ML18351A357
| ML18351A357 | |
| Person / Time | |
|---|---|
| Site: | NuScale |
| Issue date: | 12/17/2018 |
| From: | Rad Z NuScale |
| To: | Document Control Desk, Office of New Reactors |
| References | |
| RAIO-1218-63873 | |
| Download: ML18351A357 (10) | |
Text
RAI0-1218-63873 December 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 Response to NRC Request for Additional Information No.
507 (eRAI No. 9619) on the NuScale Design Certification Application
REFERENCE:
U.S. Nuclear Regulatory Commission, "Request for Additional Information No.
507 (eRAI No. 9619)," dated October 16, 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. 9619:
- 03.02.02-7 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 Paul lnfanger at 541-452-7351 or at pinfanger@nuscalepower.com.
Sincerely,
~::--
Director, Regulatory Affairs NuScale Power, LLC Distribution: Gregory Cranston, NRC, OWFN-8G9A Samuel Lee, NRC, OWFN-8G9A Marieliz Vera, NRC, OWFN-8G9A Enclosure 1: NuScale Response to NRC Request for Additional Information eRAI No. 9619 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. 9619 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.: 9619 Date of RAI Issue: 10/16/2018 NRC Question No.: 03.02.02-7 General Design Criterion (GDC) 1, "Quality Standards and Records"; states that SSCs important to safety being designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety function to be performed. For the NuScale Design Certification, the class break information provides the detail of the boundary of the designed SSC and piping classification; such that the design requirements of ASME Class 1, 2 and 3 component and piping, interface requirements, safety criteria and ASME Section XI inspection program are applied. The staff noted that the information in the DCD Tier 1 Figure 2.1-1 and DCD Tier 2 Figure 6.6-1 do not provide the class break information, and that the design of SSC classification are not well-defined meeting the GDC 1.
As in previously approved standard plant designs certified by 10CFR52, Tier 1 means the portion of the design-related information contained in the generic DCD that is approved and certified by the NRC. The Tier 1 information includes:
- 1. Definitions and general provisions;
- 2. Design descriptions;
- 3. Inspections, tests, analyses, and acceptance criteria (ITAACs);
- 4. Significant site parameters; and
- 5. Significant interface requirements The component/system class break information is requested to be Tier 1. This information needs to be designated as Tier 1 information to support the staff's reasonable assurance NuScale Nonproprietary
finding, and because if changed, it could affect the reliability of the containment, reactor coolant, ECCS, or other coolant systems, and NRC review of any changes will be necessary to ensure the systems will still be able to perform their design function and have not introduced new potential failure mechanism. The identification of comnponent/system class information and the locations were the classifications change, i.e. the break locations define the interface between various portions of the system and meet the above Tier 1 information requirements. Therefore, the staff requests the applicant to include the class break information into the DCD Tier 1.
NuScale Response:
Component/System Class break information (including interfaces) is included in Tier 1 in tabular form (Tier 1, Tables 2.1-1 and 2.2-1). These tables were developed for use with the Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) and are the preferred method for ITAAC closure tracking. Following ITAAC closure, these tables remain Tier 1 certified design material for the life of the plant.
Tier 2 Final Safety Analysis Report (FSAR) Figure 6.6-1 has been revised to clearly indicate the class break information requested by the NRC. This revised figure is now referenced in the Tier 2 Section 14.3 discussion of ITAAC 02.01.01 and ITAAC 02.02.01.
See the attached changes to Tier 1, Table 2.1-1, Tier 2, FSAR Figure 6.6-1 and Tier 2 Table 14.3-1.
Impact on DCA:
Tier 1, Table 2.1-1, Tier 2, FSAR Figure 6.6-1 and Tier 2 Table 14.3-1 have been revised as described in the response above and as shown in the markup provided in this response.
