they're planning to 13 send a sample to a laboratory.
14 MR. THOMAS: Yes, I'm not sure. I think 15 that would be up to the COL applicant to determine how 16 they want to measure that. If I'm not mistaken I 17 thought some CE plants operating now have done those 18 verifications.
19 You know, the test is every outage more or 20 less, every two years or so.
21 MEMBER MARCH-LEUBA: So it's once every 22 two years?
23 MR. THOMAS: Yes, right, because I mean 24 that water is not normally in contact with, you know, 25 high --
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86 1 MEMBER MARCH-LEUBA: If it's every two 2 years you can send the sample to a lab, yes.
3 MR. THOMAS: And then the last issue for 4 6.3 was related to an ACRS question from the previous 5 Subcommittee meeting regarding the IRWST vacuum 6 protection swing panels, whether or not they needed to 7 be included in the tech specs as well.
8 Ultimately to ensure the operability of 9 the IRWST during an accident the staff asked an RAI 10 8819, Question 06.02.02.47 basically just, you know, 11 provide a calculation showing the net positive suction 12 head assuming conservatively, you know, vacuum 13 conditions in the IRWST.
14 They provided a calculation. We reviewed 15 it in conjunction with our Containment Branch and 16 found that the margin in the net positive suction head 17 was adequate, was ample enough to maintain operability 18 in the IRWST even when you assumed the swing panels 19 fail to function.
20 So we found that it's not necessary for 21 them to be included in the tech specs. That's all we 22 have for 6.3.
23 MS. UMANA: Okay. So the conclusion we 24 drew after having the open items in the Chapter 6 SEC 25 is that the staff found all the supplemental NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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87 1 information provided by KHNP acceptable and there was 2 sufficient conservatism built in the KHNP APR1400 3 containment design. And that's all we have.
4 CHAIR SUNSERI: All right, great. Any 5 other questions from Members?
6 MEMBER SKILLMAN: No questions, thank you.
7 CHAIR SUNSERI: So we're ready to move on 8 to the next agenda item which is a discussion of RAIs 9 after Phase 4 meeting, mainly Chapter 7 and 19. This 10 was also intended originally as a closed session but 11 due to the content it has been decided to hold it as 12 an open session.
13 So we're going to turn it over to Bill 14 Ward it looks like.
15 MEMBER BROWN: Do we have any slides for 16 this?
17 CHAIR SUNSERI: There are no slides for 18 this. The content was more or less open. But Bill is 19 going to provide an overview and then we can ask any 20 questions.
21 (Off the record comments.)
22 MR. WARD: Bill Ward, lead PM. The 23 discussion here we, there was a concern on the part of 24 the Committee that there were RAI responses coming in 25 since we had the various Subcommittees, various NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 1 chapters.
2 And while it seemed like a lot if you're 3 not really counting in order to, you know, clarify and 4 quantify what there was I went through all the RAIs 5 that came in since the Subcommittee meetings for each 6 chapter and organized them and provided a table to 7 Chris Brown who has passed it on to you.
8 And it summarized the RAIs that came in 9 and gave you links to the outgoing RAI and responses 10 that came in, gave you a little description and my 11 evaluation with support from the tech staff about the 12 significance of the response.
13 And I don't know that we have it here.
14 But anyway, a number of them were going to, were in 15 support of this meeting so they are identified just as 16 support to be discussed in this meeting.
17 Even a few of those that weren't 18 identified that way actually were in support of this 19 meeting as well, ITAAC specifically. So they were 20 covered in part during the 14.3 presentation.
21 The rest of them were not very 22 significant. A lot of them were fairly, sort of 23 making up for issues that were previously identified.
24 There were, I think about six or eight of them that 25 specifically related to the, for the 19.3 beyond NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 1 design basis external event there were discussions in 2 there that there was a 480 volt GTG generator.
3 And that would be on site. And there's a 4 4.16 kV generator which is kept off site but would be 5 brought on site in the event that it was needed.
6 However, I guess the discussions have been 7 with whoever was maintaining those generators they 8 wouldn't necessarily be a GTG. So they've had to 9 update their DCD in a number of places to say this is 10 just the 4.16 kV mobile generator.
11 It's not necessarily GTGs because they've 12 taken the GTG out of it and they're clarifying that 13 discussion in a number of places where it got, before 14 it was easy to say, you know, this and this GTG 15 generators, you know.
16 Now they've got to say this GTG and this 17 other mobile generator. So they've got to clarify 18 that. So a number of these RAI responses are just old 19 RAI responses that are updating to use as the vehicle 20 to clarify the changes being made in the DCD.
21 But they are not significant in terms of 22 the design. In those cases they were beyond design 23 basis.
24 Anyway, I did not intend to go over any 25 particular one. But I am willing to take feedback and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 1 we can certainly discuss it in the full Committee if 2 there is one in particular.
3 MEMBER REMPE: So I apologize because I 4 didn't realize we were going to discuss this today.
5 But one of them caught my eye and I did not go through 6 and try and delve it out.
7 Could you talk a little bit about what the 8 corrections were to the structural containment and 9 pressure corrections for Chapter 19? It's toward the 10 bottom of your table. Let's see it's the one, two, 11 three, fourth one from the bottom of your table.
12 MR. WARD: Okay, yes --
13 MEMBER REMPE: It's got a yellow, it's 14 moderate.
15 MR. WARD: Yes, 1983 and 1992.
16 MEMBER REMPE: Yes, 1983 is the way to 17 designate it. And I just haven't looked into it.
18 Maybe it's not important. Maybe these are typos but 19 I just was curious what it was.
20 MR. WARD: No, I'm not familiar with it 21 specifically and unfortunately we don't have the PRA 22 type people here.
23 MEMBER REMPE: We can talk about it later.
24 It's nothing, I just hadn't see it and I thought --
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91 1 feedback on that.
2 MEMBER REMPE: Okay, thank you.
3 MR. WARD: So I'll mark that one.
4 CHAIR SUNSERI: You know, let me just jump 5 in here for a second and say that, you know, this 6 table was provided to all the Members to see what 7 concerns you might have had in advance. We received 8 some feedback from some Members and basically that 9 feedback has been addressed by Bill and his team.
10 So as it stands right now there were no, 11 as far as Rob and I know there are no open ACRS Member 12 questions about this RAI list. And this meeting, this 13 part of the meeting was going to be our final kind of 14 on the record discussion of that and close these 15 issues.
16 MEMBER BALLINGER: To kind of expand on 17 that a little bit the genesis of this is the third 18 iteration, if you will, because we're about to write 19 a letter and the letter was supposed to be with no 20 open items.
21 And then we in meetings realized that 22 there were several RAIs still outstanding and we 23 wanted to be sure that those RAIs when they got 24 responses which may be after we write the letter 25 actually, had no bearing on what we write in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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92 1 letter. That was the purpose, I think.
2 MR. WARD: Correct.
3 MEMBER BALLINGER: And so Bill produced 4 the table where he colored things in green, yellow and 5 some other color, moderate, something or other. And 6 then we solicited from the Members do you have any 7 issues? Do you agree with this basically?
8 And then we had a phone call, I forget 9 last week some time, right, where we passed it out and 10 we finally figured out that based on the feedback that 11 we got from some Members and additional RAI responses 12 that had already come in since the table that we were 13 probably going to be fine.
