ML21064A279
| ML21064A279 | |
| Person / Time | |
|---|---|
| Issue date: | 01/13/2021 |
| From: | Zena Abdullahi Advisory Committee on Reactor Safeguards |
| To: | |
| Abdullahi, Z, ACRS | |
| References | |
| NRC-1336 | |
| Download: ML21064A279 (89) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Thermal-Hydraulic Phenomena Subcommittee Open Session Docket Number: (n/a)
Location: teleconference Date: Wednesday, January 13, 2021 Work Order No.: NRC-1336 Pages 1-60 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 THERMAL-HYDRAULIC PHENOMENA SUBCOMMITTEE 8 + + + + +
9 OPEN SESSION 10 + + + + +
11 WEDNESDAY 12 JANUARY 13, 2021 13 + + + + +
14 The Subcommittee met via Teleconference, 15 at 9:30 a.m. EST, Jose March-Leuba, Chairman, 16 presiding.
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2 1 COMMITTEE MEMBERS:
2 JOSE MARCH-LEUBA, Chairman 3 RONALD G. BALLINGER, Member 4 DENNIS BLEY, Member 5 CHARLES H. BROWN, JR. Member 6 VESNA B. DIMITRIJEVIC, Member 7 WALTER L. KIRCHNER, Member 8 DAVID A. PETTI, Member 9 PETER RICCARDELLA, Member 10 JOY L. REMPE, Member 11 MATTHEW W. SUNSERI, Member 12 13 ACRS CONSULTANTS:
14 MICHAEL CORRADINI 15 STEPHEN SCHULTZ 16 17 DESIGNATED FEDERAL OFFICIAL:
18 ZENA ABDULLAHI 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 AGENDA 2 ACRS Chairman Opening Remarks . . . . . . . . . 4 3 GEH Overview of LTR NEDC-33991P . . . . . . . . 10 4 NRC Staff Overview of Safety Review . . . . . . 54 5
6 7
8 9
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4 1 P R O C E E D I N G S 2 9:31 a.m.
3 MEMBER MARCH-LEUBA: This meeting will now 4 come to order. This is a meeting of the ACRS Accident 5 Analysis Thermal-Hydraulic Subcommittee. I am Jose 6 March-Leuba, the SC Chairman. Because of COVID-19 7 concerns, this meeting is being conducted remotely.
8 I see the following ACRS members are in 9 attendance, which is all of them, Ronald Ballinger, 10 Dennis Bley, Charles Brown, Vesna Dimitrijevic, Walter 11 Kirchner, David Petti, Joy Rempe, Pete Riccardella, 12 and Matthew Sunseri.
13 Also note our consultant, Mike Corradini 14 is on the line, and let me check, and Steve Schultz is 15 also on the line.
16 Today's topic is Topical Report NEDC-17 33911P, BWRX-300 Containment Performance. This 18 topical report defines the criteria that will be used 19 in a future submittal to ensure that the BWRX-300 20 containment satisfies all applicable regulations.
21 Portions of our meeting will be closed to 22 the public to protect proprietary information. We 23 will have an opportunity for public comments before we 24 start the closed section of the meeting.
25 The ACRS was established by statute and is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 governed by the Federal Advisory Committee Act, FACA.
2 As such, the committee can only speak through its 3 published letter reports.
4 The ACRS section of the U.S. NRC public 5 website provides our charter, bylaws, agendas, letter 6 reports, and full transcripts for the open portions of 7 all full and subcommittee meetings, including the 8 slides presented there.
9 The Designated Federal Official today is 10 Zena Abdullahi.
11 A transcript of the meeting is being kept.
12 Therefore, please speak into the microphones clearly 13 and state your name for the benefit of the court 14 reporter.
15 Please keep the microphone on mute when 16 not being used, and don't use video feed to minimize 17 bandwidth problems.
18 We are expected to have a full committee 19 meeting on this topic on February 3, and this ends the 20 official portion of this announcement.
21 Let me now provide some personal views 22 about this topical report, SE. And again, this is, 23 again as I said before, ACRS only speaks through 24 letters. This is my personal opinion.
25 I find this topical report and associated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 SE at best confusing and sometimes lacking, and there 2 are two issues I would like the presenters to try to 3 convince me why I'm wrong about it.
4 The first one is the BWRX-300 concept 5 doesn't exist. It has not been submitted for review.
6 However, this topical report presents some 7 hypothetical concepts that could be used once it gets 8 submitted, but the SER kind of uses the language as 9 the staff has been reviewing BWRX-300 certified 10 design, which doesn't exist yet.
11 So, GE has submitted some concepts and the 12 staff has looked at them, but the SE should be more 13 explicit in saying that these are concepts, that once 14 the design is really sent for review, we will make 15 sure that these are the same concepts that were 16 introduced.
17 By approving, I am not sure legally what 18 happens when you approve this topical report with 19 these concepts embedded on it, and I will be talking 20 to the staff during their presentation about the legal 21 implications of putting a dash A on the topical report 22 number with concepts that are not part of a 23 certification.
24 On that same line, the SE special 25 limitations and conditions, they look to me like an SE NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 with open items. The limitations and conditions, when 2 we go in, they'll be on the slides, but for them, they 3 look more like requests for information than a 4 limitation. So, we'll go through those details, and 5 please keep that in mind when we do the presentation.
6 The third topic of concern, and this one 7 is important to me, and it deals with a lot of 8 proprietary information, so we'll be discussing this 9 in the closed session, it has to do with the GDC 55 10 compliance.
11 It is my opinion that the concepts --
12 (Audio interference.)
13 MEMBER REMPE: Hello? Jose, I don't know 14 if you can hear us, but we can no longer hear you 15 after you said the word concept.
16 MEMBER MARCH-LEUBA: Oh, boy. Can you 17 hear me?
18 MEMBER REMPE: I can hear you now, so, 19 when you said oh, boy, so could you repeat what you 20 said after the word concept?
21 MEMBER MARCH-LEUBA: Okay, I can only hear 22 myself. Can you hear me now?
23 MEMBER REMPE: We can hear you, but would 24 you repeat what you said after -- you said that you 25 had a third issue and it may have some proprietary NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 implications, and then you said the word concept in a 2 sentence, and after that, the plane flew over like 3 other folks heard.
4 MEMBER MARCH-LEUBA: Okay, my concern, and 5 I want the members to listen carefully when we review 6 this issue, is with the compliance with GDC 55, and 7 the details are proprietary, so we will talk about 8 them this afternoon in the closed session, but it is 9 --
10 I'm leaning towards suggesting that really 11 this concept requires a GDC 55 exemption if they want 12 to proceed this way instead of just politely saying 13 that, yeah, it satisfies it. It satisfies the spirit 14 of it.
15 Yeah, so when we talk about GDC 55, and 16 somehow 56 also, please, members, pay attention 17 because this might be controversial.
18 That said, those are my initial remarks, 19 my personal opinion, and I wanted to put it in here so 20 we have an opportunity, GE and the staff, to review my 21 personal thoughts on this.
22 Anybody else want to do any introductory 23 remark or shall we move to the presentation?
24 MEMBER KIRCHNER: Jose, this is Walt 25 Kirchner. Just why don't you explain for the record NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 what GDC 55 is?
2 MEMBER MARCH-LEUBA: GDC 55 requires for 3 any pipe of any, of significant diameter that 4 penetrates containment, it must have an isolation 5 valve inside and an isolation valve outside 6 containment.
7 GDC 56 is similar, but applies to pipes 8 that connect to the containment atmosphere. So, it 9 has to do with containment isolation valves.
10 Okay, hearing no more comment --
11 MEMBER REMPE: Jose, since you brought 12 this up, I guess as they try and address that issue, 13 I'm very interested in how this design, and I'm sure 14 that this something they'll come back from, I suspect 15 they'll say they have not thought all of the details 16 through, but when I look at this, I'm very interested 17 in what they're going to do with the water level 18 instrumentation that they have indicated will be used.
19 And the reason why I'm interested in this 20 is there's a diagram the staff will show in their 21 slides, but when I think about the reference leg for 22 the water level sensor that's used at higher 23 elevations and what was done with the reference leg 24 after TMI to some of the operating fleet.
25 So, I am very curious how that -- I mean, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 there's no reason to build something and make changes 2 that were put in after TMI backfits were put in. They 3 need to think about this early on, and again, as I go 4 through all of these advanced reactor designs, I'm 5 very interested in instrumentation and how it will be 6 addressed.
7 And I think that some of the -- anyway, I 8 think I've said enough, but I just want to make sure 9 that GE has remembered what was done with the 10 operating fleet and that that consideration is 11 considered with this design, okay?
12 MEMBER MARCH-LEUBA: So, please, GE, keep 13 in mind that we would like to hear about 14 instrumentation. You may not have prepared the slide.
15 Whenever you feel it belongs, please talk about water 16 level instrumentation.
17 And I know for history that the committee 18 is very interested on the post-accident 19 hydrogen/oxygen monitoring, so if you could --
20 MEMBER REMPE: Yes.
21 MEMBER MARCH-LEUBA: -- also address that.
22 Okay, George or GE, whoever is presenting, I give you 23 the microphone.
24 MR. WADKINS: Okay, thank you. Good 25 morning. My name is George Wadkins. I'm the Vice NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 President of New Power Plants and Products Licensing 2 for GE Hitachi. Today, we will be presenting an 3 overview of the BWRX-300 design and a description of 4 the content for Licensing Topical Report NEDC-33911P, 5 BWRX-300 Containment Performance.
