ML13161A175
| ML13161A175 | |
| Person / Time | |
|---|---|
| Site: | PROJ0797 |
| Issue date: | 02/12/2013 |
| From: | Bond S M, Sisk R B Westinghouse |
| To: | Document Control Desk, Office of New Reactors |
| References | |
| RIS-12-012 | |
| Download: ML13161A175 (12) | |
See also: RIS 2012-12
Text
\'~O Westinghouse
CA' 4C o -,e 0"4 A.116 2/12/13 Page 1 of 11 Westinghouse
Electric Company 1000 Westinghouse
Drive Cranberry
Township, Pennsylvania
16066 USA wAmeren MISSOURI Ameren Missouri Callaway Energy Center PO Box 620 Fulton, Missouri 65251 U.S. Nuclear Regulatory
Commission
Document Control Desk 11555 Rockville
Pike Rockville, MD 20852 Yourref: ML12319AI81
Our ref: SMR NRC 000001 / ALNRC 00059 February 12, 2013 Subject: Response regarding
the Westinghouse
Small Modular Reactor to NRC Regulatory
Issue Summary (RIS) 2012-12, "Licensing
Submittal
Information
and Design Development
Activities
for Small Modular Reactor Designs" Attached please find the combined Ameren Missouri/Westinghouse
Electric Company LLC ("Westinghouse")
response to the subject NRC Regulatory
Issue Summary (RIS) 2012-12, Licensing Submittal
Irfnbrnzation
and Design. Development
Activities.for
Small Modular Reactor Designs, dated December 28, 2012.Ameren Missouri and Westinghouse
view the Small Modular Reactor (SMR) plant design as both an important
technical
advancement
for the electric power industry and a way to stimulate
fuiture economic growth. Our responses
to the subject RIS include status of the on-going design, engineering, and licensing needs that comprise the Westinghouse
SMR design project's
essential
foundation.
As additional
information
becomes available, we will update the NRC on the status of our activities
and the regulatory
planning needs that-are this RIS' subject.If you have any questions, please do not hesitate to contact the undersigned.
S incereyA/
/Robert B. Sisk Acting Director Licensing, Small Modular Reactors Westinghouse
Electric Company (412)-374-6206
tL~ C-D~-W\i:> ~Scott M. Bond Director, Nuclear Development
Ameren Missouri (573)-676-8519
Enclosure
(9 pages)cc: M.E. Mayfield A. Bradford A. Costa (NRC)(NRC)(NRC)(02013 Westinghouse
Elecltic Company LLC All Rights Reserved'-b- io4.LeC
2/12/13 Page 2 of 11 bcc Page I of I SMRNRC_000001
/ ALNRC 00059 February 12, 2013 bcc: K.J. Jackson J.E. Goossen T.C. Geer M.G. Anness R.S. Blinn W.E. Cummins AW. Harkness R.F. Wright M.R. Godfrey J.C. Sutton J.A. Gresharn E.M. Burns R B. Sisk J.S. Monahan R.A. Rickman K.J. Fair W.L. Baxter A.C. Hefl in W.B. Bobnar W.M. Cryderman R.C. Wink S.A. Maglio (Westinghouse)(Westinghouse)(Westinghouse)(Westinghouse)(Westinghouse)(Westinghouse)(Westinghouse)(Westinghouse)(Westinghouse)(Westinghouse)(Westinghouse)(Westinghouse
CP)(Westinghouse)(Westinghouse)(Westinghouse)(Westinghouse)(WBaxter@ameren.com)(AHeflin @ameren.col)(WBobnar @ameren.con)(PCryderman
@ameren.com)(RWink@ameren.com)(SMaglio@amneren.com)
A 160.5761
2/12/13 Westinghouse
Non-Proprietary
Class 3 Page 3 of 11 Enclosure
Page I of 9 SMR_NRC_000001
/ ALNRC 00059 February 12, 2013 Response regarding
the Westinghouse
Small Modular Reactor to RIS 2012-12, "Licensing
Submittal
Information
and Design Development
Activities
for Small Modular Reactor Designs" Design and Licensing
Submittal
Information
1. When (month and year) are applications
planned for design-related
applications
and what NRC action will be requested (i.e., a CP, DC, DA, or ML, or a COL that does not reference
a DC or DA)?Response: Westinghouse
plans to submit a Design Certification
Application (DCA) in accordance
with 10 CFR Part 52 in [ ]a,c and will request that the NRC review said application
before finally ruling on and issuing the Westinghouse
SMR design design certification.