NuScale Nonproprietary
NuScale Tier 1 NuScale Power Module RAI 03.02.02-7, RAI 10.03-1 Table 2.1-1: NuScale Power Module Piping Systems Piping System Description ASME Code High/ Evaluated for Length of Section III Moderate LBB Containment Class Energy Piping (ft)
Outside CNV CNTS reactor coolant system injection line from valves 3 High No 0 CVC-HOV-0331 & CVC-HOV-0330 at CNV nozzle CNV6 up to N/A (see Note 1) and including CVC-CKV-0329 (see Note 2)
CNTS reactor coolant system pressurizer spray line from valves 3 High No 0 CVC-HOV-0325 & CVC-HOV-0324 at CNV nozzle CNV7 up to N/A (see Note 1) and including CVC-CKV-0323 (see Note 2)
CNTS reactor coolant system discharge line from valves 3 High No 0 CVC-HOV-0334 & CVC-HOV-0335 at CNV nozzle CNV13 to NPM (see Note 1) disconnect flange CNTS reactor coolant system RPV high point degasification line 3 High No 0 from valves CVC-HOV-0401 & CVC-HOV-0402 at CNV nozzle (see Note 1)
CNV14 to NPM disconnect flange CNTS containment evacuation line from valves CE-HOV-0001 & N/A No No 0 CE-HOV-0002 at CNV nozzle CNV10 to NPM disconnect flange (see Note 2) (see Note 1)
CNTS flood and drain line from valves CFD-HOV-0022 & N/A No No 0 CFD-HOV-0021 at CNV nozzle CNV11 to NPM disconnect flange (see Note 2) (see Note 1)
CNTS control rod drive mechanism cooling water supply line N/A No No 0 from valves RCCW-HOV-0185 & RCCW-HOV-0184 at CNV nozzle (see Note 2) (see Note 1)
CNV12 to NPM disconnect flange CNTS control rod drive mechanism cooling water return line N/A No No 0 from valves RCCW-HOV-0190 & RCCW-HOV-0191 at CNV nozzle (see Note 2) (see Note 1)
CNV05 to NPM disconnect flange CNTS steam generator #1 feedwater line from valves N/A High No 0 FW-HOV-0137 & FW-CKV-0136 at CNV nozzle CNV1 to NPM (see Note 2) (see Note 1) disconnect flange CNTS steam generator #2 feedwater line from valves N/A High No 0 FW-HOV-0237 & FW-CKV-0236 at CNV nozzle CNV2 to NPM (see Note 2) (see Note 1) disconnect flange CNTS steam generator #1 steam line from CNV nozzle CNV3 to 2 High No 4 and including valves MS-HOV-0101 & MS-HOV-0103 CNTS steam generator #2 steam line from CNV nozzle CNV4 to 2 High No 4 and including valves MS-HOV-0201 & MS-HOV-0203 DHRS #1 lines from steam generator #1 steam line to DHRS 2 High No N/A Passive Condenser ATrain 1 including valves DHR-HOV-0101A and DHR-HOV-0101B DHRS #1 condensate line from DHRS Passive Condenser Train 1 2 High No N/A to CNV nozzle CNV22 DHRS #2 lines from steam generator #2 steam line to DHRS 2 High No N/A Passive Condenser BTrain 2 including valves DHR-HOV-0201A and DHR-HOV-0201B DHRS #2 condensate line from DHRS Passive Condenser Train 2 2 High No N/A to CNV nozzle CNV23 Tier 1 2.1-5 Draft Revision 3
NuScale Tier 1 NuScale Power Module Table 2.1-1: NuScale Power Module Piping Systems (Continued)
Piping System Description ASME Code High/ Evaluated for Length of Section III Moderate LBB Containment Class Energy Piping (ft)
Inside CNV RCS injection line from RPV nozzle RPV11 to CNV nozzle CNV6 1 High No N/A RCS pressurizer spray line from RPV nozzles RPV14 and RPV15 1 High No N/A to CNV nozzle CNV7 RCS discharge line from RPV nozzle RPV12 to CNV nozzle 1 High No N/A CNV13 RCS RPV high point degasification line from RPV nozzle RPV20 1 High No N/A to CNV nozzle CNV14 CNTS flood and drain line from CNV nozzle CNV11 to open pipe 2 No No N/A end at bottom of CNV CRDS control rod drive mechanism cooling water supply line 2 No No N/A from CNV nozzle CNV12 to CRDM heat exchangers CRDS control rod drive mechanism cooling water return line 2 No No N/A from CRDM heat exchangers to CNV nozzle CNV5 SGS steam generator #1 feedwater line from RPV nozzles RPV3 2 High Yes N/A and RPV5 to CNV nozzle CNV1 SGS steam generator #2 feedwater line from RPV nozzles RPV4 2 High Yes N/A and RPV6 to CNV nozzle CNV2 SGS steam generator #1 steam line from RPV nozzles RPV8 and 2 High Yes N/A RPV10 to CNV nozzle CNV3 SGS steam generator #2 steam line from RPV nozzles RPV7 and 2 High Yes N/A RPV9 to CNV nozzle CNV4 DHRS #1 condensate line from CNV nozzle CNV22 to SG #1 2 High No N/A feedwater line DHRS #2 condensate line from CNV nozzle CNV23 to SG #2 2 High No N/A feedwater line Note:
- 1) The listed component is welded directly to the safe end which is part of the containment vessel.
- 2) There is no ASME Class 1, 2, or 3 piping between the listed CNTS valves and the associated CNTS removable spool piece flange. The piping between the valves and the CNTS flange is classified as ASME B31.1.
