ML19018A140

U.S. Nuclear Regulatory Commission Staff Report of Regulatory Audit for Nuscale Power, LLC; Follow-Up Audit of Component Design Specifications

ML19018A140
Person / Time
Site:	NuScale
Issue date:	02/11/2019
From:	Amadiz Marieliz Vera NRC/NRO/DLSE/LB1
To:	Samson Lee NRC/NRO/DLSE/LB1
Vera A M/nro/5861
References
Download: ML19018A140 (55)

Text

February 11, 2019 MEMORANDUM TO: Samuel S. Lee, Chief Licensing Branch 1 Division of Licensing, Siting, and Environmental Assessment Office of New Reactors FROM: Marieliz Vera, Project Manager /RA/

Licensing Branch 1 Division of Licensing, Siting, and Environmental Assessment Office of New Reactors

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSION STAFFS REPORT OF REGULATORY AUDIT FOR NUSCALE POWER, LLC; FOLLOW-UP AUDIT OF COMPONENT DESIGN SPECIFICATIONS On January 6, 2017, NuScale Power, LLC (NuScale) submitted a design certification (DC) application, for a Small Modular Reactor, to the U.S. Nuclear Regulatory Commission (NRC)

(Agencywide Documents Access and Management System (ADAMS) Accession Number ML17013A229). The NRC staff started its detailed technical review of NuScales DC application on March 15, 2017.

The NRC staff conducted an audit of component design specifications associated with the NuScale DC application, Final Safety Analysis Report (FSAR), Sections 3.2, 3.8.2, 3.9.5, 3.9.6, 3.10, and 3.11. The audit was initiated on May 14, 2018, and ran through October 8, 2018, in accordance with the audit plan in ADAMS (ML18114A055).

The purpose of the audit was to: (1) gain a better understanding of the NuScale design; (2) verify 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.

The audit was performed to gain a better understanding of the component design, qualification and classification in support of the NuScale Standard Plant DC application are being performed in accordance with the methodology and criteria described in the NuScale FSAR.

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

S. Lee The NRC staff conducted the audit via access to NuScales electronic reading room. The audit was conducted in accordance with the NRC Office of New Reactors (NRO) Office Instruction NRO-REG-108, Regulatory Audits.

The publicly available version of the audit report is provided as Enclosure 1. The List of Attendees is provided as Enclosure 2 and a List of RAI Questions for the audit is attached.

Docket No.52-048

Enclosures:

As stated cc: NuScale DC ListServ

S. Lee

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSION STAFF REPORT OF REGULATORY AUDIT FOR NUSCALE POWER, LLC; FOLLOW-UP AUDIT OF COMPONENT DESIGN SPECIFICATIONS DATED: February 11, 2019 DISTRIBUTION:

PUBLIC LB1 R/F SLee, NRO MVera, NRO CSmith, NRO TLupold, NRO TLe, NRO CWu, NRO TScarbrough, NRO JHuang, NRO YLaw, NRO MBreach, NRR SLu, NRO RidsNroDnrlLB1 RidsOgcMailCenter RidsOpaMailCenter RidsAcrsAcnwMailCenter ADAMS Accession No.: ML19018A140 *via email NRO-002 OFFICE NRO/DLSE/LB1: PM NRO/DNRL/LB1: LA NRO/DEI/MEB: BC NRO/DLSE/LB1: PM NAME MVera CSmith TLupold MVera DATE 01/18/2019 02/06/2019 12/21/2018 02/11/2019 OFFICIAL RECORD

U.S. NUCLEAR REGULATORY COMMISSION STAFF REPORT OF REGULATORY AUDIT FOR NUSCALE POWER, LLC; FOLLOW-UP AUDIT OF COMPONENT DESIGN SPECIFICATIONS May 14, 2018 - October 8, 2018 NRC Audit Team:

• Tuan Le, NRO Mechanical Engineer (U.S. Nuclear Regulatory Commission (NRC), Audit Lead

• Cheng-Ih (John) Wu, Mechanical Engineer (NRC)

• Thomas G. Scarbrough, Senior Mechanical Engineer (NRC)

• James Strnisha, Mechanical Engineer (NRC)

• Jason Huang, Mechanical Engineer (NRC)

• Yiu Law, Mechanical Engineer (NRC)

• Michael Breach, Mechanical Engineer (NRC)

• Marieliz Vera Amadiz, Project Manager (NRC)

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 the design specifications, as well as design documentation for equipment seismic qualification, environment qualification and component quality group classification (e.g., piping and instrumentation and equipment classification documents) for the NRC staff to confirm the implementation of the provisions in the NuScale Final Safety Analysis Report (FSAR) for the design and qualification of these components.

This information supported the NRC staffs review of the following Standard Review Plan (SRP) sections:

• Section 3.2.1, Seismic Classification, Section 3.2.2, System Quality Group Classification, Enclosure 1

• Section 3.8.2, Steel Containment,

• Section 3.9.5, Reactor Pressure Vessel Internals,

• Section 3.9.6, Functional Design, Qualification, and Inservice 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.

At the NRC office in Rockville, Maryland, from June 1, 2017, through August 29, 2017, staff members from the Mechanical Engineering Branch (MEB) of the Division of Engineering and Infrastructure in the Office of New Reactors (NRO) conducted an initial regulatory audit (Phase

1) of the NuScale design documentation in the NuScale electronic reading room (eRR) for American Society of Mechanical Engineers (ASME) Boiler & Pressure Vessel Code (BPV Code) components, including valves, component supports, equipment seismic qualifications, and component classifications. On January 25, 2018, the NRC staff issued a report describing its audit of the NuScale design specifications including audit observations and findings as listed in Table 1 of that audit report. See Agencywide Documents Access and Management System (ADAMS) Accession Number ML18018A234.

On April 24, 2018, the NRC staff provided NuScale with a plan to facilitate the Phase 2 follow-up audit of the design specifications to resolve the initial audit findings (ML18114A055). The staff performed the follow-up audit from May 14, 2018, through October 11, 2018, at the NRC office in Rockville, Maryland, by the review of NuScale design documentation available in the eRR.

The staff followed the NRO Office Instruction, NRO-REG-108 (Revision 0), Regulatory Audits, in performing the follow-up audit of the NuScale design specifications.

2.0 AUDIT RESULTS During the Phase 1 initial audit, the NRC staff reviewed the design specifications for several types of components to be used in the NuScale nuclear power plant. The staff reviewed the design specifications to determine whether they incorporated the provisions specified in the NuScale FSAR. Table 1 of the initial audit report specified the NRC staffs findings on the NuScale design specifications.

During this Phase 2 follow-up audit, the NRC staff reviewed the design specifications for the components to be used in the NuScale nuclear power plant to confirm that the findings from the initial audit had been addressed. Based on its review of the updated design specifications, the staff found that most of the findings from the initial audit have been resolved. A total of 112 audit observation items were reviewed in this Phase 2 of the audit, 3 remain open, 30 are confirmatory, and the remainder are closed, as summarized in Table 1 of this report. RAI 9619 Question 03.02.02-7, was generated to address the class break information (Table 1 audit items1, 109 and 110). The staff closed numerous audit items based on: (1) acceptable responses by NuScale that resolved the issue, (2) NuScale having provided an ancillary RAI response that addressed the issue raised in Phase 1 of the audit, (3) the issue was reviewed in another audit, or (4) the NRC staff generated an RAI to formally track the resolution of the item.

For the items identified as confirmatory, NuScale will implement changes to design

specifications or FSAR. After these changes are completed, the staff will confirm, as appropriate, that the issue has been properly addressed. The staff also identified certain items that will remain open for a future audit, because the technical information and analyses were not available for review during this audit. The Table 1 audit items 4B, 103 and 104 are open since the stress and fatigue evaluations were not available for review and will need to be reviewed in a future audit. Table 1 (Attachment) indicates the resolution of the audit findings and those items that remain open or confirmatory.

NuScale is to complete the planned changes to the applicable documents for the confirmatory items prior to completion of the NRC staffs review of the NuScale design certification application. The NRC staff will review the revised documents to confirm that the issue has been appropriately addressed once NuScale notifies the NRC, by letter, that the changes to the applicable documents have been implemented. For other documents, NuScale may incorporate appropriate changes in response to this audit in accordance with its Quality Assurance (QA) program. The NRC staff accepted the NuScale QA program by a letter dated September 22, 2016 (ML16196A391).

The NRC staff will arrange a future audit to address the technical information and analyses that were not available for review during this audit.

3.0 DOCUMENTS REVIEWED

1. NuScale Design Specification, EQ-A010-2224, ASME Design Specification for Secondary Side Containment Isolation Valves, Revision 1, dated December 20, 2017.

2. NuScale Design Specification, EQ-A010-2235, ASME Design Specification for Primary Systems Containment Isolation Valves, Revision 2, dated December 19, 2017.

3. NuScale Design Specification, EQ-A011-2179, ASME Design Specification for Reactor Safety Valves, Revision 0, dated May 24, 2016.

4. NuScale Design Specification, EQ-A014-4255, ASME Design Specification for Thermal Relief Valves, Revision 0, dated August 18, 2016.

5. NuScale Design Specification, EQ-B010-3227, ASME Design Specification for CVCS Class 3 Valves, Revision 0, dated June 1, 2017.

6. NuScale Design Specification, EQ-B020-2140, ASME Design Specification for Emergency Core Cooling System Valves, Revision 3, dated February 14, 2018.

7. NuScale Design Specification, EQ-B030-2258, ASME Design Specification for Decay Heat Removal System Actuation Valves, Revision 1, dated January 29, 2018.