2. Will the applicants
be organized
into DCWGs? If known, what is the membership
of the DCWG, and which party is the primary point-of-contact
designated
for each DCWG?Response: Yes. Westinghouse
and Ameren Missouri fully support -and plan to use -the design-centered
working group (DCWG) approach described
in RIS 2006-06, New Reactor Standardization
Needed to Support the Design-Centered
Licensing
Review Approach.
Westinghouse
will submit an SMR plant design DCA and Ameren Missouri -depending
on establishing
necessary
agreements
to move the project forward- plans to submit the Reference
Combined Operating
License (R-COL) application
with the intent of applying for multiple SMR units. Current DCWG members are Westinghouse
as the design vendor, and Ameren Missouri as the R-COL applicant.
Additional
Subsequent
COL (S-COL)applicants
-who desire to license the Westinghouse
SMR at their locations
-will be added to the DCWG as they are identified.
Westinghouse
is the primary DCWG point of contact.3. Have protocols
been developed
to provide coordinated
responses.for
requests for additional
information
with generic applicability
to a design center?Response: Yes. The request for additional
information (RAI) process used for the AP1000 plant design certification
is being updated to coordinate
RAI responses
for SMR applications (including
DCWG review). RAIs will be reviewed to determine
if they are either generic or site-specific
COL items. If the RAI(s) are generic, the R-COL applicant
will answer the issue, with the S-COL applicants
taking an "also applies to me" approach.
2/12/13 Westinghouse
Non-Proprietary
Class 3 Page 4 of 11 Enclosure
Page 2 of 9 SMR NRC_00000I
/ ALNRC 00059 February 12, 2013 4. Which applicant
that references
the design will be designated
as the reference
COL applicant, or, alternatively, how will various applications (e.g., CP, DC, or COL applications)
be coordinated
to achieve the desired design-centered
licensing
review approach?Response: Ameren Missouri plans to be the R-COL applicant
for the Westinghouse
SMR plant design.5. When (month and year) will CP, COL, or ESP applications
be submitted
for review? In addition, what are the design, site location, and number of units at each site?Response: Ameren Missouri intends to submit an application
-in accordance
with 10 CFR Part 52 -to the NRC requesting
combined licenses for multiple Westinghouse
SMR units no earlier than []a,c The submittal
schedule depends on establishing
necessary
agreements
to complete the R-COL application.
Said units will be located at the existing Callaway Plant, Unit 1, site in Missouri.6. Are vendors or consultants
assisting
in the preparation
of the application(s)?
If so, please describe their roles and responsibilities
for the design and licensing
activities.
Response: Yes.Vendors are being strategically
used to supplement
the Westinghouse-led
plant design and construction
efforts. Vendors were chosen for their specific expertise
and ability to support the DCA design development
and delivery.
Said vendors are identified
on the Westinghouse
qualified
vendor list and have prior experience
with nuclear projects.
Westinghouse
will provide some Nuclear Steam Supply System (NSSS) components, such as the nuclear fuel.Vendors and consultants
will be contracted
to research, analyze, and write:* Portions of the Environmental
Report* Various site-specific
sections of the Safety Analysis Report* Other combined operating
license application (COLA) sections for Ameren Missouri (possibly)
Vendors will also be used to design various site-specific
Structures, Systems, and Components (SSCs), such as non-safety-related
support systems necessary
for plant operation
and support facilities.
Ameren Missouri will retain overall responsibility
for SMR R-COL application
licensing activities.
Ameren Missouri will conduct activities
related to developing
the SMR application
in accordance
with applicable
Callaway Plant Unit I Operating
Quality Assurance
Manual (OQAM)controls.
This approved quality assurance (QA) program implements
2/1 2/13 Westinghouse
Non-Proprietary
Class 3 Page 4 of 11 Enclosure
Page 2 of 9 SMR_NRC_00000
I / ALNRC 00059 February 12, 2013 4. Which applicant
that references
the design will be designated
as the reference
COL applicant, or, alternatively, how will various applications (e.g., CP, DC, or COL applications)
be coordinated
to achieve the desired design-centered
licensing
review approach?Response: Ameren Missouri plans to be the R-COL applicant
for the Westinghouse
SMR plant design.5. When (month and year) will CP, COL, or ESP applications
be submitted
for review? In addition, what are the design, site location, and number of units at each site?Response: Ameren Missouri intends to submit an application
-in accordance
with 10 CFR Part 52 -to the NRC requesting
combined licenses for multiple Westinghouse
SMR units no earlier than [Ia,c The submittal
schedule depends on establishing
necessary
agreements
to complete the R-COL application.