6 We will be describing design requirements, 7 analytical methods requirements, acceptance criteria, 8 and regulatory basis for the BWRX-300 containment, 9 including containment isolation valves and the 10 associated passive containment cooling system.
11 As noted in our previous discussions with 12 the ACRS members, the BWRX-300 builds upon our 13 extensive experience in boiling water reactor 14 technology, including our most recent experiences in 15 development and certification of the economic 16 simplified boiling water reactor or ESBWR.
17 The BWRX-300 design leverages the use of 18 proven technology to the greatest extent possible 19 while incorporating advances in design requirements 20 and features to further enhance nuclear safety.
21 One major difference between the ESBWR and 22 the BWRX-300 is in the functional design of the 23 containment. The ESBWR utilizes a compartmentalized 24 containment with a drywell surrounding the reactor and 25 connected systems, including the piping and valves, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 and a wetwell containing the suppression pool.
2 The suppression pool functions to condense 3 steam from the reactor for depressurization and to 4 allow for passive injection of water to maintain 5 reactor water inventory and cooling of the core while 6 maintaining acceptably low containment pressures and 7 temperatures.
8 The BWRX-300 has a relatively large dry 9 containment that does not require reactor or 10 containment pressure and temperature suppression 11 features using a suppression pool.
12 Reactor depressurization is achieved 13 through use of the isolation condenser system instead 14 of through an automatic depressurization system that 15 releases the steam to a suppression pool.
16 The BWRX-300 containment does include a 17 passive containment cooling system that will be 18 discussed later in this presentation, but its primary 19 function is not for immediate pressure suppression as 20 it is in the ESBWR.
21 The design of many of the piping systems 22 and valves that form the containment boundary, 23 including the containment isolation valves, are very 24 similar to those of the ESBWR.
25 These containment features, including NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 containment penetrations and the containment isolation 2 valves, are described in this licensing topical report 3 with appropriate design requirements and regulatory 4 basis for containment isolation.
5 Because of the simplified design of the 6 containment, the analytical methods' requirements are 7 also simplified with the application of a different 8 methodology using GOTHIC code instead of TRACG code 9 for containment pressure and temperature response.
10 This licensing topical report does not 11 seek approval of the use of GOTHIC as an acceptable 12 methodology, but it does establish the design --
13 (Audio interruption.)
14 MR. WADKINS: -- for example, maximum 15 allowed containment, post-accident pressures, and 16 temperatures that the methodology will be used to 17 verify.
18 The application of the GOTHIC methodology 19 is the subject of a separate Licensing Topical Report 20 NEDC-33922P, BWRX-300 Containment Evaluation Method, 21 which is currently under review by the NRC staff.
22 To support their review, the NRC staff is 23 also conducting an audit of the base and conservative 24 cases used in that follow-up licensing topical report.
25 MEMBER MARCH-LEUBA: George, this is Jose.
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14 1 You're bringing the topic of 22P, which is the NEDC-2 3392P.
3 MR. WADKINS: Yes.
4 MEMBER MARCH-LEUBA: The title of the 5 report was changed during the review as a result 6 probably of our staff RAI. Did the scope of the 7 report change to include more than just GOTHIC, 8 basically some of the TRACG energy and mass monitoring 9 conditions?
10 MR. WADKINS: Yes, it was and it always 11 had been intended to address how mass and energy 12 releases were calculated, which is why we changed the 13 title because we did need to discuss the use of the 14 TRACG code for determining those mass and energy 15 releases as inputs to the GOTHIC evaluation.
16 MEMBER MARCH-LEUBA: Yeah, for the record, 17 I don't have it in front of me, but the old title used 18 to be GOTHIC Application 2, and the new title is 19 Containment Methodology or something like that. I'm 20 paraphrasing.
21 MR. WADKINS: Yes.
22 MEMBER MARCH-LEUBA: Okay, well, that's 23 good. I mean, that's excellent. The only complaint 24 I have, and it's related to my initial comment, is 25 that Section 3 of the topical report describes this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 methodology, and even though it's clear from the text 2 of the SER that we are, and clear from your 3 presentation that GE is not asking for approval of 4 that Section 3.
5 When we put that dash A meaning approved 6 to the title to the report, we're implicitly approving 7 the Section 3, and I'll be talking to the staff about 8 that, that maybe it should be a limitation or 9 condition that which is similar to 2, the cooling 10 limitation edition 2, that explicitly says Section 3 11 is for information only and is not approved. I don't 12 think anybody would have a complaint about that.
13 MR. WADKINS: Yes, thank you. I agree 14 with you that we will also be discussing that further 15 as we go through our presentation today, so that we 16 hopefully can make it clear what the boundaries are 17 between this LTR and the containment evaluation method 18 LTR.
19 We agree that that needs to be very 20 clearly stated and understandable, and that the SERs 21 need to properly identify what they are approving in 22 those different LTRs.
23 So, continuing on, during our 24 presentation, we will pause at the end of each slide 25 to allow for questions from the members, but do please NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 feel free to raise questions at any time. If the 2 discussions involve any proprietary information, we 3 will request tabling the question until the later 4 closed session.
5 I will now turn over the presentation to 6 Frostie White, Senior Licensing Engineer for this LTR, 7 to describe the agenda for today's open session 8 presentation.
9 MS. WHITE: Can everybody see the 10 presentation slides okay? And I apologize for the 11 background noise. I live right outside of Naval Air 12 Station Pensacola, so.
13 MEMBER MARCH-LEUBA: So, it was your 14 fault, huh?
15 MS. WHITE: Yeah, the Blue Angels, you'll 16 hear them for a little while.
17 MEMBER MARCH-LEUBA: Okay.
18 MS. WHITE: Can everyone see the screen 19 okay?
20 MR. WADKINS: Yes.
21 MEMBER MARCH-LEUBA: We see slide number 22 one if the computer is not frozen.
23 MS. WHITE: All right.
24 MEMBER MARCH-LEUBA: Okay, I now see slide 25 number two, perfect.
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17 1 MS. WHITE: Okay, first I'd like to go 2 through the agenda. In the open session, we're going 3 to first discuss our report purpose and scope.
4 Then we will follow through with the 5 design requirements for the containment in the Passive 6 Containment Cooling System to meet the various 7 regulatory requirements that apply for this particular 8 design that are somewhat different in some aspects to 9 our ESBWR.
10 Then we will go through the design 11 requirements for our containment isolation valves to 12 meet these regulatory requirements.
13 Part of that discussion will be a closed 14 session regarding some of the containment isolation 15 valves that meet the other defined basis for General 16 Design Criteria 55, and we'll have that in the closed 17 session because we will be discussing some proprietary 18 information there.
19 Then we are going to go through our 20 analytical methods that we're evaluating our 21 containment performance, and in that discussion, that 22 will be slide 12 by the way, there will be some 23 information provided to the ACRS subcommittee 24 describing those items in NEDC-33922, which is the 25 containment methods LTR that George mentioned here, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 and we're hoping to be able to define and clearly 2 distinguish between this LTR and the other LTR which 3 you're going to be seeing later.
4 Then we're going to provide the acceptance 5 criteria for the containment performance. We have a 6 regulatory compliance section as well where we explain 7 what guidance documents that we're utilizing, and 8 then, of course, all of the regulatory requirements 9 that we're meeting.
10 And then finally, in our closed session, 11 we're going to be discussing how we meet the other 12 defined basis for some of the containment isolation 13 valves that are connected to the reactor pressure 14 vessel boundary.
15 So, let me go through our topical report 16 and purpose first. This LTR was going to specify the 17 design requirements for the containment in the Passive 18 Containment Cooling System to meet the various 19 regulatory General Design Criteria that we have 20 provided there. You can find that information in the 21 LTR Sections 222, 228, and Section 5.1.
22 Second, we're going to specify our design 23 requirements for the containment isolation valves in 24 order to meet the various design, General Design 25 Criteria listed. You can find that information in our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 LTR Sections 227, 5.1.5 through 5.1.7, and 5.1.21 2 through 5.1.34.
3 Again, for part of the GDC 55 compliance 4 for CIVs connected through the RPV boundary, that will 5 be discussed in closed session due to some of the 6 proprietary information in that discussion.
7 Another topical report purpose is we're 8 going to specify analytical methods for our TRACG and 9 our GOTHIC we're going to be using to evaluate our 10 mass-energy release from the pressure vessel using 11 TRACG and then containment performance based on input 12 from TRACG in our how our containment performs, and 13 that will be to comply with GDCs 38 and 50, and that 14 is discussed in the LTR Section 3.
15 That evaluation methodology again is going 16 to be demonstrated in our later LTR 3322, which is the 17 containment methods, and again, Necdet Kurul is going 18 to go over that in a slide with you and define the 19 difference, the boundary between this LTR and the 20 other one.
21 And finally, we're going to specify the 22 acceptance criteria for the containment performance 23 for the containment, the PCCS in the containment 24 oscillation valves, and that's in LTR Section 4.0.
25 DR. CORRADINI: So, this is Corradini, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 1 consultant. I had a question. Is 33922P kind of out 2 of phase with this? Was it supposed to have been 3 looked at before this? Because it seems like we're 4 looking at a broader set of requirements and 5 essentially leaving Section 3 as an open item, as Dr.