ATTACHMENT Table 1: NuScale Design Specification Audit Question Status Item # Design NRC Summary NuScale Response Status NRC Response Spec/Dwg Reviewer Open or Closed 1 Various Le Piping and Instrument NuScale P&IDs do not Closed The staff requests to Drawings (P&IDs) did not specifically identify class have uploaded P&IDs have class break breaks in design drawings; that have class break information. The U.S. however, ASME Class is information.

Nuclear Regulatory identified in pipe Commission (NRC) staff classification. In each The staff finds that the (hereafter referred to as the P&ID. applicant provided the staff), requests the applicant information of class to identify the class breaks in breaks in ER-A013-4785 the following P&IDs and Rev. 0 - Figure 7.1, and provide the staff with the is acceptable.

updated P&IDs for review:

RAI 9619 addresses this item. This item is closed.

1a Dwg. NP12 Le P&IDs no class break info. See answer above Closed The staff requests to A013-M-PD- have uploaded P&IDs 3450, CNT with class break Rev.0. information. The information of class breaks in ER-A013-4785 Rev. 0 - Figure 7.1, is acceptable.

RAI 9619 addresses this item. This item is closed.

Attachment

1b Dwg. NP12 Le P&IDs no class break info. See answer above Closed The staff requests to A014-M-PD- have uploaded P&IDs 3451, SG with class break Rev.0. information. The information of class breaks in ER-A013-4785 Rev. 0 - Figure 7.1, is acceptable.

RAI 9619 addresses this item. This item is closed.

1c Dwg. NP12 Le P&IDs no class break info. See answer above Closed The staff requests to A030-M-PD- have uploaded P&IDs 1504, RCS with class break Rev.0 information. The information of class breaks in ER-A013-4785 Rev. 0 - Figure 7.1, is acceptable.

RAI 9619 addresses this item. This item is closed.

1d Dwg. NP12 Le P&IDs no class break info. See answer above Closed The staff requests to B010-M-PD- have uploaded P&IDs 1021 R0 V7 with class break FINAL information. The information of class breaks in ER-A013-4785 Rev. 0 - Figure 7.1, is acceptable.

RAI 9619 addresses this item. This item is closed.

1e Dwg. NP12 Le P&IDs no class break info. See answer above Closed The staff requests to B020-M-PD- have uploaded P&IDs 1027-S01-Rev2 with class break Signed information. The

information of class breaks in ER-A013-4785 Rev. 0 - Figure 7.1, is acceptable.

RAI 9619 addresses this item. This item is closed.

1f Dwg. NP12 Le P&IDs no class break info. See answer above Closed The staff requests to B030-M-PD- have uploaded P&IDs 1028-S01 with class break information. The information of class breaks in ER-A013-4785 Rev. 0 - Figure 7.1, is acceptable.

RAI 9619 addresses this item. This item is closed.

1g Dwg. NP12-6A- Le P&IDs no class break info. See answer above Closed The staff requests to B200-M-PD- have uploaded P&IDs 1685-Rev 2 with class break information. The information of class breaks in ER-A013-4785 Rev. 0 - Figure 7.1, is acceptable.

RAI 9619 addresses this item. This item is closed.

2 Various Le The staff requests the Yes. RG 1.26, RG 1.29 Closed The response is applicant to confirm that RG used. Procedure 0303- acceptable.

1.26, RG 1.29, and Standard 2109.

ANSI/ANS-58.14 are used in the classification process, if that is the case, reference RG 1.26, RG 1.29, and standard ANSI/ANS-58.14 into P&IDs.

3 ER-A014-4036 Le Doc. ER-A014-4036, SSC The classifications of SG Closed RAI 8901 Question SSC Classification Report for the supports and flow 3.9.5.-2 is issued to Classification Steam Generator, Revision restrictors are to be address the Report for SG 2, Table 3-2, lists SG tube addressed by RAI 8901, classification of SG tube supports and flow restrictions Question 3.9.5-2, and to be supports and flow to be N/A quality group. The included in the DCA Part 2 restrictors.

staff requests that the Tier 2, Table 3.2-1.

applicant provide a clarification of why the SG tube supports and flow restrictions are classified with N/A quality group.

4 EQ-A013-1826 Huang DCD Section 3.8.2.4.1, Design specs provide Closed Response acceptable Containment Containment Vessel Stress loading conditions and Vessel Analysis, states: evaluation analysis requirements, but of the stress levels and do not provide analysis fatigue usage for the CNV results. Results for stress pressure boundary is analysis of CNV (not calculated for the specified including fatigue),

loading conditions discussed performed in accordance in Section 3.8.2.3 and with design spec are demonstrates that the values provided in Primary Stress are less than the allowable CNV doc. Additional stress limits. analysis for CNV support In searching the ASME skirt and bolting in separate Design Specification for docs.

Containment Vessel, EQ-A013-1826, the staff was not able to locate any demonstration that the stress levels and fatigue usage are less than the allowable limits.

Is the document demonstrating this available?

4a EC-A013-3377 Huang In 6.0 of EC-A013-3377, CNV NuScale response - ASME Closed Response acceptable.

CNV Primary Primary Stress analysis, Code is primarily Stress Analysis controlling stresses are concerned with ratios in discussed and ratios in excess of allowable 1.0 excess of 0.95 were limit and chose not to specifically mentioned, (Z31, include path 72, but there

X32, X10, X12 and Path 34 was no specific reason for and 36. However, according this.

to the Appendix F table, 6-38 Membrane Stress results for cylinder model, Path 72 has a stress ratio of 0.95 and is not mentioned in Section 6.0. Is there a reason for excluding Path 72?

4b EC-A013-3377 Huang In Section 1.1, Purpose of NuScale response - The Open DSRS 3.8.2 I.3.H CNV Primary EC-A013-3377, CNV Primary subject separate calculation requires a fatigue Stress Analysis Stress analysis, it states that for fatigue evaluation of the evaluation of the CNV fatigue was evaluated in a CNV is preliminary at this under ASME BPV Code separate calculation. Please time. NuScale recognizes Section III, NB fatigue make that calculation that certified design reports evaluation rules.

document available. will be required for all of the Seismic Category I The fatigue evaluation Notify the NRC when the components. However, as was not available for fatigue analyses is completed discussed with the staff, review and will need to for the design of the reactor stress analysis (including be reviewed in a future vessel and the containment. fatigue) is completed using audit.

a graded approach. For the DCA, NuScale has performed selected stress analysis (including fatigue) for the most critical components. But all of the analysis of even the most critical components (RPV and CNV) has not been finalized at this time.

5 EQ-B020-2140 Scarbroug Is Design Specification EQ- Yes, intended to specify Closed Response acceptable.

ECCS Valves h B020-2140 intended to design requirements establish the specific requirements for the ECCS valves that must be satisfied by the valve supplier?

6 EQ-B020-2140 Scarbroug Is the ECCS Functional ECCS Functional Closed ECCS functional ECCS Valves h Specification referenced FS- Specification in eRR information acceptable B020-517 in Section 1.4.2.14 for this audit. Therefore,

of Design Specification EQ- Item 6 is closed for this B020-2140 available for audit.

review?

7 EQ-B020-2140 Scarbroug What is the status of the ODI-16-0221on Reactor Closed Will address issue in ECCS Valves h Open Items for mechanical Vessel Nozzle Loading ECCS Valve Follow-up loads and containment vessel remains open Audit, including design transients indicated in Section specification 1.5 of Design Specification confirmation.

EQ-B020-2140?

8 EQ-B020-2140 Scarbroug What is the status of Design Certification will occur when Closed Response acceptable.

ECCS Valves h Specification EQ-B020-2140 COL applicant is that has not been certified by determined a Professional Engineer in Section 1.6?

9 EQ-B020-2140 Scarbroug What is the basis for re- ECCS valves have no Closed Review OM Code ECCS Valves h categorizing the ECCS valves specific leakage criteria Assessment during which are actuated by ECCS Valve Follow-up solenoid components to a Audit.

self-actuated (Category C) valve with inconsequential leakage limitations (Category B)? Also, is the ASME Operations and Maintenance Code Assessment Report ECN-B020-5225 that is referenced in ECN-B020-5225 available for review?

10 EQ-B020-2140 Scarbroug Section 3.4.3 of Design Screening or analysis will Closed Response acceptable.

ECCS Valves h Specification EQ-B020-2140 evaluate for water hammer states that the supplier shall evaluate the potential for and effects of water hammer.

What are the requirements for the supplier if water hammer will be evaluated through testing?

11 EQ-B020-2140 Scarbroug Table 3-3 in Design FSAR Section 3.6.3 Closed NRO Materials and ECCS Valves h Specification EQ-B020-2140 referenced. Chemical Branch (MCB) specifies that leak-before- is evaluating LBB break (LBB) considerations

are allowed for a potential proposal. Therefore, main steam pipe break closed for this audit.

(MSPB) and feedwater pipe break (FWPB). What is the justification for leak-before-break considerations for MSPB and FWPB?

12 EQ-B020-2140 Scarbroug Section 3.6 of Design Section 3.6.3 of Design Closed Item 92 in the list below ECCS Valves h Specification EQ-B020-2140 Specification addresses addresses EQ issues.

specifies that the RRVs must radiation effects Therefore, this item is be qualified for radiation closed.

effects while the RVVs are sufficiently remote to not require radiation qualification.

What are the requirements for the qualification of the RRVs for radiation effects? What is the justification for not requiring radiation qualification for the RVVs?

