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Audit Summary for the Regulatory Audit of Ge-Hitachi Topical Report, BWRX-300 Steel - Plate Composite Containment Vessel and Reactor Building Structural Design
	ML24103A005
Person / Time
Site:	99900003, 99902078
Issue date:	06/14/2024
From:	Glisan J; NRC/NRR/DNRL/NVIB
To:	Hayes M; NRC/NRR/DNRL/NLIB
References
	Download: ML24103A005 (34)
	v • d • e

June 14, 2024 MEMORANDUM TO:

Michelle W. Hayes, Chief Licensing and Regulatory Infrastructure Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation FROM:

Jordan Glisan, Project Manager /RA/

Licensing and Regulatory Infrastructure Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation

SUBJECT:

AUDIT

SUMMARY

FOR THE REGULATORY AUDIT OF GE-HITACHI TOPICAL REPORT, BWRX-300 STEEL-PLATE COMPOSITE CONTAINMENT VESSEL AND REACTOR BUILDING STRUCTURAL DESIGN This memorandum transmits the audit summary for the regulatory audit of GE-Hitachi Nuclear Energy Americas, LLC (GEH) Licensing Topical Report (LTR), BWRX-300 Steel-Plate Composite Containment Vessel and Reactor Building Structural Design. This audit was announced via the publicly available audit plan (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23254A064) that was issued on September 12, 2023. Due to the reopening of this regulatory audit as described in the following report, this audit was based on both revision 1 and 2 of the LTR. Revision 2 was submitted to the NRC April 18, 2024 and can be found at ML24110A134.

As prescribed by a September 2022, Charter - Collaboration on GEHs BWRX300 Design, (ML22284A024), the Nuclear Regulatory Commission (NRC) and Canadian Nuclear Safety Commission (CNSC) have been in collaboration on the review of this LTR. As a result, CNSC staff participated in this audit.

The audit was conducted in accordance with the guidance provided in the NRC Office Instruction LIC-111, Regulatory Audits, (ML19226A274).

CONTACT:

Jordan Glisan, NRR/DNRL 301-415-3478

The audit took place via use of the GEH electronic reading room found on Certrec online portal.

The audit entrance was held on September 13, 2023, with the exit meeting taking place on January 17, 2024. The audit was briefly reopened to review a new reference mentioned in Revision 2 of the LTR. The contents of the audit summary are provided as an enclosure.

Docket No. 99902078

Enclosures:

1. Structural Design LTR Audit Summary (Public)

2. List of Information Needs/Observations -

Proprietary (Non-Public)

Pkg: ML24103A004 Enclosure No. 1: ML24103A005 PUBLIC Enclosure No. 2: ML24103A006 PROP *via email NRR-106 OFFICE NRR/DNRL/NLIB:PM NRR/DNRL/NLIB:LA NRR/DNRL/NLIB:BC NAME JGlisan SGreen*

MHayes DATE 06/03/2024 06/06/2024 06/14/2024 UNITED STATES NUCLEAR REGULATORY COMMISSION AUDIT

SUMMARY

FOR THE REGULATORY AUDIT OF GE-HITACHI TOPICAL REPORT, REVISION 1, BWRX-300 STEEL-PLATE COMPOSITE CONTAINMENT VESSEL AND REACTOR BUILDING STRUCTURAL DESIGN Docket No. 99900003 AUDIT

SUMMARY

REPORT APPLICANT: GE-Hitachi Nuclear Energy Americas, LLC (GEH)

CONTACTS: Suzanne Karkour and Phillip Henderson DURATION:

September 13, 2023 - January 17, 2024 April 15, 2024 - April 29, 2024 LOCATION:

U.S. Nuclear Regulatory Commission (NRC) Headquarters (via GEHs electronic reading room (ERR))

One White Flint North 11545 Rockville Pike Rockville, Maryland 20852-2738 AUDIT TEAM: George Thomas, (Technical Reviewer)

Office of Nuclear Reactor Regulation (NRR)

Jordan Glisan, (Project Manager) (NRR)

Jose Pires, (Senior Technical Advisor/Technical Reviewer)

Office of Research (RES)

George Stoyanov, (Technical Reviewer) (Canadian Nuclear Safety Commission)

Ahmed Ashour (GEH)

Ahmed Abdelaziz (GEH)

Ahmed Abouhussien (GEH)

Peter Ostrowski (GEH)

Sharon Chikota (GEH)

Jordan Supler (GEH)

Genevieve Watts (GEH)

Luben Todorovski (GEH)

Osama Bedair (GEH)

Mohtady Sherif (GEH)

Ossama Ali (GEH)

Ai-Shen Liu (GEH)

Cybil Miller (GEH)

Phillip Henderson (GEH)

Lamia Chouda (GEH)

2 AUDIT

SUMMARY

REPORT REGULATORY AUDIT BASIS This regulatory audit is based on Licensing Topical Report (LTR) NEDC-33926P/NEDO-33926, BWRX-300 Steel-Plate Composite Containment Vessel (SCCV) and Reactor Building (RB)

Structural Design.

REGULATORY AUDIT SCOPE AND ACTIVITIES The audit team examined LTR references and GEHs response to NRC requested information needs provided in the online portal. The audit team met with GEH approximately bi-weekly to share observations and identify any additional information needed to gain further understanding of the technical bases of the methodology being reviewed in the LTR. Near the end of the audit, GEH provided a draft update to the LTR that incorporated their response to several information needs.

DEVIATIONS FROM AUDIT PLAN The audit plan was issued for September 12, 2023, and can be accessed via public under ML23254A064. The following items were different from the audit plan:

Due to the delayed availability of some of the references, the audit was extended from ending October 20th to ending January 17th.

