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U.S. Nuclear Regulatory Commission Report of Regulatory Audit for Nuscale Power, LLC Seismic Category 1 Equipment and Environment Qualification of Electrical Equipment Specifications
	ML18173A291
Person / Time
Site:	NuScale
Issue date:	10/25/2018
From:	Amadiz M; NRC/NRO/DNRL/LB1
To:	Samson Lee; NRC/NRO/DLSE/LB1
	VERA M/415-5861
References
	Download: ML18173A291 (12)
	v • d • e

October 25, 2018 MEMORANDUM TO: Samuel S. Lee, Chief Licensing Branch 1 Division of Licensing, Siting, and Environment Analysis Office of New Reactors FROM: Marieliz Vera Amadiz, Project Manager /RA/

Licensing Branch 1 Division of Licensing, Siting, and Environment Analysis Office of New Reactors

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSION STAFF REPORT OF REGULATORY AUDIT FOR NUSCALE POWER, LLC: SEISMIC CATEGORY I EQUIPMENT AND ENVIRONMENT QUALIFICATION OF ELECTRICAL EQUIPMENT SPECIFICATIONS On January 6, 2017, NuScale Power, LLC (NuScale) submitted a design certification (DC) application for a small modular reactor (SMR) to the U.S. Nuclear Regulatory Commission (NRC) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17013A229). In a letter dated March 23, 2017, the NRC accepted for docketing the DC application for the SMR design submitted by NuScale (ADAMS Accession No. ML17074A087).

The NRC staff has conducted an initial audit of design specifications for Seismic Category I equipment described in the NuScale DC application, Final Safety Analysis Report (FSAR),

Section 3.9.6, Functional Design, Qualification, and In-service Testing Programs for Pumps, Valves, and Dynamic Restraints, Section 3.10, Seismic and Dynamic Qualification of Mechanical and Electrical Equipment,and Section 3.11, Environmental Qualification of Mechanical and Electrical Equipment. The audit was conducted from November 8, 2017 -

January 31, 2018, in accordance with the audit plan (ADAMS Accession No. ML17307A382).

The purpose of the audit was to: (1) gain a better understanding of the NuScale design; (2) verify FSAR information; (3) identify information that may require docketing to support the basis of the licensing or regulatory decision; and (4) review related documentation and non-docketed information to evaluate conformance with regulatory guidance and compliance with NRC regulations.

NuScale provided acceptable corrective course of action to the observations and the NRC will track the items as confirmatory items, which will need to be completed before the safety evaluation can be advanced beyond phase 6.

CONTACT: Marieliz Vera Amadiz, NRO/DNRL 301-415-5861

S. Lee 2 The NRC staff conducted the audit via access to NuScales electronic reading room and telephone conferences with the applicant. The audit was conducted in accordance with the NRC Office of New Reactors (NRO) Office Instruction, NRO-REG-108, Regulatory Audits (ADAMS Accession No. ML081910260).

The audit report, audit attendee list, and follow-up item list are enclosed with this memorandum.

Docket No.52-048

Enclosures:

1. Audit Report

2. List of Audit Attendees

3. Follow-Up Items List cc: NuScale DC ListServ

ML18173A291 NRO-002 OFFICE NRO/DNRL/LB1: PM NRO/DNRL/LB1: LA NRO/DEI/MEB: BC NRO/DNRL/LB1: PM NAME MVera MMoore TLupold MVera DATE 10/10/2018 10/10/2018 10/12/2018 10/25/2018 U.S. NUCLEAR REGULATORY COMMISSION STAFF REPORT OF REGULATORY AUDIT FOR NUSCALE POWER, LLC; SEISMIC CATEGORY I EQUIPMENT AND ENVIRONMENT QUALIFICATION OF ELECTRICAL EQUIPMENT SPECIFICATIONS NRC AUDIT TEAM:

Tuan Le, Office of New Reactors (NRO) Mechanical Engineer Thomas G. Scarbrough, Sr. Mechanical Engineer Michael Breach, Mechanical Engineer Marieliz Vera Amadiz, Project Manager Sheila Ray, Sr. Electrical Engineer Jorge, Cintron-Rivera, Electrical Engineer

