ML17268A397

LLC Response to NRC Request for Additional Information No. 141 (Erai No. 8924) on the NuScale Design Certification Application

ML17268A397
Person / Time
Site:	NuScale
Issue date:	09/25/2017
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
References
RAIO-0917-56163
Download: ML17268A397 (7)

Text

RAIO-0917-56163 September 25, 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.

141 (eRAI No. 8924) on the NuScale Design Certification Application

REFERENCE:

U.S. Nuclear Regulatory Commission, "Request for Additional Information No.

141 (eRAI No. 8924)," dated August 05, 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. 8924:

09.05.01-6 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 Carrie Fosaaen at 541-452-7126 or at cfosaaen@nuscalepower.com.

Sincerely, y

Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution: Gregory Cranston, NRC, OWFN-8G9A Samuel Lee, NRC, OWFN-8G9A Anthony Markley, NRC, OWFN-8G9A : NuScale Response to NRC Request for Additional Information eRAI No. 8924 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0917-56163 :

NuScale Response to NRC Request for Additional Information eRAI No. 8924 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

Response to Request for Additional Information Docket No.52-048 eRAI No.: 8924 Date of RAI Issue: 08/05/2017 NRC Question No.: 09.05.01-6 10 CFR 52.47, Contents of applications; technical information, Item (b)(1) requires that a design certification application contain the proposed ITAAC that are necessary and sufficient to provide reasonable assurance that, if inspections, tests, and analyses are performed and acceptance criteria are met, a facility that incorporates the design certification has been constructed and will be operated in accordance with the design certification, the provisions of the AEA and NRC regulations.

In DCD Tier 1, Table 3.7-1, Fire Protection System Inspection, Tests, Analyses, and Acceptance Criteria, Item 2 currently states the following:

Inspection, Tests, No. Design Commitment Acceptance Criteria Analysis 2 The FPS has a sufficient i. An analysis will be i. A report exists and number of fire pumps to performed of the concludes that the fire satisfy the flow demand for as-built fire pumps. pumps for fire protection any FPS connected to the ii. A test will be performed are selected so that the pumps. of the fire pumps. greatest single demand for any FPS connected to the pump is less than or equal to 150 percent of the rated capacity (flow) of the pump.

ii. Each fire pump delivers the design flow to the FPS, while operating in the fire- fighting alignment.

The staff notices that the applicant is not following the guidance in NEI 15-02, Industry Guideline for the Development of Tier 1 and ITAAC Under 10 CFR Part 52, for the use of standard ITAAC no. F04 on Fire Protection System Pump Capacity, and Regulatory Guide 1.189, Regulatory Positon 3.2.1, Fire Protection Water Supply, on the expected fire pumps flow demand.

NuScale Nonproprietary

Also noticed by the staff is an inconsistency between FSAR Tier 1, Table 3.7-1,Item 2 (as shown above) and FSAR Tier 2, Section 9.5.1, Fire Protection Program, which states:

Consistent with NFPA 13, each pump is capable of delivering the demand from the largest sprinkler or deluge system plus an additional 500 gpm for fire hoses.

The applicant is requested to follow NEI 15-02 and correct the inconsistency identified above by revising the ITAAC to read as follows:

Inspection, Tests, No. Design Commitment Acceptance Criteria Analysis 2 The FPS has a sufficient i. An analysis will be i. A report exists and number of fire pumps to performed of the as-built concludes that the fire satisfy the flow demand for fire pumps. pumps can provide the the largest sprinkler or ii. A test will be performed flow demand for the deluge system plus an of the fire pumps. largest sprinkler or additional 500 gpm for fire deluge system plus an hoses assuming failure of additional 500 gpm for the largest fire pump or loss fire hoses assuming of off-site power. failure of the largest fire pump or loss of off-site power.

ii. Each fire pump delivers the design flow to the

[Fire Water Distribution System], while operating in the fire- fighting alignment.

If there is a reason for not following existing guidance, the applicant is requested to fully justify such departure. The FSAR is to be modified accordingly.

NuScale Response:

FSAR Tier 1, Table 3.7-1, Item 2 has been modified consistent with NEI 15-02. Detail has been added, stating that each pump is capable of delivering the demand from the largest sprinkler or deluge system plus an additional 500 gpm for fire hoses. This change also impacts FSAR Tier 2, Table 14.3-2, where FSAR Tier 1, Table 3.7-1, Item 2 is discussed.

Impact on DCA:

The FSAR has been revised as described in the response above and as shown in the markup provided in this response.

NuScale Nonproprietary

NuScale Tier 1 Fire Protection System RAI 09.05.01-6 Table 3.7-1: Fire Protection System Inspections, Tests, Analyses, and Acceptance Criteria No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria 1 Two separate firewater storage tanks An inspection will be performed of the Each firewater storage tank provides a provide a dedicated volume of water as-built firewater storage tanks. usable water volume dedicated for for firefighting. firefighting that is greater than or equal to 300,000 gallons.

