ML22118A371

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GEH BWRX-300 SMR - Approval Letter for GEH LTR NEDC-33922P Containment Evaluation Method Revision 2
ML22118A371
Person / Time
Site: 99900003
Issue date: 04/28/2022
From:
NRC
To:
NRC/NRR/DNRL/NRLB
References
Download: ML22118A371 (10)


Text

From:

Shea, James Sent:

Thursday, April 28, 2022 12:28 PM To:

Schichlein, Lisa (GE Power Portfolio)

Cc:

GEH-BWRX-300DocsPEm Resource; Wadkins, George (GE Power Portfolio); Diaz-Quiroz, Jesus G. (GE Power Portfolio); Dudek, Michael; Schiller, Alina

Subject:

Approval Letter for GEH LTR NEDC-33922P Containment Evaluation Method Revision 2 Attachments:

Approval and FSER submittal letter to GEH for the BWRX-300 Containment Evaluation Method LTR ML22110A008.pdf; SAFETY EVALUATION FOR TOPICAL REPORT NEDC-33922P, BWRX-300 CONTAINMENT EVALUATION METHOD, REVISION 2.pdf

Lisa, Please see attached an advance copy of the NRC approval and final safety evaluation transmittal letter for GEH LTR NEDC-33922P, Containment Evaluation Method Revision 2, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22110A008). Also attached for your reference is the Publicly Available ACRS staff SE Approval Letter.

ADAMS

References:

ML22101A298 4/25/2022 ACRS Approval Letter Publicly Available Letter 99900003 ML22110A007 4/27/2022 Approval letter and FSER submittal for GEH LTR Containment Evaluation Method Publicly Available Package 99900003 ML22110A008 4/27/2022 Approval letter and FSER submittal for GEH LTR Containment Evaluation Method Publicly Available Letter 99900003 ML22004A080 3/9/2022 AFSE BWRX-300 LTR NEDC-33922P Containment Evaluation Method Non-Public Proprietary FSER 99900003 ML22040A004 3/9/2022 AFSE BWRX-300 LTR NEDC-33922P Containment Evaluation Method Public Redacted FSER 99900003 Let me know if you have any questions Thanks!

James Shea Senior Project Manager phone: (301)415-1388 james.shea@nrc.gov U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Mail Stop O-7D21 Washington, DC, 20555-0001

Hearing Identifier:

GEH_BWRX300_Docs_Public Email Number:

14 Mail Envelope Properties (BLAPR09MB6899255840728483E27B8DB094FD9)

Subject:

Approval Letter for GEH LTR NEDC-33922P Containment Evaluation Method Revision 2 Sent Date:

4/28/2022 12:27:50 PM Received Date:

4/28/2022 12:27:54 PM From:

Shea, James Created By:

James.Shea@nrc.gov Recipients:

"GEH-BWRX-300DocsPEm Resource" <GEH-BWRX-300DocsPEm.Resource@usnrc.onmicrosoft.com>

Tracking Status: None "Wadkins, George (GE Power Portfolio)" <George.Wadkins@ge.com>

Tracking Status: None "Diaz-Quiroz, Jesus G. (GE Power Portfolio)" <Jesus.Diaz-Quiroz@ge.com>

Tracking Status: None "Dudek, Michael" <Michael.Dudek@nrc.gov>

Tracking Status: None "Schiller, Alina" <Alina.Schiller@nrc.gov>

Tracking Status: None "Schichlein, Lisa (GE Power Portfolio)" <lisa.schichlein@ge.com>

Tracking Status: None Post Office:

BLAPR09MB6899.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1399 4/28/2022 12:27:54 PM Approval and FSER submittal letter to GEH for the BWRX-300 Containment Evaluation Method LTR ML22110A008.pdf 255958 SAFETY EVALUATION FOR TOPICAL REPORT NEDC-33922P, BWRX-300 CONTAINMENT EVALUATION METHOD, REVISION 2.pdf 594435 Options Priority:

Normal Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

April 27, 2022 Ms. Michelle Catts Senior Vice President, Nuclear Programs GE-Hitachi Nuclear Energy Americas, LLC P.O. Box 780, M/C A-18 Wilmington, NC 28402

SUBJECT:

FINAL SAFETY EVALUATION FOR GE-HITACHI LICENSING TOPICAL REPORT NEDC-33922P, REVISION 2, BWRX-300 CONTAINMENT EVALUATION METHOD (DOCKET NO. 99900003)

Dear Ms. Catts:

By letter dated September 25, 2021, GE-Hitachi Nuclear Energy Americas, LLC (GEH),

submitted Licensing Topical Report (LTR) NEDO-33922, BWRX-300 Containment Evaluation Method, Revision 0 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML20269A469), to the U.S. Nuclear Regulatory Commission (NRC) staff for review and approval in support of a future licensing application for the GEH small modular reactor (SMR) under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, or Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants. Subsequently, during the staff review, GEH submitted Revision 1, By letter dated November 19, 2021 (ADAMS Accession No. ML21323A008), and then on December 17, 2021 (ADAMS Accession No. ML21351A168), GEH submitted Revision 2 of the LTR.

The NRC staff has found GEH LTR NEDC-33922, Revision 2, to be acceptable for referencing in licensing applications for the GEH SMR design to the extent specified in the enclosed final safety evaluation (SE) that defines the basis for acceptance. In addition, on April 21, 2022 (ADAMS Accession No. ML22101A298), the Advisory Committee on Reactor Safeguards concluded that the staffs SE for LTR NEDC-33922, Revision 2, with the limitations and conditions imposed, is appropriate and should be issued. Therefore the staff did not make any changes to the staff Advanced Final Safety Evaluation submitted to you on March 09, 2022 (ADAMS Accession No. ML22004A080 - Non-Public and ML22040A004 - Public).

In accordance with the guidance provided on the NRCs LTR Web site (http://www.nrc.gov/about-nrc/regulatory/licensing/topical-reports.html), the NRC requests that GEH publish an accepted version of this LTR within three months of receipt of this letter. The accepted version shall incorporate this letter and the enclosed SE after the title page. Also, it must contain in its appendices historical review information, such as requests for additional information, accepted responses, and the actual revised pages (showing revision bars) that were included as part of LTR NEDC-33922, Revision 2. The accepted version shall include an

"-A" (designated accepted) following the report identification symbol.

If the NRCs criteria or regulations change so that its conclusion in this letter (that the LTR is acceptable) is invalidated, GEH and/or an applicant referencing the LTR will be expected to revise and resubmit its respective documentation or submit justification for the continued applicability of the LTR without revision of the respective documentation.

If you have any questions or comments concerning this matter, I can be reached via e-mail at James.Shea@nrc.gov.

Sincerely,

/RA/

James J. Shea, Senior Project Manager New Reactor Licensing Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation Docket No.: 99900003

Enclosure:

Safety Evaluation cc: GEH BWRX-300 NEDO-33922P ListServ

PKG: ML22110A007 LTR: ML22110A008 SE: ML22040A004 (Public)

SE: ML22004A080(Non-Public)

  • via e-mail NRR-106 OFFICE DNRL/NRLB:PM DNRL/NRLB:LA DNRL/NRLB: BC DNRL/NRLB:PM NAME JShea SGreen MDudek JShea DATE 04/19/2022 04/20/2022 04/27/2022 04/27/2022

UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, DC 20555 - 0001 Mr. Daniel H. Dorman Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

SAFETY EVALUATION FOR TOPICAL REPORT NEDC-33922P, BWRX-300 CONTAINMENT EVALUATION METHOD, REVISION 2

Dear Mr. Dorman:

During the 694th meeting of the Advisory Committee on Reactor Safeguards (ACRS),

April 6-8, 2022, we completed our review of topical report NEDC-33922P, BWRX-300 Containment Evaluation Method, Revision 2, and the associated safety evaluation (SE). Our BWRX-300 Design Centered Subcommittee reviewed this matter on March 18, 2022. During these meetings, we had the benefit of discussions with representatives of the U. S. Nuclear Regulatory Commission (NRC) staff and GE-Hitachi Nuclear Energy Americas, LLC (GEH or the applicant). We also benefited from the referenced documents.

