ML24039A081

GEH BWRX-300 SMR - January 24, 2024 Meeting Summary Regarding the GEH Approach to the Bez for the BWRX-300

ML24039A081
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Issue date:	02/08/2024
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Download: ML24039A081 (19)

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From:

Jim Shea Sent:

Thursday, February 8, 2024 6:50 AM To:

GEH-BWRX-300MtgSumPEm Resource Cc:

Jordan Glisan

Subject:

January 24, 2024 Meeting Summary regarding the GEH approach to the BEZ for the BWRX-300 Attachments:

January 24, 2024 Public Closed Meeting Summary on NRC Staff Feedback on GEH BEZ for BWRX-300.docx; BTP 3-3 & 3-4 Public Meeting Slides.pdf On January 24, 2024, from 10:00am to 11:30am, the NRC held an open and partially closed meeting with GEH regarding the application of NRC SRP BTP 3-3 & 3-4 to the piping configuration associated with the BWRX-300 SMR design.

The public / partially closed meeting summary is attached along with the GEH presentation and piping configuration that is the subject of the meeting.

If there are any further questions regarding this subject, please contact the NRC project manager.

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

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January 24, 2024 Meeting Summary regarding the GEH approach to the BEZ for the BWRX-300 Sent Date:

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U.S. Nuclear Regulatory Commission Public Meeting Summary

Title:

Pre-application meeting with GE-Hitachi Nuclear Energy Americas, LLC (GEH) on U.S. Nuclear Regulatory Commission (NRC) staff NUREG 0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, (SRP) Branch Technical Positions (BTP) 3-3 & 3-4.

Meeting Notice: Agency Document Accession Management System (ADAMS) Accession No. ML24023A307.

Date of Meeting: Wednesday, January 24, 2024.

Location: Via teleconference Microsoft Teams.

Type of Meeting: Observation / Partially Closed.

Purpose of the Meetings:

The purpose of this pre-application meeting is to have a discussion of GEH's proposed alternative to NRC staff SRP branch technical position BTP 3-3 & 3-4, Postulated Rupture Locations in Fluid System Piping Inside and Outside Containment.

Meeting objectives are to:

Provide a high-level overview of the BWRX-300 containment penetration area configuration.

Seek NRC feedback on the approach to the Break Exclusion Zone (BEZ) for the BWRX300.

Summary of Meeting:

On January 24, 2024, an observation public and partially closed meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and GEH concerning the application of SRP BTP 3.3 & 3-4, to the GEH BWRX-300 piping configurations. This topic is related to the NRC approved Pre-Application License Topical Report (LTR), NEDO-33910P-A, Revision 2, BWRX-300, "Reactor Pressure Vessel Isolation and Overpressure Protection." The LTR was submitted on December 31, 2019 (ADAMS Accession No. ML20174A577) and was approved by the staff in a letter dated November 18, 2020 (ADAMS Accession No. ML20310A153). The public NRC staff approved -A LTR can be located on the NRC public website under small modular reactor (SMR) Pre-Application Activities GEH BWRX-300 (ADAMS Accession No. ML23167A086). In the LTR, the staff accepted the design functions described for the BWRX-300 SMR in general specifically related to the isolation and pressure relief aspects. In addition, GEH described its BWRX-300 design requirements to identify postulated pipe rupture locations and configurations inside containment as specified in SRP Chapter 3, Design of Structures, Components, Equipment, and Systems, BTP 3-4, Postulated Rupture Locations in Fluid System Piping Inside and Outside Containment, Revision 3, December 2016, Part B, Item 1(iii)(2), and identifying leakage cracks as specified in BTP 3-4, Part B, Item 1(v)(2). However,

