MHI's Response To US-APWR DCD RAI No. 459-3331, SRP .

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AkMITSUBISHI HEAVY INDUSTRIES, LTD.16-5, KONAN 2-CHOME, MINATO-KUTOKYO, JAPANDecember 1, 2009Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001Attention:Mr. Jeffery A. CioccoDocket No. 52-021MHI Ref: UAP-HF-09542Subject:MHI's Responses to US-APWR DCD RAI No. 459-3331Reference: 1) "Request for Additional Information No. 459-3331 Revision 1, SRP Section:03.06.02 - Determination of Rupture Locations and Dynamic EffectsAssociated with the Postulated Rupture of Piping, Application Section:3.6.2," dated 9/16/2009.2) "MHI's Responses to US-APWR DCD RAI No. 459-3331," UAP-HF-09488,dated 10/19/2009.With this letter, Mitsubishi Heavy Industries, Ltd. ("MHI") transmits to the U.S. NuclearRegulatory Commission ("NRC") a document entitled "Responses to Request for AdditionalInformation No. 459-3331, Revision 1."Enclosed are the responses to the remaining 9 RAls contained within Reference 1. Elevenadditional RAI responses contained within Reference 1 were previously provided inReference 2.As indicated in the enclosed materials, this document contains information that MHI considersproprietary, and therefore should be withheld from public disclosure pursuant to 10 C.F.R. §2.390 (a)(4) as trade secrets and commercial or financial information which is privileged orconfidential. A non-proprietary version of the document is also being submitted with theinformation identified as proprietary redacted and replaced by the designation"[ ]".This letter includes a copy of thenon-proprietary version (Enclosure 3),identifies the reasons MHI respectfullyin Enclosure 2 be withheld from publicproprietary version (Enclosure 2), a copy of theand the Affidavit of Yoshiki Ogata (Enclosure 1) whichrequests that all materials designated as "Proprietary"disclosure pursuant to 10 C.F.R. § 2.390 (a)(4).Please contact Dr. C. Keith Paulson, Senior Technical Manager, Mitsubishi Nuclear EnergySystems, Inc. if the NRC has questions concerning any aspect of this submittal. His contactinformation is provided below.

Sincerely,Yoshiki Ogata,General Manager- APWR Promoting DepartmentMitsubishi Heavy Industries, LTD.Enclosures:1. Affidavit of Yoshiki Ogata2. Responses to Request for Additional Information No. 459-3331,(Proprietary)Revision I13. Responses to Request for Additional Information No. 459-3331,(Non-Proprietary)Revision 1CC: J. A. CioccoC. K. PaulsonContact InformationC. Keith Paulson, Senior Technical ManagerMitsubishi Nuclear Energy Systems, Inc.300 Oxford Drive, Suite 301Monroeville, PA 15146E-mail: ck-paulson@mnes-us.comTelephone: (412) 373-6466

Enclosure 1Docket No. 52-021MHI Ref: UAP-HF-09542MITSUBISHI HEAVY INDUSTRIES, LTD.AFFIDAVIT1,Yoshiki Ogata, state as follows:1. I am General Manager, APWR Promoting Department, of Mitsubishi Heavy Industries,LTD ("MHI"), and have been delegated the function of reviewing MHI's US-APWRdocumentation to determine whether it contains information that should be withheld frompublic disclosure pursuant to 10 C.F.R. § 2.390 (a)(4) as trade secrets and commercial orfinancial information which is privileged or confidential.2. In accordance with my responsibilities, I.have reviewed the enclosed document entitled"Responses to Request for Additional Information No. 459-3331, Revision 1," and havedetermined that portions of the document contain proprietary information that should bewithheld from public disclosure. All pages contain proprietary information as identifiedwith the label "Proprietary" on the top of the page, and the proprietary information hasbeen bracketed with an open and closed bracket as shown here "[ ]". The first page ofthe document indicates that all information identified as "Proprietary" should be withheldfrom public disclosure pursuant to 10 C.F.R. § 2.390 (a)(4).3.The information identified as proprietary in the enclosed documents has in the past been,and will continue to be, held in confidence by MHI and its disclosure outside the companyis limited to regulatory bodies, customers and potential customers, and their agents,suppliers, and licensees, and others with a legitimate need for the information, and isalways subject to suitable measures to protect it from unauthorized use or disclosure.4.The basis for holding the referenced information confidential is that it describes theunique design and methodology developed by MHI for performing the plant design ofprotection against postulated piping failures.5. The referenced information is being furnished to the Nuclear Regulatory Commission("NRC") in confidence and solely for the purpose of information to the NRC staff.6. The referenced information is not available in public-sources and could not be gatheredreadily from other publicly available information. Other than through the provisions inparagraph 3 above, MHI knows of no way the information could be lawfully acquired byorganizations or individuals outside of MHI.7.Public disclosure of the referenced information would assist competitors of MHI in theirdesign of new nuclear power plants without incurring the costs or risks associated withthe design of the subject systems. Therefore, disclosure of the information contained inthe referenced document would have the following negative impacts on the competitiveposition of MHI in the U.S. nuclear plant market:

A.Loss of competitive advantage due to the costs associated with the developmentof the methodology related to the analysis.B.Loss of competitive advantage of the US-APWR created by the benefits of theapproach to jet expansion modeling that maintains the desired level ofconservatism.I declare under penalty of perjury that the foregoing affidavit and the matters stated thereinare true and correct to the best of my knowledge, information and belief.Executed on this 1st day of December, 2009.Yoshiki Ogata,General Manager- APWR Promoting DepartmentMitsubishi Heavy Industries, LTD.

Enclosure 3UAP-HF-09542Docket No. 52-021Responses to Request for Additional Information No. 459-3331,Revision 1December, 2009(Non-Proprietary)

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION12/11/2009US-APWR Design CertificationMitsubishi Heavy IndustriesDocket No. 52-021RAI NO.:NO. 459-3331 REVISION ISRP SECTION:03.06.02 - Determination of Rupture Locations and DynamicEffects Associated with the Postulated Rupture of PipingAPPLICATION SECTION:3.6.2DATE OF RAI ISSUE:09/16/2009QUESTION NO.: RAI 03.06.02-28This is the supplemental RAI S01 for RAI 71-986, 03.06.02-9(e).In its response to RAI 03.06.02-9(e), MHI referred to its response to RAI 03.06.02-13. However,the staff found the response of RAI 03.06.02-13 not acceptable. Thus, it does not adequatelyaddress the concern of how potential feedback between the jet and nearby reflecting surface(s).The staff requests MHI to address the original RAI item (e). For your convenience, it is updatedand restated below.RAI 03.06.02-9(e)SRP Section 3.6.2, Item 111.2.A provides dynamic analysis criteria and discusses material capacitylimitations for a crushable material type of whip restraint, while SRP Section 3.6.2, Item 111.2.Bdiscusses various methods of analyses. Also, ANSI/ANS-58.2-1988, Section 6.3 presents severaldifferent types of dynamic analysis methods. In US-APWR DCD Tier 2 Section 3.6.2.3, MHIprovided details regarding assumptions in the piping dynamic analysis. The staff noted that someblowdown forces are computed using a steady jet force based on ANS 58.2, while others, suchas those for the Reactor Coolant System (RCS) piping, are computed using an MHI transientanalysis with the MULTIFLEX code. Provide answers to the following:(a) - (d) Not shown here.(e) There does not appear to be any consideration of how potential feedback between the jet andany nearby reflecting surface(s), which can increase substantially the dynamic jet forcesimpinging on the nearby target component and the dynamic thrust blowdown forces on theruptured pipe through resonance, is considered. Provide details (with example, if available) thatdescribe the methods including a description of how feedback amplification of dynamic blowdownforces will be considered for calculating the blowdown forcing functions at break locations andidentify the computer program that will be used, if any.03.06.02-1

