ML21064A279

Transcript for the Advisory Committee on Reactor Safeguards Thermal-Hydraulic Phenomena Subcommittee Meeting - January 13, 2021, Pages 1-89 (Open)

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

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1

1 2

3 DISCLAIMER 4

5 6

UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7

ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8

9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.

15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.

19 20 21 22 23

1 UNITED STATES OF AMERICA 1

NUCLEAR REGULATORY COMMISSION 2

+ + + + +

3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4

(ACRS) 5

+ + + + +

6 THERMAL-HYDRAULIC PHENOMENA SUBCOMMITTEE 7

+ + + + +

8 OPEN SESSION 9

+ + + + +

10 WEDNESDAY 11 JANUARY 13, 2021 12

+ + + + +

13 The Subcommittee met via Teleconference, 14 at 9:30 a.m. EST, Jose March-Leuba, Chairman, 15 presiding.

16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

2 COMMITTEE MEMBERS:

1 JOSE MARCH-LEUBA, Chairman 2

RONALD G. BALLINGER, Member 3

DENNIS BLEY, Member 4

CHARLES H. BROWN, JR. Member 5

VESNA B. DIMITRIJEVIC, Member 6

WALTER L. KIRCHNER, Member 7

DAVID A. PETTI, Member 8

PETER RICCARDELLA, Member 9

JOY L. REMPE, Member 10 MATTHEW W. SUNSERI, Member 11 12 ACRS CONSULTANTS:

13 MICHAEL CORRADINI 14 STEPHEN SCHULTZ 15 16 DESIGNATED FEDERAL OFFICIAL:

17 ZENA ABDULLAHI 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

3 AGENDA 1

ACRS Chairman Opening Remarks 4

2 GEH Overview of LTR NEDC-33991P

........ 10 3

NRC Staff Overview of Safety Review

...... 54 4

5 6

7 8

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

4 P R O C E E D I N G S 1

9:31 a.m.

2 MEMBER MARCH-LEUBA: This meeting will now 3

come to order. This is a meeting of the ACRS Accident 4

Analysis Thermal-Hydraulic Subcommittee. I am Jose 5

March-Leuba, the SC Chairman. Because of COVID-19 6

concerns, this meeting is being conducted remotely.

7 I see the following ACRS members are in 8

attendance, which is all of them, Ronald Ballinger, 9

Dennis Bley, Charles Brown, Vesna Dimitrijevic, Walter 10 Kirchner, David Petti, Joy Rempe, Pete Riccardella, 11 and Matthew Sunseri.

12 Also note our consultant, Mike Corradini 13 is on the line, and let me check, and Steve Schultz is 14 also on the line.

15 Today's topic is Topical Report NEDC-16 33911P, BWRX-300 Containment Performance. This 17 topical report defines the criteria that will be used 18 in a future submittal to ensure that the BWRX-300 19 containment satisfies all applicable regulations.

20 Portions of our meeting will be closed to 21 the public to protect proprietary information. We 22 will have an opportunity for public comments before we 23 start the closed section of the meeting.

24 The ACRS was established by statute and is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

5 governed by the Federal Advisory Committee Act, FACA.

1 As such, the committee can only speak through its 2

published letter reports.

3 The ACRS section of the U.S. NRC public 4

website provides our charter, bylaws, agendas, letter 5

reports, and full transcripts for the open portions of 6

all full and subcommittee meetings, including the 7

slides presented there.

8 The Designated Federal Official today is 9

Zena Abdullahi.

10 A transcript of the meeting is being kept.

11 Therefore, please speak into the microphones clearly 12 and state your name for the benefit of the court 13 reporter.

14 Please keep the microphone on mute when 15 not being used, and don't use video feed to minimize 16 bandwidth problems.

17 We are expected to have a full committee 18 meeting on this topic on February 3, and this ends the 19 official portion of this announcement.

20 Let me now provide some personal views 21 about this topical report, SE. And again, this is, 22 again as I said before, ACRS only speaks through 23 letters. This is my personal opinion.

24 I find this topical report and associated 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

6 SE at best confusing and sometimes lacking, and there 1

are two issues I would like the presenters to try to 2

convince me why I'm wrong about it.

3 The first one is the BWRX-300 concept 4

doesn't exist. It has not been submitted for review.

5

However, this topical report presents some 6

hypothetical concepts that could be used once it gets 7

submitted, but the SER kind of uses the language as 8

the staff has been reviewing BWRX-300 certified 9

design, which doesn't exist yet.

10 So, GE has submitted some concepts and the 11 staff has looked at them, but the SE should be more 12 explicit in saying that these are concepts, that once 13 the design is really sent for review, we will make 14 sure that these are the same concepts that were 15 introduced.

16 By approving, I am not sure legally what 17 happens when you approve this topical report with 18 these concepts embedded on it, and I will be talking 19 to the staff during their presentation about the legal 20 implications of putting a dash A on the topical report 21 number with concepts that are not part of a 22 certification.

23 On that same line, the SE special 24 limitations and conditions, they look to me like an SE 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

7 with open items. The limitations and conditions, when 1

we go in, they'll be on the slides, but for them, they 2

look more like requests for information than a 3

limitation. So, we'll go through those details, and 4

please keep that in mind when we do the presentation.

5 The third topic of concern, and this one 6

is important to me, and it deals with a lot of 7

proprietary information, so we'll be discussing this 8

in the closed session, it has to do with the GDC 55 9

compliance.

10 It is my opinion that the concepts --

11 (Audio interference.)

12 MEMBER REMPE: Hello? Jose, I don't know 13 if you can hear us, but we can no longer hear you 14 after you said the word concept.

15 MEMBER MARCH-LEUBA: Oh, boy. Can you 16 hear me?

17 MEMBER REMPE: I can hear you now, so, 18 when you said oh, boy, so could you repeat what you 19 said after the word concept?

20 MEMBER MARCH-LEUBA: Okay, I can only hear 21 myself. Can you hear me now?

22 MEMBER REMPE: We can hear you, but would 23 you repeat what you said after -- you said that you 24 had a third issue and it may have some proprietary 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

8 implications, and then you said the word concept in a 1

sentence, and after that, the plane flew over like 2

other folks heard.

3 MEMBER MARCH-LEUBA: Okay, my concern, and 4

I want the members to listen carefully when we review 5

this issue, is with the compliance with GDC 55, and 6

the details are proprietary, so we will talk about 7

them this afternoon in the closed session, but it is 8

9 I'm leaning towards suggesting that really 10 this concept requires a GDC 55 exemption if they want 11 to proceed this way instead of just politely saying 12 that, yeah, it satisfies it. It satisfies the spirit 13 of it.

14 Yeah, so when we talk about GDC 55, and 15 somehow 56 also, please, members, pay attention 16 because this might be controversial.

17 That said, those are my initial remarks, 18 my personal opinion, and I wanted to put it in here so 19 we have an opportunity, GE and the staff, to review my 20 personal thoughts on this.

21 Anybody else want to do any introductory 22 remark or shall we move to the presentation?

23 MEMBER KIRCHNER: Jose, this is Walt 24 Kirchner. Just why don't you explain for the record 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

9 what GDC 55 is?

1 MEMBER MARCH-LEUBA: GDC 55 requires for 2

any pipe of any, of significant diameter that 3

penetrates containment, it must have an isolation 4

valve inside and an isolation valve outside 5

containment.

6 GDC 56 is similar, but applies to pipes 7

that connect to the containment atmosphere. So, it 8

has to do with containment isolation valves.

9 Okay, hearing no more comment --

10 MEMBER REMPE: Jose, since you brought 11 this up, I guess as they try and address that issue, 12 I'm very interested in how this design, and I'm sure 13 that this something they'll come back from, I suspect 14 they'll say they have not thought all of the details 15 through, but when I look at this, I'm very interested 16 in what they're going to do with the water level 17 instrumentation that they have indicated will be used.

18 And the reason why I'm interested in this 19 is there's a diagram the staff will show in their 20 slides, but when I think about the reference leg for 21 the water level sensor that's used at higher 22 elevations and what was done with the reference leg 23 after TMI to some of the operating fleet.

24 So, I am very curious how that -- I mean, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

10 there's no reason to build something and make changes 1

that were put in after TMI backfits were put in. They 2

need to think about this early on, and again, as I go 3

through all of these advanced reactor designs, I'm 4

very interested in instrumentation and how it will be 5

addressed.

6 And I think that some of the -- anyway, I 7

think I've said enough, but I just want to make sure 8

that GE has remembered what was done with the 9

operating fleet and that that consideration is 10 considered with this design, okay?

11 MEMBER MARCH-LEUBA: So, please, GE, keep 12 in mind that we would like to hear about 13 instrumentation. You may not have prepared the slide.

14 Whenever you feel it belongs, please talk about water 15 level instrumentation.

16 And I know for history that the committee 17 is very interested on the post-accident 18 hydrogen/oxygen monitoring, so if you could --

19 MEMBER REMPE: Yes.

20 MEMBER MARCH-LEUBA: -- also address that.

21 Okay, George or GE, whoever is presenting, I give you 22 the microphone.

23 MR. WADKINS: Okay, thank you. Good 24 morning. My name is George Wadkins. I'm the Vice 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

11 President of New Power Plants and Products Licensing 1

for GE Hitachi. Today, we will be presenting an 2

overview of the BWRX-300 design and a description of 3

the content for Licensing Topical Report NEDC-33911P, 4

BWRX-300 Containment Performance.

5 We will be describing design requirements, 6

analytical methods requirements, acceptance criteria, 7

and regulatory basis for the BWRX-300 containment, 8

including containment isolation valves and the 9

associated passive containment cooling system.

10 As noted in our previous discussions with 11 the ACRS members, the BWRX-300 builds upon our 12 extensive experience in boiling water reactor 13 technology, including our most recent experiences in 14 development and certification of the economic 15 simplified boiling water reactor or ESBWR.