13 EQ-B020-2140 Scarbroug Section 3.6 of Design Design Specification Closed Item 92 in the list below ECCS Valves h Specification EQ-B020-2140 references QME-1 addresses EQ issues.

specifies that nonmetallic Therefore, this item is components be evaluated for closed.

radiation effects. Does Design Specification EQ-B020-2140 require application of Appendix QR-B in ASME QME-1-2007 for environmental qualification of nonmetallics in the ECCS valves and their subcomponents for radiation and other environmental effects? Table 3-4 (RRV) and Table 3-5 (RVV) in Design Specification EQ-B020-2140 allow a range for the Cv flow coefficient, valve seat area, and pressure drop ratio factor

XT, as applicable. What is the basis for allowing a range for these valve parameters in the design specification?

14 EQ-B020-2140 Scarbroug Table 3-4 (RRV) and Table 3- Range of permissible Closed Response acceptable.

ECCS Valves h 5 (RVV) in Design parameters specified in Specification EQ-B020-2140 Design Specification allow a range for the Cv flow coefficient, valve seat area, and pressure drop ratio factor XT, as applicable. What is the basis for allowing a range for these valve parameters in the design specification?

15 EQ-B020-2140 Scarbroug Section 3.11.4 of Design Equipment Qualification Closed Response acceptable.

ECCS Valves h Specification EQ-B020-2140 Specification will address.

states that the RRV will be oriented vertically with the discharge port opening downward. Section 3.11.5 specifies that the RVV will be oriented horizontally with the port pointed radially outward.

What design features and qualification requirements are necessary to account for this difference in valve orientation?

16 EQ-B020-2140 Scarbroug Section 3.12.2 of Design Equipment Qualification Closed Response acceptable.

ECCS Valves h Specification EQ-B020-2140 Specification will address.

states that the ECCS valves and their actuators shall be designed such that leakage does not result in boric acid buildup or transport that impacts the ability of the valves to perform their safety function. What design features and qualification requirements are required to

satisfy this provision in the design specification?

17 EQ-B020-2140 Scarbroug Section 6.2 of Design Revision 3 to Design Closed Response acceptable.

ECCS Valves h Specification EQ-B020-2140 Specification requires specifies the QA requirements Appendix B.

for the ECCS valves. Does Design Specification EQ-B020-2140 require the application of Appendix B to 10 CFR Part 50 for the QA requirements for the ECCS valves?

18 EQ-B020-2140 Scarbroug Section 8.0 of Design Revision 3 to Design Closed Response acceptable.

ECCS Valves h Specification EQ-B020-2140 Specification requires states that the ECCS valves QME-1 without individual and their actuators shall be tests.

qualified in accordance with ASME QME-1-2007 as accepted in RG 1.100 (Revision 3). How do the tests and their sequence listed in Section 8.0 satisfy the provisions of ASME QME-1-2007 for qualification of the valve assembly design (including the four ECCS subcomponents),

extrapolation of the design following adjustments during the qualification process, demonstration of the capability of production valves consistent with the qualified valve design, and demonstration of the capability of the as-installed valves?

19 EQ-B020-2140 Scarbroug Table 8-2 in Design Revision 3 of Design Closed Review during ECCS ECCS Valves h Specification EQ-B020-2140 Specification classifies Valve Follow-up Audit.

states that the inservice

leakage limits are reserved. ECCS valves as OM Therefore, closed for this When will the leakage limits Category B/C. audit.

be available for review?

Section 8.0 of Design Specification EQ-B020-2140 states that the ECCS valves and their actuators shall be qualified in accordance with ASME QME-1-2007 as accepted in RG 1.100 (Revision 3). How do the tests and their sequence listed in Section 8.0 satisfy the provisions of ASME QME-1-2007 for qualification of the valve assembly design (including the four ECCS subcomponents),

extrapolation of the design following adjustments during the qualification process, demonstration of the capability of production valves consistent with the qualified valve design, and demonstration of the capability of the as-installed valves?

20 EQ-B020-2140 Scarbroug Where are the following ECCS Valves h aspects of the design and qualification requirements for the ECCS valves and their subcomponents addressed in Design Specification EQ-B020-2140?

20a EQ-B020-2140 Scarbroug Specific first-of-a-kind (FOAK) Design Specification Closed Response acceptable.

ECCS Valves h valve attributes, such as valve includes critical internal and disc design. parameters.

20b EQ-B020-2140 Scarbroug Preparation of a failure modes FMEA addresses Closed Response acceptable.

ECCS Valves h and effects analysis (FMEA). separately.

20c EQ-B020-2140 Scarbroug Performance of a weak link NuScale will update design Confirma ECCS Valves h analysis. specification to require tory analysis of the valve internals for the opening and closing forces applied during operation.

20d EQ-B020-2140 Scarbroug Seismic qualification testing Design Specification Closed Response acceptable.

ECCS Valves h with static side load testing references QME-1 for static along the least rigid axis. side load testing.

20e EQ-B020-2140 Scarbroug Thermal stress analysis in Stand-alone calculation or Closed Response acceptable.

ECCS Valves h accordance with the ASME ASME Design Report will BPV Code. address.

20f EQ-B020-2140 Scarbroug Capacity certification for the ECCS valves will not be Closed Response acceptable.

ECCS Valves h ECCS valves over their full capacity certified, but flow range of fluid flow and tested during qualification.

applicable conditions.

20g EQ-B020-2140 Scarbroug Evaluation of potential flow- Vibration will be addressed Closed Response acceptable.

ECCS Valves h induced vibration and its during qualification.

effects.

20h EQ-B020-2140 Scarbroug Evaluation of potential Revision 3 to Design Closed Response acceptable.

ECCS Valves h pressure locking and thermal Specification indicates binding. design will avoid pressure locking and thermal binding.

20i EQ-B020-2140 Scarbroug Sizing and setting of the Differential pressure Closed Response acceptable.

ECCS Valves h individual springs in each of requirement used to specify the four ECCS valve spring size with combined subcomponents, including license (COL) holder pressure and flow load, responsible for evaluating.

seating and unseating load, uncertainties, and margin requirements.

20j EQ-B020-2140 Scarbroug Preparation of an operating No design requirement for Closed Response acceptable.

ECCS Valves h experience report related to suppliers to address the specific valve design to be operating experience.

provided by the supplier. NuScale will rely on Part 21 requirements.

20k EQ-B020-2140 Scarbroug Documentation in accordance Design Specification Closed Response acceptable.

ECCS Valves h with ASME QME-1-2007. requires QME-1 including documentation.

20 EQ-B020-2140 Scarbroug Specific comments on Closed Review during ECCS Addition Revision 3 h Revision 3 provided during Valve Follow-up Audit.

al ECCS valve audit 21 EQ-A010-2235 Section 1.1 of Design Design Specification does Closed Review during CIV PSCIVs Specification EQ-A010-2235 not address size or type. Audit. Therefore, closed states that the purpose of the for this audit.

document is to provide the ASME design specification for the primary systems containment isolation valves (PSCIVs), such as used for the reactor coolant system (RCS) injection and discharge lines, pressurizer spray supply line, and reactor pressure vessel degasification line. Design Specification EQ-A010-2235 is also said to apply to isolation valves in other lines. Is Design Specification EQ-A010-2235 intended to establish the specific requirements for the PSCIVs that must be satisfied by the valve supplier, such as the types and sizes of the tandem PSCIVs for their various applications?

22 EQ-A010-2235 Scarbroug Is the Containment System Containment System Closed Containment information PSCIVs h Functional Specification FS- Functional Specification in acceptable for this audit.

A013-509 referenced in eRR. Therefore, Item 22 Section 1.5.1.1 of Design closed for this audit.

Specification EQ-A010-2235 available for review?

23 EQ-A010-2235 Scarbroug What is the status of the ODI 16-0221 remains open. Closed Review during CIV PSCIVs h Open Items for high energy Audit. Therefore, closed line break conditions, lowest for this audit.

service temperature, mechanical design loads, and containment vessel combustible gas control indicated in Section 1.6 of Design Specification EQ-A010-2235?

24 EQ-A010-2235 Scarbroug What is the status of Design See Item 8 Closed Response acceptable.

PSCIVs h Specification EQ-A010-2235 that has not been certified by a Professional Engineer in Section 1.7?

25 EQ-A010-2235 Scarbroug Note (3) in Table 3-2 in ECN- LBB used. Closed MCB reviewing LBB.

PSCIVs h A010-4613 for Design Therefore, closed for this Specification EQ-A010-2235 audit.

states that leak-before-break (LBB) considerations are allowed for a potential main steam pipe break (MSPB) and feedwater pipe break (FWPB). What is the justification for leak-before-break considerations for an MSPB and FWPB?

26 EQ-A010-2235 Scarbroug Table 3-1 and Section 3.6.2 of Revision 2 to Design Closed Item 92 in the list below PSCIVs h Design Specification EQ- Specification includes addresses EQ issues.

A010-2235 discuss the radiation requirements. Therefore, this item is radiation conditions for the closed.

PSCIVs, including a zero 1-hour accident dose. What is the justification for the radiation qualification requirements for the PSCIVs?

27 EQ-A010-2235 Scarbroug Does Design Specification Design Specification Closed Item 92 in the list below PSCIVs h EQ-A010-2235 require requires QME-1 and QR-B addresses EQ issues.

application of Appendix QR-B may be used. Therefore, this item is in ASME QME-1-2007 for closed.

environmental qualification of nonmetallics in the PSCIVs

for radiation and other environmental effects?

28 EQ-A010-2235 Scarbroug Section 3.11 of Design Equipment Qualification Closed Response acceptable.

PSCIVs h Specification EQ-A010-2235 Specification will address states that the PSCIVs will be orientation.

oriented with the flow axis vertical. What design features and qualification requirements are necessary to account for this valve orientation?

29 EQ-A010-2235 Scarbroug Section 8.0 of Design Revision 2 to Design Closed Response acceptable.

PSCIVs h Specification EQ-A010-2235 Specification removes states that the PSCIVs shall conflicting requirements be qualified in accordance and requires QME-1.

with ASME QME-1-2007.