6 March-Leuba said. So, was this just simply out of 7 phase and this got ahead of the other topical report?
8 MS. WHITE: No, this was not out of phase.
9 This is -- the TRACG, Dr. Corradini, was obviously --
10 I think you actually reviewed it previously for ESBWR 11 in our --
12 DR. CORRADINI: Right.
13 MS. WHITE: -- BWR applications. We're 14 still using TRACG and many of the method inputs are 15 still applicable to the BWRX-300. So, this leads into 16 the containment evaluation methodology where we 17 actually provide results of TRACG-4 specifically with 18 some nodalization changes for the BWRX-300 versus the 19 ESBWR, but it's a lead-in to that, so they're not out 20 of sync.
21 DR. CORRADINI: Okay, it's just that the 22 way I read the limitations and conditions led me to 23 believe that I would have expected to see the 24 methodology discussed and reviewed before I would put 25 it amongst all of the other design requirements, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 1 methods, and acceptance criteria. It just seemed out 2 of phase to me, but I see what you're saying and I was 3 in a similar fashion to Dr. March-Leuba, a bit 4 confused. Go ahead. I'm sorry.
5 MEMBER MARCH-LEUBA: Yeah, since you used 6 my name, let me state for the record in the opposition 7 that I have no problem whatsoever with the use of 8 TRACG and GOTHIC. I think they're both excellent 9 codes and they both will -- are going to be proven to 10 benchmark all the available experiments and data.
11 My concern is related to my issue number 12 one, that it feels when you're reading the topic 13 report and the SER that we are approving the 14 containment for X-300 and such thing doesn't exist 15 yet.
16 Whenever the BWRX-300 submits an FSAR and 17 a certification design application, they will have 18 some calculations using TRACG and GOTHIC to show that 19 the containment satisfies the criteria and 20 requirements specified in this report, which is 11P, 21 and they will use the methodology defined in 22P, 22 which is still not approved, but I have no problems 23 with it, I'm sure. We just need to cross the Ts and 24 dot the Is. So, I don't have any technical concern 25 with these two codes. Please, Frostie, continue.
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22 1 MS. WHITE: Okay, thank you. So, let me 2 go on now to the purpose and our scope here. For the 3 scope, we're providing a technical description of our 4 containment, our PCCS and our CIV design features, and 5 these are all based on our proven design concepts from 6 our PWRs with emphasis on an ESBWR and some of our 7 later BWR models, and you can find this information in 8 our topical Section 2.2.
9 Secondly, we have a technical description 10 of the analytical methods utilizing the applicable 11 parts of the ESBWR TRACG model to calculate the mass 12 and energy release, and we use that input to GOTHIC 13 for evaluating the containment response from that mass 14 and energy release.
15 These models are then used to demonstrate 16 compliance for the containment PCCS and CIV acceptance 17 criteria, and that's where we basically lead into the 18 actual methods evaluation is we're specifying these 19 are our acceptance criteria in this topical report, 20 and we're using the methods LTR to prove that we have 21 met these particular acceptance criteria, and you can 22 find this information in our LTR Sections 3.2 to 3.4.
23 And finally, due to the changes in the 24 BWRX-300 versus the ESBWR and some of the other BWRs 25 that are in the fleet, we're doing a regulatory NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 evaluation of applicable regulations and some 2 different guidance that will be applied to the BWRX-3 300 containment.
4 For example, we're using SRP 62111A 5 instead of the typical SRP that we've used for ESBWR 6 because we have a dry inert containment, so that's one 7 of the features that we're bringing out for evaluation 8 that we're seeking approval for and agreement from the 9 staff and the NRC. This information is located in our 10 LTR Section 5.0. Any questions on this?
11 All right, we're getting ready now to get 12 into our design requirements for containment in PCCS 13 to meet these regulatory requirements we're going to 14 be discussing later, and I'll be turning the 15 microphone over to our project principal engineer, 16 David Hinds. David, are you available?
17 MR. HINDS: Yes, this is David. I'm here, 18 David Hines. Can you hear me okay?
19 MEMBER MARCH-LEUBA: Yes, we can hear you.
20 MR. HINDS: Okay, thank you. So, in this 21 section, we have summarized the content related to 22 design requirements. Of course, it's not the entire 23 content.
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24 1 into proprietary information, so we've got some 2 additional content for the closed session, and if some 3 of your questions get into that, I'd kindly ask that 4 we defer the answer to that time, but I'll give you 5 the brief summary here and please feel free to ask 6 questions.
7 So, the primary containment or the 8 containment for the BWRX-300 is a safety-related 9 structure similar to and drawing upon the lessons from 10 our prior BWRs, but as was already mentioned, it is 11 not a pressure suppression containment, meaning wet 12 containment. It's a dry containment.
13 So, we felt it was important to clearly 14 specify the design requirements even though many of 15 them are consistent with and the same as the design 16 requirements we have used on past plants, but we 17 wanted to be very clear on the design requirements 18 moving forward for future licensing applications.
19 So, here are some summary in the next few 20 slides, and the first sub-bullet there mentions it's 21 either the LTR specifies options of either steel 22 containment vessel or a steel-lined concrete 23 containment, recognizing that future licensing 24 activities would specify in more detail the structural 25 aspects of the containment.
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25 1 However, we do credit certain features in 2 the performance, containment performance, which is the 3 subject of this LTR, such as the steel surface as a 4 condensing surface, so that is in this LTR, and we 5 also refer to ASME codes that will be credited for the 6 structural design and other design requirements of the 7 permanent containment.
8 We cover piping systems passing through 9 the containment and the design requirements associated 10 with them, and then as Frostie mentioned, we do go 11 into some concept descriptions and the associated 12 commitments and design requirements associated with 13 those penetrations and the isolation thereof.
14 We incorporate this one. We've already 15 gone through the prior LTR on our RPV isolation and 16 overpressure protection, and so we make the connection 17 of this LTR with that one related to the features of 18 RPV isolation and their function related to 19 containment isolation, and so we'll discuss that in 20 more detail primarily in the closed session. We 21 commit to the requirements associated with structural 22 supports within the containment.
23 The next sub-bullets we covered in the RPV 24 isolation LTR associated with the postulated pipe 25 breaks, but we cover it further and have consistent NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 1 requirements in this LTR related to piping within the 2 containment and our postulated pipe breaks, and you'll 3 see here that we refer to BTP 3-4, which is pointed to 4 by the regulatory standard review plans, and so our 5 requirements that we have specified are consistent 6 with the standard review plans related to postulated 7 pipe breaks as listed in BTP 3-4.
8 We refer to, as I mentioned, ASME design 9 requirements as listed in the last bullet on this 10 slide. Frostie, if you could go to the next slide, 11 please?
12 DR. CORRADINI: So, can I -- this is 13 Corradini again. Can I ask a question? So, I'm still 14 struggling to understand what is being specified here 15 that is going to be, I'll call unchanged before we get 16 more detail about the design that we can analyze or at 17 least consider.
18 So, the one thing you've said was this is 19 not a pressure suppression containment, and that's 20 going to remain. The other thing you've said, you're 21 going to follow the specified BTP 3-4 requirements.
22 So, is there a listing of what I'll call 23 the key items that are going to be held constant as 24 the design evolves? Because my sense of it is the 25 design is still evolving, so things may change.
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27 1 MR. HINDS: So, yes, thanks for your 2 question. I guess the best way to answer that is that 3 if you'll notice the title of this slide and much of 4 my language have been using the terms design 5 requirements.
6 And so what we're primarily doing in this 7 section of the LTR is we're being very explicit about 8 what design requirements that we are applying and 9 their relationship to the regulations and the 10 associated regulatory evaluation, and then also a 11 linkage into the section that Necdet Kurul will cover 12 in a few minutes related to how that links in with the 13 methods.
14 So, this LTR is pulling everything 15 together such that the requirements, when met, have 16 already been evaluated to the regulatory requirements 17 such that as we further detail out the design, we do 18 not remain in question the requirements that the 19 design meets. We are only detailing out the design 20 features to meet those requirements. I hope that 21 helps some with your question?
22 DR. CORRADINI: That helps a bit, but what 23 if, as the design evolves, you have to change the 24 requirements? So, I'm still not sure what's being 25 fixed here.
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28 1 What you said to me was that there are a 2 set of regulatory requirements and now you have 3 identified a set of design requirements to prove that 4 they match up, which I get, but to the extent that the 5 design is evolving, those requirements may change. Is 6 that not true?
7 MR. HINDS: If they were to change in 8 future licensing applications, then we would have to 9 go back and reevaluate the regulatory criteria 10 associated with it and then further justify the 11 requirements where we're trying to remove the 12 uncertainty in the licensing and design process moving 13 forward to have confirmation that these design 14 requirements, when specified to our engineering team 15 and further detailed out, which, of course, we've done 16 engineering thus far, but we'll have further 17 engineering, that we're no longer questioning the 18 requirements. We're only working through the details 19 to meet those, so --
20 DR. CORRADINI: Okay, so --
21 MR. HINDS: Yes.
22 DR. CORRADINI: -- let me then ask my 23 question maybe historically. I don't remember this 24 approach with ESBWR, so what does this approach gain 25 for GE that I might be missing? There's something NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 1 here that I'm clearly missing. Can you help me?
2 MR. HINDS: So, I'll make a comment there 3 and then I'll invite, if George or Frostie has further 4 comments, because this is a more process-related 5 question, but I'll first comment and then George or 6 Frostie, feel free to jump in.
7 So, with ESBWR, we submitted an entire 8 design certification or design certification 9 application. Our desire here was to go with a lesser 10 approach than the design certification and work to 11 address areas where our design is different than the 12 past experience, and the purpose of the LTRs is to 13 remove some of the regulatory uncertainty associated 14 with the regulatory compliance as we detail out those 15 design features that differ from our past designs.