Due to some of the references only being available by paper copy, the entirety of the audit did not take place on the online portal.

Two NRC staff originally identified as audit team members did not participate due to conflicting schedules for other projects.

Additional information needs were added to the original list provided in the audit plan.

The audit was reopened in April 2024 to review a newly referenced document mentioned in GEHs response to request for additional information (RAI) question 11 (ML24094A295).

Following GEHs submission of revision 2 of the LTR, the reopening of the audit mentioned above was based on revision 2 of the LTR.

LIST OF DOCUMENTS AUDITED The NRC staff requested the following material and information be made available for audit:

The references indicated by Audit Information Need A-1 found in the below table.

GEH 007N5115, Revision 1, Demonstration of Nondestructive Evaluation of Concrete in Mockup and Prototypes, June 2023.

3 Reference 9-54 ANSI/AISC 360-22, Specification for Structural Steel Buildings, American Institute of Steel Construction, 2022.

MUAP-11019 (R1), Mitsubishi Containment Internal Structure: Design Criteria for SC Walls Report, Non-proprietary Version, January 2013.

GEH Source Inspection Trip Report (Purdue University, Date: 18-APR-2023), Witness of In-Plane Shear Testing for NRIC Phase I Remanufactured Specimens: Part #:

IPV+OOPV-1[2]-AW; Specimen IPV+OOPV-2; Signed by GEH Source Inspector Matthew Keene on 02-MAY-2023 GEH ID: 007N1186, Revision 3, NRIC Prototype Test Plan, April 2023 GEH Source Inspection Trip Report (Purdue University, dated: March 21, 2023), Witness of Bi-Axial Testing for NRIC Phase I Remanufactured Specimens: Part #: Bi-axial #1; Signed by GEH Source Inspector Derek C. Walker on 3/28/2023 Interpretation No. III-2-83-01 (Record no. NI-81-180) on ASME Section III, Division 2, CC-3200, Load Criteria Used for Containment Vessel and Auxiliary Building, dated September 9, 1982.

R.P. Kennedy, Design of Concrete Structures to Resist Missile Impact Effects, Nuclear Engineering and Design 37, 1976.

Bruhl, J.C., Varma, A.H., Johnson, W.H., 2015, Design of Composite SC Walls to Prevent Perforation from Missile Impact, International Journal of Impact Engineering 75.

Harmon, J.R., Varma, A.H., 2021, Local Buckling of Steel Faceplates Anchored to Concrete Infill in C-PSW/CF, Thin-Walled Structures 167.

NEDC-33926P, Draft Revision 2, December 2023 AUDIT CLOSURE This audit exit briefing was held on January 17, 2024. During this meeting, NRC staff summarized the audit as well as the overall effectiveness. A total of 78 information needs were made within the audit which resulted in 11 RAIs. These RAIs were subsequently issued to GEH on January 26th and can be accessed via public ADAMS under ML24033A206. The NRC staff noted that while some audit issues were closed based on the applicants substantive response, the staff may need to place a limitation and condition in their final safety evaluation.

4 LIST OF INFORMATION NEEDS/OBSERVATIONS The table below lists each of the information needs identified by the NRC or CNSC staff on the review team along with the outcome.

Some items remained as open at the conclusion of the audit because they were a CNSC item out of the scope of the LTR, an item not necessary to be resolved during the audit (such as editorial), an item that will become a limitation or condition, or an item that will become an RAI. The latter are indicated by a red RAI in the Outcomes and GEH Commitments column.

Information Need Outcomes and GEH Commitments Status A-1.1 Provide reference 9-57 Sarraj, M. (2007), The Behavior of Steel Fin Plate Connections in Fire, Ph.D. Thesis, Department of Civil and Structural Engineering, University of Sheffield, UK.

Reference Provided in ERR

- CLOSED A-1.2 Provide reference 9-58 Varma, A.H., Zhang, K. and Malushte, S.R. (2013), Local Buckling of SC Composite Walls at Ambient and Elevated Temperatures, Transactions of the 22nd International Conference on Structural Mechanics in Reactor Technology (SMIRT 22), San Francisco, CA, IASMIRT, North Carolina State University, Raleigh, NC.

Reference Provided in ERR

- CLOSED A-1.3 Provide reference 9-59 Sener K.C., Varma A.H., Steel-Plate Composite (SC) Walls: Out-of-Plane Flexural Behavior, Database, and Design. Journal of Constructional Steel Research, May 2015, Volume 108, pages 46-59.

Reference Provided in ERR

- CLOSED A-1.4 Provide reference 9-61 Sener, K.C. & Varma, A.H., Steel-Plate Composite Walls with Different Types of Out-of-Plane Shear Reinforcement: Behavior, Analysis, and Design, ASCE Journal of Structural Engineering, 2021.

Reference Provided in ERR

- CLOSED A-1.5 Provide reference 9-62 Sener, K.C., Varma, A.H., Wang, S.,

Bhardwaj, S.R., & Gallocher, S (2019), Modular Steel-Plate Reference Provided in ERR

- CLOSED

5 Information Need Outcomes and GEH Commitments Status Composite (SC) Wall Steelbricks: Experimental and Numerical Evaluations, Nuclear Engineering and Design 350, 2019.

A-1.7 Provide reference 9-65 Kim, J.M., Behavior, Analysis and Design of Steel-Plate Composite (SC) Walls for Impactive Loading, Purdue University, 2019.

Reference Provided in ERR

- CLOSED A-1.8 Provide reference 9-67 Simplified Equations for Shear Strength of Composite Concrete-Filled Steel Tubes, AISC Engineering Journal, Third Quarter, 2021.