How do the tests and their sequence listed in Section 8.0 satisfy the provisions of ASME QME-1-2007 for qualification of the valve assembly design, extrapolation of the valve assembly qualification, demonstration of the capability of production valves consistent with the qualified valve design, and demonstration of the capability of the as-installed valves?

30 EQ-A010-2235 Scarbroug Section 11.2 of Design NuScale to revised Design Confirma PSCIVs h Specification EQ-A010-2235 Specification to require tory specifies the QA requirements Appendix B.

for the PSCIVs. Does Design Specification EQ-A010-2235 require the application of Appendix B of 10 CFR Part 50 for the QA requirements for the PSCIVs?

31 EQ-A010-2235 Scarbroug Where are the following PSCIVs h aspects of the design and qualification requirements for the PSCIVs addressed in Design Specification EQ-A010-2235?

31a EQ-A010-2235 Scarbroug Specific first-of-a-kind (FOAK) See Item 20.a Closed Response acceptable.

PSCIVs h valve attributes, such as valve internal and disc design.

31b EQ-A010-2235 Scarbroug Preparation of a failure modes See Item 20.b Closed Response acceptable.

PSCIVs h and effects analysis (FMEA).

31c EQ-A010-2235 Scarbroug Performance of a weak link NuScale will update design Confirma PSCIVs h analysis. specification to require tory weak link analysis by supplier.

31d EQ-A010-2235 Scarbroug Seismic qualification testing See Item 20.d Closed Response acceptable.

PSCIVs h with static side load testing along the least rigid axis.

31e EQ-A010-2235 Scarbroug Thermal stress analysis in See Item 20.e Closed Response acceptable.

PSCIVs h accordance with the ASME BPV Code.

31f EQ-A010-2235 Scarbroug Evaluation of potential flow- See Item 20.g Closed Response acceptable.

PSCIVs h induced vibration and its effects.

31g EQ-A010-2235 Scarbroug Evaluation of potential TBD Closed Review during CIV PSCIVs h pressure locking and thermal Audit. Therefore, closed binding. for this audit.

31h EQ-A010-2235 Scarbroug Sizing and setting of the Sizing not included in Closed Review during CIV PSCIVs h hydraulic actuators for the Design Specification. Audit. Therefore, closed PSCIVs, including pressure for this audit.

and flow load (including friction coefficient assumptions), seating and unseating load, packing load, actuator output assumptions, uncertainties, and margin requirements.

31i EQ-A010-2235 Scarbroug Preparation of an operating See Item 20.j Closed Response acceptable.

PSCIVs h experience report related to

the specific valve design to be provided by the supplier.

31j EQ-A010-2235 Scarbroug Documentation in accordance See Item 20.k Closed Response acceptable.

PSCIVs h with ASME QME-1-2007.

32 EQ-A010-2224 Scarbroug Section 1.1 of Design See Item 21 Closed Review during CIV SSCIVs h Specification EQ-A010-2224 Audit. Therefore, closed states that the purpose of the for this audit.

document is to provide the ASME design specification for the secondary side containment isolation valves (SSCIVs). Is Design Specification EQ-A010-2224 intended to establish the specific requirements for the SSCIVs that must be satisfied by the valve supplier, such as the types and sizes of the main steam isolation valves (MSIVs) with their bypass valves, and the feedwater isolation valves (FWIVs) with their combined nozzle check valve?

33 EQ-A010-2224 Scarbroug Is the Containment System See Item 22 Closed Containment information SSCIVs h Functional Specification FS- acceptable for this audit.

A013-509 referenced in Therefore, Item 33 Section 1.5.1.1 of Design closed for this audit.

Specification EQ-A010-2224 available for review?

34 EQ-A010-2224 Scarbroug What is the status of the ODI-16-0221 remains Closed Review during CIV SSCIVs h Open Items for normal open. Audit. Therefore, closed operating conditions, lowest for this audit.

service temperature, mechanical loads, and containment piping connections to the MSIVs and FWIVs indicated in Section 1.6 of Design Specification EQ-A010-2224?

35 EQ-A010-2224 Scarbroug What is the status of Design See Item 8 Closed Response acceptable.

SSCIVs h Specification EQ-A010-2224 that has not been certified by a Professional Engineer in Section 1.7?

36 EQ-A010-2224 Scarbroug Note (3) in Table 3-A in ECN- LBB used. Closed MCB reviewing LBB.

SSCIVs h A010-4614 for Design Therefore, closed for this Specification EQ-A010-2224 audit.

states that leak-before-break (LBB) considerations are allowed for a potential main steam pipe break (MSPB) and feedwater pipe break (FWPB). What is the justification for leak-before-break considerations for an MSPB and FWPB?

37 EQ-A010-2224 Scarbroug Section 2.1 of Design Orientation addressed in Closed Response acceptable.

SSCIVs h Specification EQ-A010-2224 qualification.

states that the MSIV will be oriented for vertical flow upward through the valve, and that the FWIV will be oriented for vertical flow downward through the valve.

What design features and qualification requirements are necessary to account for this difference in valve orientation?

38 EQ-A010-2224 Scarbroug Table 3-1 of Design Revision 1 to Design Closed Response acceptable.

SSCIVs h Specification EQ-A010-2224 Specification revised Table indicates that the external 3-1 design pressures for the MSIV and FWIV are reserved.

When will the external design pressures for these valves be available for review?

39 EQ-A010-2224 Scarbroug Section 3.8 of Design Radiation effects Closed Item 92 in the list below SSCIVs h Specification EQ-A010-2224 addressed in Section 3.8 addresses EQ issues.

states that the SSCIVs are Therefore, this item is sufficiently remote to not closed.

require qualification for radiation effects. What is the justification for not requiring radiation qualification of the SSCIVs?

40 EQ-A010-2224 Scarbroug Section 3.8 of Design Design Specification Closed Item 92 in the list below SSCIVs h Specification EQ-A010-2224 requires QME-1 and QR-B addresses EQ issues.

states that nonmetallic may be used. Therefore, this item is components will be evaluated closed.

for radiation effects. Does Design Specification EQ-A010-2224 require application of Appendix QR-B in ASME QME-1-2007 for environmental qualification of nonmetallics in the SSCIVs for radiation and other environmental effects?

41 EQ-A010-2224 Scarbroug Section 8.0 of Design Revision 1 to Design Spec Closed Response acceptable.

SSCIVs h Specification EQ-A010-2224 clarifies QME-1 states that the SSCIVs shall requirement.

be qualified in accordance with ASME QME-1-2007 as accepted in RG 1.100 (Revision 3). How do the tests and their sequence listed in Section 8.0 satisfy the provisions of ASME QME-1-2007 for qualification of the valve assembly design, extrapolation of the valve assembly qualification, demonstration of the capability of production valves consistent with the qualified valve design, and demonstration of the

capability of the as-installed valves?

42 EQ-A010-2224 Scarbroug Section 11.2 of Design NuScale to include Confirma SSCIVs h Specification EQ-A010-2224 Appendix B requirement. tory specifies the QA requirements for the SSCIVs. Does Design Specification EQ-A010-2224 require the application of Appendix B of 10 CFR Part 50 for the QA requirements for the SSCIVs?

43 EQ-A010-2224 Scarbroug Where are the following SSCIVs h aspects of the design and qualification requirements for the SSCIVs addressed in Design Specification EQ-A010-2224?

43a EQ-A010-2224 Scarbroug Specific first-of-a-kind (FOAK) See Item 20.a Closed Response acceptable.

SSCIVs h valve attributes, such as valve internal and disc design.

43b EQ-A010-2224 Scarbroug Preparation of a failure modes See Item 20.b Closed Response acceptable.

SSCIVs h and effects analysis (FMEA).

43c EQ-A010-2224 Scarbroug Performance of a weak link NuScale will update design Confirma SSCIVs h analysis. specification to require tory weak link analysis by supplier.

43d EQ-A010-2224 Scarbroug Seismic qualification testing See Item 20.d Closed Response acceptable.

SSCIVs h with static side load testing along the least rigid axis.

43e EQ-A010-2224 Scarbroug Thermal stress analysis in See Item 20.e Closed Response acceptable.

SSCIVs h accordance with the ASME BPV Code.

43f EQ-A010-2224 Scarbroug Evaluation of potential flow- See Item 20.g Closed Response acceptable.

SSCIVs h induced vibration and its effects.

43g EQ-A010-2224 Scarbroug Evaluation of potential Design to allow actuator to Closed Review during CIV SSCIVs h pressure locking and thermal open. Audit. Therefore, closed binding. for this audit.

43h EQ-A010-2224 Scarbroug Sizing and setting of the Vendor documents will size Closed Review during CIV SSCIVs h hydraulic actuators for the actuators. Audit. Therefore, closed PSCIVs, including pressure for this audit.

and flow load (including friction coefficient assumptions), seating and unseating load, packing load, actuator output assumptions, uncertainties, and margin requirements.

43i EQ-A010-2224 Scarbroug Preparation of an operating See Item 20.j Closed Response acceptable.

SSCIVs h experience report related to the specific valve design to be provided by the supplier.

43j EQ-A010-2224 Scarbroug Documentation in accordance See Item 20.k Closed Response acceptable.

SSCIVs h with ASME QME-1-2007.

44 EQ-A011-2179 Scarbroug Section 1.1 of Design Design Specification does Closed Review during RSV RSVs h Specification EQ-A011-2179 not include size or type. Audit. Therefore, closed states that the purpose of the for this audit.

document is to provide the ASME Design Specification for the reactor coolant system (RCS) reactor safety valves (RSVs). Is Design Specification EQ-A011-2179 intended to establish the specific requirements for the RSVs that must be satisfied by the valve supplier, such as their specific design?