14 So that was the purpose of that. And 15 this, Bill sitting here is the third iteration or sort 16 of now is your chance kind of thing.
17 MR. WARD: There is one or two other RAI 18 responses that are coming in. One came in today. It 19 was on 13.6 which is not part of the review. But 20 there might be another one coming in and I can update 21 the table for that.
22 But all the RAI responses should be done 23 by next week or so. I'm not sure exactly when we'll 24 get the last ones in. So there should be no more RAI 25 responses before the final meeting.
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93 1 However, they will all be confirmatory 2 actions so they won't actually be closed in terms of 3 closing out the confirmatory action until we see DCD 4 Rev. 3. But they will define everything that's going 5 to be in DCD Rev. 3.
6 And then all we're waiting for is when we 7 get through the final Committee and verify that there 8 are no other issues Rev. 3 will be issued. And we're 9 targeting that for, you know, a couple of weeks after 10 the meeting to get Rev. 3 issued.
11 MEMBER BALLINGER: And we just want to 12 make sure that during the full Committee presentation 13 we don't end up with migraine headaches.
14 MR. WARD: And we're writing our safety 15 evaluation, our final safety evaluation report. In 16 some cases the chapters are already written.
17 But with the idea that what we're seeing 18 here with these confirmatory actions and what will be 19 in Rev. 3 that's it so that we can finish the final 20 safety evaluation within a few weeks after Rev. 3 is 21 issued.
22 That's our process. And if there's 23 anything else we can help you with your questions on 24 it.
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94 1 to figure out based on the right hand column. But 2 when I looked at the ML numbers for a couple dozen 3 just said an ML number. I had no idea what the 4 subject was or whether I should look at it.
5 MR. WARD: Okay.
6 MEMBER BROWN: And when I tried to open 7 the ML numbers they didn't open.
8 MR. WARD: Yes, the initial table was set 9 to open within the LAN. But I created a second table 10 which would open externally. Did you get that around, 11 Chris?
12 MEMBER BROWN: Yes, I didn't, we never.
13 MEMBER REMPE: The one I have, Matt, 14 somebody sent me and said Matt had looked at it. And 15 I tried clicking on it. But I actually again thought 16 I had more time.
17 And so I moved it over to the internal 18 system and then just hadn't had time to go through it.
19 CHAIR SUNSERI: The one that Chris sent 20 out all the links worked as far as I know.
21 MR. WARD: Yes, the first was internal.
22 I updated it for external.
23 MEMBER CORRADINI: I was just going to 24 say, this is Mike. I think I got the original where 25 the links worked and I didn't see anything that was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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95 1 substantive that concerned me.
2 I think, as I think Bill said these are 3 cleaning up things in the final DCD or not necessarily 4 the final. But the final one we'll see to make 5 everything consistent.
6 CHAIR SUNSERI: All right. So, Pete, are 7 you still out with us? Do you have any questions 8 about these RAIs?
9 MEMBER RICCARDELLA: No questions for me.
10 CHAIR SUNSERI: All right, thanks. Other 11 Members?
12 MEMBER SKILLMAN: No questions from me.
13 Thank you.
14 CHAIR SUNSERI: All right. Well, Bill, I 15 guess we'll let you go then.
16 MR. WARD: Thank you.
17 CHAIR SUNSERI: Thank you for making, that 18 review of that table actually was quite helpful to 19 support the review because when we initially heard the 20 size of the open items it was a little concerning.
21 But then the breakdown made it clear.
22 MR. WARD: I wanted to make sure it was 23 easy for everybody to find the RAIs. I actually put 24 the internal and external tables all in one 25 spreadsheet. I can send that to Chris and then you'll NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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96 1 have then all and you just pick which one you want.
2 CHAIR SUNSERI: All right, great. So at 3 this point we are done with the, all the topics on the 4 agenda. I will at this point reopen the floor for any 5 comments from the participants in the room and then 6 after we hear from them we'll open the phone line for 7 any members of the public.
8 So at this point anybody in the room like 9 to make any closing remarks, provide any comments?
10 All right, nobody. And now we'll go to the phone 11 line. Any members of the public would like to make a 12 comment?
13 All right. There are none speaking up.
14 So we'll close the phone line again. And at this time 15 I'd like to go around the room and ask for individual 16 Member comments. We'll start with Pete remotely.
17 Pete, anything else?
18 MEMBER RICCARDELLA: No comments here. I 19 think it's coming to a conclusion and I just 20 appreciate all the efforts by the staff and by KHNP.
21 CHAIR SUNSERI: All right, thank you.
22 Mike, anything else?
23 MEMBER CORRADINI: No. I am happy. And 24 again, also I want to thank KHNP and the staff. I 25 think they were very good on what I still think is a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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97 1 relatively tight schedule getting things to us and 2 explaining things if we have questions and clarifying.
3 So thanks to the both of you.
4 CHAIR SUNSERI: All right. And we'll 5 start to my right with Joy.
6 MEMBER REMPE: No, I don't have any 7 additional questions or comments.
8 CHAIR SUNSERI: Charlie?
9 MEMBER BROWN: I don't have anything else 10 to add except I did want to say that this is one of 11 the best of the reviews of Chapter 7 and the I&C 12 systems and the one line diagrams.
13 I thought KHNP and I reiterate, I think I 14 stated this in the last meeting as well and the staff 15 did a good job or responding particularly to that late 16 breaking Westinghouse watchdog timer issue which was 17 a, that needed to get resolved and resolved cleanly 18 which it was.
19 So I wanted to thank both the applicant 20 and the staff for doing a good job on that and think 21 they provided excellent responses.
22 CHAIR SUNSERI: All right. Thank you, 23 Charlie. Jose?
24 MEMBER MARCH-LEUBA: Nothing to add.
25 CHAIR SUNSERI: I'm going to skip over Ron NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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98 1 for just a second and we'll go to Dick.
2 MEMBER SKILLMAN: Thank you, Mr. Chairman.
3 Just thank you to the KHNP team and to the NRC staff, 4 thank you.
5 CHAIR SUNSERI: Margaret?
6 MEMBER CHU: No comments. Thank you.
7 CHAIR SUNSERI: Okay. So people are 8 probably wondering why I was running the meeting today 9 with Ron in the room because I am the co-chairman and 10 we were giving Ron the opportunity to prepare for the 11 final meeting and not have to spend a lot of time 12 getting ready for this meeting.
13 So having said that, he is here though and 14 I will give him the respect of his comments at this 15 point.
16 MEMBER BALLINGER: Rolling.
17 CHAIR SUNSERI: Rolling, yes.
18 MEMBER BALLINGER: I fear that we have 19 established, the staff has established a precedent 20 which is going to be hard to meet because my 21 understanding is that they've never completed a review 22 in 42 months.
23 MR. WARD: That's what I understand too.
24 MEMBER BALLINGER: So I think this has 25 actually been a remarkable job. And I like everybody NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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99 1 else commend the KHNP folks and the staff.
2 But when I say staff I mean not just the 3 staff but our staff, Chris and company and all of the 4 ACRS staff who have really, really turned to on this 5 and done a great job. The communication back and 6 forth amongst the various parties has always been very 7 quick and very collegial.
