RAIO-0218-58582, LLC Response to NRC Request for Additional Information No. 323 (Erai No. 9251) on the NuScale Design Certification Application
| ML18040A648 | |
| Person / Time | |
|---|---|
| Site: | NuScale |
| Issue date: | 02/08/2018 |
| From: | Rad Z NuScale |
| To: | Document Control Desk, Office of New Reactors |
| References | |
| RAIO-0218-58582 | |
| Download: ML18040A648 (9) | |
Text
RAIO-0218-58582 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com February 08, 2018 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.
323 (eRAI No. 9251) on the NuScale Design Certification Application
REFERENCE:
U.S. Nuclear Regulatory Commission, "Request for Additional Information No.
323 (eRAI No. 9251)," dated January 08, 2018
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. 9251:
v 11.04-1 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
Anthony Markley, NRC, OWFN-8G9A : NuScale Response to NRC Request for Additional Information eRAI No. 9251 Zackary W. Rad
RAIO-0218-58582 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. 9251
NuScale Nonproprietary Response to Request for Additional Information Docket No.52-048 eRAI No.: 9251 Date of RAI Issue: 01/08/2018 NRC Question No.: 11.04-1 11.4 RAI - Waste Generation Rates and Storage Areas Regulatory Basis:
10 CFR Part 50, Appendix A, GDC 60 and 61 as it relates to understanding the estimated annual volumes of dry and wet solid waste generated by the NuScale design. The staff is seeking this information to support the minimum onsite storage assumption of 30 days, as described by ANSI/ANS-55.1-1992 and BTP 11-3.
Key Issues:
The assumptions in the DCD used in determining the generation of both solid and wet wastes as described in DCD Tables 11.4-2 and 11.4-3 are unclear.
As discussed in the audit, the staff requested the basis of the 450 cubic ft / year of spent resin.
Further review of DCD Table 11.4-2 and 11.4-3 indicated that additional details were required to confirm the applicants assertion of meeting ANSI/ANS-55.1-1992 and BTP 11-3.
Questions:
The staff requests the applicant provide the details of the assumed generation of waste 1.
volumes, and any assumptions used to determining the fractions of waste that would be accounted for in the volumes generated by the applicant.
Additionally, the staff is seeking information to verify the applicant has sufficient space for 2.
storage by identifying the waste storage areas used to store waste within corresponding waste storage areas.
NuScale Response:
Dry Solid Waste FSAR Table 11.4-2 provides the estimated annual volumes of dry solid waste (DSW) for both Class A and Class B/C. Class A dry solid waste consists of items like HVAC filters (650 ft 3),
NuScale Nonproprietary used personal protective equipment (PPE), rags, wipes (3000 ft 3), and discarded tools (9 ft 3).
Items considered to be Class B/C dry solid waste are items such as failed equipment and parts (7 ft 3).
Class A Dry Solid Waste The estimated value for HVAC filter waste volume was derived by reviewing the HVAC systems and estimating the size, quantity and change-out frequency of each filter.
Description Size Quantity Volume (ft 3)
Change-out Frequency (year
-1)
Total Volume (ft 3/yr)
Main Exhaust HEPA Filters 8'x10'x1' (80 ft 3) 8 640 0.5 320 Main Exhaust Pre-Filters 8'x10'x0.33' (24 ft 3) 8 192 1
192 Spent Fuel Pool Exhaust HEPA Filters 8'x10'x1' (80 ft 3) 1 80 0.5 40 Spent Fuel Pool Exhaust Pre-Filters 8'x10'x0.33' (24ft 3) 1 24 1
24 Activated Carbon Filters 10'x12.9'x4.7' (602 ft 3) 1 bank 602 0.1 60 Total Estimated DSW Volume from HVAC Filters 640 The total value of 640 ft 3/year is rounded up to 650 ft 3/year in FSAR Table 11.4-2.
To conservatively estimate the volume of discarded PPE, it is assumed that disposable protective clothing is not used (e.g., OREX or similar). The estimated volume for this category was estimated by considering the refueling outage frequency and estimated personnel usage of PPE.
NuScale Nonproprietary Item Basis Size Frequency Quantity Total Volume (ft 3/year)
Personal PPE (routine) 10 person/day x 1 set/person 0.25 ft 3/set Daily 3650 sets/year 913 Personal PPE (refueling) 20 person x 2 sets/person/day x 30 day refueling 0.25 ft 3/set 6 refuelings per year 2400 sets/refueling 600 Rags, etc.
(routine) 5 person/day x 4 rags/person 0.1 ft 3/rag Daily 7300 rags/year 730 Rags, etc.
(refueling) 10 person x 4 rags/person x 30 day refueling 0.1 ft 3/rag 6 refuelings per year 7200 rags/year 720 Total Estimated DSW Volume from PPE, Rags, etc.
2963 This total value of 2963 ft 3/year is rounded up to 3000 ft 3/year in FSAR Table 11.4-2.
The estimated annual volume of discarded tools is based on a review of the anticipated work and outage frequency.
Items Basis Size Frequency Quantity Total Volume (ft3/year)
Contaminated tools for disposal (routine) 2/month 0.1 ft 3/tool Daily 24 tools/year 2.4 Contaminated tools for disposal (refueling) 10/refueling 0.1 ft 3/tool 6 refuelings per year 60 tools/year 6
Total Estimated DSW Volume from Discarded Tools 8.4 This total value of 8.4 ft 3/year is rounded up to 9 ft 3/year in FSAR Table 11.4-2.
Class B/C Dry Solid Waste The estimate for the annual volume of Class B/C failed equipment is based on a review of plant equipment and typical failure rates.