GEH stated, Design details are to be described during future licensing activities and the staff noted that, Specific aspects of the connection of the RPV isolation valves to the reactor vessel will be reviewed during future licensing activities of the BWRX-300 SMR. The staff further stated in its safety evaluation report that, If an applicant for a construction permit under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, or a design certification or combined license (COL) under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants, is not able to demonstrate compliance with an NRC regulation when the detailed design of the BWRX-300 SMR is complete, the applicant will be expected to justify an exemption from the applicable regulatory requirement. The NRC staff will evaluate the regulatory compliance of the final design of the RPV isolation and overpressure protection features for the BWRX-300 SMR and the piping rupture locations or break exclusion zone(s) (BEZ) proposed by GEH during future licensing activities in accordance with 10 CFR Part 50 or 10 CFR Part 52, as applicable. As discussed in the approved LTR safety evaluation, GEH indicated in the submittal that the detailed design of the BWRX-300 SMR including the piping configuration inside and outside containment is not complete therefore, the NRC staff will make a final determination of the BWRX-300 SMRs acceptability when the detailed design is completed and reviewed by the NRC staff during future licensing activities.

The meeting commenced with a brief introduction by the NRC licensing project manager, who explained the purpose of the meeting, provided background on the approved staff LTR NEDO-33910P-A, Revision 2, and briefly introduced the NRC staff participating in the meeting and described the meeting logistics. All GEH staff participated remotely. NRC staff participated in the meeting at the designated conference room and also remotely.

In addition, The NRC introduced the Canadian Nuclear Safety Commission (CNSC) review team participating in this meeting remotely, as part of a 2019 memorandum of cooperation between the NRC and CNSC, and a September 2022, Charter - Collaboration on GEHs BWRX300 Design. Therefore, as an integral part of the meeting the CNSC can ask and participate in discussions with GEH during the public portion as well as the closed portion of the meeting.

The principal CNSC technical staff members who attended included:

Mazhar, Hazem hazem.mazhar@cnsc-ccsn.gc.ca Eom, Seyun seyun.eom@cnsc-ccsn.gc.ca GEH provided a public overview of the BWRX-300 reactor pressure vessel (RPV) piping configurations (ADAMS Accession No. ML24016A302) submitted to the NRC in a letter dated January 16, 2024 (ADAMS Accession No. ML24016A301). In its presentation GEH provided some of the piping detail that was not part of the approved LTR NEDO-33910P-A, Revision 2, which was used during the meeting discussions.

GEH specifically was seeking NRC staff feedback on its proposed alternate approach from its approved LTR, for meeting the requirements in 10 CFR Part 50, Appendix A, General Design Criteria for Nuclear Power Plants, (GDC) 4, Environmental and Dynamic Effects Design Bases, which requires, in part, that structures, systems, and components (SSCs) important to safety be designed to accommodate the effects of postulated accidents, including appropriate protection against the dynamic effects of postulated pipe ruptures. Guidelines are provided in NRC NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants (LWR Edition), Chapter 3, Design of Structures, Components,

Equipment, and Systems, Sections 3.6.1 and 3.6.2 and associated Branch Technical Positions (BTP) 3-3, 3-4. Specifically, BTP 3-4, Postulated Rupture Locations in Fluid System Piping Inside and Outside Containment, Revision 3, December 2016.

GDC 4 allows the use of analyses reviewed and approved by the Commission to eliminate from the design basis the dynamic effects of the pipe ruptures postulated in SRP Section 3.6.2, Determination of Rupture Locations and Dynamic Effects Associated with the Postulated Rupture of Piping, Revision 3, December 2016. In SRP Section 3.6.3, Leak-Before-Break Evaluation Procedures, Revision 1 March 2007, it states that, The staff reviews and approves the plant-specific piping system submitted from licensees and applicants to eliminate these dynamic effects [Break Exclusion Zone (BEZ)]. A staff approved leak-before-break (LBB) analysis permits licensees to remove protective hardware such as pipe whip restraints and jet impingement barriers, redesign pipe connected components, their supports and their internals, and other related changes in operating plants. Likewise, requirements for plants under construction or being designed are similarly relaxed. The staffs review ensures that adequate consideration has been given to direct and indirect pipe failure mechanisms and other degradation sources which could challenge the integrity of piping. The staff reviews the direct pipe plant specific and configuration specific failure mechanisms and fracture mechanics analyses.