Reference Provided in ERR

- CLOSED A-1.9 Provide reference 9-68 Neng Wang, Feng Zhou, Yunguang Qu, Zhengyu Xu, Zhongcheng Li, Fan Wang: Flexural Behavior of Curved Steel-Plate Composite (SC) Walls Under Combined Axial Compression and Cyclic Lateral Force, Engineering Structures 245 (2021) 112919.

Reference Provided in ERR

- CLOSED A-1.10 Provide reference 9-73 Bhardwaj, S.R., Wang, A.Y, & Varma, A.H., Slenderness Requirements for CF-CPSW: The Effects of Concrete Casting, Eighth International Conference on Thin-Walled Structures - ICTWS 2018, Lisbon, Portugal, July 24-27, 2018.

Reference Provided in ERR

- CLOSED A-1.11 Provide reference 9-85 Farhidzadeh, A., Epackachi, S.,

Salamone, S., & Whittaker, A.S., 2015, Bayesian Decision and Mixture Models for AE monitoring of Steel-Concrete Composite Shear Walls. Smart Materials and Structures 24 (11), 115028.

Reference Provided in ERR

- CLOSED A-1.12 Provide reference 9-86 Hamdi, S.E., Sbartai, Z.M., Boniface, A.,

Saliba, J., & Henault, J.M., 2023, Pressure-Induced Damage Monitoring in Prestressed Concrete of Nuclear Containment Wall Reference Provided in ERR

- CLOSED

6 Information Need Outcomes and GEH Commitments Status Segments Using Acoustic Emission Technique-Application to VeRCoRs Containment Building, Engineering Fracture Mechanics 281, 109089.

A-1.13 Provide reference 9-66 Design Guide 32, Design of Modular Steel-Plate Composite Walls for Safety-Related Nuclear Facilities, American Institute of Steel Construction, 2017.

Reference Provided in ERR

- CLOSED A-1.14 Provide reference 9-72 Design Guide 38, SpeedCore Systems for Steel Structures, American Institute for Steel Construction, 2023.

Reference Provided -

CLOSED A-1.15 Provide reference 9-56 EN 1993-1-8, Eurocode 3: Design of Steel Structures - Part 1-8: Design of Joints, European Committee for Standardization (CEN), 2005.

Reference Provided -

CLOSED A-1.16 Provide reference 9-71 EN 1991-1-2, Eurocode 1: Actions on Structures - Part 1-2: General Actions - Actions on Structures Exposed to Fire, European Committee for Standardization (CEN), 2022. (Confirm if this reference is intended to be the 2022 edition as stated or the 2002 edition).

Reference Provided -

CLOSED A-1.17 Provide reference 9-74 ISO-12944-5:2019, Paints and Varnishes Corrosion Protection of Steel Structures by Protective Paint Systems, International Organization for Standardization, 2019.

Reference Provided -

CLOSED A-1.18 Provide reference 9-79 ISO-12473:2017, General Principles of Cathodic Protection in Seawater Requirements, International Organization for Standardization, 2017.

Reference Provided -

CLOSED

7 Information Need Outcomes and GEH Commitments Status A-1.19 Provide reference 9-76 SSPC Painting Manual, Vol.1, Good Painting Practice The Society for Protective Coatings, 2016.

Reference Provided -

CLOSED A-1.20 Provide reference 9-77 SSPC Painting Manual, Vol.2, Systems and Specifications The Society for Protective Coatings, 2000.

Reference Provided -

CLOSED A-1.21 Provide reference 9-70 ANSI/UL 263, Fire Tests of Building Construction and Material, Underwriters Laboratories. (Since no specific edition is identified, this reference is needed only if other than 14th edition, reprinted March 14, 2022, is used).

Confirmed that they will remove reference from LTR.

CLOSED A-2 EPRI report on (or documentation of) demonstrations as described in Section 5.18.

Report to be provided in list of references in the LTR Report Provided

- CLOSED A-3 Justification for using the NRC guidance documents listed as references 9-27, 9-16, 9-23, and 9-81, which are not the latest versions or use the latest versions required pursuant to 10 CFR 50.34(h), and reference 9-54 which is inconsistent with version used in 9-12.

RAI

Response

Provided in ERR, Reference 9-54 Provided A-4 In Section 2.1.1.5, justification for stating the BWRX-300 design meets the requirements of 10 CFR 50.150 when specific details and results of the aircraft impact assessment analysis are outside the scope of this LTR.

LTR statement of compliance will be updated accordingly

Response

Provided in ERR

Provided in ERR

10 Information Need Outcomes and GEH Commitments Status and (b) the DP-SC Basemat, Intermediate DP-SC Floors, DP-SC Floor at Grade, SCCV DP-SC Top Slab, and DP-SC RB roof are curved on two edges (inside and outside) and have circular shapes in plan; and may potentially need non-rectangular modules. However, from LTR Chapter 7, the test specimen modules tested in the NRIC Prototype Test Program were fabricated as straight (flat) rectangular DP-SC modules.

a) Describe the fabrication/assembly/installation of apparently straight/flat DP-SC modules into a curved or cylindrical walls, and non-rectangular floor/basemat/roof modules with curved edges or circular shapes.

b) Describe in specific detail of how the connection between the above modules are made in the field for the SC-DP walls and floors/basemat/roof with curvature or curved or circular edges/shapes; and how the effectiveness of inter-module connections is ensured.

c) Clarify if there is an intent or plan to use DP-SC modules with curved faceplates.

d) If the answer to c) is yes, discuss how the potential impact of any residual stress that may be associated with rolling curved faceplates will be evaluated and factored into the design of the SCCV DP-SC modules.