1.0 BACKGROUND

Title 10 of the Code of Federal Regulations (10 CFR), Part 52, Section 47, Contents of applications; technical information, states that:

The application must contain a level of design information sufficient to enable the Commission to judge the applicant's proposed means of assuring that construction conforms to the design and to reach a final conclusion on all safety questions associated with the design before the certification is granted. The information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the [U.S. Nuclear Regulatory Commission] NRC, and procurement specifications and construction and installation specifications by an applicant. The Commission will require, before design certification, that information normally contained in certain procurement specifications and construction and installation specifications be completed and available for audit if the information is necessary for the Commission to make its safety determination.

In conducting the review of the NuScale Power, LLC (NuScale) design certification (DC) application, the NRC staff requested that the applicant make available design specifications for seismic category I equipment. This audit confirms that the provisions of NuScale design control document (DCD) will be properly implemented into the design qualification specifications of these components.

The NRC staff audited the equipment design specifications for active mechanical and electrical equipment in support of its review against SRP section:

Section 3.10, Seismic and Dynamic Qualification of Mechanical and Electrical Equipment.

1 Enclosure 1

Additionally, the NRC staff performed an audit of the electrical equipment qualification in support of its review against the following SRP section:

Section 3.11, Environmental Qualification of Mechanical and Electrical Equipment.

The NRC staff focused the review on the environmental qualification information for containment electrical penetration assemblies (EPAs), pressurizer heater bundles, and containment isolation valves and actuated valves.

The NRC staff provided NuScale with the audit plan documented in the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML17307A382. The NRC staff followed the NRO Office Instruction, NRO-REG-108 (Revision 0), Regulatory Audits, in performing the audit of the NuScale design specifications.

The staff conducted that audit at the NRC office in Rockville, Maryland, from November 8, 2017, through January 31, 2017. Staff members were from the Mechanical Engineering Branch (MEB) of the Division of Engineering and Infrastructure in NRO and the Mechanical Engineering and Inservice Testing Branch, the Electrical Engineering New Reactor and License Renewal Branch, and the Electrical Engineering Operating Reactor and License Renewal Branch of the Division of Engineering in the Office of Nuclear Reactor Regulation (NRR).

2.0 AUDIT RESULTS During this audit, the NRC staff reviewed the design qualification specifications to determine whether they incorporated the provisions specified in the NuScale Final Safety Analysis Report (FSAR).

The NRC staff found that seismic testing provisions specified in the NuScale DCD have not been completely and consistently incorporated into the design specifications. The NRC staff found that design specification EQ-A012-2041 ASME Design Specification for Pressurizer Heater Bundles and DCD Tier 2 Section 3.10 Seismic and Dynamic Qualifications of Mechanical and Electrical Equipment do not address the seismically induced shock loads for the seismic qualifications of reactor pressure vessel (RPV) and pressurizer (PZR), as identified in the question number 15 of the enclosure. The additional design information would need to be included in the design documents and made available for audit, such that the NRC staff can reach a conclusion regarding the specification-related provision in 10 CFR 52.47, Contents of applications; technical information.

Below are the provisions of the DCD that have not been incorporated into the affected design specifications. The provisions are:

1. Application of input motion In accordance with FSAR Tier 2, Section 3.10.2.1:

Intended for the seismic and dynamic portion of the loads, the test input motion should be applied to one vertical axis and one principal horizontal axis (or two orthogonal horizontal axes) simultaneously, unless it can be demonstrated that the equipment response in the vertical direction is not sensitive to the vibratory motion in the horizontal direction, and vice versa. The time phasing of the inputs in the vertical and horizontal directions must be such that a purely rectilinear 2

resultant input is avoided. An acceptable alternative is to test with vertical and horizontal inputs in-phase, and then repeat the test with inputs 180 degrees out-of phase. In addition, the test must be repeated with the equipment rotated 90 degrees horizontally.

2. Test Response Spectra In accordance with FSAR Tier 2, Section 3.10.1.2:

The test response spectrum (TRS) and required response spectrum (RRS) for the seismic qualification are also identified in the equipment qualification record file (EQRF). The RRS is bounded by the TRS to demonstrate the conservative qualification of equipment.