45 EQ-A011-2179 Scarbroug Is the RCS Functional RCS Functional Closed Response acceptable.

RSVs h Specification referenced in Specification in eRR Section 1.5.1.1 of Design Specification EQ-A011-2179 available for review?

46 EQ-A011-2179 Scarbroug What is the status of the Several ODIs remain open Closed ODIs will be evaluated RSVs h Open Items for inservice as part of RSV audit.

examination requirements, See CIV-RSV Audit Plan service temperature, Accession No.

mechanical design loads, ML18229A114.

containment vessel Therefore, Item 46 pneumatic and hydraulic closed for this audit.

testing, and containment transients for prototype testing indicated in Section 1.6 of Design Specification EQ-A011-2179?

47 EQ-A011-2179 Scarbroug What is the status of Design See Item 8 Closed Response acceptable.

RSVs h Specification EQ-A011-2179 that has not been certified by a Professional Engineer in Section 1.7?

48 EQ-A011-2179 Scarbroug Section 2.3 of Design RSVs are OM Category Closed Response acceptable.

RSVs h Specification EQ-A011-2179 B/C because no specific provides the ASME BPV leakage criteria.

Code classification of the RSVs. What is the ASME OM Code category for the RSVs?

49 EQ-A011-2179 Scarbroug Table 3-2 in Design LBB used. Closed MCB reviewing LBB.

RSVs h Specification EQ-A011-2179 Therefore, closed for this was modified in ECN-A011- audit.

4845 to specify that leak-before-break (LBB) considerations are allowed for a potential main steam pipe break (MSPB) and feedwater pipe break (FWPB). What is the justification for leak-before-break considerations for an MSPB and FWPB?

50 EQ-A011-2179 Scarbroug Section 3.5 of Design Radiation requirements in Closed Item 92 in the list below RSVs h Specification EQ-A011-2179 Design Specification. addresses EQ issues.

states that the RSVs are Therefore, this item is sufficiently remote to not closed.

require radiation qualification.

What is the justification for not requiring radiation qualification for the RSVs?

51 EQ-A011-2179 Scarbroug Section 3.5 of Design Design Specification Closed Item 92 in the list below RSVs h Specification EQ-A011-2179 requires QME-1 and QR-B addresses EQ issues.

states that nonmetallic may be used. Therefore, this item is components will be evaluated closed.

for radiation effects. Does Design Specification EQ-A011-2179 require application of Appendix QR-B in ASME QME-1-2007 for environmental qualification of nonmetallics in the RSVs for radiation and other environmental effects?

52 EQ-A011-2179 Scarbroug Section 3.6 of Design NuScale will include Confirma RSVs h Specification EQ-A011-2179 thermal binding precluded tory states that only the reactor by design.

pressure vessel (RPV) connection of the RSV needs to be evaluated for thermal effects. What is the justification for this assumption over the full range of safety functions for the RSVs?

53 EQ-A011-2179 Scarbroug Section 3.7 of Design RSVs must not be Closed Response acceptable.

RSVs h Specification EQ-A011-2179 damaged by water.

specifies the flow capacity NuScale indicated that RSV requirement for the RSVs for might need to saturated steam. What are accommodate water flow the flow requirements with for some ATWS transients.

respect to the full range of Section 3.8 in the design steam, steam/water mixture, specification requires that and liquid conditions for the RSV not be damaged RSV safety functions? under normal, accident, shutdown, and maintenance conditions.

54 EQ-A011-2179 Scarbroug Section 3.9 of Design Settings consistent with Closed Response acceptable.

RSVs h Specification EQ-A011-2179 NB-7311(b) specifies the valve settings for the RSVs. Are the planned

settings consistent with the ASME BPV Code requirements as incorporated by reference in 10 CFR 50.55a? If not, what is the plan to obtain NRC acceptance of the differences from the Code requirements?

55 EQ-A011-2179 Scarbroug Section 6.2 of Design NuScale to require 10 CFR Confirma RSVs h Specification EQ-A011-2179 Part 50, Appendix B in tory specifies the QA requirements Design Specification for the RSVs. Does Design Specification EQ-A011-2179 require the application of Appendix B to 10 CFR Part 50 for the QA requirements for the RSVs?

56 EQ-A011-2179 Scarbroug Section 8.0 of Design Section 8.0 references Closed Review during RSV RSVs h Specification EQ-A011-2179 QME-1 Audit. See CIV-RSV states that the RSVs shall be Audit Plan Accession functionally qualified in Number accordance with ASME QME- ML18229A114.

1. How do the tests and their Therefore, closed for this sequence listed in Section 8.0 audit.

satisfy the provisions of ASME QME-1-2007 for qualification of the valve assembly design, extrapolation of the valve assembly qualification following design adjustments during the qualification process, demonstration of the capability of production valves consistent with the qualified valve design, and demonstration of the capability of the as-installed valves for the RSVs?

57 EQ-A011-2179 Scarbroug Where are the following RSVs h aspects of the design and qualification requirements for the RSVs addressed in Design Specification EQ-A011-2179?

57a EQ-A011-2179 Scarbroug Specific first-of-a-kind (FOAK) See Item 20.a Closed Response acceptable.

RSVs h valve attributes for the RSVs.

57b EQ-A011-2179 Scarbroug Preparation of a failure modes See Item 20.b Closed Response acceptable.

RSVs h and effects analysis (FMEA).

57c EQ-A011-2179 Scarbroug Performance of a weak link NuScale will update design Confirma RSVs h analysis. specification to require tory analysis of the valve internals for the opening and closing forces applied during operation.

57d EQ-A011-2179 Scarbroug Seismic qualification testing See Item 20.d Closed Response acceptable.

RSVs h with static side load testing along the least rigid axis.

57e EQ-A011-2179 Scarbroug Thermal stress analysis in See Item 20.e Closed Response acceptable.

RSVs h accordance with the ASME BPV Code.

Capacity certification for the RSVs over their full range of fluid flow and applicable conditions.

57ee EQ-A011-2179 Scarbroug Capacity certification for the Design Specification Closed Response acceptable.

RSVs h RSVs over their full range of provides capacity fluid flow and applicable requirements. Sections conditions. 6.8.3 and 8.8 of the design specification includes capacity certification requirements for the RSVs per ASME BPV Code.

57f EQ-A011-2179 Scarbroug Evaluation of potential flow- See Item 20.g Closed Response acceptable.

RSVs h induced vibration and its effects.

57g EQ-A011-2179 Scarbroug Evaluation of potential Spring to be capable of Closed Review during RSV RSVs h pressure locking and thermal opening. Audit. See CIV-RSV binding. Audit Plan Accession

Number ML18229A114.

Therefore, closed for this audit.

57h EQ-A011-2179 Scarbroug Sizing and setting of the Design Specification Closed Review during RSV RSVs h RSVs. provides setpoint and Audit. See CIV-RSV capacity requirements. Audit Plan Accession Number ML18229A114.

Therefore, closed for this audit.

57i EQ-A011-2179 Scarbroug Preparation of an operating See Item 20.j Closed Response acceptable.

RSVs h experience report related to the specific valve design to be provided by the supplier.

57j EQ-A011-2179 Scarbroug Documentation in accordance See Item 20.k Closed Response acceptable.

RSVs h with ASME QME-1-2007.

58 EQ-B030-2258 Scarbroug Section 1.1 of Design Section 13.0, Valve Data Closed Response acceptable.

DHR Valves h Specification EQ-B030-2258 Sheet, in the design states that the purpose of the specification includes the document is to provide the valve type (wedge-ball) and ASME design specification for size (6 inch) and actuator the decay heat removal type (gas-hydraulic).

system (DHRS) actuation valves. Is Design Specification EQ-B030-2258 intended to establish the specific requirements for the DHRS actuation valves that must be satisfied by the valve supplier, such as the actuator types of hydraulic or pneumatic for the DHRS actuation valves?

59 EQ-B030-2258 Scarbroug Is the Decay Heat Removal DHR Functional Closed Response acceptable.

DHR Valves h Functional Specification FS- Specification in eRR.

B030-508 referenced in Section 1.5.1.1 of Design Specification EQ-B030-2258 available for review?

60 EQ-B030-2258 Scarbroug What is the status of the Several ODIs remain open. Confirma DHR Valves h Open Items for DHRS flow tory

rate during transients, and valve loads and piping specific acceleration values indicated in Section 1.6 of Design Specification EQ-B030-2258?

61 EQ-B030-2258 Scarbroug What is the status of Design See Item 8 Closed Response acceptable.

DHR Valves h Specification EQ-B030-2258 that has not been certified by a Professional Engineer in Section 1.7?

62 EQ-B030-2258 Scarbroug Section 3.2 of Design Revision 1 to Design Closed Response acceptable.

DHR Valves h Specification EQ-B030-2258 Specification includes states that the supplier will design pressure provide the means to address requirement.

leakage. Is Design Specification EQ-B030-2258 intended to specify the specific design features and qualification requirements for the DHRS actuation valves?

63 EQ-B030-2258 Scarbroug Table 3-1 of Design Revision 1 to Design Closed Response acceptable.

DHR Valves h Specification EQ-B030-2258 Specification includes states that the external design external design pressure pressure for the DHRS references.

actuation valves is reserved.

When will the external design pressure for these valves be available for review?

64 EQ-B030-2258 Scarbroug Section 3.7.2 of Design Design Specification Closed Item 92 in the list below DHR Valves h Specification EQ-B030-2258 includes radiation addresses EQ issues.

states that the DHRS requirements. Therefore, this item is actuation valves are closed.

sufficiently remote to not require qualification for radiation effects. What is the justification for not requiring radiation qualification of these valves?