2 The FPS has a sufficient number of fire i. An analysis will be performed of i. A report exists and concludes that pumps to satisfy the flow demand for the as-built fire pumps. the fire pumps for fire protection any FPS connected to the ii. A test will be performed of the fire are selected so that the greatest pumpsprovide the design flow pumps. single demand for any FPS requirements to satisfy the flow connected to the pump is less than demand for the largest sprinkler or or equal to 150 percent of the deluge system plus an additional rated capacity (flow) of the 500 gpm for fire hoses assuming pumpcan provide the flow failure of the largest fire pump or loss demand for the largest sprinkler or of off-site power. deluge system plus an additional 500 gpm for fire hoses assuming failure of the largest fire pump or loss of off-site power.

ii. Each fire pump delivers the design flow to the FPS, while operating in the fire-fighting alignment.

3 Safe-shutdown can be achieved A safe-shutdown analysis of the as- A safe-shutdown analysis report exists assuming that all equipment in any built plant will be performed, and concludes that:

one fire area (except for the MCR and including a post-fire safe-shutdown

• Safe-shutdown can be achieved under the bioshield) is rendered circuit analysis. assuming that all equipment in any inoperable by fire damage and that one fire area (except for the MCR and reentry into the fire area for repairs under the bioshield) is rendered and operator actions is not possible. inoperable by fire and that reentry An alternative shutdown capability into the fire area for repairs and that is physically and electrically operator actions is not possible independent of the MCR exists.

• Smoke, hot gases, or fire suppressant Additionally, smoke, hot gases, or fire cannot migrate from the affected suppressant cannot migrate from the fire area into other fire areas to the affected fire area into other fire areas extent that they could adversely to the extent that they could adversely affect safe-shutdown capabilities, affect safe-shutdown capabilities, including operator actions.

including operator actions.

• An independent alternative shutdown capability that is physically and electrically independent of the MCR exists.

4 A plant FHA considers potential fire A FHA of the as-built plant will be A FHA report exists and concludes hazards and ensures the fire performed. that:

protection features in each fire area

• Combustible loads and ignition are suitable for the hazards. sources are accounted for, and

• Fire protection features are suitable for the hazards they are intended to protect against.

Tier 1 3.7-3 Draft Revision 1

Tier 2 NuScale Final Safety Analysis Report RAI 09.01.04-1, RAI 09.05.01-6, RAI 14.03.09-1, RAI, 14.03.09-2, RAI 14.03.09-3 Table 14.3-2: Shared/Common Structures, Systems, and Components and Non-Structures, Systems, and components Based Design Features and Inspections, Tests, Analyses, and Acceptance Criteria Cross Reference ITAAC No. System Discussion DBA Internal/External Radiological PRA & Severe FP Hazard Accident 03.01.01 CRH Testing is performed on the CRE in accordance with RG X 1.197, Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors, Revision 0, to demonstrate that air exfiltration from the CRE is controlled. RG 1.197 allows two options for CRE testing; either integrated testing (tracer gas testing) or component testing. Section 6.4 Control Room Habitability, describes the testing requirements for the CRE habitability program. Section 6.4 provides the maximum air exfiltration allowed from the CRE.

In accordance with Table 14.2-18, a preoperational test using the tracer gas test method demonstrates that the air exfiltration from the CRE does not exceed the assumed unfiltered leakage rate provided in Table 6.4-1: Control 14.3-56 Room Habitability System Design Parameters. Tracer gas Certified Design Material and Inspections, Tests, Analyses, and testing in accordance with ASTM E741 will be performed to measure the unfiltered in-leakage into the CRE with the control room habitability system (CRHS) operating.

03.01.02 CRH The CRHS valves are tested by remote operation to X demonstrate the capability to perform their function to transfer open and transfer closed under preoperational temperature, differential pressure, and flow conditions.

In accordance with Table 14.2-18, a preoperational test demonstrates that each CRHS valve listed in Tier 1 Table 3.1-1 strokes fully open and fully closed by remote operation under preoperational test conditions.

Acceptance Criteria Preoperational test conditions are established that approximate design-basis temperature, differential pressure, and flow conditions to the extent practicable, Draft Revision 1 consistent with preoperational test limitations.

Table 14.3-2: Shared/Common Structures, Systems, and Components and Non-Structures, Systems, and components Based Tier 2 NuScale Final Safety Analysis Report Design Features and Inspections, Tests, Analyses, and Acceptance Criteria Cross Reference (Continued)

ITAAC No. System Discussion DBA Internal/External Radiological PRA & Severe FP Hazard Accident 03.07.02 FP Section 9.5.1, Fire Protection Program, discusses how the X capacity of each FPS pump is adequate to supply the total flow demand at the pressure required at the pump discharge. Section 9.5.1 provides the design flow of the fire pumps.

i. An analysis confirms that the as-built fire pump for fire protection shall be selected so that the greatest single demand for any FPS connected to the pump is less than or equal to 150 percent of the rated capacity (flow) of the pumppumps provide the flow demand for the largest sprinkler or deluge system plus an additional 500 gpm for fire hoses assuming failure of the largest fire pump or loss of off-site power.

ii. In accordance with Table 14.2-25, a preoperational test 14.3-66 demonstrates that each fire pump delivers the design flow to the FPS while operating in the fire-fighting Certified Design Material and Inspections, Tests, Analyses, and alignment.

Acceptance Criteria Draft Revision 1