16 In cases where our past designs or our 17 BWRX-300 agrees very closely with our past designs, we 18 feel there's low regulatory uncertainty, and 19 therefore, we feel comfortable with submitting when 20 ready for actual plant licensing.
21 In this case, we're trying to address 22 features that are different, such as we mentioned 23 several times that this is a dry containment as 24 opposed to pressure suppression containment, and we'll 25 go into more details associated with the RPV isolation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 and the associated containment isolation.
2 Those features are different than we've 3 done in the past, so we did not want to leave them for 4 our total submittal of a license application, so this 5 is a way of getting those identified and addressed up 6 front. And George or Frostie, do you have any further 7 comments?
8 DR. CORRADINI: No, I don't want to take 9 any more time for the committee, but you've helped me 10 a good bit. I think I appreciate the logic of what 11 you guys are doing in this case in difference to what 12 I remember to be the case for ESBWR.
13 MR. HINDS: Okay, well, thank you for your 14 comments. Okay, if no further on this slide, Frostie, 15 could you go to the next one, please, and the next 16 slide? I'm not sure if there's a delay on my screen, 17 but okay, I'm on slide nine.
18 Okay, so in the design requirements' 19 sections in Section 2 of the LTR, we go through a 20 number of subtopics like I had listed on the prior 21 slide.
22 On this next couple of slides, we go into 23 just a little more detail specifically on the 24 containment isolation valves since that is an area 25 that's different than our past design, and again, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 1 do have in the closed session some figures and some 2 more descriptions which may help with elaborating on 3 these, but this is the introductory two slides here.
4 The other design requirements for other 5 features, we didn't have specific call-out slides 6 other than the one that I just went through, so if we 7 need to recycle back on any of them, that's okay.
8 For the containment isolation valves, the 9 valves, the piping, the penetrations basically meet 10 ASME requirements as listed in the bullet here.
11 Our isolation limits on the containment 12 isolation and their permissible leakage is -- the 13 actual numerical values are to be set based upon our 14 safety analysis outcomes, and so we basically make 15 that linkage.
16 We have instrumentation penetrations 17 through the containment similar to the earlier 18 question, and I'll elaborate on that more in the 19 closed session as well on instrumentation. I think I 20 captured your question earlier.
21 MEMBER REMPE: So, this is Joy, and just 22 to emphasize that point, I've looked ahead and saw 23 what the slides have, and locations of those 24 penetrations are of interest to me. So, if you could 25 provide or describe in another image that's not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1 currently included as part of that discussion, I sure 2 would appreciate it.
3 MR. HINDS: Okay, thanks for your 4 question. During the closed session when we get to 5 the figures, if it's okay, I'll try to elaborate 6 further on your question, including the locations as 7 they're postulated.
8 For this slide for now, the instrument 9 isolation, we're consistent with Reg Guide 1.11 for 10 instrument isolation, in other words, instruments 11 outside, instrumentation outside the containment where 12 it's piped into sensing piping inside, and again, I'll 13 show in the figure and I'll go further than my brief 14 comment at this time.
15 The isolation valves, the actuators 16 associated with containment isolation have the 17 appropriate protection against missiles and pipe 18 breaks, and as with our past designs, the resetting 19 features are consistent such that they do not cause 20 automatic reopening when resetting the containment 21 isolation valves.
22 We consider operating experience, which is 23 the result of a number of these requirements, such as 24 trapped liquid volumes between isolation valves, and 25 we evaluate that.
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33 1 We have the appropriate diversity of 2 control systems to ensure that common cause failures 3 in the I&C platforms would not result in the inability 4 to isolate, and then when we show the figures, we'll 5 go into more of how there's the coordination between 6 isolation of the containment and associated valves.
7 We've briefly mentioned here some of the 8 key penetrations or piping penetrations, and we're 9 very careful about specifying the fail position of 10 them as listed here, those power generation and 11 systems such as main steam fail safe, in the closed 12 position.
13 The isolation condenser system, consistent 14 with our past practice with ESBWR, have special design 15 requirements because of the high importance to safety 16 of the isolation condenser system, and again, in the 17 figures that we have in the closed session, we'll go 18 into more detail on that as well, so -- yes?
19 MEMBER MARCH-LEUBA: Help me out on this 20 one. Are these valve requirements that must be met by 21 the final certified design or are these an example of 22 how one can implement it, and do they become 23 regulatory commitments?
24 You have all of those figures, 2.7 through 25 2.10 to 12 or something like that. Are those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 1 requirements that the valves must operate like that, 2 fail closed, fail open, normally closed, normally 3 open, or are they an example that would be acceptable?
4 MS. WHITE: No, these are actually -- hi, 5 this is Frostie White. These are actually listed as 6 our design requirements that we will specify, so when 7 you see a PSAR or a DCD, unless we have to change this 8 for any particular reason, and of course, we will 9 explain in great detail why we would have to change 10 it, but these are our actual design requirements for 11 the containment isolation valves, and these are 12 further discussed in meeting the regulatory sections 13 or how to comply with various guidance documents, so 14 these are --
15 MEMBER MARCH-LEUBA: It wasn't clear to me 16 when I was reading it whether it was an example that 17 you're currently thinking of implementing or these are 18 a design requirement that you must satisfy.
19 MS. WHITE: No, in the LTR Section 227, we 20 actually specify these as our design requirements for 21 the containment isolation valves.
22 MEMBER MARCH-LEUBA: Okay, and that's 23 good. That's good. Thank you.
24 MR. HINDS: And further to your question 25 and possibly the reason or basis for your question NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 1 possibly is that we did specify in the figures that 2 those figures are example figures of implementing the 3 requirement, but these are intended to be design 4 requirements, and then the figure illustrates such 5 that how they could be met, and the figures are meant 6 to be very representative.
7 However, it's recognized that, you know, 8 pipe routing and things -- we wanted to call the 9 figures examples, but the requirements are 10 requirements. Hopefully that helps to further seal 11 that.
12 MS. WHITE: And it should be noted as well 13 that many of these requirements are consistent with 14 what we did on ESBWR for many of these valves, so the 15 key thing is the difference, some of the differences 16 between the BWRX-300 on containment isolation valves 17 and ESBWR, so we're trying to bring that out as well 18 in this LTR to give you an idea about how this design 19 is a little bit different than our ESBWR in that 20 regard.
21 MEMBER MARCH-LEUBA: Okay, thank you.
22 That helps. Please continue.
23 MR. HINDS: Okay, thanks. Frostie, could 24 you go to the next slide, please? Okay, further on 25 the containment isolation valves, we already mentioned NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 1 that on resetting, the containment isolation valves do 2 not reopen, so they're maintained in their required 3 post-accident condition. Valve qualification in the 4 ASME code is listed here, QME 1.
5 Further on the instrument penetration, we 6 do employ excess flow check valves which is consistent 7 with our predecessor designs and our operating 8 experience.
9 We have the piping for the isolation 10 condenser system which again, it gets special 11 treatment because of the safety-related nature and the 12 importance of the emergency core cooling system 13 functions of the isolation condenser.
14 That piping, we list the ASME 15 classification, a very high ASME classification to 16 minimize any probability of postulated or possibility 17 of breaks or leaks.
18 The CRD hydraulics, which is also 19 consistent with the ABWR, and somewhat consistent with 20 past designs, meaning the ABWR uses fine motion 21 control rod drives as the BWRX-300 and the ESBWR also, 22 so consistent with ABWR, ESBWR, the fine motion 23 control rod drives.
24 So, we're piping for the hydraulics for 25 the insert feature is consistent with the design, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 so we go into the commitments associated with ASME on 2 the penetrations, and we'll show those figures as 3 well. The pressure boundary of FMCRDs are made with 4 ASME materials and meet the ASME code.
5 The other defined basis is our regulatory 6 position associated with GDC 55 for the isolation 7 condenser system and for the HCUs, and that's what we 8 highlight more in the closed session because that's 9 where the figures come into -- can better illustrate.
10 But this is just the introductory slide to 11 indicate that we did use what's called other defined 12 basis for our regulatory position associated with that 13 configuration since those two safety systems, scram 14 and isolation condenser system cooling, are of high 15 safety significance and therefore receive special 16 treatment.
17 That's the introduction to the design 18 requirements and that's the extent of this session.
19 If there's no immediate questions, again, we'll 20 elaborate in the closed session, and move to the next 21 slide.
22 This is -- I'll turn it over to Necdet 23 Kurul at this point.
24 MR. KURUL: Hi, this is Necdet Kurul, GE 25 Hitachi. Can you hear me clearly?
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38 1 MEMBER MARCH-LEUBA: Yes, yes, I can hear 2 you.
3 MR. KURUL: Okay, thanks. There were 4 several questions regarding Section 3 previously and 5 comments, but we have one slide to go over Section 3 6 in this presentation. In this section, we present the 7 evaluation method that's used to demonstrate 8 compliance with the regulatory requirements.
9 Section 3.1 lists the accidents and events 10 that form the bases of containment thermal-hydraulic 11 performance requirements. So, the design pressures 12 and design temperatures are based on the accidents 13 that are listed in the section, so that's one major 14 set of requirements listed in this section.
15 And we are meeting GDCs. By using this 16 evaluation method, we are meeting GDCs 38 and 50. GDC 17 50 is the containment performance peak accident 18 pressure and temperature, and GDC 38 is the 19 containment cooling requirement to depressurize the 20 containment after an accident.
21 And we also, in this section, we list not 22 just general large break LOCAs, but we also name what 23 those piping are that may be included in the design 24 basis accidents.