Said units will be located at the existing Callaway Plant, Unit 1, site in Missouri.6. Are vendors or consultants
assisting
in the preparation
of the application(s)?
If so, please describe their roles and responsibilities
for the design and licensing
activities.
Response: Yes.Vendors are being strategically
used to supplement
the Westinghouse-led
plant design and construction
efforts. Vendors were chosen for their specific expertise
and ability to support the DCA design development
and delivery.
Said vendors are identified
on the Westinghouse
qualified
vendor list and have prior experience
with nuclear projects.
Westinghouse
will provide some Nuclear Steam Supply System (NSSS) components, such as the nuclear fuel.Vendors and consultants
will be contracted
to research, analyze, and write:* Portions of the Environmental
Report* Various site-specific
sections of the Safety Analysis Report* Other combined operating
license application (COLA) sections for Ameren Missouri (possibly)
Vendors will also be used to design various site-specific
Structures, Systems, and Components (SSCs), such as non-safety-related
support systems necessary
for plant operation
and support facilities.
Ameren Missouri will retain overall responsibility
for SMR R-COL application
licensing activities.
Ameren Missouri will conduct activities
related to developing
the SMR application
in accordance
with applicable
Callaway Plant Unit I Operating
Quality Assurance
Manual (OQAM)controls.
This approved quality assurance (QA) program implements
2/12/13 Westinghouse
Non-Proprietary
Class 3 Page 5 of 11 Enclosure
Page 3 of 9 SMRNRC_000001
/ ALNRC 00059 February 12, 2013 requirements.
Vendors, consultants, or suppliers
contracted
to perform safety-related
activities
will be qualified
and maintained
under existing Callaway Plant Unit I OQAM procedures
and controls.7. What is the current status of the development
of the plant design (i.e., conceptual, preliminary, or finalizing)?
Has the applicant
established
a schedule for completing
the design? If so, please describe the schedule.Response: Westinghouse
is using a management
strategy that focuses on completing
parallel design tasks to mitigate potential
emergent or challenging
issues that could threaten completing
the Westinghouse
SMR plant design. [I".C The design is sufficient
to support preparing
and submitting
the DCA. Design work will continue in parallel with the design certification (DC)preparation
and application.
To implement
this management
approach, an integrated
project schedule is being used. Said schedule covers the entire design process. Rolling wave planning is being used -in which detailed activities
are planned for the near-term
two-year period, and major activities
are planned for following
years. This approach is being used to efficiently
plan and address necessary details at the appropriate
time.8. What is the applicant's
current status (i.e., planning, in progress, or complete)for
the qualification
of fuel and other major systems and components?
Has the applicant
established
a schedule for completing
the qualification
testing? If so, please describe the schedule.Response: For design simplification
and licensing
ease, Westinghouse
chose to fuel the Westinghouse
SMR with a shorter version of the highly successful
17x 17 Robust Fuel Assembly (RFA) design. Said design was chosen because of its significant
operating
experience
and excellent
performance.
The fuel itself will be manufactured
and tested at Westinghouse's
fuel plant in Columbia, South Carolina.
Said assemblies
are similar to the fuel assemblies
that power many operating
reactors -as well as the AP10000 reactor -but are shorter in overall length, with an 8-foot active fuel height versus the AP1000 reactor assemblies'
14-foot height. The fuel design also includes optimized
ZIRLOcladding for corrosion
resistance, and other features that mitigate debris-related
failures.Westinghouse
is highly confident
that this fuel will provide the expected Westinghouse
SMR fuel lifetime, while minimizing
unanticipated
outages and fuel failures, and their associated
costs. The fuel management
strategy includes effective
use of uranium; average assembly discharge
burnup is approximately
[ ia,c, which is consistent
with Westinghouse
experience.
]ac Westinghouse
will be seeking an extension
to use [ 1 .The Control Rod Drive Mechanisms (CRDMs) that will operate within the primary system's internal environment
will be based on proven API000 plant technology.