CONCLUSIONS AND RECOMMENDATION 1.

The proposed analysis methodology documented in NEDC-33922P, Revision 2, subject to the staff-imposed limitations and conditions, is appropriate to evaluate BWRX-300 containment performance.

2.

A key BWRX-300 performance issue is the potential accumulation of non-condensable gases that may limit heat transfer capability or increase the potential for deflagration during accidents. When the design is finalized, the methodology report limitations and conditions require that these performance issues are addressed.

3.

The SE report should be issued.

BACKGROUND BWRX-300 is an evolutionary light-water reactor based on the certified Economically Simplified Boiling Water Reactor (ESBWR) design and operating experience of the boiling water reactor fleet. Rated at 300 MW-electric, it is a natural-circulation small modular reactor being developed by GEH. The applicant has employed risk-informed design principles with the goal of reducing overall plant size and minimizing the highest risk contributors from the ESBWR design.

April 21, 2022

D.H. Dorman Topical Report NEDC-33922P presents the analysis methodology that will be used to demonstrate that the BWRX-300 containment design satisfies the acceptance criteria listed in topical report NEDC-33911P, BWRX-300 Containment Performance. In our letter of March 1, 2021, documenting our review of NEDC-33911P, we concluded that these criteria are appropriate to evaluate the BWRX-300 containment performance.

The NRC and the Canadian Nuclear Safety Commission (CNSC) are conducting joint reviews of GEH topical reports related to BWRX-300. For this joint review on containment evaluation, the scope was focused on the methodology and not necessarily the design inputs or simulation outputs. The report from the joint review does not affect the jurisdiction and/or the discretion of CNSC or NRC.

DISCUSSION The containment analysis methodology is applied to the events that are evaluated to establish the suitability of the containment performance with respect to the acceptance criteria, including:

anticipated operational occurrences; station blackout, as required by 10 CFR 50.63; anticipated transients without scram, as required by 10 CFR 50.62; large-break loss-of-coolant accident (LOCA) inside containment; and small-break LOCA inside containment.

GEH performed a detailed phenomena identification and ranking table (PIRT) evaluation. The staff reviewed the qualitative details of the containment PIRT survey methodology and found it to be rigorous and consistent with industry best practices. The methodology uses the TRACG code to calculate the mass and energy release from the reactor coolant system and the GOTHIC code to evaluate the containment response, including its passive cooling system. The staff concluded that the proposed methodology is consistent with Regulatory Guide 1.203 because it is based on a conservative analysis using mature computer codes with a sufficient qualification basis, and is therefore, acceptable. We concur.

The staff has performed a series of confirmatory calculations using the TRACE and MELCOR computer codes. These independent analyses provided significant value, not just by confirming the accuracy of GEHs calculations, but also by providing technical insights about the proposed design. Based on these calculations, the staff focused their efforts on identifying the possibility and consequences of ingress of non-condensable gases in the isolation condenser (IC), which would degrade its performance. It is encouraging that, rather than analyzing the problem away with increasingly sophisticated analyses, GEH has committed to improve the BWRX-300 design to make gas accumulation in the IC highly unlikely. We concur with the staff conclusion that the proposed design improvements should address potential degradation concerns.

The staff imposes four limitations and conditions for future applications of this methodology.

Three of them are related to non-condensable gases, and one is related to passive containment cooling. Specifically, the limitations are:

1.

Limit the radiolytic gas accumulation to a safe concentration in the IC.