A-15 Provide reference 9-54 ANSI/AISC 360-22, "Specification for Structural Steel Buildings," American Institute of Steel Construction, 2022 Reference Provided in ERR

- CLOSED A-16

[CNSC]The summary of Operating Experience (OpEx) and typical degradation and failure mechanisms, monitoring, preventive, mitigation, and corrective actions against the degradation of any structures, systems, and components (SSCs) whose operating RAI

Response

Provided in ERR

Provided in ERR

- CLOSED A-23 LTR Section 2.1.1 10 CFR Part 50 Regulations includes GDC 53 but does not appear to include 10 CFR Part 50, Appendix A, GDC 52, Capability for containment leakage rate testing, as an applicable regulation. While the language of the statement of compliance (SOC) in LTR Section 2.1.1.14 captures GDC 52, it does not appear to capture GDC 53 (with regard to local leakage rate testing of penetrations) in order to comply with 10 CFR 50, Appendix J.

(a) Clarify or justify why GDC 52 is not included in the LTR as an applicable regulation to BWRX-300 SCCV or include GDC 52 if determined to be applicable.

(b) Clarify and provide a revised SOC language in LTR Section 2.1.1.14 10 CFR Part 50, Appendix J that also captures LTR will be changed to explain compliance with GDC 52. SOC in Section 2.1.1.14 to be revised to clarify specific compliance with provisions for periodic integrated leak rate testing and local leak rate test

Response

Provided in ERR

- CLOSED

13 Information Need Outcomes and GEH Commitments Status requirements of GDC 53 local leakage testing of penetrations in addition to GDC 52.

A-24 LTR Section 2.1.1.5 10 CFR 50.150, regarding Aircraft Impact Assessment, under Statement of Compliance uses the phrases:

The BWRX-300 design considers the airports based on a site-specific parameter. and.for aircraft crash evaluations with plant-specific input on a case-by-case basis The plant-specific input phrase is also used in the SOC for LTR Section 2.2.7. Clarify what is meant by the phrases underlined above specifically in the context of 10 CFR 50.150, which requires a design-specific assessment, and has no relationship to site-specific airport locations nor plant-specific input. The design-specific assessment applies to beyond design basis malevolent aircraft impact assessment for which the commercial aircraft characteristics and loading functions to be used is provided to an applicant by the NRC as safeguards information. Any other site-specific or plant-specific applicable loads, such as potential aircraft crashes (non-tERRorism related) due to the location of airports, etc., should be addressed as part of meeting GDC 4 (which applies to dynamics effects of events external to the nuclear power unit) consistent with regulatory position C.8.a(4) of Regulatory Guide (RG) 1.136, Revision 4 (for SCCV) and position C.2.2.6 of RG 1.243 (for RB). Provide revised language if determined to be necessary.

Subject sections +

2.1.1.8 will be revised to clarify design-specific versus site-specific aircraft impact assessments

Response

Provided in ERR

- CLOSED A-25 ASME Section III (Division 1) and Section XI (Division 1) codes are incorporated by reference (IBR) in 50.55a, and editions of these codes used should be IBR in 50.55a. The most recent IBR of 50.55a for Section III, Division 1 is the 2019 edition. Clarify and indicate as such if reference 9-1 is intended to specify the 2021 edition of ASME Section III, Division 2, as stated in LTR Sections 1.1, 3.1 and 4.3. Likewise, for reference 9-6, the 2021 edition of Latest versions of Reference 9-5 and 9-7 will be referenced in LTR

Response

Provided in ERR

- CLOSED

14 Information Need Outcomes and GEH Commitments Status ASME Section XI, Division 1 is currently not IBR in 50.55a. The most recent IBR is the 2019 edition. Also, for related references 9-5 (RG 1.192, Revision 3) and 9-7 (RG 1.147, Revision 19), the latest revisions are Revision 4 and Revision 20, respectively.

Clarify which edition is proposed to be used, consistent with 10 CFR 50.55a regulation for ASME Section III, Division 1 and Section XI, Division 1, and the above referenced RGs.

A-26 LTR Section 4.3 Design Loads and Load Combinations states that the loads and load combinations are in accordance with CC-3230 for SCCV and AISC N690-18 for RB, as supplemented by RG 1.136 and RG 1.243 respectively. However, notations used in the LTR for several loads appear inconsistent with the referenced codes and RGs (e.g., F, Po, E, Sx, Eo, Ess, Es, G, Pv), the load Po and Sx does not exist in either, and the LTR is silent with regard to OBE.

(a) Clarify and reconcile the loads and load combinations, including notation, between the LTR and referenced codes and RGs. Also, address OBE which are included in the LCs.

(b) Clarify or explain why design basis accident (DBA) pressure (Pa) is based on main steam line break and not LOCA.

(c) Clarify, with basis, whether or not safety relief valve actuation load (G) or hydrodynamic pool loads exists for BWRX-300 (d) Confirm the LRFD design philosophy in AISC N690 and AISC 360 is used for the RB DP-SC design provisions.

Section 4.3 will be updated accordingly

Response

Provided in ERR

- CLOSED A-27 LTR Section 4.4 states, and Figure 4-1 indicates, that Design procedures and acceptance criteria for the containment mat foundation are the same as for the SCCV. The mat foundation portion outside the containment boundary is designed to ANSI/AISC N690, supplemented by USNRC RG 1.243. Clarify if the basemat foundation for the SCCV and RB are constructed as integral to each other, or if they are separated. If constructed Clarification and ASME code interpretation provided.