16 The BWRX-300 design leverages the use of 17 proven technology to the greatest extent possible 18 while incorporating advances in design requirements 19 and features to further enhance nuclear safety.

20 One major difference between the ESBWR and 21 the BWRX-300 is in the functional design of the 22 containment. The ESBWR utilizes a compartmentalized 23 containment with a drywell surrounding the reactor and 24 connected systems, including the piping and valves, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

12 and a wetwell containing the suppression pool.

1 The suppression pool functions to condense 2

steam from the reactor for depressurization and to 3

allow for passive injection of water to maintain 4

reactor water inventory and cooling of the core while 5

maintaining acceptably low containment pressures and 6

temperatures.

7 The BWRX-300 has a relatively large dry 8

containment that does not require reactor or 9

containment pressure and temperature suppression 10 features using a suppression pool.

11 Reactor depressurization is achieved 12 through use of the isolation condenser system instead 13 of through an automatic depressurization system that 14 releases the steam to a suppression pool.

15 The BWRX-300 containment does include a 16 passive containment cooling system that will be 17 discussed later in this presentation, but its primary 18 function is not for immediate pressure suppression as 19 it is in the ESBWR.

20 The design of many of the piping systems 21 and valves that form the containment boundary, 22 including the containment isolation valves, are very 23 similar to those of the ESBWR.

24 These containment features, including 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

13 containment penetrations and the containment isolation 1

valves, are described in this licensing topical report 2

with appropriate design requirements and regulatory 3

basis for containment isolation.

4 Because of the simplified design of the 5

containment, the analytical methods' requirements are 6

also simplified with the application of a different 7

methodology using GOTHIC code instead of TRACG code 8

for containment pressure and temperature response.

9 This licensing topical report does not 10 seek approval of the use of GOTHIC as an acceptable 11 methodology, but it does establish the design --

12 (Audio interruption.)

13 MR. WADKINS: -- for example, maximum 14 allowed containment, post-accident pressures, and 15 temperatures that the methodology will be used to 16 verify.

17 The application of the GOTHIC methodology 18 is the subject of a separate Licensing Topical Report 19 NEDC-33922P, BWRX-300 Containment Evaluation Method, 20 which is currently under review by the NRC staff.

21 To support their review, the NRC staff is 22 also conducting an audit of the base and conservative 23 cases used in that follow-up licensing topical report.

24 MEMBER MARCH-LEUBA: George, this is Jose.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

14 You're bringing the topic of 22P, which is the NEDC-1 3392P.

2 MR. WADKINS: Yes.

3 MEMBER MARCH-LEUBA: The title of the 4

report was changed during the review as a result 5

probably of our staff RAI. Did the scope of the 6

report change to include more than just GOTHIC, 7

basically some of the TRACG energy and mass monitoring 8

conditions?

9 MR. WADKINS: Yes, it was and it always 10 had been intended to address how mass and energy 11 releases were calculated, which is why we changed the 12 title because we did need to discuss the use of the 13 TRACG code for determining those mass and energy 14 releases as inputs to the GOTHIC evaluation.

15 MEMBER MARCH-LEUBA: Yeah, for the record, 16 I don't have it in front of me, but the old title used 17 to be GOTHIC Application 2, and the new title is 18 Containment Methodology or something like that. I'm 19 paraphrasing.

20 MR. WADKINS: Yes.

21 MEMBER MARCH-LEUBA: Okay, well, that's 22 good. I mean, that's excellent. The only complaint 23 I have, and it's related to my initial comment, is 24 that Section 3 of the topical report describes this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

15 methodology, and even though it's clear from the text 1

of the SER that we are, and clear from your 2

presentation that GE is not asking for approval of 3

that Section 3.

4 When we put that dash A meaning approved 5

to the title to the report, we're implicitly approving 6

the Section 3, and I'll be talking to the staff about 7

that, that maybe it should be a limitation or 8

condition that which is similar to 2, the cooling 9

limitation edition 2, that explicitly says Section 3 10 is for information only and is not approved. I don't 11 think anybody would have a complaint about that.

12 MR. WADKINS: Yes, thank you. I agree 13 with you that we will also be discussing that further 14 as we go through our presentation today, so that we 15 hopefully can make it clear what the boundaries are 16 between this LTR and the containment evaluation method 17 LTR.

18 We agree that that needs to be very 19 clearly stated and understandable, and that the SERs 20 need to properly identify what they are approving in 21 those different LTRs.

22 So, continuing on, during our 23 presentation, we will pause at the end of each slide 24 to allow for questions from the members, but do please 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

16 feel free to raise questions at any time. If the 1

discussions involve any proprietary information, we 2

will request tabling the question until the later 3

closed session.

4 I will now turn over the presentation to 5

Frostie White, Senior Licensing Engineer for this LTR, 6

to describe the agenda for today's open session 7

presentation.

8 MS. WHITE: Can everybody see the 9

presentation slides okay? And I apologize for the 10 background noise. I live right outside of Naval Air 11 Station Pensacola, so.

12 MEMBER MARCH-LEUBA: So, it was your 13 fault, huh?

14 MS. WHITE: Yeah, the Blue Angels, you'll 15 hear them for a little while.

16 MEMBER MARCH-LEUBA: Okay.

17 MS. WHITE: Can everyone see the screen 18 okay?

19 MR. WADKINS: Yes.

20 MEMBER MARCH-LEUBA: We see slide number 21 one if the computer is not frozen.

22 MS. WHITE: All right.

23 MEMBER MARCH-LEUBA: Okay, I now see slide 24 number two, perfect.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

17 MS. WHITE: Okay, first I'd like to go 1

through the agenda. In the open session, we're going 2

to first discuss our report purpose and scope.

3 Then we will follow through with the 4

design requirements for the containment in the Passive 5

Containment Cooling System to meet the various 6

regulatory requirements that apply for this particular 7

design that are somewhat different in some aspects to 8

our ESBWR.

9 Then we will go through the design 10 requirements for our containment isolation valves to 11 meet these regulatory requirements.

12 Part of that discussion will be a closed 13 session regarding some of the containment isolation 14 valves that meet the other defined basis for General 15 Design Criteria 55, and we'll have that in the closed 16 session because we will be discussing some proprietary 17 information there.

18 Then we are going to go through our 19 analytical methods that we're evaluating our 20 containment performance, and in that discussion, that 21 will be slide 12 by the way, there will be some 22 information provided to the ACRS subcommittee 23 describing those items in NEDC-33922, which is the 24 containment methods LTR that George mentioned here, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

18 and we're hoping to be able to define and clearly 1

distinguish between this LTR and the other LTR which 2

you're going to be seeing later.

3 Then we're going to provide the acceptance 4

criteria for the containment performance. We have a 5

regulatory compliance section as well where we explain 6

what guidance documents that we're utilizing, and 7

then, of course, all of the regulatory requirements 8

that we're meeting.

9 And then finally, in our closed session, 10 we're going to be discussing how we meet the other 11 defined basis for some of the containment isolation 12 valves that are connected to the reactor pressure 13 vessel boundary.

14 So, let me go through our topical report 15 and purpose first. This LTR was going to specify the 16 design requirements for the containment in the Passive 17 Containment Cooling System to meet the various 18 regulatory General Design Criteria that we have 19 provided there. You can find that information in the 20 LTR Sections 222, 228, and Section 5.1.

21 Second, we're going to specify our design 22 requirements for the containment isolation valves in 23 order to meet the various design, General Design 24 Criteria listed. You can find that information in our 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

19 LTR Sections 227, 5.1.5 through 5.1.7, and 5.1.21 1

through 5.1.34.

2 Again, for part of the GDC 55 compliance 3

for CIVs connected through the RPV boundary, that will 4

be discussed in closed session due to some of the 5

proprietary information in that discussion.

6 Another topical report purpose is we're 7

going to specify analytical methods for our TRACG and 8

our GOTHIC we're going to be using to evaluate our 9

mass-energy release from the pressure vessel using 10 TRACG and then containment performance based on input 11 from TRACG in our how our containment performs, and 12 that will be to comply with GDCs 38 and 50, and that 13 is discussed in the LTR Section 3.

14 That evaluation methodology again is going 15 to be demonstrated in our later LTR 3322, which is the 16 containment methods, and again, Necdet Kurul is going 17 to go over that in a slide with you and define the 18 difference, the boundary between this LTR and the 19 other one.

20 And finally, we're going to specify the 21 acceptance criteria for the containment performance 22 for the containment, the PCCS in the containment 23 oscillation valves, and that's in LTR Section 4.0.

24 DR. CORRADINI: So, this is Corradini, the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

20 consultant. I had a question. Is 33922P kind of out 1

of phase with this? Was it supposed to have been 2

looked at before this? Because it seems like we're 3

looking at a broader set of requirements and 4

essentially leaving Section 3 as an open item, as Dr.

5 March-Leuba said. So, was this just simply out of 6

phase and this got ahead of the other topical report?

7 MS. WHITE: No, this was not out of phase.

8 This is -- the TRACG, Dr. Corradini, was obviously --

9 I think you actually reviewed it previously for ESBWR 10 in our --

11 DR. CORRADINI: Right.

12 MS. WHITE: -- BWR applications. We're 13 still using TRACG and many of the method inputs are 14 still applicable to the BWRX-300. So, this leads into 15 the containment evaluation methodology where we 16 actually provide results of TRACG-4 specifically with 17 some nodalization changes for the BWRX-300 versus the 18 ESBWR, but it's a lead-in to that, so they're not out 19 of sync.

20 DR. CORRADINI: Okay, it's just that the 21 way I read the limitations and conditions led me to 22 believe that I would have expected to see the 23 methodology discussed and reviewed before I would put 24 it amongst all of the other design requirements, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

21 methods, and acceptance criteria. It just seemed out 1

of phase to me, but I see what you're saying and I was 2

in a similar fashion to Dr. March-Leuba, a bit 3

confused. Go ahead. I'm sorry.