NuScale Nonproprietary Item Size Frequency Total Volume (ft 3/year)
Small equipment (e.g., pump) 2 ft 3
1 failure/year 2
Small valves (i.e., 2 inch) 0.5 ft 3
2 failures/year 1
Large equipment 6 ft 3
0.1 failures/year 0.6 Large valves (i.e., 6 inch) 1.5 ft 3
2 failures/year 3
Total Estimated DSW Volume from Failed Equipment 6.6 This total value of 6.6 ft 3/year is rounded up to 7 ft 3/year in FSAR Table 11.4-2.
Wet Solid Waste FSAR Table 11.4-3 provides the estimated annual volumes of wet solid waste (WSW) for both Class A and Class B/C. Class A wet solid waste comes from various spent resins, filters, charcoal and other sources. Class B/C wet solid waste is composed of chemical and volume control system (CVCS) and pool cleanup system (PCUS) spent resins and cartridge filters.
FSAR Table 11.4-3 has been revised to reflect the information provided below, and a markup is provided with this response.
Class B/C Wet Solid Waste Details for the estimated annual volume of Class B/C spent resins from the CVCS and PCUS are provided in the NuScale response to RAI 12.02-7 (eRAI 9267).
The volume of wet solid Class B/C wastes from the CVCS and PCUS cartridge filters was estimated by reviewing the CVCS and PCUS design and estimating the filter size and change-out frequency.
Description Filter Radius (ft)
Filter Height (ft)
Filter Volume (ft 3)
Change-out Frequency (year
-1)
Total Volume (ft 3/year)
CVCS filter cartridge 0.54 4
3.7 12 45 PCUS filter cartridge (7 cartridges/filter) 0.25 5
6.9 1
7 Total Estimated WSW Volume from Class B/C Filters 52 Class A Wet Solid Waste Details for the estimated annual volume of Class A spent resins from the liquid radioactive waste system (LRWS) and CVCS deborating demineralizers is provided in the NuScale response to RAI 12.02-21 (eRAI 9271).
Charcoal waste from the LRWS granulated activated carbon (GAC) is estimated by assuming
NuScale Nonproprietary that the two 50 ft 3 carbon beds are replaced every 5 years (typical operating plants replace these every 5-10 years). Assuming a replacement every 5 years yields an effective annual rate of 20 ft 3/year.
Other Class A wet solid waste volume estimates were developed from typical industry experience related to tubular ultrafiltration (TUF) and reverse osmosis (RO) equipment, plus LRWS detergent filter cartridges, oily waste, and mixed waste.
Item Volume (ft 3)
Total Volume (ft 3/year)
LRWS filter 0.3 1
TUF filter membranes 5
5 RO membranes 7
7 Total Estimated Class A WSW Volume from Miscellaneous Sources 13 (20)
Mixed Waste 14 Oily Waste 14 GAC charcoal 50 20 Packaged Waste Storage Space The space available in the Radioactive Waste Building (RWB) to store packaged waste was evaluated using the above solid waste generation rates. The number of storage containers needed to package these estimated annual waste volumes is provided in FSAR Table 11.4-2 and 11.4-3. Oily wastes are stored in the oil separator rooms, and therefore are not included in the estimates for storage space needed in the storage room. Volumes for mixed wastes that can be stored in the oil separator room or shipped offsite are not included in the storage space estimate.
Class B/C Container Storage The required floor space for the Class B/C containers is summarized as follows:
Container Type Number of Containers per Year Floor Space Required per Container (ft 2)
Total Floor Space per Year (ft 2/year)
HIC 6 (resin) 25 150 HIC 1 (filter) 25 25 Drum 1
4 4
Total floor space needed for Class B/C containers 179 Because there is more than 1,000 ft 2 of available space for Class B/C storage on the 71' elevation of the Radioactive Waste Building, there is sufficient storage space to meet the storage assumption of 30 days, as described by ANSI/ANS-55.1-1992 and BTP 11-3.
NuScale Nonproprietary Class A Container Storage The required floor space for the Class A container is summarized as follows:
Container Type Number of Containers per Year Floor Space Required per Container (ft 2)
Total Floor Space per Year (ft 2/year)
HIC 2
25 50 Drum 7
4 28 B25 box 40 23/2 (boxes are double stacked) 460 Total floor space needed for Class A containers 538 Because there is more than 1,000 ft 2 of available space for Class A storage on the 100' elevation of the Radioactive Waste Building, there is sufficient storage space to meet the storage assumption of 30 days, as described by ANSI/ANS-55.1-1992 and BTP 11-3.
Impact on DCA:
FSAR Table 11.4-3 been revised as described in the response above and as shown in the markup provided in this response.
NuScale Final Safety Analysis Report Solid Waste Management System Tier 2 11.4-15 Draft Revision 1 Table 11.4-3: Estimated Annual Volumes of Wet Solid Waste Waste Classification Sources Volume Generated (ft3/yr)
Container Type Container Volume (ft3)
No. of Containers (rounded up)
Class B/C CVCS and PCUS spent resins 450600 8-120 HIC 120112 46 HICs Class B/C cartridge filters from CVCS and PCUS 52 8-120 HIC 120112 1 HIC Class A LRWS spent resins and CVCS deborating spent resins 200170 8-120 HIC 120112 2 HICs LRWS filter cartridges, TUF filter rejects, RO rejects, membranes, and misc.
20 55 gal drum 7.3 3 drums Class A oily waste 14 55 gal drum 7.3 2 drums mixed waste 14 55 gal drum 7.3 2 drums charcoal (from GAC)
(replaced every 5 years) 1020 (avg) 8-120 HIC 120112 1 HIC every five years