ML20217B186
ML20217B186 | |
Person / Time | |
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Site: | 05200003 |
Issue date: | 09/16/1997 |
From: | Scaletti D NRC (Affiliation Not Assigned) |
To: | Quay T NRC (Affiliation Not Assigned) |
References | |
NUDOCS 9709230262 | |
Download: ML20217B186 (12) | |
Text
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, , September 16, 1997 MEMORANDUM TO: Theodore E. Qu'.y, Director St nd:Idiz ti:n ProJ:ct Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation FROM: Dino Scaletti, Senior Project Manager original signed by:
Standardization Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation
SUBJECT:
FORTHCOMING MEETING WITH WESTINGHOUSE ELECTRIC CORPORATION DATE AND TIME: September 16 and 17,1997 - 8:30 a.m. - 4 p.m.
LOCATION: U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 Room 06- 811 PURPOSE: To resolve PIRT and scaling issues related to review of the design certifi-cation application of the AP600 design, See attached agenda. The agenda was previously provided to Westinghouse in order to prepare for this meeting PARTICIPANTS *: NRC Westinahouse E. Throm G Piplica J. Kudrick J. Gresham D. Scaletti B. Rarig D. Spencer Scientech. Inc, J. Woodcock B. Brown B Gitnick D. Prelewicz L. Wolf
)
Docket No.52-003
Attachment:
As stated I cc w/att: See next page
' Meetings between the NRC technical staff and applicants or licensees are open for interested members of the public, petitioners, intervenors, or other parties to attend as observers pursuant to " Commission Policy Statement on Staff Meeting Open to the Public," 59 Federal Reaister 48344,9/20/94. Members of the public who wish to attend should contact me at (301) 415-1104.
DISTRIBUTION:
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DATE 09/l(/97 09/N/97 OFFICIAL RECORD COPY 9709230262 970916 PDR ADOCK 05200003 l{ ,
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i DISTRIBUTION: Memorandum to Theodore R. Quav. Dated: Seotember 16. 1997 Docket File i
PUBLIC PDST R/F SCollins/FMiraglia,0-12 G18 BSheron,0-12 G18 RZimmerman,0-12 G18 JRoe DMatthews TJKenyon WCHuffman JMSebrosky JNWilson DScaletti ,
WDean,0-5 E23 JMoore,0-15 B18 ACRS (11)
RBailey,0 2 B2 EThrom,0-8 H7 JKudrick,0-8 H7 PMNS (e-mail)
OPA (e-mail) d 4
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l Westinghouse Electric Cerporation Docket No.52-003 l
cc: Mr. Nicholas J. Liparulo, Manager Mr, Frank A. Ross 1
Nuclear Safety and Regulatory Analysis U.S. Department of Energy, NE 42
- _ Nuclear and Advanced Technology Division Office of LWR Safety and Technology i Westinghouse Electric Corporation 19901 Germar. town Road P.O. Box 355 Germantown, MD 20874
- Pittsburgh, PA 15230 Mr. Russ Bell Mr. B. A. McIntyre Senior Project Manager, Programs l Advanced Plant Safety & Licensing Nuclear Energy Institute l Westinghouse Electric Corporation 17761 Street, NW
- Energy Systems Business Unit Suite 300 i Box 355 Washington, DC 20006-3706 j Pittsburgh, PA 15230
- i. Ms. Lyren Connor
!. ' Ms. Cindy L. Haag _ Doc-Search Associates 4 l Advanced Plant Safety & Licensing Post Office Box 34
- Westinghouse Electric Corporation Cabin John, MD 20818
, Energy Systems Business Unit Box 355 Dr. Craig D. Sawyer, Manager
.i Pittsburf,h, PA 15230 Advanced Reactor Programs GE Nuclear Energy Mr. M. D. Beaumont 175 Curtner Avenue, MC-754 j Nuclear and Advanced Technology Division San Jose, CA g5125
- Westinghouse Electric Corporation One Montrose Metro Mr. Robert H. Buchholz 11921 Rockville Pike GE Nuclear Energy ,
Suite 350 175 Curtner Avenue, MC-781 Rockville, MD 20852 San Jose, CA 95125 Mr. Sterfing Franks Barton Z. Cowan, Esq.