4 MEMBER MARCH-LEUBA: Yeah, since you used 5

my name, let me state for the record in the opposition 6

that I have no problem whatsoever with the use of 7

TRACG and GOTHIC. I think they're both excellent 8

codes and they both will -- are going to be proven to 9

benchmark all the available experiments and data.

10 My concern is related to my issue number 11 one, that it feels when you're reading the topic 12 report and the SER that we are approving the 13 containment for X-300 and such thing doesn't exist 14 yet.

15 Whenever the BWRX-300 submits an FSAR and 16 a certification design application, they will have 17 some calculations using TRACG and GOTHIC to show that 18 the containment satisfies the criteria and 19 requirements specified in this report, which is 11P, 20 and they will use the methodology defined in 22P, 21 which is still not approved, but I have no problems 22 with it, I'm sure. We just need to cross the Ts and 23 dot the Is. So, I don't have any technical concern 24 with these two codes. Please, Frostie, continue.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

22 MS. WHITE: Okay, thank you. So, let me 1

go on now to the purpose and our scope here. For the 2

scope, we're providing a technical description of our 3

containment, our PCCS and our CIV design features, and 4

these are all based on our proven design concepts from 5

our PWRs with emphasis on an ESBWR and some of our 6

later BWR models, and you can find this information in 7

our topical Section 2.2.

8 Secondly, we have a technical description 9

of the analytical methods utilizing the applicable 10 parts of the ESBWR TRACG model to calculate the mass 11 and energy release, and we use that input to GOTHIC 12 for evaluating the containment response from that mass 13 and energy release.

14 These models are then used to demonstrate 15 compliance for the containment PCCS and CIV acceptance 16 criteria, and that's where we basically lead into the 17 actual methods evaluation is we're specifying these 18 are our acceptance criteria in this topical report, 19 and we're using the methods LTR to prove that we have 20 met these particular acceptance criteria, and you can 21 find this information in our LTR Sections 3.2 to 3.4.

22 And finally, due to the changes in the 23 BWRX-300 versus the ESBWR and some of the other BWRs 24 that are in the fleet, we're doing a regulatory 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

23 evaluation of applicable regulations and some 1

different guidance that will be applied to the BWRX-2 300 containment.

3 For example, we're using SRP 62111A 4

instead of the typical SRP that we've used for ESBWR 5

because we have a dry inert containment, so that's one 6

of the features that we're bringing out for evaluation 7

that we're seeking approval for and agreement from the 8

staff and the NRC. This information is located in our 9

LTR Section 5.0. Any questions on this?

10 All right, we're getting ready now to get 11 into our design requirements for containment in PCCS 12 to meet these regulatory requirements we're going to 13 be discussing later, and I'll be turning the 14 microphone over to our project principal engineer, 15 David Hinds. David, are you available?

16 MR. HINDS: Yes, this is David. I'm here, 17 David Hines. Can you hear me okay?

18 MEMBER MARCH-LEUBA: Yes, we can hear you.

19 MR. HINDS: Okay, thank you. So, in this 20 section, we have summarized the content related to 21 design requirements. Of course, it's not the entire 22 content.

23 And I will note, as George mentioned in 24 the beginning, that questions very likely could get 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

24 into proprietary information, so we've got some 1

additional content for the closed session, and if some 2

of your questions get into that, I'd kindly ask that 3

we defer the answer to that time, but I'll give you 4

the brief summary here and please feel free to ask 5

questions.

6 So, the primary containment or the 7

containment for the BWRX-300 is a safety-related 8

structure similar to and drawing upon the lessons from 9

our prior BWRs, but as was already mentioned, it is 10 not a pressure suppression containment, meaning wet 11 containment. It's a dry containment.

12 So, we felt it was important to clearly 13 specify the design requirements even though many of 14 them are consistent with and the same as the design 15 requirements we have used on past plants, but we 16 wanted to be very clear on the design requirements 17 moving forward for future licensing applications.

18 So, here are some summary in the next few 19 slides, and the first sub-bullet there mentions it's 20 either the LTR specifies options of either steel 21 containment vessel or a

steel-lined concrete 22 containment, recognizing that future licensing 23 activities would specify in more detail the structural 24 aspects of the containment.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

25 However, we do credit certain features in 1

the performance, containment performance, which is the 2

subject of this LTR, such as the steel surface as a 3

condensing surface, so that is in this LTR, and we 4

also refer to ASME codes that will be credited for the 5

structural design and other design requirements of the 6

permanent containment.

7 We cover piping systems passing through 8

the containment and the design requirements associated 9

with them, and then as Frostie mentioned, we do go 10 into some concept descriptions and the associated 11 commitments and design requirements associated with 12 those penetrations and the isolation thereof.

13 We incorporate this one. We've already 14 gone through the prior LTR on our RPV isolation and 15 overpressure protection, and so we make the connection 16 of this LTR with that one related to the features of 17 RPV isolation and their function related to 18 containment isolation, and so we'll discuss that in 19 more detail primarily in the closed session. We 20 commit to the requirements associated with structural 21 supports within the containment.

22 The next sub-bullets we covered in the RPV 23 isolation LTR associated with the postulated pipe 24 breaks, but we cover it further and have consistent 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

26 requirements in this LTR related to piping within the 1

containment and our postulated pipe breaks, and you'll 2

see here that we refer to BTP 3-4, which is pointed to 3

by the regulatory standard review plans, and so our 4

requirements that we have specified are consistent 5

with the standard review plans related to postulated 6

pipe breaks as listed in BTP 3-4.

7 We refer to, as I mentioned, ASME design 8

requirements as listed in the last bullet on this 9

slide. Frostie, if you could go to the next slide, 10 please?

11 DR. CORRADINI: So, can I -- this is 12 Corradini again. Can I ask a question? So, I'm still 13 struggling to understand what is being specified here 14 that is going to be, I'll call unchanged before we get 15 more detail about the design that we can analyze or at 16 least consider.

17 So, the one thing you've said was this is 18 not a pressure suppression containment, and that's 19 going to remain. The other thing you've said, you're 20 going to follow the specified BTP 3-4 requirements.

21 So, is there a listing of what I'll call 22 the key items that are going to be held constant as 23 the design evolves? Because my sense of it is the 24 design is still evolving, so things may change.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

27 MR. HINDS: So, yes, thanks for your 1

question. I guess the best way to answer that is that 2

if you'll notice the title of this slide and much of 3

my language have been using the terms design 4

requirements.

5 And so what we're primarily doing in this 6

section of the LTR is we're being very explicit about 7

what design requirements that we are applying and 8

their relationship to the regulations and the 9

associated regulatory evaluation, and then also a 10 linkage into the section that Necdet Kurul will cover 11 in a few minutes related to how that links in with the 12 methods.

13 So, this LTR is pulling everything 14 together such that the requirements, when met, have 15 already been evaluated to the regulatory requirements 16 such that as we further detail out the design, we do 17 not remain in question the requirements that the 18 design meets. We are only detailing out the design 19 features to meet those requirements. I hope that 20 helps some with your question?

21 DR. CORRADINI: That helps a bit, but what 22 if, as the design evolves, you have to change the 23 requirements? So, I'm still not sure what's being 24 fixed here.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

28 What you said to me was that there are a 1

set of regulatory requirements and now you have 2

identified a set of design requirements to prove that 3

they match up, which I get, but to the extent that the 4

design is evolving, those requirements may change. Is 5

that not true?

6 MR. HINDS: If they were to change in 7

future licensing applications, then we would have to 8

go back and reevaluate the regulatory criteria 9

associated with it and then further justify the 10 requirements where we're trying to remove the 11 uncertainty in the licensing and design process moving 12 forward to have confirmation that these design 13 requirements, when specified to our engineering team 14 and further detailed out, which, of course, we've done 15 engineering thus far, but we'll have further 16 engineering, that we're no longer questioning the 17 requirements. We're only working through the details 18 to meet those, so --

19 DR. CORRADINI: Okay, so --

20 MR. HINDS: Yes.

21 DR. CORRADINI: -- let me then ask my 22 question maybe historically. I don't remember this 23 approach with ESBWR, so what does this approach gain 24 for GE that I might be missing? There's something 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

29 here that I'm clearly missing. Can you help me?

1 MR. HINDS: So, I'll make a comment there 2

and then I'll invite, if George or Frostie has further 3

comments, because this is a more process-related 4

question, but I'll first comment and then George or 5

Frostie, feel free to jump in.

6 So, with ESBWR, we submitted an entire 7

design certification or design certification 8

application. Our desire here was to go with a lesser 9

approach than the design certification and work to 10 address areas where our design is different than the 11 past experience, and the purpose of the LTRs is to 12 remove some of the regulatory uncertainty associated 13 with the regulatory compliance as we detail out those 14 design features that differ from our past designs.

15 In cases where our past designs or our 16 BWRX-300 agrees very closely with our past designs, we 17 feel there's low regulatory uncertainty, and 18 therefore, we feel comfortable with submitting when 19 ready for actual plant licensing.

20 In this case, we're trying to address 21 features that are different, such as we mentioned 22 several times that this is a dry containment as 23 opposed to pressure suppression containment, and we'll 24 go into more details associated with the RPV isolation 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

30 and the associated containment isolation.

1 Those features are different than we've 2

done in the past, so we did not want to leave them for 3

our total submittal of a license application, so this 4

is a way of getting those identified and addressed up 5

front. And George or Frostie, do you have any further 6

comments?

7 DR. CORRADINI: No, I don't want to take 8

any more time for the committee, but you've helped me 9

a good bit. I think I appreciate the logic of what 10 you guys are doing in this case in difference to what 11 I remember to be the case for ESBWR.