Response

Provided in ERR

- CLOSED

15 Information Need Outcomes and GEH Commitments Status integrally, clarify how it is designed considering that the RB is designed to Load and Resistance Factor Design provisions and the SCCV to Allowable Strength Design provisions. If separated, clarify how and where are they separated.

A-28 LTR Section 4.4, on page 58, states, in part: ASME BPVC,Section XI and [Sub]Section IWE are followed considering the inner face faceplates are serving as leak-tight containment liner.

This statement appears to give the impression that only the inner faceplate will be subject to the inservice inspection (ISI) requirements of Subsection IWE. Clarify what components of the SCCV will be in the scope of the ISI examinations in accordance with Subsection IWE consistent with 10 CFR 50.55a.

RAI

Response

Provided in ERR A-29 LTR Section 5.1 Design Parameters: Staff notes that DP-SC has faceplates and diaphragm plates, and Figure 5-1 does not include a thickness notation for the diaphragm plate. Where not specifically indicated, provide clarification of which parameter applies to what plate(s). Item (iii) - Clarify and state whether the parameter plate thickness, tp is for the faceplate, the diaphragm plate, or both (in which case the design approach may need to specify the thickness faceplate and diaphragm plate should be the same)

Item (iv) - Clarify and state which plate the parameter steel-plate yield strength Fy is for.

LTR to be updated -

potential L&C.

Response

Provided in ERR

- OPEN A-30 LTR Section 5.1, at the top of page 61, states: The minimum and maximum depths, tsc, of DP-SC modules are in accordance with ANSI/AISC N690, Section N9.1.1a provisions. These limits are based on practical fabrication considerations, and do not suggest any deviations in the fundamental behavior or mechanics. The boldened statement appears inconsistent to LTR to be updated -

potential L&C

Response

Provided in ERR

16 Information Need Outcomes and GEH Commitments Status that in the AISC N690, Appendix N9 Commentary, Section N9.1.1(a), which states: SC wall thickness greater than 60 in are not permitted due to the lack of test data (for in-plane and out-of-plane forces) and possible concerns about the section behaving as a unit (structural integrity)... Clarify the intent and relevance of the non-codified statement in bold and underlined above when the proposed BWRX-300 design provisions appears to limit DP-SC thickness to 60 inches consistent with N690-18, Appendix N9. Provide supporting test data (experimental evidence) to justify the statement if it has relevance to the proposed provisions in the LTR.

A-31 LTR Section 5.1, on page 61, states: The maximum reinforcement ratio for the non-containment DP-SC walls is taken as 0.10 following the requirements of ANSI/AISC 360 [-22]

(reference 9-54), Section I1.6. Provide the technical justification for increasing the maximum reinforcement ratio from 0.05 in AISC N690-18, Appendix N9, to 0.10 using commercial standard provisions for slender walls that is independent of the requirements for SC walls in nuclear facilities. Clarify/justify why a minimum reinforcement ratio is not specified, as in N690-18, Appendix N9, as well as AISC 360-22.

Draft AISC N690-24 to be included as a reference and Section 5.1 will be updated

Provided in ERR

- CLOSED A-35

[CNSC]Please provide reference R.G.8 from M230099, Enclosure 2, NEDC-33926P/NEDO-33926, Revision 0, Additional Information to Support NRC Acceptance Review, namely: URS Energy and Construction Inc., MUAP-11019 Containment Internal Structure: Design Criteria for SC Walls for US-APWR Standard Plant (Report CIS-13-05-160-006).

Non-proprietary version provided in ERR

Response

Provided in ERR

- CLOSED A-36

[CNSC]Please provide references supporting scaling as suggested in M230099, Enclosure 1 NEDC-33926P/NEDO-33926, Revision 0 Additional Information to Support NRC Acceptance Review, page 3 of 5, GEH Response to Request for Additional Information #2, namely: GEH will provide access to supporting references, upon request, during the USNRC review of the LTR.

Response

Provided in ERR

18 Information Need Outcomes and GEH Commitments Status A-37

[CNSC] Please provide information on how creep and shrinkage effects on concrete are accounted for in design and if there are any evaluations and limits on those. Presently only one reference on shrinkage impact on properties can be found in the submission with regard to higher degree of shrinkage induced tensile strains during curing (M230099, Enclosure 2 NEDC-33926P/NEDO-33926, Revision 0 Additional Information to Support NRC Acceptance Review, APPENDIX G, Appendix G.1 Pre-Test Simulation - Missile Impact Tests).

Response

Provided in ERR A-38 LTR Section 5.6 Effective Stiffness of Semi-Rigid Connections, proposes as an alternative the component-based model approach in Sarrajs PhD thesis (reference 9-57). However, the LTR does not appear to point to specific equation(s) or section(s) of reference 9-57 that will be used to model stiffnesses of semi-rigid connection as part of the LTR methodology. (a)

Identify in the LTR specific sections and/or equations from reference 9-57 that will be used to model semi-rigid connections in the proposed LTR methodology. (b) Clarify if the single fin plate connection studied in reference 9-57 will be used as the semi-rigid floor-to-wall and wing wall connections for the RB.

LTR Section 5.7.5.1 will be updated to remove the alternative approach based on reference 9-57.

Response

Provided in ERR

- CLOSED A-39 This information has been withheld due to its proprietary nature.

LTR Section 5.7.5.1 will be updated to clarify Reference Provided in ERR

- CLOSED A-40 This information has been withheld due to its proprietary nature.

LTR Section 5.7.5.2 will be updated.

Response

Provided in ERR

- CLOSED

19 Information Need Outcomes and GEH Commitments Status A-41 This information has been withheld due to its proprietary nature.