U.S. Department of Energy Eckert Seamans Cherin & Mellott NE-50 600 Grant Street 42nd Floor-19901 Germantown Road Pittsburgh, PA 15219 Germantown, MD 20874 Mr. Ed Rodwell, Manager Mr. S. M. Modro PWR Design Certification Nuclear Systems Analysis Technologies Electric Power Research Institute Lockheed Idaho Technologies Company 3412 Hillview Avenue Post Office Box 1625 Palo Alto, CA 94303 Idaho Falls,ID 83415 Mr. Charles Thompson, Nuclear Engineer AP600 Certification NE-50 19901 Germantown Road Germantown, MD 20874
T AGENDA SEPTEMBER 16 AND 17,1997 Comments WCAP-14326. Rev.1 WCAP-14326 Rev 1, " Experimental Basis for the AP600 Containment. Hest and Mass Transfer Correlations"
- 1. RAI 480.358: What is the potential significanoe of the " dense screens"?
Response: NSD NRC-96-4850, October 17,1996: "It is assumed that the dense screens were installed to breakup the velocity profile at the entrance of the heated channel. In this way, both the temperature and velocity profiles would develop simultaneously."
The response is not consistent with Eckert/Disguila paper. The reference paper states: "To assure that the air entered the tube proper with a constant velocity, dense screens E were installed at the top and bottom of the tube,"
Neitheris addressed in Rev.1.
- 2. In Section 4.4.4 m Open Uterature Tests, it is stated that: "Unceainties in the Hugot", Eckert and Diaguila , Siegel and Norris", Gi,liland and Sherwood", and Chun and Seban M tests are discussed in the open literature references,"
The staff finds no discussions ci the uncertainty in the data in any of the referenced papers (except minimally in the Gilliland and Sherwood paper) reviewed (staff has not reviewed the Hugot work). Papers assess correlations fits to a scatter of data without addressing the significance of the scatter in the data.
- 3. Sechon 2.2.11s based on a three foot wide well? Is this a mistake? If not, then show a plant (SSAR) diagram. If it is really 4.5 feet, how can any conclusion be drawn conceming the competing effects?
- 4. References for analyses are to WCAP-14407 for WGOTHIC code. (eg, page 3-23) Were -
analyses done with V 4.0 (4,1) or 1.x? Were analyses re-done? Should they be re-done?
Are the "ccvel" changes sigcificant?
- 5. Figure 3.6-2 (pg 3-47) X-axis not labeled (Reynolds Number).
Was correctly labeled in Rev 0,
- 6. Page 3-63. LST 222.4 (not stated if part a or part b), Reference is the original LST data report, June 1994. Test values revised in April 1997 update, if wrong data used, how can -
any conclusion be drawn conceming the model selection (amount of conservatism)?
- 7. Consider error bars on F gute 3.9-4. Consider Section 4.5 method to bound data. How can an assessment of the amount of conservatism be made? May be conservative but not bounding, cannot " quantify."
- 8. The values presented in Section 4.5 relating to the app!ication of the condensation test vata are not consistent with the information provided in letter NTD-NRC-9570, dated September 28,1995. Also on page 4-17, third line from bottom, word " evaporating" should be " condensing."
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Attachment
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1' 4
WCAP 14845 Revision 2," Scaling Analysis for AP600 Containment Pressure During Design Basis Accidents" 4
Page E 5: The data table, which supports statement on validation of equation, is no longar part
! of the report. Was Table 10 8, Secticr.10.2.1.1.
Page E-8: The is no Figure 11 1. Is it 10 57 l Page E-8: Last paragraph. Where and what is the support, code version (1.x,4.x), models i j (LP,DP, errors), ete? In what section (sections) can this material be found?
h Page P-2: Thought GOTHIC was selected but needed additional model for the clime.
- WGOTHIC was result of effort.
l Page P-4: LST ref is old June 1994 report. April 1997, revisions indicates potential for bad i analyses if based on original.
! Page P-6: Distributed parameter model? Role and status. Is there a summary or which
! sections describe use of this model?
Page 15: Ref to Ref 4? Should be Ref S. Section 9 of 4 is not to be reviewed.
- Page 2-1
- What is the mixing and stratification report? Section 9 of WCAP 144077 i
j Page 8-3: There is no shading visible on Table B-3, or any other table (8-4 and 8-5), to indicate l > 10 percent.