25 So, in Section 3, we also present what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 1 computer codes we use and what the evaluation -- and 2 the method to develop the evaluation method. So, 3 initially, the title of the subsequent LTR was GOTHIC 4 method LTR, but it is now evaluation method LTR 5 because it naturally included mass and energy release 6 calculation as well.
7 And we also show that, or set the 8 requirements for the method, that we established the 9 evaluation method following Regulatory Guidance 10 1.2.03. This is the same regulatory guidance which we 11 used for TRACG mass and energy release and containment 12 evaluation method for ESBWR.
13 We are now replacing the containment 14 evaluation part of the method by GOTHIC instead of 15 doing the entire evaluation using TRACG, and that's 16 primarily because a dry containment presents a 17 different type of important phenomena than a wet 18 containment, a pressure suppression type of 19 containment that was used in ESBWR.
20 And in fact, BWRX-300 containment is much 21 less challenging than ESBWR containment for an 22 evaluation method.
23 DR. CORRADINI: So, this is Corradini.
24 Let me make sure I understand. I understand why you 25 want to make the switch. If it's less challenging, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 1 what is it about TRACG that doesn't allow you to 2 essentially apply it?
3 MR. KURUL: It is -- using TRACG and 4 GOTHIC gives us more flexibility for nodalization of 5 containment.
6 DR. CORRADINI: Right, but then --
7 MR. KURUL: Because it --
8 DR. CORRADINI: Well, that kind of goes 9 against what you said, it was easier to analyze. At 10 least, that's what I thought I heard you say.
11 MR. KURUL: Yes, it's still easier than 12 TRACG because the challenging part of containment 13 analysis with a pressure suppression type of 14 containment is what happens in the wetwell, the loads, 15 the air exchange between drywell and wetwell.
16 Those are actually challenges to 17 developing an evaluation method, but an otherwise dry 18 containment is a different approach, but it is -- it 19 has elements that are well established. From that 20 perspective, it is easier.
21 It takes more work because now we have to 22 use two different codes, but in terms of the 23 uncertainties and the methods, it is much easier to do 24 a dry containment.
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41 1 I understand your logic. We'll have to wait until we 2 get to that licensing topical report. Thank you.
3 MR. KURUL: Yes.
4 MEMBER KIRCHNER: This is --
5 MR. KURUL: Yes?
6 MEMBER KIRCHNER: -- Walt Kirchner. Mike, 7 what I'm thinking is I guess I have to be careful what 8 I say here, but probably when we get to the closed 9 session, the justification for the GOTHIC application 10 to their dry containment would be a topic to revisit.
11 DR. CORRADINI: I agree, Walt, but I guess 12 the reasoning given here made me want to ask the 13 question because I think I have a reasoning in my 14 mind, but I was trying to understand the reasoning 15 that was presented to us.
16 MR. KURUL: Okay, if there are any follow-17 up questions, maybe we can defer it to the closed 18 session. It is difficult for me to draw a line on the 19 fly between what is public and what's proprietary.
20 MEMBER REMPE: Could you elaborate about 21 this integral effect test? And I note that the report 22 regularly talks about conservatisms and it also talks 23 about beyond design basis events. Is the planned 24 approach going to continue to be conservative when you 25 go to beyond design basis events or are you going to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 1 go back to some sort of best estimate, or have you 2 guys thought about that yet?
3 MR. KURUL: Okay, so in this section, 4 that's what we are trying to clarify, that the 5 requirements for the evaluation method are for the 6 design of the containment, and the design of the 7 containment is just GDC 50 and 38 which requires these 8 evaluations.
9 And in that respect, the events that are 10 listed here are the events that are in the scope of 11 the containment design bases, accidents, and the 12 evaluation developed for it.
13 Beyond design basis events are in a 14 different area and the evaluation method does not 15 address those events. We will have a separate set of 16 methods to address the beyond design bases events.
17 MEMBER REMPE: What is the integral effect 18 test?
19 MR. KURUL: That is actually shown in the 20 subsequent licensing topical report for the evaluation 21 method, and we can discuss it in some length if you'd 22 like in the closed session.
23 MEMBER REMPE: Okay, thank you.
24 MR. KURUL: So, this Section 3 of NEDC-25 33911 sets the requirements for the evaluation method, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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43 1 which is that the list of accidents and the method 2 that's used in developing the evaluation method, which 3 is Reg Guide 1.203, so, but we are applying Reg Guide 4 1.203 for a mature code such as TRACG and GOTHIC.
5 And we identified -- these methods are 6 best estimate methods, and we established a phenomena 7 identification and ranking table, and identify 8 important phenomena, identify the uncertainties in the 9 modeling parameters and in the input parameters, and 10 then apply those conservatisms to make a conservative 11 method at the end.
12 And as I explained in Section 3, we are 13 not doing a statistical analysis to account for those 14 uncertainties in important phenomena, but rather we 15 are applying the uncertainty on each individual 16 phenomenon or modeling parameter and input, and at the 17 end, we have a conservative estimate, so that is the 18 way we apply Reg Guide 1.203, so that is --
19 MEMBER MARCH-LEUBA: So, let me summarize.
20 Instead of doing best estimate verse uncertainty, you 21 perform a single calculation with all the parameters, 22 input parameters and input data, biased to the most 23 conservative setting. Is that correct?
24 MR. KURUL: That is correct. Actually, we 25 do two calculations. One of them is best estimate and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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44 1 the other one is conservative, and that way we can 2 show the conservatism in the method that is in the 3 LTR, but when the method is reviewed, once we convince 4 ourselves that, yes, that is conservative, then we can 5 apply just the conservative going forward.
6 MEMBER MARCH-LEUBA: And I see that the 7 current PIRT has been moved to 22P, the topical 8 report, and that all these conservative others will be 9 discussed in the report?
10 MR. KURUL: That is correct because 11 keeping it in this report was making the presentation 12 a little confusing.
13 MEMBER MARCH-LEUBA: So, I agree, I agree, 14 and I'm not complaining. It was just an information 15 question. So, we look forward to look at it when we 16 review the Topical Report 22B. Thank you.
17 MEMBER REMPE: So, I know it's coming 18 later, but out of curiosity, sometimes what's 19 conservative for one event may not be conservative for 20 another event. It depends on what kind of requirement 21 you're trying to meet.
22 Did you look at a lot of different 23 requirements and look at a lot of different events 24 when you declare that all of your inputs are 25 conservative?
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45 1 MR. KURUL: Yes, excuse me, yes, actually, 2 that's the reason that we want to use a best estimate 3 method and apply conservatisms in the important 4 phenomena to arrive at the conservative method as 5 opposed to trying to do a very, very conservative 6 method that does not represent the transient, but 7 tries to establish a conservative bound to it.
8 We get surprised when we try to do that, 9 and that's the reason that we are applying CSAU 10 methodology so that our method is best estimate, and 11 then we identify the uncertainties and make sure that 12 these uncertainties are in the conservative direction.
13 MEMBER REMPE: Okay, thank you.
14 MR. KURUL: So, in the downstream 15 licensing topical report, we then show how we meet the 16 requirements that are established in this containment 17 performance LTR.
18 We show why TRACG, that method that was 19 developed for ESBWR, is applicable for the mass and 20 energy release calculation for BWRX-300 containment.
21 As I mentioned, we did a PIRT with the 22 participation of our chief engineers and also a 23 consultant from academia, and then we have established 24 the knowledge level and the uncertainties in each of 25 the phenomena.
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46 1 We have applied those uncertainties to 2 make bounding correlations, to bias the correlations 3 and inputs. We performed nodalization studies and we 4 performed benchmarking to integral effect test, which 5 is representative of BWRX-300 type.
6 That is all I planned on presenting on 7 this slide unless there are questions. I know that 8 there's one question about what is the integral effect 9 test? What's the integral test?
10 CHAIRMAN BLEY: This is Dennis Bley. I 11 got a little confused in the report and in your 12 statement that you used the CSAU methodology, but it 13 seems to me you really don't. You do a best estimate 14 calc and then you do an extension of that with all of 15 the conservative values thrown in rather than the 16 uncertainty approach.
17 MR. HECK: This is Charles Heck, GNF. I'd 18 like to address this question. The CSAU methodology 19 as it was laid out does not address how the 20 uncertainties are to be combined. It doesn't specify 21 that. It specifies the process for identifying the 22 uncertainties, identifying the phenomena, but in the 23 end, it is silent on exactly how you combine those.
24 Now, in the operating fleet, we chose to 25 combine those via a statistical process, and here, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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47 1 we're free to choose to combine them by accounting for 2 them by biasing to address the uncertainties to make 3 the overall methodology conservative, so there is a 4 wide range of ways to apply the combination of 5 uncertainties using the CSAU process.
6 CHAIRMAN BLEY: Okay.
7 MEMBER MARCH-LEUBA: Okay, if there are no 8 more questions, GE, please proceed. I'm planning to 9 have a break around 11:00. I'm hoping we make it to 10 the end of GE's presentation, but let's go for another 11 20 minutes, please.
12 MS. WHITE: All right, now we're getting 13 ready to get into the acceptance criteria for 14 containment performance and data that's, I believe --
15 MEMBER MARCH-LEUBA: Okay.
16 MR. HINDS: Yes, hopefully this is an easy 17 section here. This is just a listing of what's in 18 Section 4 of the LTR.
19 In Section 4 of the LTR, we explicitly 20 commit to GDCs for, the top bullet is for containment 21 pressure, pressure boundary and penetrations, meeting 22 the pressure and temperature requirements during 23 design basis accidents for the, we list the GDCs that 24 we meet or comply with.
