ML18290A557

LLC Submittal of Supplemental Response to Design Specification Audit Issue No. 92-99

ML18290A557
Person / Time
Site:	NuScale
Issue date:	10/17/2018
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
References
LO-1018-62155
Download: ML18290A557 (13)

Text

LO-1018-62155 October 17, 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 Submittal of Supplemental Response to Design Specification Audit Issue No. 92-99

REFERENCE:

NuScale Power, LLC Submittal of Response to Design Specification Audit Issue No. 92-99, LO-0818-61395, dated September 06, 2018 This supplemental response to Design Specification Audit Issue No. 92-99 supersedes the referenced response in its entirety. It reflects follow-on comments provided in a public telecon with NRC reviewers on September 25, 2018.

During an August 8, 2018 public Design Specification Audit Phase 2 teleconference with NRC Project Manager Marieliz Vera and NRC audit reviewer Jim Strnisha, NuScale Power, LLC (NuScale) discussed a proposed response to Audit Issue No. 92-99. Audit Issue No. 92-99 addresses compliance with Appendix QR-B in ASME QME-1-2007 with exceptions to ASME QME-1 2007, Appendix QR-B for the valve design specifications. As a result of this discussion, NuScale agreed to formally submit its detailed response to Issue 92-99 for further NRC review, identifying the alternatives to ASME QME-1 2007, Appendix QR-B and the basis for their suitability.

The Enclosures to this letter provide the response to the Design Specification Audit Issue No. 92-99, addressing alternatives and basis for each of the following.

1. Identification of activation energy

2. Determination and recording of shelf life for nonmetallics

3. Qualification Report that documents the tests performed on the nonmetallic parts, and

4. Shelf life preservation requirements This response includes FSAR pages incorporating revisions to Table 1.9-2, Section 3.11, and Appendix 3C in redline/strikeout format. NuScale will include these changes as part of a future revision to the NuScale Design Certification Application.

This letter makes no regulatory commitments or revisions to any existing regulatory commitments.

If you have any questions, please feel free to contact Marty Bryan at 541.452.7172 or at mbryan@nuscalepower.com.

Sincerely, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

LO-1018-62155 Page 2 of 2 10/16/18 Distribution: Samuel Lee, NRC, OWFN-8G9A Prosanta Chowdhury, NRC, OWFN-8G9A Marieliz Vera, NRC, OWFN-8G9A Enclosure 1: Alternatives to ASME QME-1 2007 Appendix QR-B Exceptions and Basis for Suitability Enclosure 2: Changes to NuScale Final Safety Analysis Report Table 1.9-2, Conformance with Regulatory Guides Enclosure 3: Changes to NuScale Final Safety Analysis Report Section 3.11.6, Qualification of Mechanical Equipment Enclosure 4: Changes to NuScale Final Safety Analysis Report Section 3.11.8, References Enclosure 5: Changes to NuScale Final Safety Analysis Report Appendix 3C, Section 3C.4, Aging NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

LO-1018-62155 :

Alternatives to ASME QME-1 2007 Appendix QR-B Exceptions and Basis for Suitability NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

LO-1018-62155 Alternatives to ASME QME-1 2007, Appendix QR-B Exceptions and Basis for Suitability NuScale complies with ASME QME-1 2007, Appendix QR-B for the environmental qualification of nonmetallic in active mechanical components with the following exceptions noted below.

1. QR-B5200, Identification and Specification of Qualification Requirements, (g) material's activation energy (in conjunction with one of the above identification methods only and that is based on the material's critical failure mechanism in the intended service).

Alternative:

In accordance with Appendix QR-B5200, nonmetallic material will be qualified to perform its intended functions. Although activation energy might not be used for material identification purposes per QR-B5200, the activation energy is applied to the thermal energy equation for determining material degradation and qualification.

Basis:

ASME QME-1, 2007, Appendix QR-B5200, item (g) requires identification of a material activation energy (in conjunction with one of the above identification methods only and that is based on the material's critical failure mechanism in the intended service). To be clear, NuScale is not taking exception to using the material activation energy as part of the qualification and testing. As stated in FSAR, Tier 2, Appendix 3C, Section 3C.4.2, Aging, NuScale recognizes the Arrhenius Methodology is considered an acceptable method of addressing accelerated aging. The development of the accelerated thermal aging parameters and activation energies are considered based upon the IEEE standards referenced in Section 3C.4.2.

This response addresses NRC question 1 (Identification of activation energy).

2. QR-B5300, Selection of Qualification Methods, last paragraph which states, The shelf life of all nonmetallics, and any applicable storage limitations, should be determined and recorded in the qualification documentation.

Alternative:

Shelf life and storage limitations are documented in accordance with the NQA-1 2008, Requirement 13 and Subpart 2.2, in lieu of ASME QME-1 2007, Appendix QR-B5300. These requirements will not be included in the environmental qualification record file, but will be documented separately.

Basis:

ASME QME-1, 2007, Appendix QR-B5300 states that shelf life needs to be part of the qualification documentation. Shelf life and qualified life are not necessarily linked and the basis for shelf life should be allowed to exist outside of the EQ documentation. This would be a unique requirement that is not imposed on the qualification of electrical equipment.