8 And so I think, you know, it's not an 9 understatement to say that they did an outstanding 10 job. And so we look forward to what, July the last 11 meeting.
12 And so we'll continue to work with the 13 staff and KHNP as necessary. We'll be working on the 14 draft for the letter starting on Wednesday, Thursday, 15 excuse me, Thursday. So and again, thank you all 16 very, very, very much.
17 CHAIR SUNSERI: All right. Thanks, Ron.
18 So with those good remarks there I would like to say 19 that, I opened the meeting saying this was the last 20 planned Subcommittee meeting.
21 Having gone through these topics today I 22 do not see any issues that would cause us to want to 23 have another Subcommittee meeting. So therefore, I 24 would float a recommendation that we go forward with 25 the full Committee on July 11th which would be the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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100 1 final APR1400 review.
2 So can I just get an acknowledgment from 3 the Subcommittee Members to support that?
4 MEMBER REMPE: But a Subcommittee can make 5 a recommendation but it has to be a P&P. Isn't that 6 the way our processes are established?
7 CHAIR SUNSERI: Well that's what I'm 8 saying. I mean I'm asking for a recommendation right.
9 MEMBER REMPE: Okay. So we're making that 10 recommendation and then we'll have P&P and we're 11 having the meeting the same month we're having the 12 P&P.
13 MEMBER MARCH-LEUBA: Didn't we already 14 have the P&P last week?
15 MEMBER REMPE: Well last, mid-June. We're 16 kind of a little bit outside the normal process, 17 right. I mean we can say we agree at the full 18 Committee P&P and then issue the letter. But we're 19 really, do you understand where I'm coming from?
20 CHAIR SUNSERI: So I get it right. But I 21 suppose we held these Subcommittee meetings in support 22 of the full Committee meetings. And when the P&P met 23 in July we hadn't had this meeting yet.
24 So they made a, the P&P made a 25 recommendation based on the knowledge that was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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101 1 available at the time. We have more information now 2 which continues to support the recommendation.
3 So I guess I'm just asking for our 4 Committee support of the continuing on with the July 5 full Committee meeting. Maybe that's a better way of 6 saying it. Okay, everybody.
7 All right, very good. All right, so with 8 that I would like to extend my appreciation for 9 everyone's support today. We did advance through the 10 schedule faster than it was on paper and I appreciate 11 the efforts to do that.
12 So without any further comments we are 13 closed.
14 (Whereupon, the above-entitled matter went 15 off the record at 3:08 p.m.)
16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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NON-PROPRIETARY APR1400 DCA Chapter 13: Conduct of Operation ACRS SC Meeting (June 19, 2018 ) KEPCO/KHNP June 19, 2018 APR1400-K-O-EC-17014-NP
NON-PROPRIETARY Contents Overview of Chapter 13 List of Submitted Documents and Summary of RAIs Section Overview List of Open Items Current Status Attachments Acronym ACRS SC Meeting (June 19, 2018 )
1 APR1400-K-O-EC-17014-NP
NON-PROPRIETARY Overview of Chapter 13 List of Submitted Documents Document No. Title Rev. Type APR1400-K-X-FS-14002 APR1400 Design Control Document 2 DCD
-P & NP Tier 2: Chapter 13 Conduct of Operations APR1400-K-X-IT-14001 APR1400 Design Control Document 2 DCD
-P & NP Tier 1 Summary of RAIs No. of Questions No. of Responses Not Responded No. of OI ACRS SC Meeting (June 19, 2018 )
52 52 0 0 List of Open Items There are no open items.
2 APR1400-K-O-EC-17014-NP
NON-PROPRIETARY Overview of Chapter 13 Section Overview Section Title Major Contents Organizational Structure Specific management, technical support, operating organization and 13.1 of the Applicant qualification of NPP personnel will be developed by COL applicant Plant staff training program will be developed in in accordance with NEI 06-13.2 Training 13A Template for an Industry Training Program Description Emergency plan features considered in design basis (TSC, OSC, EOF 13.3 Emergency Planning and so on) provided for Emergency planning Operational Program 13.4 Operational Program will be implemented per SECY 05-197 ACRS SC Meeting (June 19, 2018 )
Implementation APR1400 Emergency Operating Guidelines to support Plant Specific 13.5 Plant Procedures Guidelines(P-STGs) 13.6 Physical Security SRI and SGI 13.7 Fitness for Duty Fitness-for-duty program will be developed by COL applicant 3 APR1400-K-O-EC-17014-NP
NON-PROPRIETARY Current Status Chapter 13 is completed with no open item.
KHNP continues to monitor Chapter 13 to assure any conforming changes are addressed.
ACRS SC Meeting (June 19, 2018 )
4 APR1400-K-O-EC-17014-NP
NON-PROPRIETARY
Attachment:
Acronyms COL : combined license SGI : security safeguards information SRI : security-related information ACRS SC Meeting (June 19, 2018 )
5 APR1400-K-O-EC-17014-NP
Presentation to the ACRS Subcommittee Korea Hydro & Nuclear Power Co., Ltd (KHNP)
APR1400 Design Certification Application Review Safety Evaluation with No Open Items: Chapter 13 CONDUCT OF OPERATIONS JUNE 19, 2018
Staff Review Team
Surinder Arora Sections 13.2 and 13.5 Reactor Licensing Branch (NSIR)
Eddie Robinson Section 13.3 Licensing Branch 2 (NRO)
William Ward Sections 13.1 and 13.4
- Project Managers Lead Project Manager - William Ward Chapter 13 Project Manager - William Ward June 19, 2018 Chapter 13 Conduct of Operations 2
Overview of Design Certification Application, Chapter 13 SRP Section/Application Section Organizational Structure of the Applicant - contains COL items which require the COL applicant to develop the management and tech support organizational structure including design, construction, 13.1 operating, and maintenance responsibilities. This includes the qualification requirements such as education, training, and experience for each position.
Training - contains COL items which require the COL applicant to 13.2 develop the description and schedule of the training program for licensed reactor operators and non-licensed plant staff.
Emergency Planning (EP) - describes the design features, facilities, 13.3 functions, and eqpt. necessary for EP and requires the COL applicant to develop the site-specific design.
Operational Program Implementation - contains COL items which 13.4 require the COL applicant referencing this design to develop operational programs consistent with SRM-SECY-05-0197.
Plant Procedures - contains COL items which require the COL 13.5 applicant to briefly describe the admin & operating procedures for all operational modes, and a schedule for preparing the procedures.
June 19, 2018 Chapter 13 Conduct of Operations 3
Technical Topics Section 13.1 - Organizational Structure Scope of Review
- The purpose of this section is to provide assurance that the applicant has established acceptable COL Information Items pertaining to the corporate-level management and technical support organizations necessary for the safe construction and operation of this design, including training and qualification requirements. That is, the COL applicant will have the necessary managerial and technical resources to support the plant staff in construction, operation, maintenance, and in the event of an emergency.
Technical Challenges
- None.
Finding
- Eleven COL information items are provided, COL 13.1(1) through 13.1(11). Staff found that the COL information items appropriately identified and sufficiently addressed the required information without the need for additional items.
Conclusion
- The staff has reviewed DCD Tier 2, Section 13.1, Organizational Structure of the Applicant, and determined that this approach to describing the corporate-level management and technical support organization, and the onsite operating organization, is acceptable to meet all applicable requirements.