RAI

Response

Provided in ERR A-42 This information has been withheld due to its proprietary nature.

Section 5.7.5.1 to be updated to clarify.

Response

Provided in ERR

- CLOSED A-43 LTR Section 5.8.1.1, second bullet, states: DP-SC panels designed to resist impulse loads and dynamic effects in the abnormal, extreme environmental, and abnormal and extreme environmental categories are allowed to have permanent plastic deformations. Design adequacy is controlled by limiting the support rotation and ductility, as well as steel and concrete strains. Clarify with basis the damage level (limited, moderate, or severe damage) or ductility criteria that will be used to determine design adequacy for the stated load cases where the structures are allowed to have permanent, plastic deformations.

Table 5-2 will be updated; RAI

Response

Provided in ERR A-44 LTR Section 5.8.1.3 Allowable Limits, states: Damage criteria for DP-SC structures subject to impulsive loads are presented in Table 5-2 and Table 5-3, conservatively adapted from ACI 349.4R (reference 9-63) and meet the general criteria discussed in Subsection 5.8.1.1. GEH response to request for additional information #4 to support NRC acceptance review, by letter dated 7/31/2023, states: Reference to ACI 349.4R, Revision 4, will be replaced where similar information regarding impactive and impulsive forces in included in the LTR with the following:

USNRC RG 1.243, Revision 0, CNSC REGDOC-2.5.2, Version 1, and IAEA Safety Reports Series No 87, Revision 0 (a) For clarity of the staffs understanding and to facilitate review, provide a draft markup or explanation of specifically how the reference to ACI 349.4R will be replaced with the stated Section 5.8.1.3 to be updated and a Reference 9-88, IAEA Safety Reports Series No. 87, Revision 0 will be added; RAI

Response

Provided in ERR

20 Information Need Outcomes and GEH Commitments Status documents where similar information regarding impactive and impulsive forces in included in the LTR. Include reference to specific sections of the documents that will be used.

(b) Also, clarify the ductility criteria that will be used in Section 5.8.3 where cross-reference is made to Section 5.8.1.3.

A-45 LTR Section 5.8.2.2 states, in part: Local areas for missile impact are defined as having a maximum diameter equal to 10 times the effective diameter of the impacting missiles, or 5 sqrt(tsc)

(2.76 sqrt(tsc)) plus the effective diameter of the impacting missile, whichever is smaller. (a) Clarify and cite the source or basis of this statement; and (b) State the units for 5 sqrt(tsc) (2.76 sqrt(tsc)).

2 References to be added to the LTR (A Review of Procedures for the Analysis and Design of Concrete Structures to Resist Missile Impact Effects, Nuclear Engineering and Design, Volume 37, Issue 2, pp. 183-203, May 1976 and "Design of composite SC walls to prevent perforation from missile impact.

International Journal of Impact Engineering, Elsevier Ltd, 75, 75-87.)

Response

Provided in ERR

- CLOSED A-46 LTR Section 5.8.2.2.1 Steel-Plate Thickness Preventing Perforation, on page 78 makes a general reference to ref 9-65 for the methodology presented. Reference 9-65 is a 300-page Ph.D dissertation and without pointing to specific sections and equations in the document, it is difficult for the staff or user of the LTR to figure out without expending a large amount of time where the information is taken from.

2 missile impacts references to be added to LTR, Section 5 equations will be clarified via update,

Response

Provided in ERR

- CLOSED

21 Information Need Outcomes and GEH Commitments Status (a) Clarify and point to specific sections and equations from reference 9-65 that are credited for the methodology presented in the stated the LTR section.

(b) Reference 9-65, in Section 7.4.4 on page 224, states that Ksc calculated using equation 7-14 (LTR equation 5-34) provides a level of confidence of about 50% which is appropriate for the best estimate approach aiming at the beyond design basis accident.

Clarify and justify the appropriateness of the use of LTR equation 5-34 to calculate Ksc for evaluating perforation due to a missile from a design basis event for which it appears to be intended in the LTR.

(c) Define the term tc and its unit in LTR equation 5-34.

(d) Define the units for xsc and xc derived using LTR empirical equations 5-34, 5-35 and 5-36.

(e) Provide the source of the definition of K = concrete penetrability factor = 180/sqrt(fc) used in in LTR empirical equations 5-35 and 5-36; and the source of equation 5-45 and the unit of theta.

(f) Define the unit for Vp.conc and Vr calculated by LTR empirical equations 5-37, 5-38, 5-39, and 5-40.

(g) Clarify, in LTR equation 5-41, if the middle term in the part (r22 + r1r1 + r12) should be r1r2, and if so please correct.

(h) Clarify if unit for concrete density rc in LTR equation 5-41 is lbs/ft3, as stated therein, or should it be lbs/in3 to be consistent with other terms in the equation, and if so please correct.

(i) Define unit for Fy in equations (on LTR p81) for von Mises yield criterion ss.

revision of Section 5.8.2.2.1 A-47 This information has been withheld due to its proprietary nature.

Explanation provided.

Response

Provided in ERR

- CLOSED

22 Information Need Outcomes and GEH Commitments Status A-48 With reference to LTR Section 5.11 Design of Steel-Plate Composite Connections, clarify how the related regulatory guidance position C.11.5 in RG 1.243, Revision 0, is incorporated, or will be incorporated.

Explanation provided.

Response

Provided in ERR

- CLOSED A-49 This information has been withheld due to its proprietary nature.