GEH started the meeting discussions with the outline of its planned approach for applying a BEZ to the design configuration for the BWRX-300 that would apply SRP BTP 3-4 Rev.3 Section B.1.(ii) related to Fluid System Piping in Containment Penetration Areas which states that, Breaks and cracks need not be postulated in those portions of piping from containment wall to and including the inboard or outboard isolation valves, provided that they meet the design criteria of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),Section III, Subarticle NE-1120, and the additional design criteria listed as well as criteria 4 of BTP 3-4 Section B.1.(ii): The length of these portions of piping should be reduced to the minimum length practical. This alternative approach from the approved LTR NEDO-33910P-A, Revision 2, was the primary subject of this meeting.

GEH proposed that, Consistent with current industry practice, that the BWRX-300 will apply the BWRX-300 BEZ from the inboard containment isolation valve to the nearest seismic anchor beyond the outboard isolation valve. GEH also stated that the BEZ pipe length is minimized and associated routing is optimized to achieve sufficient flexibility and minimize stresses given thermal expansion and anchor motions. The BWRX-300 RPV Isolation Valves (which also serve as containment inboard isolation valves) are located integral to the RPV which GEH states is a design element to restore the reactor coolant boundary integrity in the event of a loss of coolant accident condition. GEH pointed to previous precedents from the NRC staff that evaluated piping segments for BEZ treatment that would bound the GEH BWRX-300 piping lengths expected in the final detailed design of the BWRX-300.

The NRC staff did not have a specific objection to this interpretation of BTP 3-4, however it is noted that approval of the elimination of dynamic effects from postulated pipe ruptures is obtained individually for particular piping systems and particular design configurations. LBB is applicable only to an entire piping system or analyzable portion thereof. LBB cannot be applied to individual welded joints or other discrete locations. Analyzable portions are typically segments located between piping anchor points. When LBB technology is applied, all potential pipe rupture locations are examined. The examination is not limited to those postulated pipe rupture locations determined from SRP Section 3.6.2. LBB analyses should demonstrate that the probability of pipe rupture is extremely low under conditions consistent with the design basis for

the piping. A deterministic evaluation of the piping system that demonstrates sufficient margins against failure, including verified design and fabrication and an adequate in-service inspection program, including leakage detection capabilities, can be assumed to satisfy the extremely low probability criterion. Also, according to NRC BTP 3-3, Protection Against Postulated Piping Failures in Fluid Systems Outside Containment, it states that, Even though portions of the main steam and feedwater lines meet the break exclusion requirements of item 2.A(ii) of BTP 3-4, [BEZ] they should be separated from essential equipment. Designers are cautioned to avoid concentrating essential equipment in the break exclusion zone. Essential equipment must be protected from the environmental effects of an assumed nonmechanistic longitudinal break of the main steam and feedwater lines. Each assumed nonmechanistic longitudinal break should have a cross sectional area of at least one square foot and should be postulated to occur at a location that has the greatest effect on essential equipment. In the staff approved LTR NEDO-33910P-A, Revision 2, there was no discussion, and the staff did not make any regulatory findings on the application of BTP 3-3 or BTP 3-4 B.1.(ii) for the BWRX-300. As previously described the LTR did not include sufficient design information for NRC staff to make conclusive findings related to either BTP 3-3, 3-4, or the application of LBB analysis to determine specific BEZ applicability to the BWRX-300 design. In addition, the staff pointed to LBB criteria related to fatigue cracking or failure to ensure that the potential for pipe rupture due to thermal and mechanical induced fatigue is unlikely. Licensees and applicants must demonstrate that (a) adequate mixing of high and low temperature fluids occurs in the piping so that there is no potential for cyclic thermal stresses, and (b) there is no potential for vibration-induced fatigue cracking or failure.

At the conclusion of the open portion of the meeting the public was invited to make comments or ask questions of the NRC staff and since there were no comments or question from members of the public, the NRC staff continued the meeting in a closed session continuing to discuss at more depth the questions raised during the public open portion of the meeting as well as some discussion on the specific isolation valve configuration as depicted in the GEH presentation diagrams.