12 MR. HINDS: Okay, well, thank you for your 13 comments. Okay, if no further on this slide, Frostie, 14 could you go to the next one, please, and the next 15 slide? I'm not sure if there's a delay on my screen, 16 but okay, I'm on slide nine.

17 Okay, so in the design requirements' 18 sections in Section 2 of the LTR, we go through a 19 number of subtopics like I had listed on the prior 20 slide.

21 On this next couple of slides, we go into 22 just a little more detail specifically on the 23 containment isolation valves since that is an area 24 that's different than our past design, and again, we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

31 do have in the closed session some figures and some 1

more descriptions which may help with elaborating on 2

these, but this is the introductory two slides here.

3 The other design requirements for other 4

features, we didn't have specific call-out slides 5

other than the one that I just went through, so if we 6

need to recycle back on any of them, that's okay.

7 For the containment isolation valves, the 8

valves, the piping, the penetrations basically meet 9

ASME requirements as listed in the bullet here.

10 Our isolation limits on the containment 11 isolation and their permissible leakage is -- the 12 actual numerical values are to be set based upon our 13 safety analysis outcomes, and so we basically make 14 that linkage.

15 We have instrumentation penetrations 16 through the containment similar to the earlier 17 question, and I'll elaborate on that more in the 18 closed session as well on instrumentation. I think I 19 captured your question earlier.

20 MEMBER REMPE: So, this is Joy, and just 21 to emphasize that point, I've looked ahead and saw 22 what the slides have, and locations of those 23 penetrations are of interest to me. So, if you could 24 provide or describe in another image that's not 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

32 currently included as part of that discussion, I sure 1

would appreciate it.

2 MR. HINDS: Okay, thanks for your 3

question. During the closed session when we get to 4

the figures, if it's okay, I'll try to elaborate 5

further on your question, including the locations as 6

they're postulated.

7 For this slide for now, the instrument 8

isolation, we're consistent with Reg Guide 1.11 for 9

instrument isolation, in other words, instruments 10 outside, instrumentation outside the containment where 11 it's piped into sensing piping inside, and again, I'll 12 show in the figure and I'll go further than my brief 13 comment at this time.

14 The isolation valves, the actuators 15 associated with containment isolation have the 16 appropriate protection against missiles and pipe 17 breaks, and as with our past designs, the resetting 18 features are consistent such that they do not cause 19 automatic reopening when resetting the containment 20 isolation valves.

21 We consider operating experience, which is 22 the result of a number of these requirements, such as 23 trapped liquid volumes between isolation valves, and 24 we evaluate that.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

33 We have the appropriate diversity of 1

control systems to ensure that common cause failures 2

in the I&C platforms would not result in the inability 3

to isolate, and then when we show the figures, we'll 4

go into more of how there's the coordination between 5

isolation of the containment and associated valves.

6 We've briefly mentioned here some of the 7

key penetrations or piping penetrations, and we're 8

very careful about specifying the fail position of 9

them as listed here, those power generation and 10 systems such as main steam fail safe, in the closed 11 position.

12 The isolation condenser system, consistent 13 with our past practice with ESBWR, have special design 14 requirements because of the high importance to safety 15 of the isolation condenser system, and again, in the 16 figures that we have in the closed session, we'll go 17 into more detail on that as well, so -- yes?

18 MEMBER MARCH-LEUBA: Help me out on this 19 one. Are these valve requirements that must be met by 20 the final certified design or are these an example of 21 how one can implement it, and do they become 22 regulatory commitments?

23 You have all of those figures, 2.7 through 24 2.10 to 12 or something like that. Are those 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

34 requirements that the valves must operate like that, 1

fail closed, fail open, normally closed, normally 2

open, or are they an example that would be acceptable?

3 MS. WHITE: No, these are actually -- hi, 4

this is Frostie White. These are actually listed as 5

our design requirements that we will specify, so when 6

you see a PSAR or a DCD, unless we have to change this 7

for any particular reason, and of course, we will 8

explain in great detail why we would have to change 9

it, but these are our actual design requirements for 10 the containment isolation valves, and these are 11 further discussed in meeting the regulatory sections 12 or how to comply with various guidance documents, so 13 these are --

14 MEMBER MARCH-LEUBA: It wasn't clear to me 15 when I was reading it whether it was an example that 16 you're currently thinking of implementing or these are 17 a design requirement that you must satisfy.

18 MS. WHITE: No, in the LTR Section 227, we 19 actually specify these as our design requirements for 20 the containment isolation valves.

21 MEMBER MARCH-LEUBA: Okay, and that's 22 good. That's good. Thank you.

23 MR. HINDS: And further to your question 24 and possibly the reason or basis for your question 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

35 possibly is that we did specify in the figures that 1

those figures are example figures of implementing the 2

requirement, but these are intended to be design 3

requirements, and then the figure illustrates such 4

that how they could be met, and the figures are meant 5

to be very representative.

6 However, it's recognized that, you know, 7

pipe routing and things -- we wanted to call the 8

figures

examples, but the requirements are 9

requirements. Hopefully that helps to further seal 10 that.

11 MS. WHITE: And it should be noted as well 12 that many of these requirements are consistent with 13 what we did on ESBWR for many of these valves, so the 14 key thing is the difference, some of the differences 15 between the BWRX-300 on containment isolation valves 16 and ESBWR, so we're trying to bring that out as well 17 in this LTR to give you an idea about how this design 18 is a little bit different than our ESBWR in that 19 regard.

20 MEMBER MARCH-LEUBA: Okay, thank you.

21 That helps. Please continue.

22 MR. HINDS: Okay, thanks. Frostie, could 23 you go to the next slide, please? Okay, further on 24 the containment isolation valves, we already mentioned 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

36 that on resetting, the containment isolation valves do 1

not reopen, so they're maintained in their required 2

post-accident condition. Valve qualification in the 3

ASME code is listed here, QME 1.

4 Further on the instrument penetration, we 5

do employ excess flow check valves which is consistent 6

with our predecessor designs and our operating 7

experience.

8 We have the piping for the isolation 9

condenser system which again, it gets special 10 treatment because of the safety-related nature and the 11 importance of the emergency core cooling system 12 functions of the isolation condenser.

13 That

piping, we list the ASME 14 classification, a very high ASME classification to 15 minimize any probability of postulated or possibility 16 of breaks or leaks.

17 The CRD hydraulics, which is also 18 consistent with the ABWR, and somewhat consistent with 19 past designs, meaning the ABWR uses fine motion 20 control rod drives as the BWRX-300 and the ESBWR also, 21 so consistent with ABWR, ESBWR, the fine motion 22 control rod drives.

23 So, we're piping for the hydraulics for 24 the insert feature is consistent with the design, and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

37 so we go into the commitments associated with ASME on 1

the penetrations, and we'll show those figures as 2

well. The pressure boundary of FMCRDs are made with 3

ASME materials and meet the ASME code.

4 The other defined basis is our regulatory 5

position associated with GDC 55 for the isolation 6

condenser system and for the HCUs, and that's what we 7

highlight more in the closed session because that's 8

where the figures come into -- can better illustrate.

9 But this is just the introductory slide to 10 indicate that we did use what's called other defined 11 basis for our regulatory position associated with that 12 configuration since those two safety systems, scram 13 and isolation condenser system cooling, are of high 14 safety significance and therefore receive special 15 treatment.

16 That's the introduction to the design 17 requirements and that's the extent of this session.

18 If there's no immediate questions, again, we'll 19 elaborate in the closed session, and move to the next 20 slide.

21 This is -- I'll turn it over to Necdet 22 Kurul at this point.

23 MR. KURUL: Hi, this is Necdet Kurul, GE 24 Hitachi. Can you hear me clearly?

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

38 MEMBER MARCH-LEUBA: Yes, yes, I can hear 1

you.

2 MR. KURUL: Okay, thanks. There were 3

several questions regarding Section 3 previously and 4

comments, but we have one slide to go over Section 3 5

in this presentation. In this section, we present the 6

evaluation method that's used to demonstrate 7

compliance with the regulatory requirements.

8 Section 3.1 lists the accidents and events 9

that form the bases of containment thermal-hydraulic 10 performance requirements. So, the design pressures 11 and design temperatures are based on the accidents 12 that are listed in the section, so that's one major 13 set of requirements listed in this section.

14 And we are meeting GDCs. By using this 15 evaluation method, we are meeting GDCs 38 and 50. GDC 16 50 is the containment performance peak accident 17 pressure and temperature, and GDC 38 is the 18 containment cooling requirement to depressurize the 19 containment after an accident.

20 And we also, in this section, we list not 21 just general large break LOCAs, but we also name what 22 those piping are that may be included in the design 23 basis accidents.

24 So, in Section 3, we also present what 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

39 computer codes we use and what the evaluation -- and 1

the method to develop the evaluation method. So, 2

initially, the title of the subsequent LTR was GOTHIC 3

method LTR, but it is now evaluation method LTR 4

because it naturally included mass and energy release 5

calculation as well.

6 And we also show that, or set the 7

requirements for the method, that we established the 8

evaluation method following Regulatory Guidance 9

1.2.03. This is the same regulatory guidance which we 10 used for TRACG mass and energy release and containment 11 evaluation method for ESBWR.

12 We are now replacing the containment 13 evaluation part of the method by GOTHIC instead of 14 doing the entire evaluation using TRACG, and that's 15 primarily because a dry containment presents a 16 different type of important phenomena than a wet 17 containment, a

pressure suppression type of 18 containment that was used in ESBWR.

19 And in fact, BWRX-300 containment is much 20 less challenging than ESBWR containment for an 21 evaluation method.

22 DR. CORRADINI: So, this is Corradini.

23 Let me make sure I understand. I understand why you 24 want to make the switch. If it's less challenging, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

40 what is it about TRACG that doesn't allow you to 1

essentially apply it?