Linking shelf life to Qualified Life (QL) also is contrary to current industry practice. It can also significantly complicate the establishment and management of EQ replacement activities since the QL (or replacement due dates) become item specific (e.g. each item issued from the warehouse for the same application would likely have a unique due date if shelf life is considered as part of QL.

This response addresses NRC question 2 (Determination and recording of shelf life for nonmetallic).

NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

LO-1018-62155

3. QR-B5500, Documentation, (d) the Qualification Report NuScale has reconsidered this requirement and will comply with providing a qualification report for nonmetallic items that were tested as part of their qualification process.

This response addresses NRC question 3 (Qualification Report that documents the tests performed on the nonmetallic parts).

4. QR-B5500, Documentation, (h) shelf life preservation requirements.

Alternative:

Shelf life preservation requirements are documented in accordance with the NQA-1 2008, Requirement 13 and Subpart 2.2 in lieu of ASME QME-1 2007, Appendix QR-B5500, item h). These requirements will not be included in the environmental qualification record file, but will be documented separately.

Basis:

ASME QME-1, 2007, Appendix QR-B5500 states that shelf life preservation requirements need to be part of the qualification documentation. Shelf life and qualified life are not necessarily linked and the basis for shelf life preservation should be allowed to exist outside of the EQ documentation. This would be a unique requirement that is not imposed on the qualification of electrical equipment.

This response addresses NRC question 4 (Shelf life preservation requirements).

NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

LO-1018-62155 :

Changes to NuScale Final Safety Analysis Report Table 1.9-2, Conformance with Regulatory Guides NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

Table 1.9-2: Conformance with Regulatory Guides (Continued)

Tier 2 NuScale Final Safety Analysis Report RG Division Title Rev. Conformance Sta- Comments Section tus 1.100 Seismic Qualification of Elec- 3 Partially Conforms This RG is applicable except for aspects related 3.9 trical and Active Mechanical to: (1) when site-specific spectra exceed the 3.10 Equipment and Functional certified design spectra (e.g., Position 3.11 Qualification of Active C1.2.1.g); and (2) qualification of new and Mechanical Equipment for replacement equipment in older unresolved 5.2 Nuclear Power Plants safety issue A46 plants (e.g., Position C.1.2.2.j). 14.3 Not applicable to electrical equipment. Site- 3C specific guidance is the responsibility of the COL applicant. RG 1.100 endorses ASME QME-1 2007. NuScale complies with the non-mandatory Appendix QR-B with the following exceptions:

QR-B5200, Identification and Specification of Qualification Requirements, (g) material acti-vation energy.

QR-B5300 Selection of Qualification Methods 1.9-23 for determination and recording of shelf life of nonmetallics.

QR-B5500 Documentation, (h) shelf life preservation requirements.

Appendix 3C describes the exceptions cited.

1.101 Emergency Response Plan- 5 Not Applicable This RG is limited to providing emergency Not Applicable ning and Preparedness for response guidance for co-located licensees. As Nuclear Power Reactors such, this RG is the responsibility of the COL applicant proposing to site a power plant such Conformance with Regulatory Criteria that the definition of co-located is met. Since RG 1.101, Revision 4, is the most current revi-sion that endorses NUREG-0654/FEMA-REP-1, Revision 1, Revision 4 of RG 1.101 is applicable to the extent that it endorses (through NUREG-06554/FEMA-REP-1) the design-specific aspects of NUREG-0696.

Draft Revision 2 1.102 Flood Protection for Nuclear 1 Applicable The design assumes the NPP is located above 2.4 Power Plants the maximum flood height (including wind 3.4 induced wave run-up).

LO-1018-62155 :

Changes to NuScale Final Safety Analysis Report Sections 3.11.6, Qualification of Mechanical Equipment NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

NuScale Final Safety Analysis Report Environmental Qualification of Mechanical and Electrical Equipment accident, and post-accident conditions as required by GDC 4 and 10 CFR 50 Appendix B.

Mechanical equipment qualification verifies the design is capable of functioning during normal, abnormal and accident conditions and includes the effects of the fluid medium (e.g., borated water) on the environmental conditions.

RAI 03.11-13 For mechanical equipment located in a mild environment, acceptable environmental design is demonstrated by the design and purchase specifications for the equipment. The specifications contain a description of the functional requirements for a specific environmental zone during normal environmental conditions and anticipated operational occurrences. The programs identified in Section 3.11.2.1 for verifying that electrical equipment located in a mild environment are capable of performing their intended function will also be applied to mechanical equipment located in a mild environment. For mechanical equipment that must function during or following exposure to a harsh environment, compliance with the environmental design provisions of GDC 4 are generally achieved by demonstrating that the non-metallic parts/components of the equipment suitable for the postulated design basis environmental conditions. Safety-related mechanical equipment that performs an active function during or following exposure to harsh environmental conditions will beis qualified in accordance with ASME QME-1, Appendix QR-B (Reference 3.11-13) as endorsed by RG 1.100, Seismic Qualification of Electrical and Active Mechanical Equipment and Functional Qualification of Active Mechanical Equipment for Nuclear Power Plants, Revision 3 with the following exceptions noted below.