One of the points that was brought out during the closed session from the NRC staff is that following acceptance of an applicants BEZ only dynamic effects of postulated pipe ruptures may be eliminated when LBB technology is shown to be applicable. Requirements for containment design, emergency core cooling system performance, and environmental qualification of electrical and mechanical equipment are not affected. In addition, the staff discussed some details of the isolation valves with GEH and as was stated in the staff safety evaluation report of the LTR, The NRC staff will review the specific aspects of the connection of the RPV isolation valves to the reactor vessel during future licensing activities of the BWRX-300 SMR. In addition to the NRC staff discussions with GEH the CNSC had similar and more specific discussions of the regulatory treatment and requirements that are specific to Canada.

Since the CNSC was not specifically acquainted with the NRC guidance found in BTP 3-3, 3-4 and the LBB requirements the staff is planning to have a discussion separately with CNSC on these subjects.

There were no regulatory decisions made as a result of this public meeting.

The meeting was then adjourned as scheduled at 11:30 am.

Meeting participants: See the following page.

January 24, 2021, Meeting Attendees Open Closed Name Affiliation Open Closed Name Affiliation X

X Allen Fetter NRC X

X Ben Jordan GEH X

X Basavaraju Chakrapani NRC X

X George Wadkins GEH X

Bedi Gurjendra NRC X

X Geping Song GEH X

X Brian Smith NRC X

Mirin Morgan GEH X

X Brian Wittick NRC X

X

Mirin, Alexander GEH X

X Derek Scully NRC X

X Suzanne Karkour GEH X

X Donna Williams NRC X

X Tanya Kirby GEH X

X Jim Shea NRC X

X Terri Walsh GEH X

X John Bozga NRC X

Veeresh Soyagavi GEH X

John Philip NRC X

X Michele Moorrees TVA X

X Jordan Glisan NRC X

X

Jackson, Tony TVA X

X Kaihwa Hsu NRC X

X James Thornton TVA X

X Kamal Manoly NRC X

X John Lockaby TVA X

X Michelle Hayes NRC X

Ray Schiele TVA X

X Nicholas Soliz NRC X

Scott Owen TVA X

X Raul Hernandez NRC X

Stephen Kimura TVA X

Rob Atienza NRC X

Veronica Kyles TVA X

X Ryan Nolan NRC X

X Hazem Mazhar CNSC X

X Samuel Lee NRC X

Kevin Fice CNSC X

X Stewart Bailey NRC X

X Seyun Eom CNSC X

X Travis Boyce NRC X

Andrew Rahn AREVA X

X Christopher Horwarth GEH X

Tony Lentz AREVA X

X

Edde, Charles GEH X

Edward Schulte Duke Energy X

X

Eng, Christopher GEH X

Lee Grzeck Duke Energy X

X Hinds, David H

GEH X

Andrew Brenner Holtec X

Neil Graham GEH X

Kris Commings NEI

GEHitachiNuclearEnergy

George E. Wadkins GE-Hitachi Nuclear Energy Americas, LLC Chief Consulting Engineer - Licensing 3901 Castle Hayne Road Wilmington, NC 28402 USA T 910.200.3295 George.Wadkins@ge.com M240010 January 16, 2024 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001

Subject:

Presentation Slides for Pre-Application Meeting for GE Hitachi Nuclear Energy BWRX-300 Proposed Break Exclusion Zone Methodology and Application Requirements Enclosed are the presentation slides for the pre-application meeting to discuss proposed Break Exclusion Zone (BEZ) methodology and application requirements for the GE-Hitachi Nuclear Energy Americas, LLC (GEH) BWRX-300 to be held on January 24, 2024. contains non-proprietary information and may be made available to the public.

If you have any questions, please contact me at 910-200-3295.

Sincerely, George E. Wadkins Chief Consulting Engineer - Licensing GE Hitachi Nuclear Energy Americas, LLC

Enclosures:

1.