65 EQ-B030-2258 Scarbroug Does Design Specification Design Specification Closed Item 92 in the list below DHR Valves h require application of requires QME-1 and QR-B addresses EQ issues.

Appendix QR-B in ASME may be used. Therefore, this item is QME-1-2007 for closed.

environmental qualification of nonmetallics in the DHRS actuation valves for radiation and other environmental effects?

66 EQ-B030-2258 Scarbroug Section 8.0 of Design Section 8.0 revised to Confirma Section 8.1.1 needs to DHR Valves h Specification EQ-B030-2258 clarify QME-1 requirement. tory be corrected to include states that the DHRS analysis, testing, or actuation valves shall be combination language.

qualified in accordance with ASME QME-1-2007. How do the tests and their sequence listed in Section 8.0 satisfy the provisions of ASME QME-1-2007 for qualification of the valve assembly design, extrapolation of the valve assembly qualification to account for design adjustments, demonstration of the capability of production valves consistent with the qualified valve design, and demonstration of the capability of the as-installed valves?

67 EQ-B030-2258 Scarbroug Does Design Specification NuScale to include Confirma DHR Valves h EQ-B030-2258 require the Appendix B requirement. tory application of Appendix B of 10 CFR Part 50 for the QA (Question 17, 30, 42, 55, requirements for the DHRS 67, 77, 88) actuation valves?

68 EQ-B030-2258 Scarbroug Where are the following (Question 20, 31, 43, 57, DHR Valves h aspects of the design and 68, 78, 90) qualification requirements for the DHRS actuation valves See below

addressed in Design Specification EQ-B030-2258?

68a EQ-B030-2258 Scarbroug Specific first-of-a-kind (FOAK) See Item 20.a Closed Response acceptable.

DHR Valves h valve attributes.

68b EQ-B030-2258 Scarbroug Preparation of a failure modes See Item 20.b Closed Response acceptable.

DHR Valves h and effects analysis (FMEA).

68c EQ-B030-2258 Scarbroug Performance of a weak link NuScale will update design Confirma DHR Valves h analysis. specification to require tory weak link analysis by supplier.

68d EQ-B030-2258 Scarbroug Seismic qualification testing See Item 20.d Closed Response acceptable.

DHR Valves h with static side load testing along the least rigid axis.

68e EQ-B030-2258 Scarbroug Thermal stress analysis in See Item 20.e Closed Response acceptable.

DHR Valves h accordance with the ASME BPV Code.

68f EQ-B030-2258 Scarbroug Evaluation of potential flow- See Item 20.g Closed Response acceptable.

DHR Valves h induced vibration and its effects.

68g EQ-B030-2258 Scarbroug Evaluation of potential Qualification to address. Closed Response acceptable.

DHR Valves h thermal binding.

68h EQ-B030-2258 Scarbroug Sizing and setting of the Vendor documentation will Closed Response acceptable.

DHR Valves h DHRS actuation valves, include design details.

including pressure and flow load (including friction coefficient assumptions),

seating and unseating load, packing load, actuator output assumptions, uncertainties, and margin requirements.

68i EQ-B030-2258 Scarbroug Preparation of an operating See Item 20.j Closed Response acceptable.

DHR Valves h experience report related to the specific valve design to be provided by the supplier.

68j EQ-B030-2258 Scarbroug Documentation in accordance See Item 20.k Closed Response acceptable.

DHR Valves h with ASME QME-1-2007.

69 EQ-B010-3227 Scarbroug Section 1.1 of Design Appendix A, Valve Data Closed Response acceptable.

CVCS Class 3 h Specification EQ-B010-3227 Sheets, in the design states that the purpose of the specification includes the document is to provide the specific valve and actuator

ASME design specification for information for the various the ASME BPV Code Class 3 CVCS valves.

valves in the chemical and volume control system (CVCS). Is Design Specification EQ-B010-3227 intended to establish the specific requirements for the CVCS Class 3 valves that include multiple valve types, such as air-operated isolation valves, check valves, manual drain valves, and solenoid valves?

70 EQ-B010-3227 Scarbroug What is the status of the ODI remains open. Confirma CVCS Class 3 h Open Items for the valve tory locations in the reactor building indicated in Section 1.6 of Design Specification EQ-B010-3227?

71 EQ-B010-3227 Scarbroug What is the status of Design See Item 8 Closed Response acceptable.

CVCS Class 3 h Specification EQ-B010-3227 that has not been certified by a Professional Engineer in Section 1.7?

72 EQ-B010-3227 Scarbroug Sections 2.3.2 and 2.3.3.1 of Components specified in Closed Response acceptable.

CVCS Class 3 h Design Specification EQ- Scope section.

B010-3227 specifies that Quality Group C and ASME BPV Code Class 3 applies to specific CVCS Class 3 valves.

Is this applicable to all CVCS Class 3 valves within the scope of this design specification?

73 EQ-B010-3227 Scarbroug Section 3.6.2.2 of Design NuScale will revise Design Confirma CVCS Class 3 h Specification EQ-B010-3227 Specification to require tory states that the CVCS FSAR Section 3.11 demineralized water isolation process.

valves are sufficiently remote

to not require qualification for radiation effects. What is the justification for not requiring radiation qualification of these valves?

74 EQ-B010-3227 Scarbroug Does Design Specification Design Spec requires Closed Item 92 in the list below CVCS Class 3 h EQ-B010-3227 require QME-1 and QR-B may be addresses EQ issues.

application of Appendix QR-B used. Therefore, this item is in ASME QME-1-2007 for closed.

environmental qualification of nonmetallics in the CVCS Class 3 valves for radiation and other environmental effects?

75 EQ-B010-3227 Scarbroug Table 3-2 of Design Greater than Cv intended to Closed Response acceptable.

CVCS Class 3 h Specification EQ-B010-3227 indicate minimum Cv.

specifies the flow characteristics of various CVCS Class 3 valves. What is the basis for the greater-than values for Cv flow coefficients for various valves? What is the intent for the table not specifying the flow coefficient for the degasification line isolation valve?

76 EQ-B010-3227 Scarbroug Section 7.0 of Design Section 8.0 requires QME- Closed Response acceptable.

CVCS Class 3 h Specification EQ-B010-3227 1.

addresses the testing and qualification requirements for the CVCS Class 3 valves.

Does Design Specification EQ-B010-3227 require that the CVCS Class 3 valves be qualified in accordance with ASME QME-1-2007 as accepted in RG 1.100 (Revision 3)? If so, how do the tests and their sequence

listed in Section 7.0 satisfy the provisions of ASME QME-1-2007 for qualification of the valve assembly design, extrapolation of the valve assembly qualification, demonstration of the capability of production valves consistent with the qualified valve design, and demonstration of the capability of the as-installed valves?

77 EQ-B010-3227 Scarbroug Section 10.2 of Design NuScale will revise Design Confirma CVCS Class 3 h Specification EQ-B010-3227 Specification to require tory specifies the QA requirements Appendix B.

for the CVCS Class 3 valves.

Does Design Specification EQ-B010-3227 require the application of Appendix B of 10 CFR Part 50 for the QA requirements for these valves?

78 EQ-B010-3227 Scarbroug Where are the following (Question 20, 31, 43, 57, CVCS Class 3 h aspects of the design and 68, 78, 90) qualification requirements for the CVCS Class 3 valves See below addressed in Design Specification EQ-B010-3227?

78a EQ-B010-3227 Scarbroug Specific first-of-a-kind (FOAK) See Item 20.a Closed Response acceptable.

CVCS Class 3 h valve attributes.

78b EQ-B010-3227 Scarbroug Preparation of a failure modes See Item 20.b Closed Response acceptable.

CVCS Class 3 h and effects analysis (FMEA).

78c EQ-B010-3227 Scarbroug Performance of a weak link NuScale will update design Confirma CVCS Class 3 h analysis. specification to require tory weak link analysis by supplier.

78d EQ-B010-3227 Scarbroug Seismic qualification testing See Item 20.d Closed Response acceptable.

CVCS Class 3 h with static side load testing along the least rigid axis.

78e EQ-B010-3227 Scarbroug Thermal stress analysis in See Item 20.e Closed Response acceptable.

CVCS Class 3 h accordance with the ASME BPV Code.

78f EQ-B010-3227 Scarbroug Evaluation of potential flow- See Item 20.g Closed Response acceptable.

CVCS Class 3 h induced vibration and its effects.

78g EQ-B010-3227 Scarbroug Evaluation of potential Design will avoid PL/TB. Closed Response acceptable.

CVCS Class 3 h pressure locking (PL) and thermal binding (TB).

78h EQ-B010-3227 Scarbroug Sizing and setting of the Supplier responsible for Closed Response acceptable.

CVCS Class 3 h actuators for the CVCS Class sizing and setting of 3 valves, including pressure actuators.

and flow load (including friction coefficient assumptions), seating and unseating load, packing load, actuator output assumptions, uncertainties, and margin requirements.

78i EQ-B010-3227 Scarbroug Preparation of an operating See Item 20.j Closed Response acceptable.

CVCS Class 3 h experience report related to the specific valve design to be provided by the supplier.

78j EQ-B010-3227 Scarbroug Documentation in accordance See Item 20.k Closed Response acceptable.

CVCS Class 3 h with ASME QME-1-2007.

79 EQ-A014-4255 Scarbroug Section 1.1 of Design See Item 21 Confirma NuScale will add valve Thermal Relief h Specification EQ-A014-4255 tory data sheet.