ANSWER:The sonic speed of air-liquid two phase flow is decreased because the sonic wave is reflected bydroplets as shown in the figure below. This decrease of sonic speed varies with droplet density,and the sonic speed itself has a distribution in the jet. Then the resonance phenomena itself doesnot occur because the frequency of pressure wave propagation changes by location. Therefore,the feedback of dynamic blowdown forces does not occur and amplification of feedback ofdynamic blowdown forces does not-have to be considered for calculating the blowdown forcingfunctions at break locations.0 .4."--0).3A Seinov and .K,;terin! 224 kPa(D K airplh.I kil-oM: KarphtsS0.2oOkHz (extrapolating)U)00)Eq.(11.9) Eq.(11.7) Eq.(11.2)'0 0.20.40.6Void fraction aImpact on DCDThere is no impact on the DCD.Impact on COLAThere is no impact on the COLA.Impact on PRAThere is no impact on the PRA.03.06.02-2O's-I.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION12/1/2009US-APWR Design CertificationMitsubishi Heavy IndustriesDocket No. 52-021RAI NO.:NO. 459-3331 REVISION ISRP SECTION:03.06.02 - Determination of Rupture Locations and DynamicEffects Associated with the Postulated Rupture of PipingAPPLICATION SECTION:3.6.2DATE OF RAI ISSUE:09116/2009QUESTION NO.: RAI 03.06.02-29This is the supplemental RAI S01 for RAI 71-986 (questions 10-15 were responded to by MHIRef: UAP-HF-08258, dated 11/7/2008), 03.06.02-10.In its response to RAI 03.06.02-10, MHI stated that the loading time duration of a blast wave on astructure neighboring a pipe break would be negligibly small (less than 1/400th of a second), sothat the impulse load acting on the structure (computed by integrating the product of the force andapplication time) would be negligible compared with loads induced by a jet impingement.However, based on the information in the Knowledge Base for Emergency Core Cooling SystemRecirculation Reliability, February 1996, Issued by the rl995-11 .pdf, and ACRS concerns [Wallis - ADAMSML050830344, Ransom -ADAMS ML 050830341], all high pressure and temperature pipesshould be considered as sources of blast waves'with initial energy and mass roughly equal to theexposed volume from a hypothesized break. The subsequent damage from such waves has beenwell documented and is not properly accounted for in ANS 58.2 by the isolated analysis of a purespherically expanding wave. MHI should provide a rigorous and thorough explanation of theirprocedures for estimating the effects of blast waves on nearby SSCs. Also, the staff points outthat blast wave load analyses should be based on three dimensional (or asymmetric) unsteadyanalysis of the flow field, with appropriate representation of the surrounding structures,subsequent to the initial blast. MHI is requested to document their blast wave assessmentapproach(es) in a revised version of the DCD.ANSWER:The propagation of shock wave is affected by the surrounding sonic speed. The sonic speed atthe end of the propagating shock wave is one of air, because downstream of the shock wave isair. It is possible that the blast wave force is evaluated using the pressure difference between theshock wave back and forward, and the velocity of the shock wave. Also, the property of shockwave can be evaluated using the pressure ratio of pipe break opening mouth to atmosphere andinitial energy of pipe break opening mouth.03.06.02-3

This progressive velocity of the shock wave seems to be greater than sonic speed of the air andthe passing time duration of shock wave on a structure is extremely short. Even if the Machnumber of shock wave is equal to 1.0, the passing time duration of shock wave on a barrierstructure having thickness of I m (3.28 ft) is about 1/350'h of a second. Therefore, as for thebarrier structure having natural frequency of less than 5OHz, the passing time duration of shockwave on the barrier structure is a split second.The force on the barrier structure subjected to blast wave is as shown in the figure below. Theresponse of the barrier structure can not follow the shock wave because the shock wave passesthe barrier structure in a split second. The force on the barrier structure subjected to blast wave isless than twice of the static force generated by shock wave. Therefore, the MHl method isconservative even if dynamic response is considered.F-2Valuation modelingReal response.LD-------------0UResponse a Characteristic frequencyTimeImpact on DCDThere is no impact on the DCD.Impact on COLAThere is no impact on the COLA.Impact on PRAThere is no impact on the PRA.03.06.02-4