Page 10 5: 2 percent, is it non-conservative?
]
- Page 11-6
- There is no Table 10-10. Table 10 3?
i Westinghouse has prepared AP600 Response to Requests for Additional Information as an
- enclosure to letter NSD-NRC-97-5216 of June 27,1997. The majority of the responses appear to
! .be acceptabl e. However, comments and clarifications apply to the following RAls:
i in (RAI 480.975) Pi-groups pi,, mand pi..,,, have not been replaced in Table 2-1 as stated in the response. Please clarify where numerical values for these pi-groups can be found.
- 2. (RAI 480.995) In the previous revision of the scaling report, the Biot number had been i calculated to be 0.08. Now it has been recalculated as 0.13. According to Kreith, Principles
, of Heat Transfer ,35 ed., p.140, a criterion for treating a heat structure as a lumped mass l is that the Biot number be less than 0.1. Since Kreith's criteria is no longer satisfied, what
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is the justification for lumping the steel? What is the estimated magnitude of the error introduced by this approximation?
- 3. (RAI 480.1002) There still appears to be a problem with the nomenclature in equation 135
- and in the equation on the second line of page 7 30. Why is it necessary to change the 1 - temperature subscripts in going between these two equations? Also, the subscript " sex" (not j in the nomenclature section or in Figure 7-3) is not cefined.
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- 4. (RAl 480.1011) The stated revision to the text does not appear to have been made, i 5. (RAI 480.1017) The RAI was directed toward determining whether any of the remaining pi-1 group values contained an anomaly similar to that for pl . . The NRC review did not check l the value of every pi-group. Please provide an evaluation of the anomaly effect for pl and l I' 'Pi c..- l l 6. (RAI 480.1026) Why does increasing heat transfer coefficient with increasing Reynolds ,
i Number imply that there is no concem?
1 l
! . 7. (RAI 480.1027) in addition to dw information in the RAI, the following is needed to complete e
the review. Please compare the physical film thickness (as predicted by the Nusselt 2
equation) to the Chun and Seban effective film thickness over the range of Reynolds Numbers expected for AP600 (both inside and outside the PCS, above and below the second weir). For each Reynold's number, compare the heat transfer coefficient for the
[ water film using the Nusselt model to the Chun and Seban model, i
The wording in the first paragraph of Section 7.4 has been improved to distinguish the effective film thickness from the physical film thickness. Unfortunately, in the second paragraph, the effective film thickness is used to get the heat capacity of the film, whereas the physical thickness should be used. The difference in the ratio calculated is not significant, but it confuses the issue, in the sense that it encourages the reader to thing of the effective thickness as a physical distance.
- 8. (RAI 480.1031) In Table 10-3 the new footnote reveals that for 15f, measured air / steam concentrations were usmi since LST is not homogeneous. How were air steam concentra-tions for AP-600 determined for use in calculating the pi-gmup values?
- 9. (RAI 480.1032) The definition of distortion provided appears to be appropriate for phenomena which are quantified by pbgroups. However, some phenomena, such as mixing and stratification are not represented by pi-groups. A broader definition of distortion appears to be needed to cover phenomenon not quantified by pi-groups.
- 10. (RAI 480.1035) Reference to the WGOTHIC Apolication Report, Appendix 7.A which you state was added could not be found. The reference citation should appear in the section I titied Extemel Wahr Flow Time Varis,tions on page 11-7, 11, - -(RAI 480.1036) The conclusions still appear to be somewhat disjoint from the main body of the report. For example, the discussion in item 1 would seem to be supported more by the Applications Report than this Scaling Report.
WCAP-14812 Rev 1," Accident Specification and Phenomena Evaluation for AP600 Passive Containment Cooling System" The following comments consider Westinghouse response to discussion items that were raised concerning WCAP-14811, Rev. O, the earlier version of the PIRT report, and how these are addressed in WCAP-14812, Rev.1.
- 1. Time phases in Table 4-1 are not consistent with the sealing report, WCAP-14845, Rev. 2 (Table 6-3).
4
- 2. There still seems to be inconsistencies in the ranking of phenomena between the PIRT and scaling reports. For example, break source item 1E droplet /!iquid flashing is rated low for all accident phases but still appears in the list of medium and high ranked phenomena in Table 2-1 of the scaling report.