2.

Provide design improvements to prevent reverse flow through the IC.

3.

Size the containment passive cooling capabilities to prevent reverse flow from containment to the reactor cooling system during small-break LOCAs to prevent ingress of containment gasses.

D.H. Dorman 4.

If the passive containment cooling system design changes, the applicability of the methodology will need to be reviewed.

The staffs limitations and conditions are adequate to ensure that important containment-design improvements are implemented and that design-specific applications of the proposed methodology are likely to satisfy regulatory requirements.

The joint CNSC/NRC review has been mutually beneficial. We encourage such interactions, when warranted, and look forward to following the staff progress on future interactions. The results of this effort, however, do not provide any regulatory bases for the implementation of future licensing submittals; those bases are provided in the staff SE. We recommend that the SE report be issued.

SUMMARY

The proposed analysis methodology documented in NEDC-33922P, Revision 2, subject to the staff-imposed limitations and conditions, is appropriate to evaluate BWRX-300 containment performance. A key BWRX-300 performance issue is the potential accumulation of non-condensable gases that may limit heat transfer capability or increase the potential for deflagration during accidents. When the design is finalized, the methodology report limitations and conditions require that these performance issues are addressed. The SE report should be issued.

We are not requesting a formal response from the staff to this letter.

Sincerely, Joy L. Rempe Chairman REFERENCES 1.

U. S. Nuclear Regulatory Commission, Safety Evaluation by the Office of Nuclear Reactor Regulation Licensing Topical Report NEDC-33922P, Revision 2, BWRX-300 Containment Evaluation Method, March 9, 2022 (ML22040A004).

2.

GE-Hitachi Nuclear Energy Americas, LLC, Licensing Topical Report NEDC-33922P, BWRX-300 Containment Evaluation Method, Revision 2, December 31, 2021 (ML21351A173).

3.

U. S. Nuclear Regulatory Commission, Regulatory Audit Report of the GE-Hitachi Nuclear Energy Americas, LLC Topical Report NEDC-33922, BWRX-300 Containment Evaluation Method, March 2, 2022 (ML21343A195).

4.

Advisory Committee on Reactor Safeguards, Safety Evaluation for Topical Report NEDC-33911P, BWRX-300 Containment Performance, March 1, 2021 (ML21049A340).

Signed by Rempe, Joy on 04/21/22

D.H. Dorman 5.

Advisory Committee on Reactor Safeguards, Applicability of TRACE Thermal-Hydraulic System Analysis Code to Evaluate the ESBWR Design and Related Matters, July 29, 2009 (ML091940352).

6.

Advisory Committee on Reactor Safeguards, Interim Letter 3: Chapters 4, 6, 15, 18, and 21 of the NRC Staffs Safety Evaluation Report with Open Items Related to the Certification of the ESBWR Design, May 23, 2008 (ML081330447).

7.

U.S. Nuclear Regulatory Commission and Canadian Nuclear Safety Commission, Joint Report on GE Hitachis Containment Evaluation Method, April 2022 (ML22091A201).

8.

U. S. Nuclear Regulatory Commission, Regulatory Guide 1.203, Transient and Accident Analysis Methods, December 30, 2005 (ML053500170).

D.H. Dorman

SUBJECT:

SAFETY EVALUATION FOR TOPICAL REPORT NEDC-33922P, BWRX-300 CONTAINMENT EVALUATION METHOD, REVISION 2 Accession No: ML22101A298 Publicly Available (Y/N): Y Sensitive (Y/N): N If Sensitive, which category?

Viewing Rights:

NRC Users or ACRS only or See restricted distribution OFFICE ACRS SUNSI Review ACRS ACRS ACRS NAME MSnodderly MSnodderly LBurkhart SMoore JRempe DATE 04/13/22 04/13/22 04/13/22 04/19/22 04/21/22 OFFICIAL RECORD COPY April 21, 2022