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION12/11/2009US-APWR Design CertificationMitsubishi Heavy IndustriesDocket No. 52-021RAI NO.:NO. 459-3331 REVISION 1SRP SECTION:03.06.02 - Determination of Rupture Locations and DynamicEffects Associated with the Postulated Rupture of PipingAPPLICATION SECTION:3.6.2DATE OF RAI ISSUE:09/16/2009QUESTION NO.: RAI 03.06.02-30This is the supplemental RAI S01 for RAI 71-986, 03.06.02-11 (a).In its response to RAI 03.06.02-11 (a), MHI cited both ANS 58.2 and their own methodologies(some of which were provided in Attachment 1, and were based on measurements cited inreferences 1-6 in their response to RAI 03.06.02-11). It is not clear exactly which procedureswere being applied. MHI provided a similar response to RAI 03.06.02-12(a). The referencesshowed measurements which clearly contradicted the methodologies in ANS 58.2. MHI istherefore requested to clarify which procedures are used for their design calculations. If differentprocedures are used for different portions of the plant, MHI should clearly state this. MHI isadvised that the methodologies in the ANS 58.2 standard, unless proven conservative, are nolonger considered universally acceptable for modeling jet forces in nuclear power plants.Alternative analysis approaches are acceptable, provided they are substantiated by validbenchmarks (such as the measurements in the citations). MHI is requested to document anyrevisions to their jet loading analysis approach in a revised version of the DCD.ANSWER:MHI uses the analysis or evaluation method as presented in Attachment 1 (MHI Proprietary).Some portions of ANS 58.2 are cited in the Attachment 1.Impact on DCDThere is no impact on the DCD.Impact on COLAThere is no impact on the COLA.Impact on PRA03.06.02-5

There is no impact on the PRA.03.06.02-6

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION12/1/2009US-APWR Design CertificationMitsubishi Heavy IndustriesDocket No. 52-021RAI NO.:NO. 459-3331 REVISION ISRP SECTION:03.06.02 - Determination of Rupture Locations and DynamicEffects Associated with the Postulated Rupture of PipingAPPLICATION SECTION:3.6.2DATE OF RAI ISSUE:09/16/2009QUESTION NO.: RAI 03.06.02-31This is the supplemental RAI S01 for RAI 71-986, 03.06.02-12(a).In its response to RAI 03.06.02-12(a), MHI cited both ANS 58.2 and their own approach forcomputing jet loads. Their approach, based on references 1-6 in their response to RAI 03.06.0211, was described in Attachment 1. It appears that MHI's approach overrided most (if not all) ofANS 58.2. While this may be acceptable (provided the new approach is substantiated byappropriate benchmarks, such as the measurements in MHI's citations), it is unclear what, if any,sections of ANS 58.2 were actually applied. While MHI allowed for varying jet expansion angles(a departure from ANS 58.2), they maintained the assumption that the pressure is uniform overthe jet (section 4.3 of Attachment 1 to their RAI response). This assumption was directlycontradicted by the measurements presented in their citations. The references cited by MHI intheir RAI response (1-6) clearly showed strongly nonuniform pressure distributions which variedwith distance from the pipe break. MHI is requested to justify assuming a uniform pressuredistribution in light of the existing measurements. Should MHI revise their approach to modelingpressure distributions, the revision should be documented in a revised version of the DCD.ANSWER:MHI uses the analysis or evaluation method as presented in Attachment 1. Some of the portion ofANS 58.2 is cited in the Attachment 1.The pressure essentially has non-uniform distributions which varies with distance from the pipebreak as shown in References 1-6 in our response to RAI 03.06.02-11. However, MHI usesmaximum pressure in the non-uniform distribution as uniform distribution conservatively.Impact on DCDThere is no impact on the DCD.Impact on COLA03.06.02-7

There is no impact on the COLA.Impact on PRAThere is no impact on the PRA.03.06.02-8