- 3. In Appendix A, Westinghouse has now at least identified the experts by name, but still has nciidentified opinions and positions with an expert, so that the reader cannot tell who held what opinion. Also, source documents, such as written materials from the experts, are not included. The value of the expert judgements is reduced considerably by the lack of information in this area.
4 4. Pg. 2 3: The following sentence is unclear:
6 Such active systems in current PWRs lead to somewhat different thermal hydraulic conditions in AP600, so that AP600 specific venfication was needed.
i Suggest rephrasing the sentence with something like:
The absence of such active systems lead to somewhat...
- 5. Pg. 2-3/2-4: Scaling has been used to confirm the PIRT ranking (Ref. 2, Section 11) and to specify the applicable data from the PCS Large Scale Test (Ref. 2, Section lil) for separate effects correlation validation and WGOTHIC code validation.
The same test data may have been used for both:
- a) deriving bounding correlations and b) for WGOTHIC code validation.
Multiple uses of the same data source may lead to circular arguments. Please discuss the procedures Westinghouse used to maintained the integrity of the validation studies.
- 6. Pg. 2-4: Westinghouse states that the integral LST facility included a representation of the AP600 intemals. Although the LST intemals did not represent inter compartment flow paths, data from LST have been considered in addressing stratification since the LST test matrix addressed a range ofimposed boundary conditions. Does this limit the LST data applicability to stratification only?
- 7. Pg. 2-9: Section 2.2.7 LST, States:
Long-term heat and mass transfer test data for a geometrically similar model of the AP600 containment vessel...... determining the relative importance of various parameter that affect heat and mass transfer on both inside/outside containment surfaces.
What does relative importance means? What is the measure?
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- 8. Pg. 2-11: In the LST, a diffuser was located under a simulated steam gener ator compartment below operating deck (LOCA simulated). Steam rose in a plume, and air was entrained in the rising plume resulting in a na! ural circulation flow pattom within the simulated containment.
., However, a diffuser under a simulated SG-compartment in LST does not provide anything close to real break simulation (LOCA blowdown). How can a plume develop for an unconfined SG7 LST lacks a second SG-compartment, therefore flows and entrainment are atypical of AP600.
Pg. 2-11 : Section 2.3 : Scaling Analysis
- 9. Last paragraph, Westinghouse states
4 In Reference 2, Sect. Ill, top-down scaling is used to determine the most important system l level phenomena during blowdown and long-term phases of a large break LOCA transient and to show how well those phenomena are preserved between LST and the AP600 plant, The results of this analysis are used to determine to what extent global containment data (pressure) can be used fmm LST for WGOTHIC code validation. Thir contradicts the statements in Section 2.27 stating the LST did not simulate the blowdown phase.
J Pg. 3 5 : Sect. 3.2.1 Inside Containment
only relates to the '. lowdown phase. The water drops suspended in the steam initially flash 1 a small fraction of their mass to steam to reach thermal equilibrium within the containment atmosphere, i
- 11. After flashing, the large surface area of these many tiny water drops maintains the atmosphere at or near saturation for up to thousands of seconds. Westinghouse needs to j provide references and experimental evidence.
4 j 12. All compartments below-deck are provided with top openings to minimize the potential for i
a dead pocket of noncondensable concentration. However, this is not applicable for higher
} up break positions for steeljacketed concrete (explanation missing). The break liquid which
] is not dispersed as drops is assumed to leave the break at the containment saturation j pressure.
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2 6 L Comments WCAP-14812. Rev.1 i
Ref.: Loftus, M.; Spencer, D.; Woodcock, J., " Accident Specification and Phenomena
- Evaluaton for AP600 Passive Containment Cooling System," WCAP-14812, Rev.1, j . June 19g7 l Content 1
The following general observ.ations, issues and comments are provided conce;ning WCAP-14812,
- Rev.1
- 1) The current PIRT-report is not code-independent but rather merges PIRTs, WGOTHIC
- Evaluation Model aspects and uncertainty issues in one and the same document. This j should be reflected in the title of the report.