3. 5(OBE) +1 SSE or 2 SSE Requirement In accordance with FSAR Tier 2, Section 3.10.2.1:

The testing also simulates the effects of aging, such as the fatigue effects of five OBEs plus the loadings associated with normal operation for the design life of the equipment prior to simulating the effects of an SSE, which is equivalent to two SSEs, with 10 stress cycles each, per Section 3.10.1.1.

4. Seismic Testing Requirement In accordance with FSAR Tier 2, Section 3.10.2.1:

Seismic qualification of mechanical and electrical equipment by testing is performed in accordance with the requirements of IEEE 344-2004. For equipment qualified by testing, the test simulates normal loadings, such as thermal and flow induced loads, concurrently with the seismic and other dynamic loadings. The loads include forces imposed by piping onto the equipment. The survival and operability of the equipment is verified during and after the testing.

In general, the NRC staff found that the design specifications for the actuated valves are not complete. The design specifications did not completely incorporate the provisions specified in the FSAR. The NRC staff prepared questions on the design specifications for actuated valves missing some or all of the aforementioned provisions of the DCD and provided those questions to NuScale. In regard to the environmental qualification the NRC staff found discrepancies between design specification documentation and the FSAR Tier 2 information related to the environmental qualification of the Electrical Penetration Assemblies (EPAs). These discrepancies are enumerated in Enclosure 3 of this memorandum.

DOCUMENTS REVIEWED

1. NuScale Design Specification, EQ-A010-2224, ASME Design Specification for Secondary Side Containment Isolation Valves, Revision 0.

2. NuScale Design Specification, EQ-A010-2235, ASME Design Specification for Primary Systems Containment Isolation Valves, Revision 0.

3. NuScale Design Specification, EQ-B010-3227, ASME Design Specification for CVCS 3

Class 3 Valves, Revision 0, dated June 1, 2017.

4. NuScale Design Specification, EQ-B020-2140, ASME Design Specification for Emergency Core Cooling System Valves, Revision 2.

5. NuScale Design Specification, EQ-B030-2258, ASME Design Specification for Decay Heat Removal System Actuation Valves, Revision 0.

6. NuScale Design Specification, EQ-A012-2041, ASME Design Specification for Pressurizer Heater Bundles, Revision 0.

7. NuScale Design Specification, EQ-A013-5418, ASME Design Specification for CNV Electrical Penetration Assemblies, Revision 0.

8. NuScale Design Specification, EQ-C020-3263, Condensate and Feedwater System Regulating Valve Equipment Requirement Specification, Revision 0.

9. NuScale Design Specification, EQ-C020-3445, Feedwater System Check Valve Equipment Requirement Specification, Revision 0.

10. NuScale Design Specification, EQ-A014-4255, ASME Design Specification for Thermal Relief Valves, Revision 0.

4

LIST OF ATTENDEES November 8, 2017 - January 31, 2017 NRC Staff

Participants:

Tuan Le, NRO Mechanical Engineer Thomas G. Scarbrough, Sr. Mechanical Engineer Michael Breach, Mechanical Engineer Marieliz Vera Amadiz, Project Manager Sheila Ray, Sr. Electrical Engineer Jorge, Cintron-Rivera, Electrical Engineer NuScale (and other support organization)

Participants:

Zack Houghton Matt Mallet Vern Pence Wayne Massie Marty Bryan Enclosure 2

List of Questions and Reponses from the Designs Specifications Audit

1. The design specifications should be consistent for actuated valves. (General statement. Details in questions 2 through 6)

NuScale Power, LLC (NuScale) response: The design specifications will be revised.

The U.S. Nuclear Regulatory Commission (NRC) staff found the response acceptable.

2. The application of input motions and qualification by test are described in Design Control Document (DCD) Tier 2, 3.10.2.1. This description is omitted from the design specifications in regard to seismic testing; (EQ-A010-2224, Rev. 0, EQ-A010-2235, Rev. 1, EQ-A010-3227, Rev. 0, EQ-A010-2140, Rev. 0, EQ-A010-2258, Rev. 0)

NuScale response: NuScale indicated that IEEE 344-2004 will be followed and referenced.