2 MR. KURUL: It is -- using TRACG and 3

GOTHIC gives us more flexibility for nodalization of 4

containment.

5 DR. CORRADINI: Right, but then --

6 MR. KURUL: Because it --

7 DR. CORRADINI: Well, that kind of goes 8

against what you said, it was easier to analyze. At 9

least, that's what I thought I heard you say.

10 MR. KURUL: Yes, it's still easier than 11 TRACG because the challenging part of containment 12 analysis with a pressure suppression type of 13 containment is what happens in the wetwell, the loads, 14 the air exchange between drywell and wetwell.

15 Those are actually challenges to 16 developing an evaluation method, but an otherwise dry 17 containment is a different approach, but it is -- it 18 has elements that are well established. From that 19 perspective, it is easier.

20 It takes more work because now we have to 21 use two different codes, but in terms of the 22 uncertainties and the methods, it is much easier to do 23 a dry containment.

24 DR. CORRADINI: Okay, all right, I think 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

41 I understand your logic. We'll have to wait until we 1

get to that licensing topical report. Thank you.

2 MR. KURUL: Yes.

3 MEMBER KIRCHNER: This is --

4 MR. KURUL: Yes?

5 MEMBER KIRCHNER: -- Walt Kirchner. Mike, 6

what I'm thinking is I guess I have to be careful what 7

I say here, but probably when we get to the closed 8

session, the justification for the GOTHIC application 9

to their dry containment would be a topic to revisit.

10 DR. CORRADINI: I agree, Walt, but I guess 11 the reasoning given here made me want to ask the 12 question because I think I have a reasoning in my 13 mind, but I was trying to understand the reasoning 14 that was presented to us.

15 MR. KURUL: Okay, if there are any follow-16 up questions, maybe we can defer it to the closed 17 session. It is difficult for me to draw a line on the 18 fly between what is public and what's proprietary.

19 MEMBER REMPE: Could you elaborate about 20 this integral effect test? And I note that the report 21 regularly talks about conservatisms and it also talks 22 about beyond design basis events. Is the planned 23 approach going to continue to be conservative when you 24 go to beyond design basis events or are you going to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

42 go back to some sort of best estimate, or have you 1

guys thought about that yet?

2 MR. KURUL: Okay, so in this section, 3

that's what we are trying to clarify, that the 4

requirements for the evaluation method are for the 5

design of the containment, and the design of the 6

containment is just GDC 50 and 38 which requires these 7

evaluations.

8 And in that respect, the events that are 9

listed here are the events that are in the scope of 10 the containment design bases, accidents, and the 11 evaluation developed for it.

12 Beyond design basis events are in a 13 different area and the evaluation method does not 14 address those events. We will have a separate set of 15 methods to address the beyond design bases events.

16 MEMBER REMPE: What is the integral effect 17 test?

18 MR. KURUL: That is actually shown in the 19 subsequent licensing topical report for the evaluation 20 method, and we can discuss it in some length if you'd 21 like in the closed session.

22 MEMBER REMPE: Okay, thank you.

23 MR. KURUL: So, this Section 3 of NEDC-24 33911 sets the requirements for the evaluation method, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

43 which is that the list of accidents and the method 1

that's used in developing the evaluation method, which 2

is Reg Guide 1.203, so, but we are applying Reg Guide 3

1.203 for a mature code such as TRACG and GOTHIC.

4 And we identified -- these methods are 5

best estimate methods, and we established a phenomena 6

identification and ranking table, and identify 7

important phenomena, identify the uncertainties in the 8

modeling parameters and in the input parameters, and 9

then apply those conservatisms to make a conservative 10 method at the end.

11 And as I explained in Section 3, we are 12 not doing a statistical analysis to account for those 13 uncertainties in important phenomena, but rather we 14 are applying the uncertainty on each individual 15 phenomenon or modeling parameter and input, and at the 16 end, we have a conservative estimate, so that is the 17 way we apply Reg Guide 1.203, so that is --

18 MEMBER MARCH-LEUBA: So, let me summarize.

19 Instead of doing best estimate verse uncertainty, you 20 perform a single calculation with all the parameters, 21 input parameters and input data, biased to the most 22 conservative setting. Is that correct?

23 MR. KURUL: That is correct. Actually, we 24 do two calculations. One of them is best estimate and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

44 the other one is conservative, and that way we can 1

show the conservatism in the method that is in the 2

LTR, but when the method is reviewed, once we convince 3

ourselves that, yes, that is conservative, then we can 4

apply just the conservative going forward.

5 MEMBER MARCH-LEUBA: And I see that the 6

current PIRT has been moved to 22P, the topical 7

report, and that all these conservative others will be 8

discussed in the report?

9 MR. KURUL: That is correct because 10 keeping it in this report was making the presentation 11 a little confusing.

12 MEMBER MARCH-LEUBA: So, I agree, I agree, 13 and I'm not complaining. It was just an information 14 question. So, we look forward to look at it when we 15 review the Topical Report 22B. Thank you.

16 MEMBER REMPE: So, I know it's coming 17 later, but out of curiosity, sometimes what's 18 conservative for one event may not be conservative for 19 another event. It depends on what kind of requirement 20 you're trying to meet.

21 Did you look at a lot of different 22 requirements and look at a lot of different events 23 when you declare that all of your inputs are 24 conservative?

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

45 MR. KURUL: Yes, excuse me, yes, actually, 1

that's the reason that we want to use a best estimate 2

method and apply conservatisms in the important 3

phenomena to arrive at the conservative method as 4

opposed to trying to do a very, very conservative 5

method that does not represent the transient, but 6

tries to establish a conservative bound to it.

7 We get surprised when we try to do that, 8

and that's the reason that we are applying CSAU 9

methodology so that our method is best estimate, and 10 then we identify the uncertainties and make sure that 11 these uncertainties are in the conservative direction.

12 MEMBER REMPE: Okay, thank you.

13 MR. KURUL: So, in the downstream 14 licensing topical report, we then show how we meet the 15 requirements that are established in this containment 16 performance LTR.

17 We show why TRACG, that method that was 18 developed for ESBWR, is applicable for the mass and 19 energy release calculation for BWRX-300 containment.

20 As I mentioned, we did a PIRT with the 21 participation of our chief engineers and also a 22 consultant from academia, and then we have established 23 the knowledge level and the uncertainties in each of 24 the phenomena.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

46 We have applied those uncertainties to 1

make bounding correlations, to bias the correlations 2

and inputs. We performed nodalization studies and we 3

performed benchmarking to integral effect test, which 4

is representative of BWRX-300 type.

5 That is all I planned on presenting on 6

this slide unless there are questions. I know that 7

there's one question about what is the integral effect 8

test? What's the integral test?

9 CHAIRMAN BLEY: This is Dennis Bley. I 10 got a little confused in the report and in your 11 statement that you used the CSAU methodology, but it 12 seems to me you really don't. You do a best estimate 13 calc and then you do an extension of that with all of 14 the conservative values thrown in rather than the 15 uncertainty approach.

16 MR. HECK: This is Charles Heck, GNF. I'd 17 like to address this question. The CSAU methodology 18 as it was laid out does not address how the 19 uncertainties are to be combined. It doesn't specify 20 that. It specifies the process for identifying the 21 uncertainties, identifying the phenomena, but in the 22 end, it is silent on exactly how you combine those.

23 Now, in the operating fleet, we chose to 24 combine those via a statistical process, and here, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

47 we're free to choose to combine them by accounting for 1

them by biasing to address the uncertainties to make 2

the overall methodology conservative, so there is a 3

wide range of ways to apply the combination of 4

uncertainties using the CSAU process.

5 CHAIRMAN BLEY: Okay.

6 MEMBER MARCH-LEUBA: Okay, if there are no 7

more questions, GE, please proceed. I'm planning to 8

have a break around 11:00. I'm hoping we make it to 9

the end of GE's presentation, but let's go for another 10 20 minutes, please.

11 MS. WHITE: All right, now we're getting 12 ready to get into the acceptance criteria for 13 containment performance and data that's, I believe --

14 MEMBER MARCH-LEUBA: Okay.

15 MR. HINDS: Yes, hopefully this is an easy 16 section here. This is just a listing of what's in 17 Section 4 of the LTR.

18 In Section 4 of the LTR, we explicitly 19 commit to GDCs for, the top bullet is for containment 20 pressure, pressure boundary and penetrations, meeting 21 the pressure and temperature requirements during 22 design basis accidents for the, we list the GDCs that 23 we meet or comply with.

24 And then the next is on design pressure, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

48 bounding peak accident pressure, and we indicate that 1

we're now less than 10 percent margin for the initial 2

licensing stage that would be consistent with PSAR, 3

and we list the GDCs and the standard review plan 4

guidance like Frostie mentioned there for dry 5

containment that we used for both guidance and 6

compliance.

7 Then we have the containment design 8

features or leak-tight barrier at the design for the 9

design basis accident pressure and temperatures, which 10 the methods that Necdet was covering would evaluate, 11 and we meet the GDCs listed here.

12 And then the containment structure and 13 internal components can accommodate the design basis 14 accident, and with the appropriate leak tightness 15 required by our safety analysis and listing GDCs here 16 as well.

17 So, again, this is just a firm commitment 18 to these regulatory requirements and the guidance in 19 the SRP. All right, any questions on this one? Okay, 20 Frostie, back to you.

21 MS. WHITE: Okay, so now we're going to 22 get a little bit into our regulatory compliance and 23 I'm going to start first with the requirements.

24 We evaluated our BWRX-300 containment, our 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

49 primary, our passive containment cooling system, and 1

our containment isolation valves to the various 2

regulatory requirements. We looked at 50.34 and those 3

aspects. We looked at 50.44.

4 Please note that the 50.44 evaluation will 5

be coming in later in other licensing activities.

6 It's not evaluated here, but we will comply with those 7

sections and demonstrate that compliance in a later 8

licensing activity.