Tier 1 2.1-6 Draft Revision 3
Draft Revision 3 6.6-10 Tier 2 RAI 03.02.02-7, RAI 10.03-4 CONTAINMENT INSIDE CONTAINMENT SYSTEM CONTAINMENT VESSEL HEAD (CNTS)
NPS 2 CE NPS 2 CONTAINMENT CNV 10 ASME B31.1 ASME B31.1 EVACUATION OPEN TO CNT FLOOD AND DRAIN NPS 2 CFD NPS 2 CONTAINMENT NPS 2 ASME CLASS 2 CNV 11 ASME B31.1 ASME B31.1 FLOOD & DRAIN CONTAINMENT NPS 2 CVC NPS 2 RCS INJECTION ASME B31.1 ASME B31.1 RCS INJECTION RPV 11 NPS 2 ASME CL 1 CNV 6 RCS DISCHARGE NPS 2 NPS 2 CVC NPS 2 RPV 12 NPS 2 ASME CL 1 CNV 13 ASME CL 3 ASME CL 3 ASME B31.1 RCS DISCHARGE RPV / PZR RPV HIGH POINT DEGAS NPS 2 NPS 2 CVC NPS 2 RPV HIGH NPS 2 ASME CL 1 CNV 14 ASME CL 3 ASME CL 3 ASME B31.1 POINT DEGAS RPV 20 RPV / PZR RCS PZR SPRAY NPS 2 CVC NPS 2 ASME B31.1 ASME B31.1 PZR SPRAY NPS 2 ASME CL 1 CNV 7 RPV 14 & 15 CRDS COOLING NPS 2 RCCW NPS 2 CRDM COOLING ASME CL 2 CNV 12 ASME B31.1 ASME B31.1 SUPPLY CRDM HEAT EXCHANGERS CRDS COOLING NPS 2 RCCW NPS 2 CRDM COOLING ASME CL 2 CNV 5 ASME B31.1 ASME B31.1 RETURN SGS STEAM NPS 12 ASME MS NPS 12 ASME CL 2 NPS 12 STEAM RPV 8 CNV 3 B31.1 ASME B31.1 ASME CL 2 NPS 8 RPV 10 NPS 4 FW NPS 4 RPV 3 SGS FEED NPS 5 CNV 1 FEEDWATER ASME B31.1 ASME B31.1 ASME CL 2 STEAM GENERATOR 1 NPS 4 RPV 5 DHR NPS 6 ASME CL 2 DHRS HX #1 CNV 22 DHR COND. DHR NPS 2 ASME CL 2 NPS 2 ASME CL 2 ASME CL 2 SGS STEAM NPS 12 ASME MS NPS 12 NPS 12 STEAM RPV 7 ASME CL 2 CNV 4 B31.1 ASME B31.1 ASME CL 2 NPS 8 RPV 9 SGS FEED NPS 5 NPS 4 FW NPS 4 RPV 4 FEEDWATER ASME CL 2 CNV 2 ASME B31.1 ASME B31.1 STEAM GENERATOR 2 NPS 4 System Legend RPV 6 DHR NPS 6 ASME CL 1 ASME CL 2 DHRS HX #2 CNTS CNV 23 DHR COND. DHR NPS 2 ASME CL 2 Figure 6.6-1: ASME Class Boundaries for NuScale Power Module Piping Systems ASME CL 2 CRDS NPS 2 ASME CL 2 ASME CL 2 ASME CL 3 SGS ASME B31.1 DHR Various Classification Legend Inservice Inspection and Testing of Class 2 and 3 Systems and NuScale Final Safety Analysis Report Components
Tier 2 NuScale Final Safety Analysis Report RAI 03.02.02-7, RAI 06.02.06-22, RAI 06.02.06-23, RAI 08.01-1S1, RAI 08.01-2, RAI 10.02-3, RAI 10.02.03-1, RAI 10.02.03-2, RAI 14.03.03-3S1, RAI 14.03.03-4S1, RAI 14.03.03-6, RAI 14.03.03-6S1, RAI 14.03.03-7, RAI 14.03.03-7S1, RAI 14.03.03-8, RAI 14.03.03-9, RAI 14.03.03-9S1, RAI 14.03.07-1 Table 14.3-1: Module-Specific Structures, Systems, and Components Based Design Features and Inspections, Tests, Analyses, and Acceptance Criteria Cross Reference(1)
ITAAC No. System Discussion DBA Internal/External Radiological PRA & Severe FP Hazard Accident 02.01.01 NPM As required by ASME Code Section III NCA-1210, each ASME Code X Class 1, 2 and 3 component (including piping systems) of a nuclear power plant requires a Design Report in accordance with NCA-3550. NCA-3551.1 requires that the drawings used for construction be in agreement with the Design Report before it is certified and be identified and described in the Design Report. It is the responsibility of the N Certificate Holder to furnish a Design Report for each component and support, except as provided in NCA-3551.2 and NCA-3551.3. NCA-3551.1 also requires that the Design Report be certified by a registered professional engineer when it is for Class 1 components and supports, Class CS core support structures, Class MC vessels and supports, Class 2 vessels 14.3-14 designed to NC-3200 (NC-3131.1), or Class 2 or Class 3 components designed to Service Loadings greater than Design Loadings. A Class Certified Design Material and Inspections, Tests, Analyses, and 2 Design Report shall be prepared for Class 1 piping NPS 1 or smaller that is designed in accordance with the rules of Subsection NC. NCA-3554 requires that any modification of any document used for construction, from the corresponding document used for design analysis, shall be reconciled with the Design Report.