- 2) The ranking rationale as displayed on pg. 4-20 deviates from PIRT guidelines as it lists h21h
- energy transfer process ad containment pressure. The chosen wording opens many 4 avenues for ambiguity and speculaton if it is decided to really keep two objective functions, 4 namely energy transferpmcass and contasnment pressure reduction, then the items in the ranking rationale should correctly read increase in energy transfer and resultant containment pressure reduction. This could be also reconciled by eliminating the word l reduction,
! 3) Ahhough the ranking rationale encompasses both energy transfer process and containment pressure, the texts, references and arguments for the individual phenomenon in the main j body of the report refers to the containment pressure only for the majority of them because j this is the only figure of merit for which results have been provided .
i
! 4) Westinghouse has applied the bounding methodology for High-ranked phenomena, such as
! for instance for the most important energy transfer processes; condensation and evaporation l inside and outside the. a.ontainment, respectively, rather than as recommended for the Low-
- ranked phenomena.
i 5) The basis for PlRT ranking is not based on experimental evidence (even for High-ranked l phenomena) as would be expected. Rather, the majority of PIRT-ranking is based on scaling
! calculations, done using a special code with a simple model of the containment.
l 6) Although the majority of PIRT-rankings is based on the results of scaling considerations and j expert review, Westinghouse did not specify criteria for the numerical values for the PI-ratios forwhich the importance of a phenomenon would be ranked differently although they have essentially the same values for the PI-rations. This leads to a non-uniform ranking, rationale l and resultant confusion.
- 7) Wcinghouse has evaluated the PI-ratios at the beginning of a time please. Some physical i
quantities drastically change over the time phast but this change was not evaluated.
l Therefore, the numerical PI-ratio evaluated at the beginning of the next time phase, for
- - instance, ! efill, results in a very much different (higher) value, in some cases, Westinghouse
! notced and commented on these discrepancies. However for the majority of phenomenon i
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- 8) Most subsechons in the discussions on phenomena are geared too much toward the LOCA l time phase, although MSLB results in the highest computed containment pressure by the AP600 EM. In most descriptions, MSLB is not mentioned at all except for the PIRT ranking.
This may be acceptaHe for equally ranked phenomena, but for all other cases this may pose i the potential for omitting important information. The non-uniform treatment of LOCA and
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MSLB time phases does not seem justified. '
- 9) Some high-ranked phenomena, such as evaporation of the extemalliquid film, require the success of a medium- and low-ranked phenomenon, i.e., PCS riser annulus natural circulation, vapor acceleration, fog and flow stability. Based on this PIRT, modelers may mistakenly downgrade the conservatism of models associated with critical systems.
- 10) Westinghouse may not be crediting the expert review effor5, because of the following reasons:
a a) The export review is no substitute for an independent PIRT panel, b) There is not a single phenomenon for which Westinghouse has adopted the experts' different ranking. Rather the experts' opinions were dismissed and the results of the scaling PI-ratios were adopted (compare comment under point) maintaining Westinghouse's original ranking. Most often the experts ranked the phenomenon higher but Westinghouse consistently downgraded the rank.
This is acceptable only for phenomena fer which an in-depth knowledge and experimental databaso exists. Most often this is not tne case in the ranking should tend toward higher than lower importance.
- 11) Descriptions under the headline How Phenomenon is implemented in Evaluation Model do not actually refer to the implementation but rather to input quantities or general descriptions of the phenomenon / process in or between components / subsystems. In fact, for many phenomena the text is a repeat of at least parts of the generalintroductory description of the phenomenon under consideration. Under the headline one would expect reference to models, correlations / procedures implemented in WGOTHIC.
- 12) Westinghouse lists a number of Test Experience under the headline Justification for T a Treatment of Phenomenon. However, for many phenomena this consists only of a test description or reference of a correlatho which is not really a justification. Under justification it would be expected to reference results how the containment pressure / energy transfer processes are affected using the cited correlation in comparison with data. This has not been done consistently, rather sensitivity studies and LST-result comparisons are references.
In hindsight, the test experience cited should well have been referenced as basis for the PIRT-ranking (compare comment under point) rather than fc justification of WGOTHIC AP600 EM.
Issues Related to the Ranking of Specific Phenomena and Treatment in EM General comment: The phenomena listed under the components are not systematically handled in terms of time phases in Section 4.1.
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!- - Pg. 4 8 Table 41 1
- 1) Westinghouse ranks all characteristics (dwoction, elevation, momentum, density) of (1) Break 4 Source Low during LOCA long-term. Equally, inter-compartment flow for (2) Containment volume is ranked Low for LOCA blowdown phase and so on. Given the fact that LST did 1
) not consistently cover all these phenomena with respect to AP600 requirements, the ranking )
seems too low especially when considering the impact of memory effect of early heat up !