June 19, 2018 Chapter 13 Conduct of Operations 4
Technical Topics Section 13.2 - Training Scope of Review
- The purpose of this section is to provide assurance that the applicant analyses job performance to design, develop, implement, and evaluate licensed and non-licensed staff training programs.
- The applicant establishes and maintains a staff of adequate size, ability & technical competence to operate and maintain the facility and to protect public health and safety.
Technical Challenges
- None. The applicant has provided six COL information items stating that the COL applicant is responsible for developing the site-specific training programs for the plant staff.
Findings
- COL information items COL 13.2(3) and COL 13.2(4) pertaining to training programs for licensed and non-licensed staff, initially stated that these programs will be in accordance with NUREG-800, Sections 13.2.1.l.3 and 13.2.2.l.3, respectively. In response to the staffs RAI, references to the NUREG-800 sections were changed to NEI 06-13A.
- Except for the verification of the confirmatory item 13.02.01 in Revision 3 of the DCD, there are no open issues.
Conclusion
- The staff has reviewed DCD Tier 2, Section 13.2, Training, and determined that applicants approach to describing, developing, and documenting the training programs is acceptable.
June 19, 2018 Chapter 13 Conduct of Operations 5
Technical Topics Section 13.3 - Emergency Planning (EP)
Scope of Review
- The review addresses areas which are technically relevant to the design and are not site-specific, such as a habitable technical support center (TSC) with adequate space, data retrieval capabilities and dedicated communications eqpt., and an operational support center (OSC) with adequate communications.
- The applicant determines the extent to which EP features are included in the application as part of the certified design. There is no minimum amount of design-related EP that must be addressed.
Technical Challenges
- None. The applicant has provided six COL information items.
Findings
- The DCD describes the TSC with adequate space, data retrieval capabilities and dedicated communications eqpt. The TSC satisfies size, feature, and location requirements.
- SRP Interface Areas Protection of MCR personnel during an emergency is addressed in SE Section 6.4 TSC data retrieval capabilities is addressed in SE Section 7.5 June 19, 2018 Chapter 13 Conduct of Operations 6
Technical Topics Section 13.3 - Emergency Planning Findings (contd)
Post Accident Sampling System is addressed in SE Section 9.3.2 TSC HVAC is addressed in SE Section 9.4.1 TSC Voice and Data Communications Equipment is addressed in SE Section 9.5.2 Onsite Decontamination Facilities is addressed in SE Section 12.3 TSC dose analysis is addressed in SE Section 15.0.3 Evaluation of the emergency preparedness for a Beyond Design Basis External Event (BDBEE), including addressing Near Term Task Force (NTTF) Recommendation 9.3, is in SE Section 19.3.
Conclusion
- The staff has reviewed DCD Tier 2, Section 13.5, Emergency Planning, and determined that applicants approach to EP, including descriptions of facilities and capabilities, adequately addresses the EP design-related features and generic issues for the APR1400 standard plant.
- The staff determined that the COL items for emergency planning are appropriate and acceptable.
June 19, 2018 Chapter 13 Conduct of Operations 7
Technical Topics Section 13.4 - Operational Programs Scope of Review
- SRM-SECY-05-0197 (February 22, 2006) approved an approach for Operational Programs which relieved the DC applicant of the burden of describing operational programs which only the COL applicant could describe. As a result, NRC guidance states that the DCD should include a COL Information Item(s) directing the COL applicant to develop operational programs in accordance with SECY-05-0197.
- NRC staff reviews the application for the required COL Information Item(s).
Technical Challenges
- None.
Findings
- The applicant provided COL information items COL 13.4(1) and COL 13.4(2) stating that the COL applicant is responsible for developing the operational programs in accordance with SECY 1997 and a leakage monitoring and prevention program in accordance with NUREG-0737, Clarification of TMI Action Plan Requirements, Item III.D.1.1.
Conclusion
- The staff has reviewed DCD Tier 2, Section 13.4, Operational Program Implementation, and determined that the three COL Information Items the applicant provided are appropriate and acceptable.
June 19, 2018 Chapter 13 Conduct of Operations 8
Technical Topics Section 13.5 - Plant Procedures Scope of Review
- Plant Procedures encompass:
Administrative Procedures, Operating and Emergency Operating Procedures (EOPs), and Maintenance and Other Operating Procedures for safety-related activities.
- Development of site-specific procedures is beyond the scope of the DC application.
Responsibility resides with the COL applicant referencing the design.
COL information items pertaining to procedure descriptions, and procedure program development / implementation, are identified by the DC applicant.
- Generic Technical Guidelines (GTGs); otherwise referred to as the Emergency Operating Guidelines (EOGs)
Used by COL applicants to develop their Plant-Specific Technical Guidelines (P-STGs), from which their EOPs will be developed.
Preparation of the APR1400 EOGs and submittal to the NRC for review is the responsibility of the DC applicant.
June 19, 2018 Chapter 13 Conduct of Operations 9
Technical Topics Section 13.5 - Plant Procedures Scope of Review (contd)
- Staff evaluated the DC application for:
Acceptability of COL information items pertaining to the establishment of a program for development and implementation of plant procedures and to the descriptions of plant procedures.
Technical adequacy of the APR 1400 EOGs, and determination of their acceptability for use as a basis for development of COL applicant P-STGs.
Technical Challenges
- None.
Findings
- The EOGs are based on the Combustion Engineering Owners Group GTGs (CEN-152), which have been previously reviewed and approved by the staff,
- The EOGs retain the structural format and event mitigation strategies of CEN-152,
- The EOGs have been modified to reflect the APR1400 specific design features, June 19, 2018 Chapter 13 Conduct of Operations 10
Technical Topics Section 13.5 - Plant Procedures Findings (contd)
- APR1400 specific design features have been incorporated into the transient analyses for events categorized in the Optimal Recovery Guidelines of the APR1400 EOGs, and
- Transient analyses results provided in APR1400 technical report KEPCO E&C/ND/TR/11-005, "Best Estimate Analyses for the Operational Transients and Accidents for APR1400 Emergency Operating Guidelines, have been reviewed and found to be acceptable for use in the development of the APR1400 EOGs.
Conclusions
- The staff determined that 6 out of 7 COL information items in Section 13.5 are acceptable. The remaining COL information item [13.5(7)] requires modifications that have been adequately resolved through the RAI process and have been identified as a Confirmatory Action for confirmation in Revision 3 of the DCD.
- The staff determined that the APR1400 EOGs are technically adequate and acceptable for use in development of the COL applicant P-STGs.