1) Exception to QR-B5200, Identification and Specification of Qualification Requirements, (g) material activation energy.

2) Exception to QR-B5300, Selection of Qualification Methods for determination and recording of shelf life of nonmetallics.

3) Exception to QR-B5500 Documentation, (h) shelf life preservation requirements.

Documentation and the status of the testing and analysis are performed in accordance with the processes presented in Appendix 3.C.

Mechanical equipment located in harsh environmental zones is designed to perform under all appropriate environmental conditions. The primary focus with mechanical equipment is on materials that are sensitive to environmental effects (e.g., seals, gaskets, lubricants, fluids for hydraulic systems, and diaphragms). A list of the mechanical components that contain non-metallic or consumable parts located in harsh environment areas that require EQ is provided in Table 3.11-1.

RAI 12.03-7S1 There can be no environmentally induced debris inside the CNV that could interfere with the proper functioning of the ECCS. This requirement is addressed as a generic requirement to ensure that all SSCs inside the CNV that have the potential to generate debris during the course of an accident have been qualified to demonstrate that no debris is generated or released that could impair the performance of the ECCS.

RAI 03.11-14 Tier 2 3.11-11 Draft Revision 2

LO-1018-62155 :

Changes to NuScale Final Safety Analysis Report Section 3.11.8, References NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

NuScale Final Safety Analysis Report Environmental Qualification of Mechanical and Electrical Equipment 3.11-6 IEEE Std. 7-4.3.2-2003, Standard Criteria for Digital Computers in Safety Systems of Nuclear Power Generating Stations.

3.11-7 IEEE Std. 603-1991, Criteria for Safety Systems for Nuclear Power Generating Stations.

3.11-8 IEEE Std. 572-2006, IEEE Standard for Qualification of Class 1E Connection Assemblies for Nuclear Power Generating Stations.

3.11-9 IEEE Std. 535-1986, IEEE Standard for Qualification of Class 1E Lead Storage Batteries for Nuclear Power Generating Stations.

3.11-10 Topical Report TR-0915-17565-P, Accident Source Term Methodology.

3.11-11 IEEE Std. 383-2003, IEEE Standard for Qualifying Class 1E Electric Cables and Field Splices for Nuclear Power Generating Stations.

3.11-12 IEEE Std. 323-2003, IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations.

3.11-13 American Society of Mechanical Engineers, ASME QME-1-200712, Qualification of Active Mechanical Equipment Used In Nuclear Facilities.

CP2-1289 Tier 2 3.11-13 Draft Revision 2

LO-1018-62155 :

Changes to NuScale Final Safety Analysis Report Appendix 3C, Section 3C.4, Aging NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

Methodology for Environmental Qualification of Electrical and NuScale Final Safety Analysis Report Mechanical Equipment QR-B5200, Identification and Specification of Qualification Requirements, (g) material activation energy.

QR-B5300 Selection of Qualification Methods for determination and recording of shelf life of nonmetallics.

QR-B5500 Documentation, (h) shelf life preservation requirements.

These exceptions are addressed with the following alternatives:

QR-B5200, Identification and Specification of Qualification Requirements, (g) material's activation energy (in conjunction with one of the above identification methods only and that is based on the material's critical failure mechanism in the intended service).

Alternative:

In accordance with Appendix QR-B5200, nonmetallic material will be qualified to perform its intended functions. Although activation energy might not be used for material identification purposes per QR-B5200, the activation energy will be applied to the thermal energy equation for determining material degradation and qualification.Listing the activation energy as a required identification method for commercial grade item dedication purposes has been shown to conflict with existing industry guidance regarding dedication activities (see ADAMS ML18208A208). Identification methods identified per QR-B5200 items (a) through (g) are acceptable for identification purposes for qualification, and no alternative is therefore provided.

QR-B5300, Selection of Qualification Methods, last paragraph which states, The shelf life of all nonmetallics, and any applicable storage limitations, should be determined and recorded in the qualification documentation.

Alternative:

Shelf life and preservation requirements are documented in accordance with the NQA-1 2008, Requirement 13 and Subpart 2.2, in lieu of ASME QME-1 2007, Appendix QR-B5300. These requirements are not included in the environmental qualification record file, but are documented separately.

QR-B5500, Documentation, (h) shelf life preservation requirements.

Alternative:

Shelf life preservation requirements are documented in accordance with the NQA-1 2008, Requirement 13 and Subpart 2.2 in lieu of ASME QME-1 2007, Appendix QR-B5500, item (h).

These requirements are not included in the environmental qualification record file, but are documented separately.

Mechanical and electrical equipment required to perform a design function related to safety located in mild environments is qualified in accordance with the provisions of GDC 4.

For each piece of equipment selected for environmental qualification, the environmental Tier 2 3C-3 Draft Revision 3