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48 1 bounding peak accident pressure, and we indicate that 2 we're now less than 10 percent margin for the initial 3 licensing stage that would be consistent with PSAR, 4 and we list the GDCs and the standard review plan 5 guidance like Frostie mentioned there for dry 6 containment that we used for both guidance and 7 compliance.
8 Then we have the containment design 9 features or leak-tight barrier at the design for the 10 design basis accident pressure and temperatures, which 11 the methods that Necdet was covering would evaluate, 12 and we meet the GDCs listed here.
13 And then the containment structure and 14 internal components can accommodate the design basis 15 accident, and with the appropriate leak tightness 16 required by our safety analysis and listing GDCs here 17 as well.
18 So, again, this is just a firm commitment 19 to these regulatory requirements and the guidance in 20 the SRP. All right, any questions on this one? Okay, 21 Frostie, back to you.
22 MS. WHITE: Okay, so now we're going to 23 get a little bit into our regulatory compliance and 24 I'm going to start first with the requirements.
25 We evaluated our BWRX-300 containment, our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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49 1 primary, our passive containment cooling system, and 2 our containment isolation valves to the various 3 regulatory requirements. We looked at 50.34 and those 4 aspects. We looked at 50.44.
5 Please note that the 50.44 evaluation will 6 be coming in later in other licensing activities.
7 It's not evaluated here, but we will comply with those 8 sections and demonstrate that compliance in a later 9 licensing activity.
10 50.55a, these standards that we're going 11 to use will be in effect six months after license 12 application. We will comply for station blackout 13 under 50.63. We have class 1e battery backed DC power 14 for safety-related components, and then we list the 15 various GDCs we comply with for our containment PCCS 16 and our CIVs.
17 There are some CIVs that we have discussed 18 previously, and we mentioned for GDC 55 for CIVs that 19 are connected to RPV boundary that do meet the other 20 defined basis. It's not all of them, but there are 21 some of them, and we will discuss that in a closed 22 session.
23 And finally, under Appendix J, we will 24 perform our periodic integrated leak rate testing 25 consistent with the reg guide, and that's also NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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50 1 consistent with what we did on ESBWR. Any questions 2 at this stage?
3 MEMBER MARCH-LEUBA: Yeah, it may be too 4 detailed, but we are relying on the nitrogen inert 5 containment to prevent ignitions of the hydrogen. If 6 there is a leak because of a break of a pipe that is 7 not isolated, do we have sufficient nitrogen 8 requirements in the plan to make up the leak?
9 MS. WHITE: Yes.
10 MEMBER MARCH-LEUBA: So, your containment 11 becomes non-inerted.
12 MS. WHITE: Right, yes, we do, and we have 13 both oxygen and hydrogen monitors and analyzers on 14 there in that system as well to identify that.
15 MEMBER MARCH-LEUBA: Okay, so you'll talk 16 about that in the closed session, how it is then, and 17 if we have recombiners, the stacks?
18 MS. WHITE: Currently, we do not have 19 recombiners, but again, we have not evaluated this for 20 beyond design basis accident events.
21 MEMBER MARCH-LEUBA: So, that would be 22 more for the Topical Report 21P?
23 MS. WHITE: Yes, the later severe 24 accident, we will evaluate that, yes. We do discuss 25 that in this topical report that that will be provided NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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51 1 in another licensing activity such as that topical 2 report.
3 MEMBER MARCH-LEUBA: Thank you.
4 MS. WHITE: Any more questions for this 5 slide? Here is the various regulatory guides that we 6 have evaluated. We will comply with these. You know, 7 that's listed in this portion in Section 5 of the LTR.
8 Do we have questions for this?
9 Okay, further on guidance, we evaluated 10 this particular design with the differences to the 11 ESBWR, and these are the SRPs, some of the SRPs, I 12 have another page coming up in another slide coming up 13 that evaluates these, but specifically I wanted to get 14 down to SRP 6.2.1.
15 Again, because of this being a dry inerted 16 containment, some of the SRPs don't really apply to us 17 any longer, so we thought it was prudent to bring this 18 up to the NRC so that they understood the approach 19 we're taking and which guidance documents were 20 applicable.
21 So, 6.2.11A, which is typically a PWR SRP 22 guidance document, is actually applicable to this 23 design, although there are sections, and I'm going to 24 go over that in the next bullet, that are not 25 applicable in that particular section.
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52 1 But because we don't have a suppression 2 pool, we don't have subcompartments with large bore 3 high energy lines, we don't have secondary system 4 piping, we don't have an official emergency core 5 cooling system to maintain pressure, those particular 6 SRPs are no longer applicable to us. The staff did 7 review that and found that to be the case and agreed 8 with us.
9 Then, as I mentioned, on 6.2.11A, which is 10 a PWR dry containment, we excluded Sections 1, 2, and 11 3 because we don't have an ECCS system. We don't have 12 subcompartments and there's no secondary system, so 13 those particular sections weren't applicable, but 14 overall, that particular guidance is applicable.
15 MEMBER MARCH-LEUBA: And this is an 16 administrative question and probably more for the 17 staff than for you, but I applaud the approach you 18 have taken of bringing these things up, up front and 19 communicating with the staff and reaching an 20 agreement.
21 The first SRP is just guidance. You don't 22 have to satisfy it. You don't have to follow it, but 23 it would be a waste of time to elevate this to the 24 Commission as to an exemption. Simply the reason, a 25 technical discussion between the applicant and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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53 1 staff that you agree that we don't have a suppression 2 pool, so this doesn't apply to us, and they say yes, 3 and we're done. So, I applaud this approach and I 4 hope we continue to use it.
5 MS. WHITE: Thank you. All right, I'm 6 going on to the next one. Again, these are the SRPs 7 that we evaluated. 6.2.1.3 is mass and energy 8 release. As mentioned previously under the evaluation 9 method discussion, we are using TRACG and GOTHIC to do 10 those evaluations.
11 I was going to move down to 6.2.4, 12 containment isolation valves. Again, we're going to 13 have that discussion for GDC 55 compliance for some of 14 those valves in closed session. This is just a 15 further identification of the SRPs that we have 16 evaluated against this particular design.
17 Any questions on this? Okay, all right, 18 now we'd like to move into the closed session unless 19 there is any further questions.
20 MEMBER MARCH-LEUBA: So, we are going to 21 stop right here. We are not going to move to the 22 closed session. We're going to have the open session 23 from the staff first, but it's time to have a break.
24 If everybody agrees, let's have a 15-minute break and 25 come back at 11:05, and we will have the staff open NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 1 session.
2 MS. WHITE: Thank you.
3 MEMBER MARCH-LEUBA: So, we are on recess 4 until 11:05.
5 (Whereupon, the above-entitled matter went 6 off the record at 10:49 a.m. and resumed at 11:05 7 a.m.)
8 MEMBER MARCH-LEUBA: Let's just start the 9 meeting because we are five minutes late, which is not 10 bad. So, Court Reporter, we are back in session, and 11 we are still in open session, and the staff is going 12 to start their presentation any time they are ready.
13 MR. WUNDER: Okay, do I have Chang Li and 14 Renee Li, and -- right, all I need for the open 15 session is Chang Li.
16 MR. LI: Yes, Chang Li is here now.
17 MR. WUNDER: Okay, great. In that case, 18 let's go ahead and get started. Good morning, Mr.
19 Chairman, ladies and gentlemen of the committee.
20 We're here to present the results of the staff's 21 review of Topical Report NEDC-33911 on BWRX-300 22 containment performance.
23 I'm George Wunder and I've been assigned 24 as the project manager for this topical report, and 25 being so assigned, I have the pleasure one last time NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 1 of talking to you fine ladies and gentlemen before I 2 shuffle off into retirement at the end of the month.
3 We have a very brief presentation for the 4 open session before we move onto our more detailed 5 presentation in the closed session. We're going to 6 introduce the team and then present a high-level 7 overview.
8 Okay, I have the pleasure of introducing 9 our team. From Plant Systems, we have Chang Li and 10 Angelo Stubbs. Dr. Syed Haider is here representing 11 the Nuclear Systems Performance Branch. From 12 Mechanical Engineering, we have Renee Li and Tom 13 Scarbrough.
14 And not joining us today, not joining us 15 to present today, but nevertheless an important 16 contributor from Vessels and Internals, we have Dan 17 Widrevitz. Rani Franovich is the lead PM for this 18 project, and I have already introduced myself. With 19 that, I would like to turn the presentation over to 20 Chang Li. Chang Li, please take it from here, sir.
21 MR. LI: Can you hear me now?
22 MEMBER MARCH-LEUBA: Yes, yes, we can hear 23 you.
24 MR. LI: Okay, thank you, George. I am 25 Chang Li from the NRR Containment and Plant Systems NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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56 1 Branch. I will be presenting a brief overview of our 2 safety evaluation in the open session.
3 This slide discusses several design 4 features related to the BWRX-300 containment design.
5 Actually, there's the system design that were 6 described in the previous session by GEH. Next slide, 7 please?
8 The containment design that's in this 9 topical report, they have focused the review, focused 10 the presentation in the topical report in PCCS, 11 passive containment cooling systems, containment 12 isolation valves, analytic methods evaluating 13 containment performance, and acceptance criteria in 14 design of those systems. Next slide, please?
15 This topical report provides the design 16 requirements and our review is in accordance with 17 Standard Review Plan 6.2 even though, as mentioned, 18 the standard review plan is not a requirement, but it 19 provides us guidance as to the scope of our review.