June 19, 2018 Chapter 13 Conduct of Operations 11
NON-PROPRIETARY APR1400 DCA Chapter 14.3 Inspections, Tests, Analyses, and Acceptance Criteria ACRS Meeting (June 19 , 2018)
KEPCO/KHNP June 19, 2018 1 APR1400-K-X-EC-18005-NP
NON-PROPRIETARY Contents Overview of Chapter 14.3 Section Overview List of Submitted Documents RAI Questions related to Section 14.3 Summary of Major Responses Current Status ACRS Meeting (June 19 , 2018)
Attachment Acronyms 2 APR1400-K-X-EC-18005-NP
NON-PROPRIETARY Overview of Chapter 14.3 Section Overview Section Description Remark 14.1 Specific Information to be Addressed for the Initial Plant Test Program Presented in ACRS SC on January 14.2 Initial Plant Test Program 24, 2018 14.3 Inspection, Tests, Analyses, and Acceptance Criteria 14.3.1 Tier 1, Chapter 1: Introduction 14.3.2 Tier 1, Chapter 2: Design Descriptions and ITAAC ACRS Meeting (June 19 , 2018) 14.3.3 Tier 1, Chapter 3: Interface Requirement 14.3.4 Elements of Design Material Incorporated into Tier 1 14.3.5 Design ITAAC Closure Process 14.3.6 Combined License Information 3 APR1400-K-X-EC-18005-NP
NON-PROPRIETARY Overview of Chapter 14.3 List of Submitted Documents ADAMS Document No. Title Revision Type Accession No.
APR1400-K-X-FS-14002-APR1400 Design Control Document Tier 2 2 DCD -
P/NP APR1400-K-X-FS-14001-APR1400 Design Control Document Tier 1 2 DCD -
P/NP ACRS Meeting (June 19 , 2018) 4 APR1400-K-X-EC-18005-NP
NON-PROPRIETARY Overview of Chapter 14.3 91 RAI Questions 14.3.2 Tier 1, Chapter 2: Design Descriptions and ITAAC # of Qs 14.3.2.1 Site Parameters 0 14.3.2.2 Structural and Systems Engineering 3 14.3.2.3 Piping Systems and Component 9 14.3.2.4 Reactor Systems 5 14.3.2.5 Instrumentation and Controls 33 14.3.2.6 Electrical Systems 9 14.3.2.7 Plant Systems 0 ACRS Meeting (June 19 , 2018) 14.3.2.8 Radiation Protection 16 14.3.2.9 Human Factors Engineering 3 14.3.2.10 Emergency Planning 0 14.3.2.11 Containment Systems 3 14.3.2.12 Physical Security Hardware 10 14.3.2.13 Design Reliability Assurance Program 0 Total 91 5 APR1400-K-X-EC-18005-NP
NON-PROPRIETARY Overview of Chapter 14.3 Current APR1400 ITAAC 2.0 Design Descriptions and ITAAC # in Rev.2 Final (2018.6) 2.1 Site Parameters 0 0 2.2 Structural and Systems Engineering 30 36 2.3 Piping Systems and Component 2 2 2.4 Reactor Systems 213 209 2.5 Instrumentation and Controls 159 159 2.6 Electric Power 187 187 2.7 Plant Systems 484 483 ACRS Meeting (June 19 , 2018) 2.8 Radiation Protection 3 3 2.9 Human Factors Engineering 2 2 2.10 Emergency Planning 6 6 2.11 Containment Systems 81 84 2.12 Physical Security Hardware 30 30 2.13 Design Reliability Assurance Program 1 1 Total 1198 1202 6 APR1400-K-X-EC-18005-NP
NON-PROPRIETARY Summary of Major Responses ITAAC Wording Changes - RAI 558-9456 (Q. 14.03.01-1)
Issue:
- ITAAC wording changes based on NRC guidance, and lessons learned from plants under construction
- Resolve discrepancies and provide technical clarifications Resolution:
ACRS Meeting (June 19 , 2018)
- Revise applicable sections based on suggested ITAAC word changes or alternative language
- Discrepancies were corrected to ensure overall consistency 7 APR1400-K-X-EC-18005-NP
NON-PROPRIETARY Summary of Major Responses ITAAC information on Structures - RAI 557-9199 (Q. 03.08.05-20)
Issue: Structural information on seismic Category I structures required
- Principal codes and standards with editions
- Key dimensions and tolerances, Critical sections and design attributes
- Seismic analysis method, in-structure response spectra for key locations ACRS Meeting (June 19 , 2018)
Resolution: The requested information will be added
- Tier 1 Section 2.2 : Related information added COL 2 Section 3.8 : COL item added for tolerances acceptance
- Tier Description Identifier criteria COL 3.8(22) The COL applicant may provide construction tolerance acceptance criteria and the basis for criteria (e.g., through the use of analysis, industry research, and/or testing) for cases where the tolerances in ACI 117 and ANSI/AISC 303 may be exceeded, for structural concrete and steel, respectively.
8 APR1400-K-X-EC-18005-NP
NON-PROPRIETARY Summary of Major Responses Communication Independence of ESF-CCS - RAI 71-7906 (Q. 14.03.05-11)
Issue: Verification of communication independence in as-built ESF-CCS.
Resolution: ITAAC are added as follows Independences are achieved using key communication features Use of dual ported memory ACRS Meeting (June 19 , 2018)
Separation between functional and communication processor Pre-defined data sets, protocol, error checking code Related interfaces PPS and ESF-CCS (between safety divisions)
ESCM and IFPD (between safety and non-safety) 9 APR1400-K-X-EC-18005-NP
NON-PROPRIETARY Summary of Major Responses Priority Logic within ESF-CCS - RAI 317-8271 (Q. 14.03.05-29)
Issue: Priority logic for manual controls and automatic safety system at the ESF-CCS loop controller Resolution: ITAAC are added to confirm that priority logic for 3 different signals are implemented as follows High priority : ESF actuation signal from PPS Low priority : ESCM manual command signal and minimum ACRS Meeting (June 19 , 2018) inventory switch manual command signal 10 APR1400-K-X-EC-18005-NP
NON-PROPRIETARY Summary of Major Responses CPU load restrictions in CPCS - RAI 554-9146 (Q. 07.02-18)
Issue: Include the CPU load restrictions in ITAAC.
Resolution:15 restrictions are included in 2.5.1.1.
ACRS Meeting (June 19 , 2018) 11 APR1400-K-X-EC-18005-NP
NON-PROPRIETARY Summary of Major Responses Clarification of Diversity between DAS & PPS/ESF-CCS - RAI 33-7880 (Q. 07.08-1)
Issue: Clarify the diversity between the DAS and the PPS/ESF-CCS.
Resolution: ITAAC is revised to confirm that the diversity is maintained in below aspects ACRS Meeting (June 19 , 2018)
Hardware diversity : PLC vs FPGA Software diversity : Different programing tools used Human diversity : Independent development design team 12 APR1400-K-X-EC-18005-NP
NON-PROPRIETARY Current Status Chapter 14, Section 14.3 is completed.
All RAI responses were submitted.
Some issues regarding ITAAC have been resolved with adequate and sufficient discussion with the staff.
Changes in the responses to RAIs were incorporated into DCD Rev.2, and remaining will be reflected upcoming DCD Rev.3.