? in one region of the plant on global natural circulation pattom during the LOCA long-term time i i phase. This concem also encompassos the inter-compartmental flows as this determines i the region ofinitial heatup.
i j 2) The component / subsystem (5) Break pool does not list pool heatup as a phenomena. Is there any special consideration why Westinghouse has disregard this potential source for f
energy release during long-term?
- 3) Under point (7) Steel Shell and energy transport phenomena have been ranked either Low i
or Medium , yet the ere jy removal from the film evaporation (ranked High) is mandatory in order to guarantee the efficiency of the passive PCS cooling. Westinghouse is asked to
! provide information about the ranking rationale applied for energy transport phenomena in the downcomer riser component.
- 4) Under point (8) PCS Cooling Water, subpoint D) Film Striping received only Low ranks for j all time phases, yet this is the cause for introducing a correction for accounting for 2 D heat
, ccnduction effects to increase film evaporation. Westinghouse is asked to explain the Low j -ranking for this phenomena even for later phases when film flow is low.
j 5) Under point (10) Baffle, subpoint G) potential leaks through the baffle are ranked Medium i
for LOCA time phases peak pressure and long-term. Westinghouse is asked to explain this j ranking in view of the fact that this poses a potential threat for short-circuiting and thereby i disabling the natural draft effect.
l
- 6) Under point 13) Downcomer, subpoints A) PCS Natural Circulation and B) Air Flow Stability are ranked Medium and Low , respectively, yet the efficiency of the PCS system depend
- very mucn on sustaining both phenomena, for transport purposes of the evaporation mass 4
and energy from the coomg film. Westinghouse is asked to provide the ranking rationale for j both phenomena given their importance for the functionability of the PCS cooling concept.
! Pg. 4-16 l
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Westinghouse states that increased heat transfer coefficients were observed when the steam jet directly impinges on the horizontal plate and that this simulates the steamline break. Westinghouse
! is asked to provide information why this is the case, given the fact mat the realistic break positions i for both LOCA and MSLB are still not displayed in the associated figures.
Pg. 4-17 k Westinghouse reports observations from the Small Scale PCS Integral Tests conceming higher than
- vessel-averaged heat removal at the top uf the dome. However, the phenomenon of non-uniformity j in h&,at transfer is not listed in the PIRTs. Does this mean that this phenomenon has not been
{ observed during LST-tests?
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- 1) Westinghouse reports film behavior during the LST PCS Integral Tests, yet is unclear what
' the goveming heat fluxes wem at the outside steel shell surface and how they compare with -
,the relevant ones for AP600.
- 2) in this context, Westinghouse states that striped film coverage provided better heat removal than forced quadrant coverage for the same wetted perimeter. Is this statement referring to an experimental setup or to a calculational exercise?
1
- 3) Westinghouse states that heat removal rate appeared to be more aMected by ambient air temperature than by liquid flim temperature. Yet, ambient air temperature was ranked Low.
Westmghouse is asked to explain this effect and whether this effect has been observed in s all tests.
- 4) Westinghouse reports that also during the LST-test non-uniform heat flux was observed.
Why has this phenomenon not be included in the PIRTs? This deems especially important for the horizontal, high-velocliy steam jet injection. Please explain.
- 5) Westinghouse states that by raising the steam injechon location, heat removal rate increased as the steam concentration near the containment shell increases. This is true but this positive effect is offset by the reduction in steam concentration at lower levels by stratification. Westinghouse is asked to provide more quantitative results for these observations.
General Remarks The summary presentation of experimental results has largely improved and is more focused than
' before. However, most information are of qualitative, descriptive nature, rather than quantitative solid evidence. Overall, the list of fincings seems still too short. The findings should be structured such that the results are directly related to the phenomenon under consideration.
Pg. 41g Outside Containment Westinghouse states that the buoyancy and flow resistance in the PCS air flow path are important and have a strong effect on the evaporatum rate. However, both buoyancy and flow resistance are not listed as phenomenon / parameter in the PIRT. If it is assumed that both phenomena were considered to be covered by natural circulation , these phenomena would only be ranked medium,
, an apparent inconsistency.
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