[]BC
Westinghouse
Non-Proprietary
Class 3 2/12/13 Page 6 of 11 Enclosure
Page 4 of 9 SMRNRC_000001
/ ALNRC 00059 February 12, 2013 9. What is the applicant's
status (i.e., planning, in progress, or complete)
in developing
computer codes and models to perform design and licensing
analyses?
Has the applicant
defined principal
design criteria, licensing-basis
events, and other fundamental
design and licensing
relationships?
Has the applicant
established
a schedule for completing
the design and licensing
analyses?
If so, please describe the schedule.Response: Computer codes used to model the Westinghouse
SMR are [Iac. Said codes are being confirmed
to apply to the Westinghouse
SMR design.la)c 10. What is the applicant's
status in designing, constructing, and using thermal-fluidic
testing facilities
and in using such tests to validate computer models? Has the applicant
established
a schedule for the construction
of testing facilities?
If so, please describe the schedule.
Has the applicant
established
a schedule for completing
the thermal-fluidic
testing? If so, please describe the schedule.Response: 1 1. What is the applicant's
status in defining system and component
suppliers (including
fuel), manufacturing
processes, and other major factors that could influence
design decisions?
Has the applicant
established
a schedule for identijfing
suppliers
and key contractors?
If so, please describe the schedule.
Westinghouse
Non-Proprietary
Class 3 2/12/13 Page 7 of 11 Enclosure
Page 5 of 9 SMRNRC_000001
/ ALNRC 00059 February 12, 2013 Response: Westinghouse
has a proven nuclear component
supply chain that will be used to both deliver the Westinghouse
SMR plant design to market and ensure that the necessary
support services are available
to Westinghouse
SMR customers
after startup. Westinghouse
has identified
U.S.manufacturers
as suppliers
for all Westinghouse
SMR components.
Additionally, Westinghouse
will manufacture
and deliver [],, located throughout
the U.S.Qualified
suppliers
were also identified
for the 1 ]a" a key component
in the Westinghouse
SMR. Furthermore, qualified
suppliers
who can factory manufacture
the[I" were identified.
12. What is the applicant's
status in the development
and implementation
of a quality assurance program?Response: To comply with regulatory, industry, statutory, and customer quality requirements
imposed by customers
or regulatory
agencies, Westinghouse
produces items and services under the Westinghouse
Quality Management
System (QMS). The QMS describes
Westinghouse
commitments
to the quality assurance (QA) requirements
of:* IS0 9001* ISO 90003* 10CFR50, Appendix B" ASME NQA- I-1994 Edition" Other national/international
regulatory
requirements
The U.S. NRC reviewed and approved the Westinghouse
QMS.Ameren Missouri will conduct activities
related to developing
the SMR application
in accordance
with applicable
Callaway Plant Unit I Operating
Quality Assurance
Manual (OQAM) controls.
This approved QA program implements
10 CFR 50 Appendix B requirements.
Suppliers
delegated
to perform safety-related
activities
will be qualified
and maintained
under existing Callaway Plant Unit 1 OQAM procedures
and controls.
Ameren Missouri previously
prepared and implemented
a QA program to support the Callaway Plant Unit 2 U.S. EPR COLA project. When appropriate, said QA program will be revised and updated to support the SMR project.
2/1 2/13 Westinghouse
Non-Proprietary
Class 3 Page 8 of 11 Enclosure
Page 6 of 9 SMRNRC-000001
/ ALNRC 00059 February 12, 2013 13. What is the applicant's
status in the development
of probabilistic
risk assessment (PRA) models needed to support applications (e.g., needed for Chapter 19 of safely analysis reports or needed to support risk-informed
licensing
approaches)?
Does the applicant
plan to use the PRA for any risk-informed applications (i.e., risk-informed
technical
specifications, risk-informed
inservice
inspection, risk-informed
categorization
and treatment, risk-informed
inservice
testing, etc.). What are the applicant's
plans for using the PRA models in the development
of the design? At what level will the PRA be prepared, and when will it be submitted
in the application
process?Response: Westinghouse
is underway.
[Westinghouse
plans to document the PRA when []al.As recommended
in Regulatory
Issue Summary 2012-08, Developing
Inservice
Testing and Inservice Inspection
Programs Under 10 CFR Part 52: Ameren Missouri does not plan to submit -as part of the COL application
-a request for risk-informed
in-service
inspection (ISI) or in-service
testing (IST) programs.