The NRC staff found the response acceptable because the design specification will require testing in accordance with Institute of Electrical and Electronics Engineers (IEEE) 344-2004, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations, which is the reference for the application of input motions in the DCD.

3. Where is the test response spectra (TRS) included? (This applies to the following documents; (EQ-A010-2224, Rev. 0, EQ-A010-2235, Rev. 1, EQ-A010-3227, Rev. 0, Rev. 0, EQ-A010-2258, Rev. 0)

NuScale response: Addressed in QME-1 section QR-A7222 The NRC staff found the response acceptable, because following Qualification of Active Mechanical Equipment Used in Nuclear Facilities (QME-1) section QR-A7222 is required by the design specification. The TRS will be furnished from the design control documentation.

4. 5 OBE + 1 SSE and testing - (the requirement is missing from the following documents.;

EQ-A010-2235, Rev. 1, EQ-A010-3227 EQ-A010-2258, Rev. 0)

NuScale response: The design specifications will be revised.

The NRC staff found the response acceptable, because all of the listed document will be revised.

5. Seismic testing required for actuated valves - (the requirement is missing from the following documents; EQ-A010-2224, Rev. 0, EQ-A010-2235, Rev. 1, EQ-A010-3227, Rev. 0, Rev. 0, EQ-A010-2258, Rev. 0)

NuScale response: The design specifications will be revised.

1 Enclosure 3

The NRC staff found the response acceptable, because all of the listed document will be revised.

6. Valve and actuator - The NRC staff stated that, it is unclear what is required for testing, i.e., if both valve and actuator or just the valve.

NuScale response: The design specifications will be revised.

The NRC staff found the response acceptable. (The valve with the actuator must be tested.)

7. Do the non-actuated valves required analysis? Among EQ-A010-4255, EQ-A010-3263 and EQ-A010-3445 only EQ-A010-4255 state that a seismic analysis is required? This appears to be an inconsistency.

NuScale response: The design specifications will be revised.

The NRC staff found the response acceptable. (All of the non-actuated valves will state that a seismic analysis is required)

8. The definition of qualified life in document EQ-A013-5418 R0, ASME Design Specification for Containment EPAs, does not include the Design Basis Event (DBE). How is DBE addressed in the qualification of the EPAs?

NuScale response: Used the 1974 version, will change the definition to make it consistent.

The NRC staff found the response acceptable. (The definition in the design specification will be made consistent with the 1974 version.)

9. EQ-A013-5418 Rev. 0, ASME Design Specification for Containment EPAs. FSAR Tier 2, Section 3.11 describes the applicants approach for conformance to Title 10 of the Code of Federal Regulations (CFR), Section 50.49, Environmental qualification of electric equipment important to safety for nuclear power plants. All equipment subject to the requirements of 10 CFR 50.49 will be qualified in accordance to IEEE 323-1974, IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations. In addition FSAR Tier 2, Table 1.9-2, Conformance with Regulatory Guides, states that NuScale conforms to Regulatory Guide 1.63, Electrical Penetration Assemblies in Containment Structures for Nuclear Power Plants, that endorses IEEE Standard (Std.) 317-1983, "IEEE Standard for Electric Penetration Assemblies in Containment Structures for Nuclear Power Generating Stations." During the audit the NRC staff found discrepancies between the design specification documentation and the FSAR Tier 2 information related to the environmental qualification of the EPAs. The following discrepancies were found during the review:

The definition of qualified life in document EQ-A013-5418 Rev. 0 does not include Design Basis Event (DBE). This definition deviated from the definition of qualified life in IEEE Std. 323-1974. The staff requested the applicant to explain how DBE is addressed in the qualification of the EPAs. In addition, the definition of EPAs 2

does not include terminal/junction boxes, terminal blocks, or splices as defined in IEEE Std. 317-1983.

NuScale response: NuScale will revise the definitions in the design specifications documents to ensure they are consistent with IEEE Std. 323-1974 and IEEE Std. 317-1983 definitions.