ACRS Meeting (June 19 , 2018) 13 APR1400-K-X-EC-18005-NP
NON-PROPRIETARY Attachment : Acronyms ESF-CCS: Engineered Safety Features - Component Control System CPCS : Core protection Calculator System DAS : Diverse Actuation System LC : Loop Controllers PPS : Plant Protection System PLC : Programmable Logic Controller ACRS Meeting (June 19 , 2018)
FPGA : Field Programmable Gate Array 14 APR1400-K-X-EC-18005-NP
Presentation to the ACRS Subcommittee Korea Hydro & Nuclear Power Co., Ltd (KHNP)
APR1400 Design Certification Application Review Safety Evaluation with No Open Items:
CHAPTER 14 VERIFICATION PROGRAMS Section 14.3 ITAAC June 19, 2018 1
Staff Review Team
- Project Managers
- Lead Project Manager: William Ward, NRO/DLSE/LB2
- Project Manager: Cayetano Santos, NRO/DLSE/LB2
- Technical Staff
- Various staff in NRO, NRR, and NSIR 2
Technical Topics
- Overview of SER Section 14.3
- RAI 551-9199 Q 03.08.05-20
- RAI 541-8724 Q 06.02.05-12
- RAI 554-9146 Q 07.02-18
- RAI 555-9163 Q 07.02-19
- RAI 553-9084 Q 18-134 3
Technical Topics Overview of SER Section 14.3
- Section 14.3.1 documents staff review of Tier 1 information including definitions, general provisions, design descriptions, and ITAAC Tables
- Based on DCD Revision 1 and RAI responses as of September 2017
- RAI 558-9456 Question 14.03.01-1
- Requested applicant make changes to Tier 1 information and ITAAC to
- Clarify the technical content
- Ensure the ITAAC can be performed prior to fuel load
- Incorporate lessons learned from a plant currently under construction
- Staff found RAI response acceptable because applicant agreed to the requested changes, provided clarification, and corrected discrepancies 4
Technical Topics Overview of SER Section 14.3
- Sections 14.3.2 through 14.3.13 document the staffs review of the ITAAC or reference other SER Chapters containing ITAAC evaluation
- While finalizing Section 14.3 staff determined that some of the ITAAC evaluations in other SER chapters needed to be revised
- Since many of these other chapters were previously provided to ACRS, staff provided ITAAC Evaluation Cross Reference Table 5
Technical Topics Central Processing Unit (CPU) load Restriction
- RAI 554-9146, Question 07.02-18
- Requested applicant to include
- CPU load restrictions for the core protection calculator system (CPCS) in Section 2.5.1, Tier 1 of the DCD
- ITAAC to verify the load restrictions are adequately implemented in the as-built CPCS
- Staff found RAI response acceptable because applicant agreed to include load restrictions in Tier 1, Section 2.5.1 and corresponding ITAAC to verify the implementation of the load restrictions 6
Technical Topics Watchdog Timer (WDT) Implementation
- RAI 555-9163, Question 07.02-19 requested applicant to address WEC NSAL 17-2 as related to WDT implementation within Common Q-based safety-related I&C systems
- Confirmation on software stall timer activation
- Window WDT timer implementation
- ITAAC to verify implementation of Window WDT in as-built system
- Staff found RAI response acceptable because applicant agreed to activate software stall timers, modify all references to WDT to specify use of Window WDT, specify Window WDTs are hardware, and include ITAAC to verify WDT implementation in as-built system 7
Technical Topics Overview of SER Section 14.3.9
- There are still two HFE ITAAC; however, additional information has been added to DCD Tier 1, Section 2.9 to provide a means for constraining changes to the Tier 2 HFE IPs in lieu of designating the HFE IPs as Tier 2*
- The staff initially planned to designate the HFE IPs as Tier 2*
- SECY-17-0075 (issued in July 2017) explains that Tier 2* information must be demonstrated to have the same safety significance as Tier 1, and Tier 2* should be applied only when an applicant determines the additional flexibility for making changes could be beneficial.
- Following its issuance, KHNP informed staff it did not intend to use Tier 2* information
- Given the IPs would not be Tier 2* and were designated as Tier 2 in the application, the staff could not rely on the 50.59-like process to ensure that any changes made to the IPs would not invalidate the safety finding for the applicants HFE program
- The staff issued RAI 553-9084, Question 18-134 to address this issue 8
Technical Topics Overview of SER Section 14.3.9
- In response to RAI 553-9084, Question 18-134 the applicant provided additional information in DCD Tier 1 to constrain changes to the Tier 2 information
- As a result, changes to the HFE IPs can be made without staff approval as long as the IPs continue to conform to the review criteria in NUREG-0711, Rev 3 and comply with the Tier 1 information related to the ISV testing.
- The staff finds this acceptable because the staffs findings on the applicants HFE program are based on conformance to the review criteria in NUREG-0711, Rev 3 and the specific information related to ISV testing that has been added to Tier 1.
9
Conclusion Upon incorporation of the confirmatory items into a subsequent DCD revision, the staff concludes that the APR1400 ITAAC are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will operate in accordance with the design certification, the provisions of the AEA, and the NRCs rules and regulations.
10
NON PROPRIETARY APR1400 DCA Chapter 6: Engineered Safety Features 15thMeeting Pre-application ACRS (June 19.Meeting 2018) KEPCO/KHNP June 19, 2018 APR1400-Z-A-EC-18001-NP
NON PROPRIETARY Contents Overview of Chapter 6 Section Overview List of Submitted Documents List of Open Items Summary of Open Items Current Status 15thMeeting Pre-application (June 19.Meeting Attachments ACRS 2018)
Acronyms 1 APR1400-Z-A-EC-18001-NP
NON PROPRIETARY Overview of Chapter 6 Section Overview Section Major Contents 6.1 Engineered Safety Features
- Material selection and fabrication of ESF components.
Materials
- Pre-stressed concrete containment
- Containment spray system 6.2 Containment Systems
- Containment air purification and cleanup systems
- Containment isolation system
- Containment combustible gas control system 6.3 Safety Injection System
- Safety injection system 15thMeeting Pre-application (June 19.Meeting 6.4 Habitability Systems
- ESF filter systems 6.5 Fission Product Removal and
- Containment spray system Control Systems
- Containment 6.6 In-service Inspection of Class 2
- Preservice and in-service inspection and system pressure test for ASME and 3 Components Section III Class 2 and 3 components 6.8 In-containment Water Storage
- In-containment water storage system System 2 APR1400-Z-A-EC-18001-NP
NON PROPRIETARY Overview of Chapter 6 List of Submitted Documents ADAMS Document No. Title Revision Type Accession No.
APR1400-K-X-FS-14002-APR1400 Design Control Document Tier 2 2 DCD -
P/NP APR1400-K-X-FS-14001-APR1400 Design Control Document Tier 1 2 DCD -
P/NP APR1400-Z-A-NR-14007- Technical LOCA Mass and Energy Release Methodology 1 ML17193A960 P & NP Report 15thMeeting Pre-application ACRS (June 19.Meeting 2018) 3 APR1400-Z-A-EC-18001-NP
NON PROPRIETARY Overview of Chapter 6 List of Open Items ADAMS Item No. Related RAI Title Accession #
RAI 296-8342 Question Containment Peak Pressure/Temperature -
1 ML17170A215 06.02.01.01.A-2 Passive Heat Sink RAI 296-8342 Question 06.02.01.01.A-3 Containment Peak Pressure/Temperature- ML17081A285 2
RAI 378-8442 Question GOTHIC Model ML17186A377 06.02.01.01.A-9 RAI 327-8354 Question Basis for the back pressure assumption 3 ML16034A202 06.02.01.01.A-6 during reflood phase RAI 378-8442 Question Containment Peak Pressure/Temperature-15thMeeting Pre-application (June 19.Meeting 4 ML17178A280 06.02.01.01.A-10 Justification of Containment Pressure ACRS 2018)
ML16202A539 RAI 496-8630 Question 5 Boron-10 ML17180A454 06.03-10 ML17222A209 4 APR1400-Z-A-EC-18001-NP
NON PROPRIETARY Summary of Open Items Open Item: Containment Peak Pressure/Temperature -
Passive Heat Sink Related RAIs : RAI 296-8342 (Q 06.02.01.01.A-2)
Description of issue
- Methodology to address PHS thickness 15thMeeting Pre-application (June 19.Meeting Resolution:
ACRS 2018)
- KHNP clarified the description and number of PHS relied upon in the analysis in a revised response to the RAI.