9 50.55a, these standards that we're going 10 to use will be in effect six months after license 11 application. We will comply for station blackout 12 under 50.63. We have class 1e battery backed DC power 13 for safety-related components, and then we list the 14 various GDCs we comply with for our containment PCCS 15 and our CIVs.

16 There are some CIVs that we have discussed 17 previously, and we mentioned for GDC 55 for CIVs that 18 are connected to RPV boundary that do meet the other 19 defined basis. It's not all of them, but there are 20 some of them, and we will discuss that in a closed 21 session.

22 And finally, under Appendix J, we will 23 perform our periodic integrated leak rate testing 24 consistent with the reg guide, and that's also 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

50 consistent with what we did on ESBWR. Any questions 1

at this stage?

2 MEMBER MARCH-LEUBA: Yeah, it may be too 3

detailed, but we are relying on the nitrogen inert 4

containment to prevent ignitions of the hydrogen. If 5

there is a leak because of a break of a pipe that is 6

not isolated, do we have sufficient nitrogen 7

requirements in the plan to make up the leak?

8 MS. WHITE: Yes.

9 MEMBER MARCH-LEUBA: So, your containment 10 becomes non-inerted.

11 MS. WHITE: Right, yes, we do, and we have 12 both oxygen and hydrogen monitors and analyzers on 13 there in that system as well to identify that.

14 MEMBER MARCH-LEUBA: Okay, so you'll talk 15 about that in the closed session, how it is then, and 16 if we have recombiners, the stacks?

17 MS. WHITE: Currently, we do not have 18 recombiners, but again, we have not evaluated this for 19 beyond design basis accident events.

20 MEMBER MARCH-LEUBA: So, that would be 21 more for the Topical Report 21P?

22 MS. WHITE: Yes, the later severe 23 accident, we will evaluate that, yes. We do discuss 24 that in this topical report that that will be provided 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

51 in another licensing activity such as that topical 1

report.

2 MEMBER MARCH-LEUBA: Thank you.

3 MS. WHITE: Any more questions for this 4

slide? Here is the various regulatory guides that we 5

have evaluated. We will comply with these. You know, 6

that's listed in this portion in Section 5 of the LTR.

7 Do we have questions for this?

8 Okay, further on guidance, we evaluated 9

this particular design with the differences to the 10 ESBWR, and these are the SRPs, some of the SRPs, I 11 have another page coming up in another slide coming up 12 that evaluates these, but specifically I wanted to get 13 down to SRP 6.2.1.

14 Again, because of this being a dry inerted 15 containment, some of the SRPs don't really apply to us 16 any longer, so we thought it was prudent to bring this 17 up to the NRC so that they understood the approach 18 we're taking and which guidance documents were 19 applicable.

20 So, 6.2.11A, which is typically a PWR SRP 21 guidance document, is actually applicable to this 22 design, although there are sections, and I'm going to 23 go over that in the next bullet, that are not 24 applicable in that particular section.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

52 But because we don't have a suppression 1

pool, we don't have subcompartments with large bore 2

high energy lines, we don't have secondary system 3

piping, we don't have an official emergency core 4

cooling system to maintain pressure, those particular 5

SRPs are no longer applicable to us. The staff did 6

review that and found that to be the case and agreed 7

with us.

8 Then, as I mentioned, on 6.2.11A, which is 9

a PWR dry containment, we excluded Sections 1, 2, and 10 3 because we don't have an ECCS system. We don't have 11 subcompartments and there's no secondary system, so 12 those particular sections weren't applicable, but 13 overall, that particular guidance is applicable.

14 MEMBER MARCH-LEUBA: And this is an 15 administrative question and probably more for the 16 staff than for you, but I applaud the approach you 17 have taken of bringing these things up, up front and 18 communicating with the staff and reaching an 19 agreement.

20 The first SRP is just guidance. You don't 21 have to satisfy it. You don't have to follow it, but 22 it would be a waste of time to elevate this to the 23 Commission as to an exemption. Simply the reason, a 24 technical discussion between the applicant and the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

53 staff that you agree that we don't have a suppression 1

pool, so this doesn't apply to us, and they say yes, 2

and we're done. So, I applaud this approach and I 3

hope we continue to use it.

4 MS. WHITE: Thank you. All right, I'm 5

going on to the next one. Again, these are the SRPs 6

that we evaluated. 6.2.1.3 is mass and energy 7

release. As mentioned previously under the evaluation 8

method discussion, we are using TRACG and GOTHIC to do 9

those evaluations.

10 I was going to move down to 6.2.4, 11 containment isolation valves. Again, we're going to 12 have that discussion for GDC 55 compliance for some of 13 those valves in closed session. This is just a 14 further identification of the SRPs that we have 15 evaluated against this particular design.

16 Any questions on this? Okay, all right, 17 now we'd like to move into the closed session unless 18 there is any further questions.

19 MEMBER MARCH-LEUBA: So, we are going to 20 stop right here. We are not going to move to the 21 closed session. We're going to have the open session 22 from the staff first, but it's time to have a break.

23 If everybody agrees, let's have a 15-minute break and 24 come back at 11:05, and we will have the staff open 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

54 session.

1 MS. WHITE: Thank you.

2 MEMBER MARCH-LEUBA: So, we are on recess 3

until 11:05.

4 (Whereupon, the above-entitled matter went 5

off the record at 10:49 a.m. and resumed at 11:05 6

a.m.)

7 MEMBER MARCH-LEUBA: Let's just start the 8

meeting because we are five minutes late, which is not 9

bad. So, Court Reporter, we are back in session, and 10 we are still in open session, and the staff is going 11 to start their presentation any time they are ready.

12 MR. WUNDER: Okay, do I have Chang Li and 13 Renee Li, and -- right, all I need for the open 14 session is Chang Li.

15 MR. LI: Yes, Chang Li is here now.

16 MR. WUNDER: Okay, great. In that case, 17 let's go ahead and get started. Good morning, Mr.

18 Chairman, ladies and gentlemen of the committee.

19 We're here to present the results of the staff's 20 review of Topical Report NEDC-33911 on BWRX-300 21 containment performance.

22 I'm George Wunder and I've been assigned 23 as the project manager for this topical report, and 24 being so assigned, I have the pleasure one last time 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

55 of talking to you fine ladies and gentlemen before I 1

shuffle off into retirement at the end of the month.

2 We have a very brief presentation for the 3

open session before we move onto our more detailed 4

presentation in the closed session. We're going to 5

introduce the team and then present a high-level 6

overview.

7 Okay, I have the pleasure of introducing 8

our team. From Plant Systems, we have Chang Li and 9

Angelo Stubbs. Dr. Syed Haider is here representing 10 the Nuclear Systems Performance Branch. From 11 Mechanical Engineering, we have Renee Li and Tom 12 Scarbrough.

13 And not joining us today, not joining us 14 to present today, but nevertheless an important 15 contributor from Vessels and Internals, we have Dan 16 Widrevitz. Rani Franovich is the lead PM for this 17 project, and I have already introduced myself. With 18 that, I would like to turn the presentation over to 19 Chang Li. Chang Li, please take it from here, sir.

20 MR. LI: Can you hear me now?

21 MEMBER MARCH-LEUBA: Yes, yes, we can hear 22 you.

23 MR. LI: Okay, thank you, George. I am 24 Chang Li from the NRR Containment and Plant Systems 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

56 Branch. I will be presenting a brief overview of our 1

safety evaluation in the open session.

2 This slide discusses several design 3

features related to the BWRX-300 containment design.

4 Actually, there's the system design that were 5

described in the previous session by GEH. Next slide, 6

please?

7 The containment design that's in this 8

topical report, they have focused the review, focused 9

the presentation in the topical report in PCCS, 10 passive containment cooling systems, containment 11 isolation

valves, analytic methods evaluating 12 containment performance, and acceptance criteria in 13 design of those systems. Next slide, please?

14 This topical report provides the design 15 requirements and our review is in accordance with 16 Standard Review Plan 6.2 even though, as mentioned, 17 the standard review plan is not a requirement, but it 18 provides us guidance as to the scope of our review.

19 That includes the topics listed here, 20 piping and valves, design, containment functional 21 design, containment heat removal systems, secondary 22 containment function and design. By the way, this 23 subject will not go into detail because the BWRX-300 24 design doesn't have secondary containment function 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

57 design.

1 We have brought extensive discussing in 2

containment isolation systems that we have discussed, 3

and combustible gas control, containment leakage 4

testing, and pressure prevention for containment 5

pressure boundary. Next slide, please?

6 When we do the review of the list of 7

regulations that's being discussed in the topical 8

report, we realized that in our review, we compile all 9

of the applicable SRP guidance and relevant 10 regulations with the regulations listed in the topical 11 report.

12 We noticed that when we're talking about 13 the topical report we used for both Part 50 process 14 and our Part 52 process. So, when it used Part 52, 15 they need to address the regulations to here, 52.47b1 16 and 52.80a. That's relating to ITAAC and COL 17 information.

18 A lot of end of line materials in which we 19 made our findings is based on proprietary information, 20 so a good portion of our discussion will have to be in 21 the closed session. We will go into much more detail 22 on those systems in the closed session, and at the 23 end, summarize our review. This concludes our 24 presentation for the open session.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

58 MEMBER MARCH-LEUBA: Well, that was fast.

1 Anybody who wants to make a comment? Am I hearing an 2

echo? Can somebody acknowledge that we are here?

3 MEMBER KIRCHNER: Yes, we hear you.

4 MEMBER MARCH-LEUBA: Yeah, thank you. So, 5

any members, any more questions for the staff? We are 6

going to have a very detailed presentation in the 7

afternoon, so I'd rather we stop early and have lunch 8

early, and then maybe start a little early in the 9

afternoon. Since this is a subcommittee meeting, I 10 believe we can start a little early.