20 That includes the topics listed here, 21 piping and valves, design, containment functional 22 design, containment heat removal systems, secondary 23 containment function and design. By the way, this 24 subject will not go into detail because the BWRX-300 25 design doesn't have secondary containment function NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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57 1 design.
2 We have brought extensive discussing in 3 containment isolation systems that we have discussed, 4 and combustible gas control, containment leakage 5 testing, and pressure prevention for containment 6 pressure boundary. Next slide, please?
7 When we do the review of the list of 8 regulations that's being discussed in the topical 9 report, we realized that in our review, we compile all 10 of the applicable SRP guidance and relevant 11 regulations with the regulations listed in the topical 12 report.
13 We noticed that when we're talking about 14 the topical report we used for both Part 50 process 15 and our Part 52 process. So, when it used Part 52, 16 they need to address the regulations to here, 52.47b1 17 and 52.80a. That's relating to ITAAC and COL 18 information.
19 A lot of end of line materials in which we 20 made our findings is based on proprietary information, 21 so a good portion of our discussion will have to be in 22 the closed session. We will go into much more detail 23 on those systems in the closed session, and at the 24 end, summarize our review. This concludes our 25 presentation for the open session.
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58 1 MEMBER MARCH-LEUBA: Well, that was fast.
2 Anybody who wants to make a comment? Am I hearing an 3 echo? Can somebody acknowledge that we are here?
4 MEMBER KIRCHNER: Yes, we hear you.
5 MEMBER MARCH-LEUBA: Yeah, thank you. So, 6 any members, any more questions for the staff? We are 7 going to have a very detailed presentation in the 8 afternoon, so I'd rather we stop early and have lunch 9 early, and then maybe start a little early in the 10 afternoon. Since this is a subcommittee meeting, I 11 believe we can start a little early.
12 But at this point, I would like to have 13 the opportunity to open the public line and see if any 14 members of the public have any comments. If so, 15 please state your name and present the comment. Do we 16 have the public line open, Thomas?
17 MR. DASHIELL: The public line is open for 18 comments.
19 MEMBER MARCH-LEUBA: Thank you. Any 20 member of the public? Hearing none, we will cancel --
21 I mean, we will go into recess soon. We are scheduled 22 to come back into session at 1:00 p.m., but instead of 23 starting the closed session now, I'd like to poll the 24 members.
25 Do you prefer to have an early lunch and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 1 come back say at 12:30 and maybe finish early or do 2 you prefer to start the closed session now, go on for 3 45 minutes, and continue at 1:00?
4 My preference, being in the eastern side 5 of the country, I would prefer to have an early lunch 6 and start at 12:30. Anybody opposed to that? Okay, 7 the meeting is in recess. We will restart on the 8 closed session at 12:30, and there will be some 9 process to allow people to get in that are allowed to 10 be in. So, the meeting is in recess.
11 MEMBER KIRCHNER: Jose, this is Walt --
12 MEMBER MARCH-LEUBA: Yes, sir?
13 MEMBER KIRCHNER: -- Kirchner again. So, 14 I gather we will not come back to an open session 15 after the closed session. Should we tell the public 16 that?
17 MEMBER MARCH-LEUBA: Yeah, I was thinking 18 to ask Larry or Scott to have somebody of the staff 19 come at 5:00 and tell the public that we are not going 20 to be there, that if they want to make a comment, they 21 can do it by email to them, and maybe we can attach it 22 to the meeting minutes. Would that be acceptable?
23 Scott, are you there?
24 MR. MOORE: Yeah, I'm on. I can certainly 25 go on the public line and go back at any time NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 1 throughout. So, as I understand it, the subcommittee 2 does not intend to go on the public line anymore for 3 the rest of the day, is that correct?
4 MEMBER MARCH-LEUBA: That is correct.
5 MR. MOORE: Okay, so I will go on the 6 public line at various times and make that 7 announcement.
8 MEMBER MARCH-LEUBA: Yeah, well, you can 9 make that announcement, but especially at 5:00, if 10 somebody shows up that wants to make a comment, they 11 should be allowed to make the comment by email and be 12 part of the record? I don't know. You decide.
13 MR. MOORE: Okay, I will do that, Mr.
14 Chairman.
15 MEMBER MARCH-LEUBA: Okay, so we are again 16 on recess. We will be back at 12:30 Eastern Time when 17 we will be in the closed session.
18 (Whereupon, the above-entitled matter went 19 off the record at 11:16 a.m.)
20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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ENCLOSURE 2 M210006 ACRS Subcommittee Presentation Slides for NEDC-33911P, BWRX-300 Containment Performance Licensing Topical Report Non-Proprietary Information IMPORTANT NOTICE This is a non-proprietary version of the ACRS Subcommittee Presentation Slides for NEDC-33911P, BWRX-300 Containment Performance Licensing Topical Report, from which the proprietary information has been removed. The header of each page in this enclosure carries the notation Non-Proprietary Information. Portions of the enclosure that have been removed are indicated by an open and closed bracket as shown here
(( )).
ACRS Subcommittee Presentation GEHitachi (GEH)
Licensing Topical Report (LTR) NEDC33911P BWRX300 Containment Performance (Open and Closed Sessions)
January 13, 2021
Agenda Open Session A. Licensing Topical Report Purpose and Scope B. Design Requirements for Containment and Passive Containment Cooling System to Meet Regulatory Requirements C. Design Requirements for Containment Isolation Valves to Meet Regulatory Requirements D. Analytical Methods Used for Evaluating Containment Performance E. Acceptance Criteria for Containment Performance F. Regulatory Compliance for Containment Performance Closed Session Compliance with 10 CFR 50, Appendix A, GDC 55 For Other Defined Basis Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 2
Licensing Topical Report Purpose and Scope Licensing Topical Report Purpose and Scope Provides the design requirements, analytical methods, acceptance criteria, and regulatory basis for the BWRX300 containment design functions:
- Specifies design requirements for containment and the Passive Containment Cooling System (PCCS) that meet the regulatory requirements of 10 CFR 50, Appendix A, General Design Criteria (GDC) 1, 2, 4, 16, 38, 41, 42, 50, 51, 52, 53 and 54 (LTR Sections 2.2.2, 2.2.8, and Section 5.1)
- Specifies design requirements for the containment isolation valves (CIVs) that meet the regulatory requirements of GDCs 1, 2, 4, 54, 55, 56, and 57 (LTR Sections 2.2.7, 5.1.55.1.7, 5.1.215.1.24)
- Specifies analytical methods TRACG and GOTHIC with accompanying acceptance criteria that will be used for evaluating containment performance to demonstrate compliance with GDCs 38 and 50 (LTR Section 3). Evaluation methodology that will be used to demonstrate compliance is in NEDC33922P
- Specifies BWRX300 acceptance criteria for containment performance in accordance with the design requirements for containment, PCCS and CIVs (LTR Section 4.0)
Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 4
Licensing Topical Report Purpose and Scope LTR NEDC33911P Containment Evaluation scope is supported by:
- Technical description of BWRX300 containment, PCCS, and CIV design features and functions based upon proven design concepts from previous BWRs (LTR Section 2.2)
- Technical description of the BWRX300 analytical methods utilizing the applicable parts of the ESBWR TRACG model to calculate the mass and energy release from the reactor pressure vessel, with input to GOTHIC for evaluating containment response from the mass and energy release. These models are used to demonstrate compliance for the containment, PCCS, and CIV acceptance criteria (LTR Sections 3.23.4)
- Regulatory evaluation of applicable regulations and guidance for the BWRX300 containment, PCCS and CIV design features and functions to be used to demonstrate compliance with the acceptance criteria (LTR Section 5.0)
Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 5
Design Requirements for Containment and PCCS to Meet Regulatory Requirements
Containment and PCCS Design Requirements BWRX300 primary containment vessel (PCV) is Safety Class 1, safetyrelated and seismic Category I with ASME Code requirements specified for:
- either metal or concrete containment structure
- reactor pressure vessel (RPV) isolation valves
- structural supports for piping systems and components inside the PCV
- additional structures of the PCV internals Postulated pipe rupture locations and configurations inside containment are specified per BTP 34, Part B, Item 1(iii)(2) and identification of leakage cracks per BTP 34, Part B, Item 1(v)(2) for piping connected to the RPV isolation valve assemblies extending to the containment wall ASME Code Section III, Division 1, Subarticle NE1120 and BTP 34, Part B, Items 1(ii)(1)(d) and (e),
and Items 1(ii)(2) through (7) are applied to eliminate postulated breaks/cracks in those portions of piping from the containment wall to the outboard CIV PCV, penetration piping systems and associated support materials are designed in accordance with ASME Section II, Material Specifications with exception to nonconductive portions of electrical penetrations Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 7
Design Requirements For CIVs to Meet Regulatory Requirements
CIV Design Requirements - LTR Section 2.2.7
- CIVs, associated piping and penetrations meet seismic Cat. I and ASME Section III, Division 1, Subsection NE, Class MC Components and Subsection NC, Class 2 Components
- Isolation limits leakage within permissible limits
- CIV closure timing is commensurate with timing of fission product releases
- Instrument isolation valves that penetrate containment conform to RG 1.11
- Isolation valves, actuators and controls are protected against missiles and postulated high and moderate energy line ruptures
- Resetting automatic CIVs does not result in automatic reopening
- Penetrations with trapped liquid volume between the isolation valves have adequate relief for thermally induced pressurization
- Control diversity for penetrations with RPV isolation valves
- CIVs for main steam, feedwater, shutdown cooling and reactor water cleanup fail closed
- RPV isolation valves for IC steam supply and condensate return fail asis with valve actuators maintaining the valve asis by positive mechanical means Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 9