- KHNP clarified how it modeled PHS thickness in response to the RAI, and updated the PHS modeling description in the DCD and technical report 5 APR1400-Z-A-EC-18001-NP
NON PROPRIETARY Summary of Open Items Open Item: Containment Peak Pressure/Temperature -
RAI 296-8342 (Q 06.02.01.01 A-3),
RAI 378-8442 (Q 06.02.01.01 A-9)
Description of issues
- Application of Wall Condensing Model (Direct/DLM) 15thMeeting Pre-application (June 19.Meeting
- Effects of Inertial length ACRS 2018)
Resolution
- Applied Tagami/Uchida in lieu of Direct/DLM
- Increased Inertial Length used in the analysis
NON PROPRIETARY Summary of Open Items Open Item: Basis of the back pressure assumption during the reflood phase Related RAIs
- RAI 327-8354 Question 06.02.01.01.A-6 Description of issue
- The staff asked KHNP to provide the basis of the back pressure assumption of 58 psia and to explain whether an even lower value for containment back 15thMeeting Pre-application (June 19.Meeting pressure would be more conservative for the M&E release during the reflood phase.
ACRS 2018)
- The staff needs to establish that the applicants analysis covered a sufficient DBA analysis domain for the containment peak pressure analysis using two different computer codes in order to accept the assumed value of 58 psia of containment back pressure.
7 APR1400-Z-A-EC-18001-NP
NON PROPRIETARY Summary of Open Items Open item related RAI 327-8354 Question 06.02.01.01.A-6 (Continued)
Resolution:
- KHNP provided the calculated containment pressures between the EOB and the peak time for LOCA cases, which show that the assumed back pressure of 58 psia is lower than most of the calculated containment pressures. Therefore, the assumed containment back pressure is considered to be a conservative.
The minimum containment pressure of 57.157 psia would not significantly affect the conservatism of the back pressure assumption.
- A lower value for containment back pressure may result in more conservative output as compared to the output when 58 psia is used. However, since using 15thMeeting Pre-application (June 19.Meeting 58 psia as input is already conservative as mentioned above, additional conservatism is not considered necessary.
ACRS 2018) 8 APR1400-Z-A-EC-18001-NP
NON PROPRIETARY Summary of Open Items Open Item: Containment Peak Pressure/Temperature -
Justification of Containment Pressure Related RAIs : RAI 378-8442 (Q 06.02.01.01.A-10)
Description of issue
- KHNP was requested to justify how it determined the pressure ratio at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would meet the SRP acceptance criterion, which requires the pressure ratio be less than 50%.
Resolution:
15thMeeting Pre-application ACRS (June 19.Meeting 2018)
- KHNP used British pressure gauge units (psig) to represent pressure values in accordance with the requirement in RG 1.206 Table 6-1.
- Pressure ratio was determined from dividing peak pressure by pressure at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. APR1400 design has a pressure ratio of 37.1 % at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
9 APR1400-Z-A-EC-18001-NP
NON PROPRIETARY Summary of Open Items Open Item: Boron-10 Related RAIs : RAI 496-8630 (Q 06.03-10)
Description of issue
- For the APR1400 design, how is the minimum Boron-10 atom percent assured, if boron recycling is to be used.
Resolution:
- The surveillance requirement for minimum Boron-10 atom percent was added in TS 3.5.1 (SIT), TS 3.5.4 (IRWST), TS 3.7.15 (SFP) and the related TS Bases, 15thMeeting Pre-application (June 19.Meeting accordingly.
ACRS 2018) 10 APR1400-Z-A-EC-18001-NP
NON PROPRIETARY Current Status Chapter 6 is complete All items in Chapter 6 are completed.
5 open items, that were identified in Phase 2 and 3, have been resolved with adequate and sufficient discussion with the staff.
Changes in Chapter 6 as reviewed and marked-up in response to the RAIs have been incorporated in DCD 15thMeeting Pre-application (June 19.Meeting Rev.2 ACRS 2018) 11 APR1400-Z-A-EC-18001-NP
NON PROPRIETARY Attachment : Acronyms DEHLSB: Double Ended Hot Leg Slot Break DEDLSB: Double Ended Discharge Leg Slot Break DEDLGB: Double Ended Discharge Leg Guillotine Break EOB: End of Blowdown IRWST: In-containment Refueling Water Storage Tank KHNP: Korea Hydro & Nuclear Power LOCA: Loss of Coolant Accident MSLB: Main Steam Line Break 15thMeeting Pre-application (June 19.Meeting M/E: Mass and Energy (Release)
ACRS 2018)
P/T: Pressure and Temperature SIS: Safety Injection System 12 APR1400-Z-A-EC-18001-NP
NON PROPRIETARY Attachment : Acronyms CVCS: Chemical Volume Control System IRWST: In-containment Refueling Water Storage Tank ITAAC: Inspection, Tests, Analyses, and Acceptance Criteria NNS: Non Nuclear Safety NPSHa: available Net Positive Suction Head NPSHr: required Net Positive Suction Head SFP: Spent Fuel Pool SIFT: Safety Injection Filling Tank 15thMeeting Pre-application (June 19.Meeting SIT: Safety Injection Tank ACRS 2018)
TS: Technical Specifications 13 APR1400-Z-A-EC-18001-NP
Non-proprietary Presentation to the ACRS Subcommittee Korea Hydro Nuclear Power Co., Ltd (KHNP)
APR1400 Design Certification Application Review Safety Evaluation with No Open Items: Chapter 6 Engineered Safety Features June 19, 2018
Open Item: 06.01.01-1 Engineered Safety Features Materials Non-proprietary
==
Description:==
(RAI 8454, Question 06.01.01-1)
The DCD Tier 2 quality assurance requirements for the in-containment refueling water storage tank (IRWST) liner was unclear. The applicant stated that the liner would meet only a portion of ASME Section III, Division 2, Subsection CC-2511 with exception of the testing and quality assurance requirements.
Closure:
The DCD was revised to state that the IRWST liner will meet the quality assurance requirements of ASME NQA-1 and 10 CFR 50 Appendix B.
The use of an ASME NQA-1 and 10 CFR 50 Appendix B quality assurance program is sufficient to ensure that the IRWST liner will be high quality. This open item is closed.
June 19, 2018 Chapter 6 Engineered Safety Features 2
Open Item: 06.01.01-3 Engineered Safety Features Materials Non-proprietary
==
Description:==
(RAI 8454, Question 06.01.01-3)
Process controls for type 304 stainless steel components described in the DCD Tier 2 was not consistent with Regulatory Guide 1.44, Control of the Processing and Use of Stainless Steel. The staff requested further information on how sensitization of austenitic stainless steel was prevented.