Presentation Slides for Pre-Application Meeting for GE Hitachi Nuclear Energy BWRX-300 Proposed Break Exclusion Zone Methodology and Application Requirements

- Non-Proprietary Information cc:

J. Shea, US NRC PLM Specification 008N3519 Revision 0 Document Components:

001 M240010 Cover Letter.pdf 002 M240010 Enclosure 1 Non-Proprietary.pdf

ENCLOSURE 1 M240010 Presentation Slides for Pre-Application Meeting for GE Hitachi Nuclear Energy BWRX-300 Proposed Break Exclusion Zone Design Requirements Non-Proprietary Information

Non-Proprietary Information BWRX-300 Break Exclusion Zone (BEZ)

January 24, 2024 Copyright 2024 GE-Hitachi Nuclear Energy Americas, LLC, All Rights Reserved M240010, Enclosure 1 Presentation Slides for Pre-Application Meeting for GE Hitachi Nuclear Energy BWRX-300 Proposed Break Exclusion Zone Methodology and Application Requirements Non-Proprietary Information Enclosure Page 1 of 10

Copyright 2024 GE-Hitachi Nuclear Energy Americas, LLC, All Rights Reserved Non-Proprietary Information Break Exclusion Zone Objective

• Provide a high level overview of the BWRX-300 containment penetration area configuration

• Seek NRC feedback on the approach to the Break Exclusion Zone (BEZ) for the BWRX-300 2

M240010, Enclosure 1 Presentation Slides for Pre-Application Meeting for GE Hitachi Nuclear Energy BWRX-300 Proposed Break Exclusion Zone Methodology and Application Requirements Non-Proprietary Information Enclosure Page 2 of 10

Copyright 2024 GE-Hitachi Nuclear Energy Americas, LLC, All Rights Reserved Non-Proprietary Information Postulation of Pipe Ruptures Break Exclusion Zone 3

The postulation of pipe ruptures is specified in NRC regulation and guidance:

o 10CFR50, Appendix A, General Design Criterion 4, Environmental and dynamic effects design bases o NRC Standard Review Plan (SRP, NUREG-0800):

Sections 3.6.1 and 3.6.2, Rev.3 3.6.3, Rev.1 BTP 3-3, Rev.3 BTP 3-4, Rev.3 M240010, Enclosure 1 Presentation Slides for Pre-Application Meeting for GE Hitachi Nuclear Energy BWRX-300 Proposed Break Exclusion Zone Methodology and Application Requirements Non-Proprietary Information Enclosure Page 3 of 10

Copyright 2024 GE-Hitachi Nuclear Energy Americas, LLC, All Rights Reserved Non-Proprietary Information Break Exclusion Zone (BEZ)

Break Exclusion Zone 4

BTP 3-4 Rev.3 section B.1.(ii)

Fluid System Piping in Containment Penetration Areas.

Breaks and cracks need not be postulated in those portions of piping from containment wall to and including the inboard or outboard isolation valves, provided they meet the design criteria of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section III, Subarticle NE-1120, and the following additional design criteria:

(1)

Reduced stress and fatigue limits.

(2)

Avoidance of welded attachments, or detailed stress analysis or tests.

(3)

Minimized number of circumferential or longitudinal welds.

(4)

Lengths of these portions of piping reduced to the minimum practical.

(5)

Pipe anchors, restrains, attachments to penetrations and whip restraints not welded directly to the pipe except where 100% volumetrically examinable and detailed stress analyzed.

(6)

Requirements on guard pipes.

(7)

A 100 percent volumetric inservice examination of all pipe welds should be conducted during each inspection interval as defined in ASME Code,Section XI, IWA-2400.

M240010, Enclosure 1 Presentation Slides for Pre-Application Meeting for GE Hitachi Nuclear Energy BWRX-300 Proposed Break Exclusion Zone Methodology and Application Requirements Non-Proprietary Information Enclosure Page 4 of 10

Copyright 2024 GE-Hitachi Nuclear Energy Americas, LLC, All Rights Reserved Non-Proprietary Information Break Exclusion Zone (BEZ)

Break Exclusion Zone 5

Consistent with current industry practice, the BWRX-300 applies BEZ from the inboard containment isolation valve to the nearest anchor beyond the outboard isolation valve:

1.