Valves states that the purpose of the document is to provide the ASME Design Specification of the thermal relief valves (TRVs), including two TRVs in the feedwater piping in the steam generator system (SGS) and one TRV in the control rod drive system (CRDS) cooling piping. Is Design Specification EQ-A014-4255 intended to establish the specific

requirements for the TRVs that must be satisfied by the valve supplier?

80 EQ-A014-4255 Scarbroug Is the NuScale Reactor RXM Thermal Transient Closed RXM information Thermal Relief h Module (RXM) Thermal Load Definition in eRR. acceptable for this audit.

Valves Transient Load Definition Therefore, Item 80 Specification ER-A010-2529 closed for this audit.

referenced in Section 1.5.1.1 of Design Specification EQ-A014-4255 available for review?

81 EQ-A014-4255 Scarbroug What is the status of Design See Item 8 Closed Response acceptable.

Thermal Relief h Specification EQ-A014-4255 Valves that has not been certified by a Professional Engineer in Section 1.6?

82 EQ-A014-4255 Scarbroug Section 2.3 of Design NuScale will revise Design Confirma Thermal Relief h Specification EQ-A014-4255 Specification to require tory Valves provides the ASME BPV Category AC for SGS Code classification of the Thermal Reliefs.

TRVs. What is the ASME OM Code category for the TRVs?

83 EQ-A014-4255 Scarbroug Table 3-1 of Design NuScale will verify values Confirma Thermal Relief h Specification EQ-A014-4255 based on ODI 17-18. tory Valves (TRVs) states that the relieving capacities of the SGS and CRDS TRVs are reserved.

When will the relieving capacities for the full range of steam, steam/water mixture, and liquid conditions for the safety functions of these valves be available for review?

84 EQ-A014-4255 Scarbroug Table 3-3 in Design LBB supported by Closed MCB reviewing LBB.

Thermal Relief h Specification EQ-A014-4255 calculations. Therefore, closed for this Valves was modified in ECN-A014- audit.

4850 to specify that leak-before-break (LBB) considerations are allowed for

a potential main steam pipe break (MSPB) and feedwater pipe break (FWPB). What is the justification for leak-before-break considerations for an MSPB and FWPB?

85 EQ-A014-4255 Scarbroug Section 4.5 of Design NuScale will revise Design Confirma Thermal Relief h Specification EQ-A014-4255 Specification to require tory Valves states that the TRVs are radiation requirements in sufficiently remote to not accordance with process in require radiation qualification. FSAR Section 3.11.

What is the justification for not requiring radiation qualification for the TRVs?

86 EQ-A014-4255 Scarbroug Does Design Specification Design Specification Closed Item 92 in the list below Thermal Relief h EQ-A014-4255 require requires QME-1 and QR-B addresses EQ issues.

Valves application of Appendix QR-B may be used. Therefore, this item is in ASME QME-1-2007 for closed.

environmental qualification of nonmetallics in the TRVs for radiation and other environmental effects?

87 EQ-A014-4255 Scarbroug Section 3.9 of Design NuScale will update design Confirma Thermal Relief h Specification EQ-A014-4255 specification to require tory Valves states that the valve settings ASME BPV Code.

for the TRVs are provided in Table 3-1 of the specification.

Are the planned settings consistent with the ASME BPV Code requirements as incorporated by reference in 10 CFR 50.55a? If not, what is the plan to obtain NRC acceptance of the differences from the Code requirements?

88 EQ-A014-4255 Scarbroug Section 6.2 of Design NuScale will revise Design Confirma Thermal Relief h Specification EQ-A014-4255 Specification to include tory Valves specifies the QA requirements Appendix B requirement.

for the TRVs. Does Design Specification EQ-A014-4255

require the application of Appendix B to 10 CFR Part 50 for the QA requirements for the TRVs?

89 EQ-A014-4255 Scarbroug Section 8.0 of Design Section 8.0 requires QME-1 Closed Response acceptable.

Thermal Relief h Specification EQ-A014-4255 Valves states that the TRVs shall be functionally qualified in accordance with ASME QME-

1. How do the tests and their sequence listed in Section 8.0 satisfy the provisions of ASME QME-1-2007 for qualification of the valve assembly design, extrapolation of the valve assembly qualification, demonstration of the capability of production valves consistent with the qualified valve design, and demonstration of the capability of the as-installed valves?

90 EQ-A014-4255 Scarbroug Where are the following Thermal Relief h aspects of the design and Valves qualification requirements for the TRVs addressed in Design Specification EQ-A014-4255?

90a EQ-A014-4255 Scarbroug Any first-of-a-kind (FOAK) See Item 20.a Closed Response acceptable.

Thermal Relief h valve attributes for the TRVs.

Valves 90b EQ-A014-4255 Scarbroug Preparation of a failure modes See Item 20.b Closed Response acceptable.

Thermal Relief h and effects analysis (FMEA).

Valves 90c EQ-A014-4255 Scarbroug Performance of a weak link NuScale will update design Confirma Thermal Relief h analysis. specification to require tory Valves weak link analysis by supplier.

90d EQ-A014-4255 Scarbroug Seismic qualification testing See Item 20.d Closed Response acceptable.

Thermal Relief h with static side load testing Valves along the least rigid axis.

90e EQ-A014-4255 Scarbroug Thermal stress analysis in See Item 20.e Closed Response acceptable.

Thermal Relief h accordance with the ASME Valves BPV Code.

90f EQ-A014-4255 Scarbroug Capacity certification for the Design Specification Closed Response acceptable.

Thermal Relief h TRVs over their full range of provides capacity Valves fluid flow and applicable requirement.

conditions 90g EQ-A014-4255 Scarbroug Evaluation of potential flow- See Item 20.g Closed Response acceptable.

Thermal Relief h induced vibration and its Valves effects.

90h EQ-A014-4255 Scarbroug Evaluation of potential Spring capable of opening Closed Response acceptable.

Thermal Relief h pressure locking and thermal with qualification Valves binding. requirements.

90i EQ-A014-4255 Scarbroug Sizing and setting of the NuScale will revise design Confirma NuScale will add Valve Thermal Relief h TRVs. specification. tory Data Sheet as Valves acceptable response.

90j EQ-A014-4255 Scarbroug Preparation of an operating See Item 20.j Closed Response acceptable.

Thermal Relief h experience report related to Valves the specific valve design to be provided by the supplier.

90k EQ-A014-4255 Scarbroug Documentation in accordance See Item 20.k Closed Response acceptable.

Thermal Relief h with ASME QME-1-2007.

Valves 91 EQ-B020-2140 Strnisha Does the design specification During Telecom on June, Closed The staff verified that ECCS Valves identify LOCA-generated 20, 2018, NuScale stated NuScale Document ER-debris, latent debris, and that LOCA-generated B020-4364 identifies the chemical products debris, latent debris, and LOCA-generated debris, chemical products are latent debris, and identified in NuScale chemical products and Document ER-B020-4364 that NuScale Design revision 0, GSI-191, Specification EQ-B020-Assessment of Debris 2140, ASME Design Accumulation on Specification for Pressurized Water Reactor Emergency Core

[PWR] Sump Performance Cooling System Valves,

- Evaluation of Ex-Vessel Revision 3, references and In-Vessel Effects. NuScale Document ER-

B020-4364. This item is closed.

92 EQ-B020-2140 Strnisha Does the design specification NuScale proposed to revise Confirma Acceptable ECCS Valves require the application of FSAR Revision 3 to tory Appendix QR-B in ASME incorporate ASME QME QME-1-2007 and are the 2007, Appendix QR-B with qualification environments exceptions as stated in and post-accident operating NuScale Letter dated times October 17, 2018 (ML18290A557) and to revise the applicable specifications.

93 EQ-A010-2235 Strnisha Does the design specification Same as item 92 Confirma Same as item 92 PSCIVs require the application of tory Appendix QR-B in ASME QME-1-2007 and are the qualification environments and post-accident operating times 94 EQ-A010-2224 Strnisha Does the design specification Same as item 92 Confirma Acceptable SSCIVs require the application of tory Appendix QR-B in ASME QME-1-2007 and are the qualification environments and post-accident operating times 95 EQ-B030-2258 Strnisha Does the design specification Same as item 92 Confirma Acceptable RMX Check require the application of tory Valves Appendix QR-B in ASME QME-1-2007 and are the qualification environments and post-accident operating times 96 EQ-B010-3227 Strnisha Does the design specification Same as item 92 Confirma Acceptable CVCS Class 3 require the application of tory Valves Appendix QR-B in ASME QME-1-2007 and are the

qualification environments and post-accident operating times 97 EQ-B030-2258 Strnisha Does the design specification Same as item 92 Confirma Acceptable DHR Actuation require the application of tory Valves Appendix QR-B in ASME QME-1-2007 and are the qualification environments and post-accident operating times 98 EQ-A014-4255 Strnisha Does the design specification Same as item 92 Confirma Acceptable Thermal Relief require the application of tory Valves Appendix QR-B in ASME QME-1-2007 and are the qualification environments and post-accident operating times 99 EQ-A011-2179 Strnisha Does the design specification Same as item 92 Confirma Acceptable RSVs require the application of tory Appendix QR-B in ASME QME-1-2007 and are the qualification environments and post-accident operating times 100 EQ-A023-1943 Law In Table 3-1, where is the 10 psid is a convenient and Closed Response acceptable.

Reactor maximum design pressure bounding value established Internals difference of 10 psid from? for design conditions. (EC-A010-3204, Revision 1).

Pressure differentials as a result of thermal transients, including blowdown conditions are provided in respective loading specification that apply to various service level (A, B, C, D) conditions.