Closure:
For type 304 stainless steel with carbon content greater than 0.03 wt% (non L-grade), the welding procedures will be verified to not produce sensitization as demonstrated by meeting ASTM A262 Standard Practices for Detecting Susceptibility to Intergranular Attack in Austenitic Stainless Steels in accordance with RG 1.44.
The applicant meets staff guidance and this open item is closed.
June 19, 2018 Chapter 6 Engineered Safety Features 3
Open Item: 06.02.01-1 Peak Containment Pressure & Temperature Non-proprietary
==
Description:==
(RAI 8342, Question 06.02.01.01.A-3, and RAI 8442, Question 06.02.01.01.A-9)
The reactor containment structure and associated heat removal system need to be designed with sufficient margin to accommodate the calculated P&T conditions from any LOCA/MSLB. DCD reported greater than 10% margin to the containment design pressure. However, staff confirmatory calculations showed much smaller peak pressure margin. Three non-conservatisms identified in the GOTHIC model:
- DCD used the Direct-DLM HTC model as the convection-condensation combination, while Tagami-Uchida HTC model was shown to be more conservative,
- An inertial length of 1 ft is used in the DCD, which could be as large as the containment height that was shown to be more conservative, and
- Burnup dependent TCD (Thermal Conductivity Degradation) was not accounted for in the M&E release, and thus, in peak containment P & T.
June 19, 2018 Chapter 6 Engineered Safety Features 4
Open Item: 06.02.01-1 Rapid Reduction of Containment Pressure Non-proprietary
==
Description:==
(RAI 8442, Question 06.02.01.01.A-10)
Per GDC 38, the updated licensing basis GOTHIC model should show containment heat removal system (CHRS) will rapidly reduce the containment pressure following any LOCA, lessening the challenge to the containment integrity. SRP Section 6.2.1.1A specifies that the containment pressure should be reduced to less than 50% of the peak calculated pressure for the DB LOCA within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the postulated accident.
June 19, 2018 Chapter 6 Engineered Safety Features 5
Open Item: 06.02.01-1 GOTHIC Deck and Heat Sink Table Non-proprietary
==
Description:==
(RAI 8442, Questions 06.02.01.01.A-9 and 06.02.01.01.A-10, and RAI 8342, Question 06.02.01.01.A-2)
DCD Table 6.2.1-23 specifies the passive heat sink data (material types, thicknesses, surface areas, boundary conditions) for a total of 16 passive heat structures. The RAIs concerned about the interpretation of heat sinks in the table and GOTHIC deck has three additional heat sinks.
June 19, 2018 Chapter 6 Engineered Safety Features 6
Open Item: 06.02.01-1 Non-proprietary Closure: (confirmed incorporated in DCD Rev. 2 & TeR Rev. 1)
- DCD revised to clarify the Table 6.2.1-23 data
- Additional sensitivity analyses performed
- Three non-conservatisms (HTC, inertial length, TCD) addressed
- Break flow model modified; Water trap credited; Decay heat curve corrected
- M&E release tables revised for the TCD.
- GDC 16 & 50
- Containment design pressure has more than 10% margin.
- Peak containment wall temperature is less than the design temperature.
- Revised containment pressure drops to less than 50% within first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the DBA.
- DCD Sections 6.2.1.1, 6.2.1.3, 6.2.1.4 and TeR (graphs, tables, etc.) were updated for the revised licensing basis calculations that account for the three non-conservatisms.
June 19, 2018 Chapter 6 Engineered Safety Features 7
Open Item 06.02.04-11 Non-proprietary ITAAC for Containment Isolation Valves
==
Description:==
(RAI 8344 Question 06.02.04-11)
The RAI concerned documenting the compliance of an as-built plant with the requirements of 10 CFR 50, Appendix A, General Design Criteria 55, 56, and 57, which require, in part, that isolation valves outside containment should be located as close as possible to containment as practical. KHNP was requested to explain how this ITAAC, as written, will ensure that the supplied as-built piping distances from the outer CIV to the containment will be such that the valves are located as close to the containment structure as practical. The applicant was requested to provide an ITAAC to meet the requirements of GDCs 55, 56, and 57. The staff will review and evaluate the ITAAC in Section 14.3 of the SER.
Closure:
In a revised response to RAI 8344, Question 06.02.04-11, the applicant proposed an additional ITAAC to be added to Tier 1 of the DCD, Table 2.11.3-2, which is evaluated in Section 14.3.11 of this SER. The staff reviewed the proposed DCD markups and found the proposed ITAAC acceptable for meeting the requirements of GDCs 55, 56, and 57, This item is being tracked as a confirmatory item.
June 19, 2018 Chapter 6 Engineered Safety Features 8
Open Item: 06.03-10 Emergency Core Cooling System Non-proprietary
==
Description:==
(RAI Question 06.03-10)
APR1400 design includes provisions for recycling boron; however, the DCD provided no design/administrative controls over the boron-10 isotopic concentration in the safety injection tanks (SITs) and the IRWST, which could deplete due to excessive recycling, ultimately challenging the shutdown capability of the SITs and IRWST.
Closure:
The applicant provided a response to this RAI indicating the solution to this issue is to institute a technical specification and surveillance requirements that require periodic verification of boron-10 isotopic concentrations in the SITs and IRWST. The staff finds this acceptable because periodic verification of boron-10 isotopic concentrations assures the IRWST and SITs do not operate with boron-10 isotopic concentrations less than what is assumed in the safety analyses.
The applicant provided markups to the DCD showing the additions to its technical specifications and surveillance requirements. The staff found this response to be acceptable and is tracking this item as a confirmatory action pending the incorporation of the applicants proposed markups into the next revision of the DCD.
June 19, 2018 Chapter 6 Engineered Safety Features 9
ACRS Question on IRWST Vacuum Protection Swing Panels related to Section 6.3
==
Description:==
Non-proprietary As part of the Chapter 6 presentation to the ACRS Subcommittee in March 2017, the ACRS questioned whether the IRWST vacuum protection swing panels need to be included in the design's technical specifications in order to ensure operability of the IRWST and downstream pumps during an accident.
Closure:
The applicant provided a conservative net positive suction head (NPSH) calculation showing the amount of NPSH margin remaining for the safety injection (SI) and containment spray (CS) pumps when the IRWST is under vacuum conditions due to failed vacuum protection swing panels. The amount of margin remaining for the SI pumps is approximately 9ft-water and for the CS pumps is approximately 10ft-water. The staff finds that the IRWST vacuum protection swing panels do not need to remain operable during an accident in order to ensure the operability of the IRWST itself and the downstream pumps that the IRWST feeds.
Thus, the IRWST vacuum protection swing panels are not required to be in the APR1400s technical specifications. This issue is resolved and closed.
June 19, 2018 Chapter 6 Engineered Safety Features 10
==
Conclusion:==
Non-proprietary
- There are no open items in the chapter 6 SER.
- NRC staff reviewed all the supplemental information provided by KHNP as the result of Phase IV review and found it acceptable.
- Sufficient conservatism is built in the KHNP APR1400 containment design.
June 19, 2018 Chapter 6 Engineered Safety Features 11