An ITAAC inspection is performed of the NuScale Power Module ASME Code Class 1, 2 and 3 as-built piping system Design Report to verify that the requirements of ASME Code Section III are met.
Acceptance Criteria Draft Revision 3
Table 14.3-1: Module-Specific Structures, Systems, and Components Based Design Features Tier 2 NuScale Final Safety Analysis Report and Inspections, Tests, Analyses, and Acceptance Criteria Cross Reference(1) (Continued)
ITAAC No. System Discussion DBA Internal/External Radiological PRA & Severe FP Hazard Accident 02.01.01 The inventory of the NPM ASME Code Class, 1, 2 and 3 piping (continued) systems verified by ITAAC 02.01.01 is contained in Tier 1 Table 2.1-1: NuScale Power Module Piping Systems. The table provides the following information for each NPM piping system:
- 1) a description of the piping system
- 2) the system containing the piping system
- 3) the ASME code class of the piping system
- 4) the location of the piping system (inside or outside of containment)
Figure 6.6-1: ASME Class Boundaries for NuScale Power Module Piping Systems provides a graphical representation of the NPM piping systems inventoried in Tier 1 Table 2.1-1. Both Figure 6.6-1 and Tier 1 Table 2.1-1 indicate that the NPM systems containing ASME Code Class, 1, 2 and 3 piping systems are CNTS, CRDS, SGS, 14.3-15 DHRS and RCS. Figure 6.6-1 identifies ASME B31.1 piping systems Certified Design Material and Inspections, Tests, Analyses, and which are not verified by ITAAC 02.01.01. The ASME B31.1 piping systems are not described in Tier 1 Table 2.1-1.
Acceptance Criteria Draft Revision 3
Table 14.3-1: Module-Specific Structures, Systems, and Components Based Design Features Tier 2 NuScale Final Safety Analysis Report and Inspections, Tests, Analyses, and Acceptance Criteria Cross Reference(1) (Continued)
ITAAC No. System Discussion DBA Internal/External Radiological PRA & Severe FP Hazard Accident 02.02.01 CVCS As required by ASME Code Section III NCA-1210, each ASME Code X Class 1, 2 and 3 component (including piping systems) of a nuclear power plant requires a Design Report in accordance with NCA-3550. NCA-3551.1 requires that the drawings used for construction be in agreement with the Design Report before it is certified and be identified and described in the Design Report. It is the responsibility of the N certificate holder to furnish a Design Report for each component and support, except as provided in NCA-3551.2 and NCA-3551.3. NCA-3551.1 also requires that the Design Report be certified by a registered professional engineer when it is for Class 1 components and supports, Class CS core support structures, Class MC vessels and supports, Class 2 vessels designed to NC-3200 (NC-3131.1), or Class 2 or Class 3 components designed to service loadings greater than design loadings. A Class 2 Design Report shall be prepared for Class 1 piping NPS 1 or smaller which is 14.3-26 designed in accordance with the rules of Subsection NC. NCA-3554 requires that any modification of any document used for Certified Design Material and Inspections, Tests, Analyses, and construction, from the corresponding document used for design analysis, shall be reconciled with the Design Report.
An ITAAC inspection is performed of the chemical and volume control system (CVCS) ASME Code Class 3 as-built piping system Design Report to verify that the requirements of ASME Code Section III are met.
The inventory of the CVCS ASME Code Class 3 piping systems verified by ITAAC 02.02.01 is contained in Tier 1 Table 2.2-1:
Chemical and Volume Control Piping.
Figure 6.6-1: ASME Class Boundaries for NuScale Power Module Acceptance Criteria Piping Systems provides a graphical representation of the CVCS piping systems inventoried in Tier 1 Table 2.2-1.
Draft Revision 3