RAIO-0917-55903, LLC Response to NRC Request for Additional Information No. 98 (Erai No. 8894) on the NuScale Design Certification Application
| ML17262B222 | |
| Person / Time | |
|---|---|
| Site: | NuScale |
| Issue date: | 09/19/2017 |
| From: | Rad Z NuScale |
| To: | Document Control Desk, Office of New Reactors |
| References | |
| RAIO-0917-55903 | |
| Download: ML17262B222 (5) | |
Text
RAIO-0917-55903 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com September 19, 2017 Docket No.52-048 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738
SUBJECT:
NuScale Power, LLC Response to NRC Request for Additional Information No.
98 (eRAI No. 8894) on the NuScale Design Certification Application
REFERENCE:
U.S. Nuclear Regulatory Commission, "Request for Additional Information No.
98 (eRAI No. 8894)," dated July 21, 2017 The purpose of this letter is to provide the NuScale Power, LLC (NuScale) response to the referenced NRC Request for Additional Information (RAI).
The Enclosure to this letter contains NuScale's response to the following RAI Question from NRC eRAI No. 8894:
03.11-15 This letter and the enclosed response make no new regulatory commitments and no revisions to any existing regulatory commitments.
If you have any questions on this response, please contact Steven Mirsky at 240-833-3001 or at smirsky@nuscalepower.com.
Sincerely, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution:
Gregory Cranston, NRC, OWFN-8G9A Samuel Lee, NRC, OWFN-8G9A Marieliz Vera, NRC, OWFN-8G9A : NuScale Response to NRC Request for Additional Information eRAI No. 8894 Za Z ckary W. Rad Director Regulatory Affairs
RAIO-0917-55903 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com :
NuScale Response to NRC Request for Additional Information eRAI No. 8894
NuScale Nonproprietary Response to Request for Additional Information Docket No.52-048 eRAI No.: 8894 Date of RAI Issue: 07/21/2017 NRC Question No.: 03.11-15 In FSAR Part 2, Tier 1, Section 2.8, Equipment Qualification, and Section 3.14, Environmental Qualification - Common Equipment, provide ITAACs for qualification of Class 1E electrical equipment located in harsh environment. FSAR Part 2, Tier 1, Section 2.8.1 and 3.14.1 state that the electrical equipment identified in 10 CFR 50.49 are subject to equipment qualification.
10 CFR 52.47(a)(13) requires that the applicant of a standard design certifications to provide the list of electric equipment important to safety that is required by 10 CFR 50.49(d). The applicant or licensee shall prepare a list of electric equipment important to safety covered by 10 CFR 50.49. Equipment important to safety includes, safety-related equipment, nonsafety-related electric equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions, and certain post-accident monitoring equipment. In FSAR Tier 1, ITAAC No. 2 of Table 3.14-2 and ITAAC No. 2 of Table 2.8-2 are described below No.
Design Commitment Inspection, Test, Analyses Acceptance Criteria 2.
The Class 1E electrical equipment located in a harsh environment, including its connection assemblies, withstands the design basis harsh environmental conditions experienced during normal operations, AOOs, DBAs, and post-accident conditions and performs its function for the period of time required to complete the function.
- i. A type test or a combination of type test and analysis will be performed of the Class 1E electrical equipment, including its connection assemblies.
ii. An inspection will be performed of the Class 1E as-built electrical equipment, including its connection assemblies.
- i. An EQ record form exists and concludes that the Class 1E electrical equipment listed in Table 2.8-1, including its connection assemblies, performs its function under the environmental conditions specified in the EQ record form for the period of time required to complete the function.
ii. The Class 1E electrical equipment listed in Table 2.8-1, including its connection assemblies, is installed in its design location in a configuration bounded by the EQ record form.
NuScale Nonproprietary Question:
The staff finds that this ITAAC # 2 only covers safety related equipment (Class 1E) and does not include nonsafety-related electric equipment that could prevent satisfactory accomplishment of safety functions and post-accident monitoring equipment. Based on the information contained in the ITAAC, the staff requests the applicant to provide how the environmental qualification of any equipment important to safetysuch as nonsafety-related electric equipment and post-accident monitoring equipment, is addressed in ITAACs mentioned above.
NuScale Response:
The NuScale design does not require the use of non-safety-related electric equipment to accomplish any safety functions. The NuScale design has no PAM Type A variables because there are no operator actions credited in any FSAR Chapter 15 anticipated operational occurrence, infrequent event, or accident analysis. In addition, no operator actions are credited for the station blackout or anticipated transient without scram analyses. Therefore, in accordance with ITAAC first principles, the NuScale design does not have an ITAAC to qualify non-safety-related or post-accident monitoring instruments.
In a multi-year collaboration between the industry and the NRC, the NRC held numerous public meetings with the industry to discuss the standardization of inspections, tests, analyses and acceptance criteria (ITAAC), with the objective of clarifying the scope of ITAAC required for design certification applications. In May 2015, NEI submitted draft A of Revision 0 of NEI 15-02, "Industry Guideline for the Development of Tier 1 and ITAAC under 10 CFR Part 52" to the NRC for review. Attachment A of NEI 15-02 contains proposed standardized ITAAC Q02 for qualification of class 1E electrical equipment in a harsh environment. The NuScale ITAAC to qualify class 1E electrical equipment in a harsh environment (standardized ITAAC Q02) is included in FSAR Part 2, Tier 1, Table 2.8.1. NEI 15-02, Attachment A does not contain ITAAC to qualifiy nonsafety-related electrical or post-accident monitoring instruments.
In a letter dated April 8, 2016, from Frank Akstulewicz, NRC Director, Division of New Reactor Licensing, Office of New Reactors to Thomas Bergman, Vice-President Regulatory Affairs, NuScale Power, LLC entitled: "TRANSMITTAL OF DRAFT STANDARD INSPECTIONS, TESTS, ANALYSIS AND ACCEPTANCE CRITERIA", ADAMS Accession No. ML16096A12, the NRC issued a draft set of standardized ITAAC "that could be used in your future design certification application using the Title 10 of the Code of Federal Regulations (10 CFR) Part 52, "Licenses, Certifications, and Approvals for Nuclear Power Plants," process." In the letter, the NRC does not propose any modification to the NEI-proposed ITAAC Q02. The letter does not contain ITAAC to qualify non-safety-related electrical or post-accident monitoring instruments.
In a letter dated June 21, 2016, Frank Akstulewicz, NRC Director, Division of New Reactor Licensing, Office of New Reactors to Thomas Bergman, Vice-President Regulatory Affairs, NuScale Power, LLC entitled "TRANSMITTAL OF ADDITIONAL ITEMS INCLUDED IN THE DRAFT STANDARD INSPECTIONS, TESTS, ANALYSIS, AND ACCEPTANCE CRITERIA",
NuScale Nonproprietary ADAMS Accession No. ML16160A109, the NRC added two additional draft standard ITAAC.
The additional ITAAC were not associated with qualification of electrical equipment.
Therefore, NuScale does not propose any modifications to Tier 1 ITAAC.
Impact on DCA:
There are no impacts to the DCA as a result of this response.