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION12/112009US-APWR Design CertificationMitsubishi Heavy IndustriesDocket No. 52-021RAI NO.:NO. 459-3331 REVISION ISRP SECTION:03.06.02 - Determination of Rupture Locations and DynamicEffects Associated with the Postulated Rupture of PipingAPPLICATION SECTION:3.6.2DATE OF RAI ISSUE:09/16/2009QUESTION NO.: RAI 03.06.02-32This is the supplemental RAI S01 for RAI 71-986, 03.06.02-12(b).In its response to RAI 03.06.02-12(b), MHI provided a new table of postulated pipe breaklocations to which Leak Before Break (LBB) criteria are to be applied. MHI is requested to expandthe table to include all postulated pipe breaks, along with the properties of the fluids inside andoutside the pipes.ANSWER:The following table shows the properties for piping to which LBB will be applied and other highenergy piping, including properties of internal and external fluids.Impact on DCDThere is no impact on the DCD.Impact on COLAThere is no impact on the COLA.Impact on PRAThere is no impact on the PRA.03.06.02-9

Table for Response to RAI 459-3331, Question 03.06.02-32List of High Energy Lines for Pipe Break Hazard Analysis, Including Properties of Internal and External FluidsNo.SystemSubsystem1 RCSPrimary Loop Hot ID-RCS-2501RA,B,C,D311D37.12311D311DieN )Line No(s)1RCSPrimary Loop Hot Leg31"ID-RCS-2501RA,B,C,D2RCSPrimary Loop Crossover LegPrimary Loop Cold Leg31"ID-RCS-2501RA,B,C,D311"D-RCS-2501RA,B,C,DLop CossverLegRCPrmarPImary Loop Crossover LegPrmary Loop Cold Leg3RCS2RCS3RCS24 RCSPssurInside PipeOutside Pipepsig)3.06SA182 F3166172235Subcooled liquidAir (120, 0)37.123.06SA182 F316LN6172235Subcooled liquidAir (120, 0)37.123.06SA182 F316550.622352235Subcooled liquidSubcooled liquidAir (120, 0)37.123.06SA182 F31631"ID-RCS-2501 RABCD311D37.123.06SA182 F316LN550.62235Subcooled liquid31"1D-RCS-2501 RA,B,C,D311D37.123.06SA182 F316LN550.62235Subcooled liquidSurge Line16RCS-2501R16161.594SA-312 TP3166532235Saturated liquidAir (120, 0)Surge Line16-RCS-2501RA16161.594SA-312 TP316449400Saturated liquidAir (120, 0)A 10-RCS-2501R-BCS-50A,B,C,D, Hot Leg Side1010.751.125SA-312 TP3166172235Subcooled liquidAir (120, 0)8"- RCS -2501RA,B,C,D(COLD LEG)88.6250.906SA-312 TP316550.62235Subcooled liquidAir (120, 0)14-RCS-2501,D14141.406SA-312 TP316550.62235Subcooled liquidAir (120, 0)Pressurizer Spray Line6"-RCS-2501 RB,C66.6250.719SA-312 TP316550.62235Subcooled liquidAir (120, 0)32"-MSS-1532NA,B,C,D32321.496SA333 Gr.6535907Saturated steamAir (130, 0)6Residual RHRSHeat Removal6 RCSysemHo1LegRCSSystem (RHRS) Hot LegBranch Line off tiePpPressureTempMaterial550.65RHRS Cold Leg Branch Lineoff RCSAccumulator System9INominalNmnlDiameter(Inches)SusseRC Presurier Sray ineAir (120,0)10MSSMain Steam Line11CVSAux. Spray Line3-RCS-250133.50.438SA-312 TP316554.62266Subcooled liquidAir (120, 0)12CVSAux. Spray Line3-CVS-256133.50.438SA-312 TP316554.62366Subcooled liquidAir (120, 0)13CVSCharging Line4"-CVS-250144.50.531SA-312 TP316554.62366Subcooled liquidAir (12

This is the supplemental RAI S01 for RAI 71-986 (questions 10-15 were responded to by MHI Ref: UAP-HF-08258, dated 11/7/2008), 03.06.02-10. In its response to RAI 03.06.02-10, MHI stated that the loading time duration of a blast wave on a structure neighboring a pipe break would be negligibly small (less than 1/400th of a second), so

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