CIV Design Requirements - LTR Section 2.2.7
- All other CIV penetration configurations are maintained in the required postaccident position
- Valve qualification with ASME Standard QME12007 (or later edition)
- Outside containment automatic CIV closure time established to assure isolation prior to first fission product release
- Excess flow check valves (EFCVs) are used in small piping with level instruments
- Piping in the area between the outermost RPV isolation valve and the containment boundaries, as well as the piping through the seismic Category I reactor building where the isolation condenser system (ICS) steam supply and condensate return piping connects to the ICS heat exchanger are ASME Section III, Class 1, NB piping, limiting the possibility of breaks
- Scram insert piping from the hydraulic control unit (HCU) room to the fine motion control rod drives (FMCRDs) are ASME Articles NB2150 and NB3120
- Primary pressure boundary components of the FMCRD lower housing of the spool piece and the flange of the outer tube assembly are made with ASME Code Section III 300 series stainless steel materials
- CIVs connected to the RPV boundary comply with the other defined basis definition of GDC 55 (discussed in the Compliance with 10 CFR 50, Appendix A, GDC 55 closed session)
Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 10
Analytical Methods Used for Evaluating Containment Performance
Analytical Methods Used for Evaluating Containment Performance NEDC33911P sets the requirements for the evaluation method where approval of these requirements is requested
- LTR Section 3.0 outlines the evaluation method requirements used in demonstrating containment performance
- LTR Section 3.1 lists accidents and events that form the basis of the containment thermal hydraulic performance requirements that demonstrate compliance with GDCs 38 and 50
- The remaining subsections of Section 3 introduce computer codes used in the evaluation method and sets the requirements following the guidance in RG 1.203 NEDC33922P BWRX300 Containment Evaluation Method (submitted separately):
- Use of TRACG for mass and energy release calculations developed and approved for ESBWR with justification of same method use for BWRX300, and any application differences
- Identification of phenomena important to containment analysis and evaluation of uncertainties
- Correlations and inputs used to bound the uncertainties
- Nodalization studies
- Benchmarking to an integral effect test to demonstrate conservatisms Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 12
Acceptance Criteria for Containment Performance
Containment Performance Acceptance Criteria
- Containment pressure boundary and penetrations are designed for pressure and temperature for design base accidents (DBAs) in accordance with GDCs 2, 4, 16, 38, 41, 50 and 51
- Containment design pressure will bound the peak accident pressure resulting from the most limiting large break LOCA with margin (no less than 10% margin in PSAR) in order to conform with the requirements of GDCs 4, 16, 38, 41, 50 and 51, and the guidance of SRP 6.2.1.1.A
- Containment design features provide an essentially leaktight barrier where containment pressure and temperature can be reduced rapidly and maintained at acceptably low levels following a LOCA to meet the requirements of GDCs 16, 38, 50
- Containment structure and internal compartments can accommodate without exceeding the design leakage rate with sufficient margin, the calculated pressure and temperature conditions resulting from a LOCA to meet the requirements of GDCs 16, 38, 50 Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 14
Regulatory Compliance for Containment Performance
Regulatory Compliance The BWRX300 containment, PCCS, and CIV design complies with the following regulations:
- 10 CFR 50.34(f)(2)(xiv), (f)(2)xv), (f)(2(xvii) - all nonessential systems isolate with two isolation barriers in series except for nonessential instrument lines
- 10 CFR 50.34(f)(3)(A)(1) - containment structure integrity is maintained for an accident that releases hydrogen generated from a 100% fuel clad metalwater reaction
- 10 CFR 50.44(c)(1), (c)(2), (c)(3), (c)(4), (c)(5) - the BWRX300 containment is dry and nitrogeninerted where no subcompartments may accumulate combustible gas mixtures
- 10 CFR 50.55a - containment, PCCS, and CIV design features use standards approved in 10 CFR 50.55a(a) in effect within 6 months of license application
- 10 CFR 50.63 - design includes Class 1E batterybacked DC power for safetyrelated components for coping with station blackout
- GDCs 1, 2, 4, 5, 13, 16, 38, 39, 40, 41, 42, 43, 50, 51, 52, 53, 54, 55 (separate slide provided in closed session for CIVs complying with other defined basis), 56, 57, 64 are met for the BWRX300 containment, PCCS and CIVs
- 10 CFR 50, Appendix J - periodic integrated leakage rate testing conducted with guidance from RG 1.163 Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 16
Regulatory Guidance The guidance from the following regulatory guides is met for the BWRX300 containment, PCCS and CIVs:
- RG 1.11 Instrument Lines Penetrating the Primary Reactor Containment
- RG 1.84 Design, Fabrication and Materials Code Case Acceptability
- RG 1.141 Containment Isolation Provisions for Fluid Systems
- RG 1.147 Inservice Inspection Code Case Acceptability
- RG 1.155 Station Blackout
- RG 1.163 PerformanceBased Containment Leak Rate Test
- RG 1.192 Operation and Maintenance Code Case Acceptability
- RG 1.203 Transient and Accident Analysis Methods Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 17
Regulatory Guidance Contd.
The guidance from the following standard review plans (SRP) are met for the BWRX300 containment, PCCS and CIVs:
- SRP 3.6.2 Determination of Rupture Locations and Dynamic Effects - complete description and associated branch technical positions compliance utilizing many of the assumptions from ESBWR Design Control Document (DCD) Section 3.6.1.1 will be provided in future licensing activities
- SRP 3.9.6 Functional Design, Qualification and Inservice Testing Programs for Pumps, Valves, and Dynamic Restraints - CIV design will use standards approved in 10 CFR 50.55a(a) effective within six months of any license application
- SRP 6.2.1 Containment Functional Design - BWRX300 containment design is affected by the guidance in SRPs 6.2.1.1.A, 6.2.1.3; SRPs that are not applicable for the BWRX300 design include: 6.2.1.1.C no pressuresuppression pool; 6.2.1.2 no subcompartments with large bore high energy lines; 6.2.1.4 no secondary system piping; 6.2.1.5 no emergency core cooling system (ECCS) to maintain pressure following design base events
- SRP 6.2.1.1.A PWR Dry Containments, Including Subatmospheric Containments - excluding Sections: (1) no ECCS, (2) no subcompartments with large bore high energy lines and (3) no secondary systems Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 18
Regulatory Guidance Contd.
The guidance from the following SRPs is met for the BWRX300 containment, PCCS and CIVs:
- SRP 6.2.1.3 Mass and Energy Release for Postulated LossofCoolant Accidents - calculated neutronics and thermalhydraulics using previous TRACG Containment/LOCA submittals that are applicable to BWRX300 design (see LTR Section 3.1)
- SRP 6.2.2 Containment Heat Removal Systems - BWRX300 does not employ use of spray water, ECCS or sumps in the design to actively remove heat or pressure within containment and longterm core cooling is addressed in LTR NEDC33910P BWRX300 Reactor Pressure Vessel Isolation and Overpressure Protection
- SRP 6.2.3 Secondary Containment Functional Design - Not applicable to BWRX300 containment design
- SRP 6.2.4 Containment Isolation System - design of the CIVs and associated piping and penetrations will meet the requirements of seismic Category I components and ASME Section III, Class 1 or 2 according to their quality group classification
- SRP 6.2.5 Combustible Gas Control in Containment BWRX300 containment is dry, nitrogeninerted that does not rely upon gas control to maintain hydrogen and oxygen concentrations below combustible levels and maintain structural integrity following a DBA; for beyond design basis events and severe accidents, a separate evaluation and analysis will be provided in future licensing activities
- SRP 6.2.7 Fracture Prevention of Containment Pressure Boundary - conforms similarly to ESBWR Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 19
Closed Session Compliance With 10 CFR 50 Appendix A, GDC 55 For Other Defined Basis
10 CFR 50, Appendix A, GDC 55 Compliance The BWRX300 CIVs connected to the RPV boundary comply with the other defined basis alternative.
- BWRX300 incorporates isolation valves ((
)) for large and medium pipe break LOCAs (( ))
- RPV isolation valves are single failure proof, contained in seismic Category I containment, and meet ASME Code Section III, Class 1; associated piping is ASME Section III, Class 1 NB piping that limits the probability of breaks in these piping segments
- Breaks between the RPV isolation valves and containment would be isolated to stop the leak and would be contained by the closed system outside containment that is designed to withstand full reactor pressure Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 21
10 CFR 50, Appendix A, GDC 55 Compliance The BWRX300 CIVs connected to the RPV boundary comply with the other defined basis alternative.
Automatic CIVs outside containment are also included for GDC 55 compliance with the following exceptions:
- RPV isolation valves for the ICS steam supply and condensate return piping with the closed loop IC located outside containment serve as a passive substitute for an open active outside containment automatic CIV; ((
)) to allow the ICS to function as a part of ECCS
- HCUs of the FMCRDs also serve as a closed system outside containment similarly to what was approved for the ESBWR; adding additional isolation valves in this piping for containment isolation is not in the direction of highest safety because it could become a new potential failure mode in a safety critical system and will not improve the integrity because the small diameter high pressure hydraulic lines are attached to a closed system outside containment and therefore do not cause a risk of containment leakage Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 22
LTR Figure 25: Main Steam and Feedwater CIVs Connected to RPV Boundary
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Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 23
LTR Figure 27: Isolation Condenser CIVs Connected to the RPV Boundary
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Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 24
LTR Figure 28: FMCRD CIVs Connected to RPV Boundary Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 25
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