ML17361A136

LLC Response to NRC Request for Additional Information No. 279 (Erai No. 9131) on the NuScale Design Certification Application

ML17361A136
Person / Time
Site:	NuScale
Issue date:	12/27/2017
From:	Wike J NuScale
To:	Document Control Desk, Office of New Reactors
References
RAIO-1217-57889
Download: ML17361A136 (5)

Text

RAIO-1217-57889 December 27, 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.

279 (eRAI No. 9131) on the NuScale Design Certification Application

REFERENCE:

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

279 (eRAI No. 9131)," dated November 03, 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. 9131:

14.03.03-6 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 Steven Mirsky at 240-833-3001 or at smirsky@nuscalepower.com.

Sincerely, Jennie Wike Manager, Licensing NuScale Power, LLC Distribution: Gregory Cranston, NRC, OWFN-8G9A Samuel Lee, NRC, OWFN-8G9A Demetrius Murray, NRC, OWFN-8G9A : NuScale Response to NRC Request for Additional Information eRAI No. 9131 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-1217-57889 :

NuScale Response to NRC Request for Additional Information eRAI No. 9131 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.: 9131 Date of RAI Issue: 11/03/2017 NRC Question No.: 14.03.03-6 The NRC regulations in 10 CFR 52.47(b)(1) require that the proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the [Atomic Energy] Act, and the Commission's rules and regulations. NuScale FSAR Tier 2, Section 3.9.6.1, Functional Design and Qualification of Pumps, Valves, and Dynamic Restraints, specifies that the functional design and qualification of safety-related valves is performed in accordance with ASME Standard QME-1-2007, Qualification of Active Mechanical Equipment Used in Nuclear Power Plants, as endorsed in NRC Regulatory Guide (RG) 1.100, Revision 3, Seismic Qualification of Electrical and Active Mechanical Equipment and Functional Qualification of Active Mechanical Equipment for Nuclear Power Plants, with clarifications as described in Section 3.10.2, Methods and Procedures for Qualifying Mechanical and Electrical Equipment and Instrumentation. NuScale FSAR Tier 2, Section 3.10.2 states that ASME QME-1-2007 is used with the exceptions noted in RG 1.100 (Revision 3) for the qualification of active mechanical equipment. Based on experience with the qualification of power-operated valves used in current nuclear power plants, the NRC staff has determined that the qualification process for safety-related valves in new reactors needs to be implemented as specified in the design certification with any modifications to that process reviewed by the NRC staff prior to implementation. This lesson learned from current nuclear power plants is even more significant for the various first-of-a-kind designs planned for the safety-related valves in the NuScale Power Plant. However, the proposed ITAAC related to the qualification of safety-related valves in the NuScale FSAR Tier 1 do not contain specific references to the qualification process for safety-related valves. The NRC staff requests that the NuScale design certification applicant discuss its plans to specify the qualification process for safety-related valves as part of Tier 1 of the NuScale FSAR.

NuScale Response:

NuScale's commitment to the qualification process for safety-related valves is described in the NuScale Nonproprietary

application as follows:

In Tier 1 Table 2.8-2, ITAAC No. 6, Acceptance Criteria, identifies a Functional Qualification Report that "concludes that the safety-related valves listed in Table 2.8-1 are capable of performing their safety-related function under the full range of fluid flow, differential pressure, electrical conditions, and temperature conditions up to and including DBA conditions."

In Tier 2 Table 14.3-1, the discussion for ITAAC No. 02.08.06 states that "the functional qualification of safety-related valves is performed in accordance with ASME QME-1-2007 (or later edition), as accepted in RG 1.100 Revision 3 (or later revision), with specific revision years and numbers as presented in Section 3.9.6.1."

The "Functional Qualification Report" in Tier 1 Table 2.8-2, ITAAC No. 6, Acceptance Criteria has been revised to "Qualification Report" to agree with the definitions provided in ASME QME-1-2007 Section QR-4000 Definitions. The revision to Tier 1 Table 2.8-2, ITAAC No. 6 is attached.

Impact on DCA:

Tier 1, Table 2.8-2 has been revised as described in the response above and as shown in the markup provided in this response.

NuScale Nonproprietary

NuScale Tier 1 Equipment Qualification Table 2.8-2: Equipment Qualification Inspections, Tests, Analyses, and Acceptance Criteria (Continued)

No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria

6. The safety-related valves are A type test or a combination of type A Functional Qualification Report functionally designed and qualified to test and analysis will be performed of exists and concludes that the safety-perform their safety-related function the safety-related valves. related valves listed in Table 2.8-1 are under the full range of fluid flow, capable of performing their safety-differential pressure, electrical related function under the full range of conditions, and temperature fluid flow, differential pressure, conditions, and fluid conditions up to electrical conditions, and temperature and including DBA conditions. conditions, and fluid conditions up to and including DBA conditions.

7. The safety-related relief valves provide i. A vendor test will be performed of i. An American Society of overpressure protection. each safety-related relief valves. Mechanical Engineers Code ii. An inspection will be performed of Section III Data Report exists and each safety-related as-built relief concludes that the relief valves valves. listed in Table 2.8-1 meet the valves required set pressure, capacity, and overpressure design requirements.

ii. Each relief valve listed in Table 2.8-1 is provided with an American Society of Mechanical Engineers Code Certification Mark that identifies the sump recirculation valves set pressure, capacity, and overpressure.

8. The safety-related DHRS passive A type test or a combination of type A report exists and concludes that the condensers have the capacity to test and analysis will be performed of safety-related DHRS passive transfer their design heat load. the safety-related DHRS passive condensers listed in Table 2.8-1 have a condensers. heat removal capacity sufficient to transfer their design heat load.

9. The CNTS containment electrical i. A type test or a combination of i. An EQ record form exists and penetration assemblies located in a type test and analysis will be concludes that the CNTS electrical harsh environment, including performed of the CNTS penetration assemblies listed in associated connection assemblies, containment electrical penetration Table 2.8-1, including associated withstand the design basis harsh assemblies equipment including connection assemblies, performs environmental conditions associated connection assemblies. their function under the experienced during normal ii. An inspection will be performed of environmental conditions operations, AOOs, DBAs, and the containment CNTS electrical specified in the EQ record form for postaccident conditions and performs penetration assembles, including the period of time required to its function for the period of time associated connection assemblies. complete the function.

required to complete the function. ii. The CNTS electrical penetration assemblies listed in Table 2.8-1, including associated connection assemblies, are installed in their design location in a configuration bounded by the EQ record form.

Tier 1 2.8-21 Draft Revision 1