The BWRX-300 RPV Isolation Valves (which also serve as containment inboard isolation valves) are located integral to the RPV in order to restore the reactor coolant boundary integrity. This ensures fuel cooling in the case of a loss of coolant accident as opposed to solely relying on the containment boundary in the event of a loss of coolant.

2.

The functional boundaries of the BEZ, according to the BTP 3-4, are from inboard (inside containment) isolation valve to outboard (outside containment) isolation valve.

3.

Additionally, the structural boundaries of the BEZ are the anchors that extend beyond the outboard isolation valves up to Seismic Interface Restraint (SIR) anchors. These anchors protect the containment isolation valve function from high energy line breaks and seismic effects beyond the SIRs.

4.

Accordingly, the piping between the OCIV and the SIR maintains the enhanced piping classification and requirements of the functional boundaries of the BEZ.

5.

Pipe length is minimized and associated routing is optimized to achieve sufficient flexibility and minimize stresses given thermal expansion and anchor motions.

M240010, Enclosure 1 Presentation Slides for Pre-Application Meeting for GE Hitachi Nuclear Energy BWRX-300 Proposed Break Exclusion Zone Methodology and Application Requirements Non-Proprietary Information Enclosure Page 5 of 10

Copyright 2024 GE-Hitachi Nuclear Energy Americas, LLC, All Rights Reserved Non-Proprietary Information Example: BWRX-300 Containment Penetration Area - Nuclear Boiler System, Steam Lines Break Exclusion Zone 6

ICIV / RPV IV OCIV / MSIV Containment Penetration Seismic Interface Restraint Turbine Building Reactor Building Containment M240010, Enclosure 1 Presentation Slides for Pre-Application Meeting for GE Hitachi Nuclear Energy BWRX-300 Proposed Break Exclusion Zone Methodology and Application Requirements Non-Proprietary Information Enclosure Page 6 of 10

Non-Proprietary Information Copyright 2024 GE-Hitachi Nuclear Energy Americas, LLC, All Rights Reserved B r e a k E x c l u s i o n Z o n e 7

BWRX-300 Isolation Condenser System - BEZ Pictorial Representation of ICS Line Reactor Building Containment Reactor Building Containment M240010, Enclosure 1 Presentation Slides for Pre-Application Meeting for GE Hitachi Nuclear Energy BWRX-300 Proposed Break Exclusion Zone Methodology and Application Requirements Non-Proprietary Information Enclosure Page 7 of 10

Non-Proprietary Information Copyright 2024 GE-Hitachi Nuclear Energy Americas, LLC, All Rights Reserved B r e a k E x c l u s i o n Z o n e 8

BWRX-300 Reactor Water Cleanup - BEZ Pictorial Representation Reactor Water Cleanup ICIV / RPV IV Containment Penetration Seismic Interface Restraint Turbine Building Reactor Building Containment M240010, Enclosure 1 Presentation Slides for Pre-Application Meeting for GE Hitachi Nuclear Energy BWRX-300 Proposed Break Exclusion Zone Methodology and Application Requirements Non-Proprietary Information Enclosure Page 8 of 10

Non-Proprietary Information Copyright 2024 GE-Hitachi Nuclear Energy Americas, LLC, All Rights Reserved B r e a k E x c l u s i o n Z o n e 9

BWRX-300 Feedwater Lines - BEZ Pictorial Representation of Feedwater Line Turbine Building Reactor Building Containment Seismic Interface Restraint OCIV ICIV / RPV IV M240010, Enclosure 1 Presentation Slides for Pre-Application Meeting for GE Hitachi Nuclear Energy BWRX-300 Proposed Break Exclusion Zone Methodology and Application Requirements Non-Proprietary Information Enclosure Page 9 of 10

We build on our legacy, boldly innovating to provide reliable carbon-free power to the world.

Copyright 2024 GE-Hitachi Nuclear Energy Americas, LLC, All Rights Reserved M240010, Enclosure 1 Presentation Slides for Pre-Application Meeting for GE Hitachi Nuclear Energy BWRX-300 Proposed Break Exclusion Zone Methodology and Application Requirements Non-Proprietary Information Enclosure Page 10 of 10