RIS 2012-08 recommends
establishing
conventional
ISI or IST programs before preparing
a risk-informed
ISI or IST program. Said recommendation
is based on:* Existing design certification
applications
- The Standard Review Plan acceptance
criteria* Applicable
NUREG documents* That COL applications
conform to the idea that conventional
ISI/IST programs were developed before a risk-informed
program Similarly
-for the same reasons described
above- there are no plans to submit a request for risk-informed technical
specifications, categorization
and treatment, or fire protection
programs.
Any request for risk-informed
applications
will be submitted
after the COL application
is approved.14. What is the applicant's
status in the development, construction, and use of a control room simulator?
Response: Westinghouse
has extensively
tested and delivered
six simulators
to its AP1000 plant customers
and[]a,c
Westinghouse
Non-Proprietary
Class 3 2/12/13 Page 9 of 11 Enclosure
Page 7 of 9 SMRNRC_000001
I/ ALNRC 00059 February 12, 2013 15. What are the applicant's
current staffing levels (e.g., full-time
equivalent
stafi) for the design and testing of the reactor design? Does the applicant
have plans to increase staffing?
If so, please describe future staffing plans.Response: The Westinghouse
SMR development
program is staffed to []8C 16. What are the applicant's
plans on the submittal
of white papers or technical
and topical reports related to the features of its design or the resolution
of policy or technical
issues?Response: Currently
Westinghouse
does not plan to submit any topical reports supporting
the Westinghouse
SMR design certification.
Westinghouse
will discuss technical
reports IC with the NRC before they are submitted.
Westinghouse
expects to support the SMR DCA with a limited number of technical
reports, like those listed above.17. Has the applicant
established
a schedule for submitting
such reports? If so, please describe the schedule.Response:[]a~c 18. Will ESP applicants
seek approval of either "proposed
major features of the emergency
plans" in accordance
or "proposed
complete and integrated
emergency
plans," in accordance
with 10 CFR 52.17(b)(2)(ii)?
Response: Not applicable
because Ameren Missouri does not plan to pursue an early site permit.
2/12/13 Westinghouse
Non-Proprietary
Class 3 Page 10 of 11 Enclosure
Page 8 of 9 SMRNRC_000001
/ ALNRC 00059 February 12, 2013 19. Describe possible interest in the use of the provisions
in Subpart F, "Manufacturing
Licenses," of 10 CFR Part 52, instead of, or in combination
with, other licensing
approaches (e.g., DC or DA).Response: The Westinghouse
SMR will follow the 10 CFR Part 52 approach.
Westinghouse
is not interested
in implementing
the provisions
in Subpart F for "Manufacturing
Licenses." 20. Describe the desired scope of a possible ML and what design or licensing
process would address the remainder
of the proposed nuclear power plant. For example, would the ML address an essentially
complete plant or would it be limited to the primary coolant system that basically
comprises
the integral reactor vessel and internals?
Response: The Westinghouse
SMR will follow the 10 CFR Part 52 approach without implementing
the provisions
in Subpart F for "Manufacturing
Licenses." 21. Describe the expected combination
of manufacturing, fabrication, and site construction
that results in a completed
operational
nuclear power plant. For example, what systems, structures, and components
are being fabricated
and delivered?
Which of these are being assembled
onsite? Which of these are being constructed
onsite ?Response: The Westinghouse
approach to Westinghouse
SMR modules is both evolutionary
and revolutionary.
It is evolutionary
because it extends Westinghouse's
unique experience
in designing
and constructing
the current APIOOO plants. [1a8C Westinghouse
expects [
Westinghouse
Non-Proprietary
Class 3 2/12/13 Page 11 of 11 Enclosure
Page 9 of 9 SMRNRC_000001
/ ALNRC 00059 February 12, 2013 12,C Some non-safety-related
support systems necessary
for plant operation
will be site-specific
and constructed
at the plant site.API000 and ZIRLO are trademarks
or registered
trademarks
of Westinghouse
Electric Company LLC, its affiliates
and/or its subsidiaries
in the United Statcs of Amcrica and may be registercd
in othcr countries
throughout
the world. All rights rescrved.Unauthorized
use is strictly prohibited.
Other names may be trademarks
of their respective
owners.