11 But at this point, I would like to have 12 the opportunity to open the public line and see if any 13 members of the public have any comments. If so, 14 please state your name and present the comment. Do we 15 have the public line open, Thomas?

16 MR. DASHIELL: The public line is open for 17 comments.

18 MEMBER MARCH-LEUBA: Thank you. Any 19 member of the public? Hearing none, we will cancel --

20 I mean, we will go into recess soon. We are scheduled 21 to come back into session at 1:00 p.m., but instead of 22 starting the closed session now, I'd like to poll the 23 members.

24 Do you prefer to have an early lunch and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

59 come back say at 12:30 and maybe finish early or do 1

you prefer to start the closed session now, go on for 2

45 minutes, and continue at 1:00?

3 My preference, being in the eastern side 4

of the country, I would prefer to have an early lunch 5

and start at 12:30. Anybody opposed to that? Okay, 6

the meeting is in recess. We will restart on the 7

closed session at 12:30, and there will be some 8

process to allow people to get in that are allowed to 9

be in. So, the meeting is in recess.

10 MEMBER KIRCHNER: Jose, this is Walt --

11 MEMBER MARCH-LEUBA: Yes, sir?

12 MEMBER KIRCHNER: -- Kirchner again. So, 13 I gather we will not come back to an open session 14 after the closed session. Should we tell the public 15 that?

16 MEMBER MARCH-LEUBA: Yeah, I was thinking 17 to ask Larry or Scott to have somebody of the staff 18 come at 5:00 and tell the public that we are not going 19 to be there, that if they want to make a comment, they 20 can do it by email to them, and maybe we can attach it 21 to the meeting minutes. Would that be acceptable?

22 Scott, are you there?

23 MR. MOORE: Yeah, I'm on. I can certainly 24 go on the public line and go back at any time 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

60 throughout. So, as I understand it, the subcommittee 1

does not intend to go on the public line anymore for 2

the rest of the day, is that correct?

3 MEMBER MARCH-LEUBA: That is correct.

4 MR. MOORE: Okay, so I will go on the 5

public line at various times and make that 6

announcement.

7 MEMBER MARCH-LEUBA: Yeah, well, you can 8

make that announcement, but especially at 5:00, if 9

somebody shows up that wants to make a comment, they 10 should be allowed to make the comment by email and be 11 part of the record? I don't know. You decide.

12 MR. MOORE: Okay, I will do that, Mr.

13 Chairman.

14 MEMBER MARCH-LEUBA: Okay, so we are again 15 on recess. We will be back at 12:30 Eastern Time when 16 we will be in the closed session.

17 (Whereupon, the above-entitled matter went 18 off the record at 11:16 a.m.)

19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

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

(( )).

ACRSSubcommitteePresentation GEHitachi(GEH)

LicensingTopicalReport(LTR)NEDC33911P BWRX300ContainmentPerformance (OpenandClosedSessions)

January13,2021

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 2

Agenda OpenSession A. LicensingTopicalReportPurposeandScope B. DesignRequirementsforContainmentandPassiveContainmentCoolingSystem toMeetRegulatoryRequirements C. DesignRequirementsforContainmentIsolationValvestoMeetRegulatory Requirements D. AnalyticalMethodsUsedforEvaluatingContainmentPerformance E. AcceptanceCriteriaforContainmentPerformance F. RegulatoryComplianceforContainmentPerformance ClosedSession Compliancewith10CFR50,AppendixA,GDC55ForOtherDefinedBasis

LicensingTopicalReportPurposeandScope

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 4

LicensingTopicalReportPurposeandScope Providesthedesignrequirements,analyticalmethods,acceptancecriteria,and regulatorybasisfortheBWRX300containmentdesignfunctions:

• SpecifiesdesignrequirementsforcontainmentandthePassiveContainmentCoolingSystem (PCCS)thatmeettheregulatoryrequirementsof10CFR50,AppendixA,GeneralDesignCriteria (GDC)1,2,4,16,38,41,42,50,51,52,53and54(LTRSections2.2.2,2.2.8,andSection5.1)

• Specifiesdesignrequirementsforthecontainmentisolationvalves(CIVs)thatmeetthe regulatoryrequirementsofGDCs1,2,4,54,55,56,and57(LTRSections2.2.7,5.1.55.1.7, 5.1.215.1.24)

• SpecifiesanalyticalmethodsTRACGandGOTHICwithaccompanyingacceptancecriteriathatwill beusedforevaluatingcontainmentperformancetodemonstratecompliancewithGDCs38and 50(LTRSection3).Evaluationmethodologythatwillbeusedtodemonstratecomplianceisin NEDC33922P

• SpecifiesBWRX300acceptancecriteriaforcontainmentperformanceinaccordancewiththe designrequirementsforcontainment,PCCSandCIVs(LTRSection4.0)

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 5

LicensingTopicalReportPurposeandScope LTRNEDC33911PContainmentEvaluationscopeissupportedby:

• TechnicaldescriptionofBWRX300containment,PCCS,andCIVdesignfeaturesand functionsbaseduponprovendesignconceptsfrompreviousBWRs(LTRSection2.2)

• TechnicaldescriptionoftheBWRX300analyticalmethodsutilizingtheapplicableparts oftheESBWRTRACGmodeltocalculatethemassandenergyreleasefromthereactor pressurevessel,withinputtoGOTHICforevaluatingcontainmentresponsefromthe massandenergyrelease.Thesemodelsareusedtodemonstratecomplianceforthe containment,PCCS,andCIVacceptancecriteria(LTRSections3.23.4)

• RegulatoryevaluationofapplicableregulationsandguidancefortheBWRX300 containment,PCCSandCIVdesignfeaturesandfunctionstobeusedtodemonstrate compliancewiththeacceptancecriteria(LTRSection5.0)

DesignRequirementsforContainmentandPCCS toMeetRegulatoryRequirements

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 7

ContainmentandPCCSDesignRequirements BWRX300primarycontainmentvessel(PCV)isSafetyClass1,safetyrelatedandseismicCategoryI withASMECoderequirementsspecifiedfor:

• eithermetalorconcretecontainmentstructure

• pipingsystemspassingthroughPCVmechanicalpenetrationsandCIVs

• reactorpressurevessel(RPV)isolationvalves

• structuralsupportsforpipingsystemsandcomponentsinsidethePCV

• additionalstructuresofthePCVinternals PostulatedpiperupturelocationsandconfigurationsinsidecontainmentarespecifiedperBTP34, PartB,Item1(iii)(2)andidentificationofleakagecracksperBTP34,PartB,Item1(v)(2)forpiping connectedtotheRPVisolationvalveassembliesextendingtothecontainmentwall ASMECodeSectionIII,Division1,SubarticleNE1120andBTP34,PartB,Items1(ii)(1)(d)and(e),

andItems1(ii)(2)through(7)areappliedtoeliminatepostulatedbreaks/cracksinthoseportionsof pipingfromthecontainmentwalltotheoutboardCIV PCV,penetrationpipingsystemsandassociatedsupportmaterialsaredesignedinaccordancewith ASMESectionII,MaterialSpecificationswithexceptiontononconductiveportionsofelectrical penetrations

DesignRequirementsForCIVstoMeet RegulatoryRequirements

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 9

CIVDesignRequirements-LTRSection2.2.7

• CIVs,associatedpipingandpenetrationsmeetseismicCat.IandASMESectionIII,Division1, SubsectionNE,ClassMCComponentsandSubsectionNC,Class2Components

• Isolationlimitsleakagewithinpermissiblelimits

• CIVclosuretimingiscommensuratewithtimingoffissionproductreleases

• InstrumentisolationvalvesthatpenetratecontainmentconformtoRG1.11

• Isolationvalves,actuatorsandcontrolsareprotectedagainstmissilesandpostulatedhighand moderateenergylineruptures

• ResettingautomaticCIVsdoesnotresultinautomaticreopening

• Penetrationswithtrappedliquidvolumebetweentheisolationvalveshaveadequaterelieffor thermallyinducedpressurization

• ControldiversityforpenetrationswithRPVisolationvalves

• CIVsformainsteam,feedwater,shutdowncoolingandreactorwatercleanupfailclosed

• RPVisolationvalvesforICsteamsupplyandcondensatereturnfailasiswithvalveactuators maintainingthevalveasisbypositivemechanicalmeans

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 10 CIVDesignRequirements-LTRSection2.2.7

• AllotherCIVpenetrationconfigurationsaremaintainedintherequiredpostaccidentposition

• ValvequalificationwithASMEStandardQME12007(orlateredition)

• OutsidecontainmentautomaticCIVclosuretimeestablishedtoassureisolationpriortofirst fissionproductrelease

• Excessflowcheckvalves(EFCVs)areusedinsmallpipingwithlevelinstruments

• PipingintheareabetweentheoutermostRPVisolationvalveandthecontainmentboundaries, aswellasthepipingthroughtheseismicCategoryIreactorbuildingwheretheisolation condensersystem(ICS)steamsupplyandcondensatereturnpipingconnectstotheICSheat exchangerareASMESectionIII,Class1,NBpiping,limitingthepossibilityofbreaks

• Scraminsertpipingfromthehydrauliccontrolunit(HCU)roomtothefinemotioncontrolrod drives(FMCRDs)areASMEArticlesNB2150andNB3120

• PrimarypressureboundarycomponentsoftheFMCRDlowerhousingofthespoolpieceandthe flangeoftheoutertubeassemblyaremadewithASMECodeSectionIII300seriesstainlesssteel materials

• CIVsconnectedtotheRPVboundarycomplywiththeotherdefinedbasisdefinitionofGDC55 (discussedintheCompliancewith10CFR50,AppendixA,GDC55closedsession)