Section 5.11 to be updated and figure added to this section

Response

Provided in ERR

- CLOSED A-50 In LTR Section 5.13, confirm that ANSI/UL 263 (reference 9-70) will not be used, as was indicated in an earlier audit meeting, and all references to ANSI/UL 263 (reference 9-70) will be deleted from the LTR. Also, identify the applicable RG stated therein that is intended to be used in the description, at the bottom of LTR page 83, for limit state (i) for elements serving as fire barriers.

Reference 9-70 will be removed from LTR and all cross-references to ANSI/UL 263 to be deleted from LTR

Response

Provided in ERR

- CLOSED A-51 LTR Section 5.13 related to fire rating and capacity evaluation is based on ANSI/AISC 360, Appendix 4 (which by reference 9-54 is ANSI/AISC 360-22), and not ANSI/AISC N690-18, Appendix N4.

(a) Address the modifications stated in Appendix N4 of the nuclear code ANSI/AISC N690-18 (endorsed in RG 1.243) on the proposed LTR 5.13 provisions based on Appendix 4 of AISC 360-

22.

(b) In LTR Section 5.13.2.1, define the parameter L in equations

Provided in ERR

- CLOSED

24 Information Need Outcomes and GEH Commitments Status (b) Clarify and justify why the requirement in Section N9.1.1(e) of second public review Draft AISC N690-24 is not included in the LTR, especially considering that a maximum reinforcement ratio of 0.10 is included in the LTR for DP-SC modules. If determined to be required, please include in the LTR.

A-55 Clarify how the effect of elevated temperature on the mechanical properties of DP-SC steel materials is determined for design of RB (including CIS) DP-SC structural components (e.g., LTR Section 6.2.2 addresses it for SCCV, and AISC N690-18, NB3.3 (including User Note therein) appears to address the issue).

Likewise, also clarify what temperature limitations for normal and accidental conditions on concrete infill (e.g., LTR Section 6.5.1 appears to address it for SCCV concrete infill).

Sections 5.2.1 and 5.2.2 to be updated accordingly

Response

Provided in ERR

- CLOSED A-57 Similar to the statement in LTR Section 5.3 identified in previous audit question A-32, LTR Section 6.1 related to SCCV, states:

The SCCV DP-SC modules, including the inner and outer faceplates, diaphragm plates, steel headed stud anchors, if needed, and concrete fill are part of the containment pressure boundary. AISC N690-18, Appendix N9, N9.1.1(g), endorsed in RG 1.243, requires that composite action shall be provided between faceplates and concrete using steel anchors in accordance with N9.1.4. (a) Clarify, with supporting bases, the criteria used to determine whether steel headed stud anchors are needed and justify the apparent deviation from AISC N690-18.

(b) If not needed for SCCV and RB (LTR Section 5.3 and audit question A-32) DP-SC modules, justify how the required composite action with concrete infill is achieved for the DP-SC module without headed stud anchors, and since headed anchors were used in the NRIC prototype testing, provide supporting test data that establishes adequate composite action and RAI

Response

Provided in ERR

25 Information Need Outcomes and GEH Commitments Status performance of the DP-SC modules without headed stud anchors, for applicable limit states.

(c) If headed stud anchors are determined to be necessary, please delete the if needed qualifier from LTR Sections 5.3 (see audit question A-32) and 6.1.

A-58 The last bullet on p92 of LTR Section 6.2.1 Concrete Infill, states: The exposure categories in Table CC-2231.7.1-1 are applicable to the BWRX-300 SCCV. The category for corrosion protection of steel materials in DP-SC modules follows those for reinforcement steel. Since the exposure categories are intended to mean exposure of the structural element to the environment or soil and groundwater, clarify if the term concrete in the referenced exposure category (i.e., C) in Table CC-2231.7.1-1 should be replaced with DP-SC structural element in the LTR if the exposure category is to be adapted for DP-SC modules.

Section 6.2.1 wording in last bullet to change in LTR from "concrete" to "DP-SC structural element"

Response

Provided in ERR

- CLOSED A-59 In the first bullet of LTR Section 6.2.2, clarify what the phrase hollow diaphragm plate means, noting that to the staffs understanding the diaphragm plates are solid with holes.

GEH clarified that diaphragm plates are solid with holes for concrete to flow.

Response

Provided in ERR

- CLOSED A-60 LTR Section 6.5 states: The loading criteria provisions outlined in ASME BPVC,Section III, Division 2, Sub-article CC-3200 are applicable to the SCCV and are followed in the analysis of the structure.

(a) Clarify whether the loading criteria provisions should additionally be supplemented the applicable regulatory position(s) in RG 1.136, Revision 4, consistent with corresponding information in LTR Section 4.3. If so, please state so in the LTR, and If not, justify why. (b) Clarify why the cited statement in LTR Section 5.5 is proprietary given the required Section 6.5 will be updated, and prop markings will be removed

Response

Provided in ERR

- CLOSED

26 Information Need Outcomes and GEH Commitments Status loading criteria are directly taken from publicly available construction code and applicable regulatory guidance for concrete containments.

A-61 In LTR Section 6.6, Table 6-1, (a) Clarify if footnote (1) in Table 6-1(a) is correctly stated and should it not be consistent with footnote (1) in Table 6-1(b). If so, please correct.

(b) Clarify if footnote (1) in Tables 6-1(a) and 6-1(b) should be included also against the Primary + Secondary force classification for Steel Plates. If so, please include.

(c) Should it be clarified that for concrete, the allowable stress limit in Tables 6-1(a) and 6-1(b) is allowable compression stress only (concrete tensile strength shall not be relied upon) and shall be reduced if necessary to maintain structural stability to be consistent with CC-3421.1 and CC-3421.2. If so, please add appropriate footnote(s) to the Tables.