AnalyticalMethodsUsedforEvaluating ContainmentPerformance

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 12 AnalyticalMethodsUsedforEvaluatingContainmentPerformance NEDC33911Psetstherequirementsfortheevaluationmethodwhereapprovalofthese requirementsis requested

• LTRSection3.0outlinestheevaluationmethodrequirementsusedindemonstrating containmentperformance

• LTRSection3.1listsaccidentsandeventsthatformthebasisofthecontainmentthermal hydraulicperformancerequirementsthatdemonstratecompliancewithGDCs38and50

• TheremainingsubsectionsofSection3introducecomputercodesusedintheevaluation methodandsetstherequirementsfollowingtheguidanceinRG1.203 NEDC33922PBWRX300ContainmentEvaluationMethod(submittedseparately):

• UseofTRACGformassandenergyreleasecalculationsdevelopedandapprovedforESBWRwith justificationofsamemethoduseforBWRX300,andanyapplicationdifferences

• Identificationofphenomenaimportanttocontainmentanalysisandevaluationofuncertainties

• Correlationsandinputsusedtoboundtheuncertainties

• Nodalizationstudies

• Benchmarkingtoanintegraleffecttesttodemonstrateconservatisms

AcceptanceCriteriaforContainment Performance

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 14 ContainmentPerformanceAcceptanceCriteria

• Containmentpressureboundaryandpenetrationsaredesignedforpressureand temperaturefordesignbaseaccidents(DBAs)inaccordancewithGDCs2,4,16,38,41, 50and51

• Containmentdesignpressurewillboundthepeakaccidentpressureresultingfromthe mostlimitinglargebreakLOCAwithmargin(nolessthan10%margininPSAR)inorder toconformwiththerequirementsofGDCs4,16,38,41,50and51,andtheguidance ofSRP6.2.1.1.A

• Containmentdesignfeaturesprovideanessentiallyleaktightbarrierwhere containmentpressureandtemperaturecanbereducedrapidlyandmaintainedat acceptablylowlevelsfollowingaLOCAtomeettherequirementsofGDCs16,38,50

• Containmentstructureandinternalcompartmentscanaccommodatewithout exceedingthedesignleakageratewithsufficientmargin,thecalculatedpressureand temperatureconditionsresultingfromaLOCAtomeettherequirementsofGDCs16, 38,50

RegulatoryComplianceforContainment Performance

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 16 RegulatoryCompliance TheBWRX300containment,PCCS,andCIVdesigncomplieswiththefollowingregulations:

• 10CFR50.34(f)(2)(xiv),(f)(2)xv),(f)(2(xvii)- allnonessentialsystemsisolatewithtwoisolationbarriersin seriesexceptfornonessentialinstrumentlines

• 10CFR50.34(f)(3)(A)(1)- containmentstructureintegrityismaintainedforanaccidentthatreleases hydrogengeneratedfroma100%fuelcladmetalwaterreaction

• 10CFR50.44(c)(1),(c)(2),(c)(3),(c)(4),(c)(5)- theBWRX300containmentisdryandnitrogeninerted wherenosubcompartmentsmayaccumulatecombustiblegasmixtures

• 10CFR50.55a-containment,PCCS,andCIVdesignfeaturesusestandardsapprovedin10CFR50.55a(a)in effectwithin6monthsoflicenseapplication

• 10CFR50.63-designincludesClass1EbatterybackedDCpowerforsafetyrelatedcomponentsforcoping withstationblackout

• GDCs1,2,4,5,13,16,38,39,40,41,42,43,50,51,52,53,54,55(separateslideprovidedinclosed sessionforCIVscomplyingwithotherdefinedbasis),56,57,64aremetfortheBWRX300containment, PCCSandCIVs

• 10CFR50,AppendixJ-periodicintegratedleakageratetestingconductedwithguidancefromRG1.163

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 17 RegulatoryGuidance TheguidancefromthefollowingregulatoryguidesismetfortheBWRX300containment, PCCSandCIVs:

• RG1.11InstrumentLinesPenetratingthePrimaryReactorContainment

• RG1.84Design,FabricationandMaterialsCodeCaseAcceptability

• RG1.141ContainmentIsolationProvisionsforFluidSystems

• RG1.147InserviceInspectionCodeCaseAcceptability

• RG1.155StationBlackout

• RG1.163PerformanceBasedContainmentLeakRateTest

• RG1.192OperationandMaintenanceCodeCaseAcceptability

• RG1.203TransientandAccidentAnalysisMethods

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 18 RegulatoryGuidanceContd.

Theguidancefromthefollowingstandardreviewplans(SRP)aremetfortheBWRX300 containment,PCCSandCIVs:

• SRP3.6.2DeterminationofRuptureLocationsandDynamicEffects-completedescriptionandassociated branchtechnicalpositionscomplianceutilizingmanyoftheassumptionsfromESBWRDesignControl Document(DCD)Section3.6.1.1willbeprovidedinfuturelicensingactivities

• SRP3.9.6FunctionalDesign,QualificationandInserviceTestingProgramsforPumps,Valves,andDynamic Restraints-CIVdesignwillusestandardsapprovedin10CFR50.55a(a)effectivewithinsixmonthsofany licenseapplication

• SRP6.2.1ContainmentFunctionalDesign-BWRX300containmentdesignisaffectedbytheguidancein SRPs6.2.1.1.A,6.2.1.3;SRPsthatarenotapplicablefortheBWRX300designinclude:6.2.1.1.Cno pressuresuppressionpool;6.2.1.2nosubcompartmentswithlargeborehighenergylines;6.2.1.4no secondarysystempiping;6.2.1.5noemergencycorecoolingsystem(ECCS)tomaintainpressurefollowing designbaseevents

• SRP6.2.1.1.APWRDryContainments,IncludingSubatmosphericContainments-excludingSections:(1)no ECCS,(2)nosubcompartmentswithlargeborehighenergylinesand(3)nosecondarysystems

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 19 RegulatoryGuidanceContd.

TheguidancefromthefollowingSRPsismetfortheBWRX300containment,PCCSandCIVs:

• SRP6.2.1.3MassandEnergyReleaseforPostulatedLossofCoolantAccidents-calculatedneutronicsand thermalhydraulicsusingpreviousTRACGContainment/LOCAsubmittalsthatareapplicabletoBWRX300 design(seeLTRSection3.1)

• SRP6.2.2ContainmentHeatRemovalSystems-BWRX300doesnotemployuseofspraywater,ECCSor sumpsinthedesigntoactivelyremoveheatorpressurewithincontainmentandlongtermcorecoolingis addressedinLTRNEDC33910PBWRX300ReactorPressureVesselIsolationandOverpressureProtection

• SRP6.2.3SecondaryContainmentFunctionalDesign-NotapplicabletoBWRX300containmentdesign

• SRP6.2.4ContainmentIsolationSystem-designoftheCIVsandassociatedpipingandpenetrationswill meettherequirementsofseismicCategoryIcomponentsandASMESectionIII,Class1or2accordingto theirqualitygroupclassification

• SRP6.2.5CombustibleGasControlinContainment BWRX300containmentisdry,nitrogeninertedthat doesnotrelyupongascontroltomaintainhydrogenandoxygenconcentrationsbelowcombustiblelevels andmaintainstructuralintegrityfollowingaDBA;forbeyonddesignbasiseventsandsevereaccidents,a separateevaluationandanalysiswillbeprovidedinfuturelicensingactivities

• SRP6.2.6ContainmentLeakageTesting-conformssimilarlytoESBWR

• SRP6.2.7FracturePreventionofContainmentPressureBoundary-conformssimilarlytoESBWR

ClosedSession ComplianceWith10CFR50 AppendixA,GDC55ForOtherDefinedBasis

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 21 10CFR50,AppendixA,GDC55Compliance TheBWRX300CIVsconnectedtotheRPVboundarycomplywiththeotherdefinedbasis alternative.

• BWRX300incorporatesisolationvalves((

))forlargeand mediumpipebreakLOCAs((

))

• RPVisolationvalvesaresinglefailureproof,containedinseismicCategoryI containment,andmeetASMECodeSectionIII,Class1;associatedpipingisASME SectionIII,Class1NBpipingthatlimitstheprobabilityofbreaksinthesepiping segments

• BreaksbetweentheRPVisolationvalvesandcontainmentwouldbeisolatedtostopthe leakandwouldbecontainedbytheclosedsystemoutsidecontainmentthatisdesigned towithstandfullreactorpressure

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 22 10CFR50,AppendixA,GDC55Compliance TheBWRX300CIVsconnectedtotheRPVboundarycomplywiththeotherdefinedbasis alternative.

AutomaticCIVsoutsidecontainmentarealsoincludedforGDC55compliancewiththe followingexceptions:

• RPVisolationvalvesfortheICSsteamsupplyandcondensatereturnpipingwiththe closedloopIClocatedoutsidecontainmentserveasapassivesubstituteforanopen activeoutsidecontainmentautomaticCIV;((

))toallowtheICStofunctionasapartofECCS

• HCUsoftheFMCRDsalsoserveasaclosedsystemoutsidecontainmentsimilarlytowhat wasapprovedfortheESBWR;addingadditionalisolationvalvesinthispipingfor containmentisolationisnotinthedirectionofhighestsafetybecauseitcouldbecomea newpotentialfailuremodeinasafetycriticalsystemandwillnotimprovetheintegrity becausethesmalldiameterhighpressurehydrauliclinesareattachedtoaclosedsystem outsidecontainmentandthereforedonotcauseariskofcontainment leakage

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 23 23 LTRFigure25:MainSteamandFeedwaterCIVsConnected toRPV Boundary

((

))

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 24 24 LTRFigure27:IsolationCondenserCIVsConnectedtothe RPVBoundary

((

))

Copyright 2021 GE Hitachi Nuclear Energy Americas, LLC - All Rights Reserved 25 25 LTRFigure28:FMCRDCIVsConnectedtoRPV Boundary

QuestionsorComments