(d) Clarify the source and justify the basis of footnote (4) in LTR Table 6-1(a). Also, clarify how ey is calculated.

Section 6.6 will be updated accordingly

Response

Provided in ERR

- CLOSED A-62 LTR Section 6.7.1, defines Tsc = section thickness of SC containment. However, the equations on pages 96-97 use the notation, tsc. The notation used should be consistent.

Provided in ERR

- CLOSED A-69 In LTR Section 6.22, second paragraph, related to ISI of SCCV, since SCCV is currently not addressed in ASME Section XI, clarify whether the statement therein is intended to indicate whether Subsections IWE and IWL (or just IWE) of ASME Section XI will be adapted for ISI of SCCV consistent with the requirements in 10 CFR 50.55a(g) by considering the SC containment components as Class Metal Containment pressure-resisting and pressure-retaining boundary components and their integral attachments. If so, revise the language accordingly.

RAI

Response

Provided in ERR

29 Information Need Outcomes and GEH Commitments Status A-70 In LTR Section 6.23, clarify why the introductory paragraph with the two bullets is marked Proprietary when it is just stating the applicable regulations. Also, in the first bullet, clarify the specific 10 CFR 50, Appendix A criterion that is being addressed (e.g.,

GDC 50).

Proprietary markings in Section 6.23 to be removed and the first bullet will include the GDC being addressed

Response

Provided in ERR

- CLOSED A-71 In LTR Section 7.2.2 through 7.2.5, related to the NRIC prototype testing, clarify the rationale of comparing experimental strengths to design strength (e.g., Mno, Vn ) rather than comparing experimental strength to the calculated nominal strength (e.g., Mn, Vn), considering that the capacity reduction factor is used in design to account for uncertainty related to strength.

RAI

Response

Provided in ERR A-72

[CNSC]The submission noted in Section 5.13 that, all BWRX-300 DP-SC panels are designed to have a fire resistance rating not less than three hours. The submission further discusses different path for obtaining the fire resistance rating - Design by Engineering Analysis and Design by Qualification Testing. Clarify if the project intends to use both methodologies.

OPEN A-73

[CNSC]Under the Design by Engineering Analysis, the submission noted that the design basis fire exposure is as specified in ASTM E119, ANSI/UL 263, or Eurocode 1 (reference 9-71). No reference has been made to actual postulated design fire expected based on expected fuel loads. Clarify and justify how the design basis fire exposure as specified in ASTM E119, ANSI/UL 263 provides bounding scenario for the actual postulated design fire expected based on expected fuel loads.

OPEN A-74

[CNSC]Specific to Canada. Qualification testing regarding fire resistance rating of the assembly references ASTM E119 or OPEN

30 Information Need Outcomes and GEH Commitments Status ANSI/UL 263. In Canada, the National Building Code of Canada requires that the rating of a material, assembly of materials or a structural member that is required to have a fire resistance rating, shall be determined on the basis of the results of tests conducted in conformance with CAN/ULC-S101, Standard Method of Fire Endurance Tests of Building Construction and Materials. Provide clarification on how the testing protocols of ASTM E119 or ANSI/UL 263 compares or differ to CAN/ULC-S101 and how GEH intend to conform to the requirement of CAN/ULC-S101.

A-75 Editorial: Section 1.1 Second bullet should also reference Section 5.0, in addition to Section 6.0 since RB structures are also included in the bullet.

OPEN A-76 Editorial: LTR Section 4.3, p68, Define Seismic Loads (Es) as Safe Shutdown Earthquake (SSE) or Design Basis Event (DBE)

Seismic Loads (Es).

OPEN A-77 Editorial Comments on Draft Revision 2, LTR Chapter 9 -

References:

Reference 9-7 (RG 1.136, Revision 4 publication date is February 2021 and not March 2007 indicated); Refence 9-55 should be cited as published for comment (e.g., AISC N690-XX, Public Review Draft Dated October 9, 2023);

Reference 9-92, Enclosure 2 title needs to be included, e.g.,

NRIC Prototype Test Report, Revision 2.

OPEN A-78 Proprietary Markings...

(a) Why are Sections 5.5, 5.7.1 thru 5.7.7 Proprietary in their entirety when it is generally taken out of publicly available standards AISC 360 and N690-18?

(b) Why are Sections 6.8.1, 6.8.2, 6.8.3, and 6.9 including their subparagraphs Proprietary when they are generally taken directly OPEN

31 Information Need Outcomes and GEH Commitments Status out of ASME Section III, Division 2?

(c) Sections 6.23.1, 6.23.2 and 6.23.3 (including subparts 6.23.3.1 & 6.23.3.2) are marked Proprietary in their entirety.

Justify why these sections are proprietary when they directly use publicly available guidance from NUREG-1800, Section 3.8.1, RG 1.216 and SECY-93-087 Paper to Commission to meet applicable regulatory requirements?

A-79 Please provide GEH document DBR-0079014 as mentioned in response to RAI question 11.

Reference Provided in ERR

- CLOSED A-80 Regarding LTR Revision 2, in Section 3.3 on page 35, there is new information (compared to Revision 1 and Draft Revision 2) added regarding bioshield SC wall and that the bioshield is designed per ANSI/AISC N690 as supplemented by USNRC RG 1.243 in addition to Section 5.12 of this report. Since during the first audit it was reported it was represented that the bioshield wall is a standalone steel structure, for staff clarity, please clarify (1) whether the bioshield wall will be constructed of steel, traditional SC, or DP-SC; and (2) whether or not the bioshield is within or outside the scope of the LTR?

Response

Provided in ERR

- CLOSED

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