101 EQ-A023-1943 Law When will deflection limit in Deflection limits in Table 3- Closed This issue was assessed Reactor Table 3-3 be available? 3 are dependent on several and closed via the Internals factors. Deflection limits for control rod drive system the upper riser section and

control rod drive shaft audit in September 2018 supports are dependent on (ML18235A509).

the results of control rod drop alignment testing (testing is currently in progress). Final determination of all deflection limits depend both on established manufacturing tolerances as well as critical review of component functions, both of which are being performed as part of design for lifecycle (DFL) efforts which are currently in progress.

102 EQ-A023-1943 Law Explain the use of OBE loads An OBE event is Closed Response acceptable.

Reactor in Table 4-1. Is OBE load established as 1/3 of SSE.

Internals included in Level A, B and C OBE is only included in analyses? fatigue analysis conducted to satisfy service level B loading conditions and is not considered as part of satisfying service level A or C loading conditions. This approach is consistent with guidance in Appendix S of 10 CFR Part 50, as well as NUREG-0800, Section 3.7.3 103 EQ-A023-1943 Law When will mechanical loads in This question applies to Open The staff considers the Reactor Appendix A be available? EQ-A023-1943, Revision 1 mechanical loads for Internals What about other loads such (ASME Design RVI, which is information as thermal and seismic? Specification for Reactor required to have a Vessel Internals). The completed design scope of Appendix A specification, to be includes mechanical loads necessary information due to support/restraint of for a safety finding, and the RVI within the reactor should not be addressed

pressure vessel (RPV). solely using ITAAC.

The necessary analysis This issue remains open required to develop these and will need to be loads has not yet been reviewed in a future performed, but will be audit required to be completed to develop a certified ASME design report for the RVI.

See ITAAC Items 02.01.01 and 02.01.03 for inspection commitments which provided verification that certified design reports (inclusive of all ASME code analysis) are provided.

Thermal (transient) loads are available in ER-A010-2529, Revision 0 (RXM Thermal Transient Load Definition Specification).

Seismic loads are available in EC-A010-3559, Revision 4 (Reactor Module Seismic Calculation).

104 EQ-A023-1943 Wu In ASME Design Stress analysis result for Open The staff requested Reactor Specifications: EQ-A010- the RPV (conducted in NuScale to provide Internals 2235, for Primary System CIV accordance with analysis preliminary stress (PSCIV), EQ-A023-1775 for requirements of EQ-A011- analysis for RVI and Reactor Pressure Vessel, 1775) are provided in EC- PSCIVs.

EQ-A023-1943 for Reactor A011-2278, Revision 0.

Vessel Internals, it is not clear EC-A011-2278 presents No CUF and Fen were as to how the stress analyses the stress analysis for calculated for reactor were performed for loads to applicable Service level A, vessel as required by be considered for the design B, C and D conditions, the design specification in compliance with service including evaluation of EQ-A011-1775.

Level A, B, C and D limits. thermal and mechanical Please list and upload the transient events. No stress and fatigue stress analysis reports for Generically, thermal and analysis for RVIs and staff review for thermal and mechanical transients are PSCIV was available for mechanical transients related covered under Service level review and will need to

to DBPB (CVCS injection and A and B conditions. be reviewed in a future discharging line breaks, Inadvertent main steam audit MSPB and FWPB), and isolation valve closure is a actuations of RVVs, RSVs, Service level B event as RRVs and inadvertent MSIV defined in FSAR Section closure, if they become 3.9 and Table 3.9-1.

available. Opening of the ECCS RRV and RVV and RSVs are defined as Service Level C events and DBPB are defined as Service level D (Section 3.9 of the FSAR and Table 3.9-1). All of the indicated transient events are addressed in the analysis documented in EC-A011-2278. There are no other stress calculations applicable to the RPV.

Final stress analysis results from the RVI and PSCIVs conducted in accordance with EQ-A010-2235, EQ-A023-1943 are not currently available.

NuScale does not consider these analyses to be part of the DCA review. Design analysis required for these components has been defined within the applicable ASME design specifications (provided for review) and will be completed in support of providing certified design reports for these ASME components. See ITAAC items 02.01.01 and

02.01.03 for inspection commitments which provide verification that certified design reports (inclusive of all ASME code analysis) are provided.

105 EQ-A023-1943 Wu Open items are listed in A factor of 2.0 is not a Closed Response acceptable.

Reactor Section 1.6 of EQ-A023-1775. standard dynamic loading Internals It appears that RXM Nozzle factor, it is a theoretical loads are either preliminary or maximum value. There are not available. The staff asked no specific regulatory or NuScale when these open industry standards or Items will be closed. Section requirements which require 4.4.1 of ASME Design use of a factor of 2.0. A Specification, EQ-A023-1775 factor of 2.0 represents a for Reactor Pressure Vessel, worst case scenario and states that Dynamic load may be unnecessarily factors of 15 percent (1.15 limiting to apply to all times the expected DW load) design situations. The shall be applied at all lifting factor of 1.15 selected by and transportation support NuScale applies to points. The staff requests the controlled lifts. This factor basis for using a 1.15 factor in is selected consistent with lieu of 2.0 standard dynamic guidance provided in load factor. NUREG-0612. NUREG-0612, Section 1.2 defines a handling system as All load bearing components used to lift the load, including the crane or hoist, the lifting device, and interfacing load lift points.

Based on this definition, the interfacing load points are part of the components (e.g., CNV, RPV, RXM, etc.) and guidance for the handling system applies to interfacing points on the component being lifted.

NUREG-0612 (paragraph 5.1.1(7)) indicates the crane should be design to meet applicable requirements of criteria or CMAA-70. CMAA-70 (Section 3.3.2.1.1.4.2) indicates a minimum hoist load factor (i.e. dynamic loading factor) of 15 percent. The NuScale requirement of a factor of 1.15 is consistent with CMAA-70.

As discussed in DCA Tier 2, Section 9.1.5.1, the NuScale reactor building crane is designed in accordance with NOG-1 and therefore no safety related SSCs (e.g. the RXM) are affected by load drops. In lieu of application of the guidance in NUREG-0612, as supplemented by NOG-1, there does not appear to be any other regulatory guidance related to the selection of dynamic load factors for lifting and handling of safety related SSCs. The full, practical implementation of the factor of 1.15 is not necessarily fully defined by a design specification. In order to

verify/enforce this design dynamic loading factor, measures such as accelerometers may be employed during shipping and/or other controls may be applied during controlled lifts. These additional measures and controls for shipping and conduct of controlled lifts have not been developed at this time and may or may not be implemented through the ASME design specification.

106 EQ-A023-1943 Wu Section 2.2 of EC-A011-3428 The evaluations performed Closed NuScales response is Reactor and EC-A013-3036-01, stated in EC-A011-3428 and EC- acceptable as the case Internals that the maximum allowable A013-3036 are very was for the loading gap between flanges at the conservative analyses to beyond the design center of the outer o-ring is provide a bounding (lowest condition.

assumed to be 0.03 inches. possible) maximum Therefore, the pressure ultimate pressure at which capacity is determined when the vessel is considered to the flange gap of 0.03 begins fail. Failure criteria to form. It appears that the established that no leakage opening of the flange joint is a would occur with a 0.03 result of deformation from the inch gap or less at the o-opening in the shell deforming ring. It is not until the gap resulting from the vessel shell exceeds a 0.03 inch gap expansion. The opening will that leakage would be allow mass to escape from expected to occur. The RPV to CNV and from CNV to gap at the reported the surrounding pool water. pressure is just prior to the The applicant stated that seal being lost and since actual seal/o-ring therefore there is no specifications are not leakage to calculate.

available, the severity of the Neither the RPV nor CNV failure is uncertain. Was a vessels are expected to thermal hydraulic analysis reach accident conditions performed for the blowdown at these higher pressures.

to the CNV during the RPV depressurization?

106a EQ-A023-1943 Wu Also, what are the The evaluation performed Closed The response is Reactor consequences of 1240 psi in EC-A013-3036 is a very acceptable for the Internals steam escaping from the CNV conservative analysis to reason as stated in to the pool water? It might provide a bounding (lowest Question 106.

cause a RXB vibration similar possible) maximum to the suppression pool ultimate pressure at which loading in the BWR plants. containment is considered to fail. Failure criteria was established that no leakage would occur at a 0.03 inch gap or less at the o-ring. It is not until the gap exceeds 0.03 inch that leakage would be expected to occur. The containment is not expected to reach any accident conditions at this pressure or higher. The 1240 psi pressure is a bounding condition when containment has been considered to fail so no leakage is calculated. It is expected that a more realistic ultimate pressure will be at a significantly higher pressure.

107 EQ-A023-1943 Wu In Section Lifting, handling, All handling loads are Closed Response acceptable.

Reactor and transportation loads are covered by requirement Internals not required to meet ASME 4.4.3. In a future revision stress limits specified in we may choose to clarify Section 4.1. However, the this and explicitly break out ASME Service Level B maintenance loads as a primary limits shall be used as separate requirement but the allowable limits for the the current requirement is lifting, handling and intended to cover all transportation loads. The handling loads.

lifting points shall be analyzed

to ensure minimum safety factors of five, (5) for material ultimate strength and three (3) for material yield strength are maintained for all lifting and handling conditions including consideration of the dynamic load factor, specified in Section 4.4.1. Are the lifting, handling and transportation loads shall be considered during the refueling operation for the plant life of 60 years.

108 EP-0303-21019 Le In the Procedure section Revision 6 of EP-0303- Closed Response acceptable.

Classification of (page 13 of 35), the applicant 2109 removed to NuAQ as SSCs states NuAQ = NuScale it is no longer applicable.

augmented quality. This sub- All B1 and B2 items that classification includes the require augmented quality functions that are identified by requirements are reflected NuScale that require in DCD Tier 2, Table 3.2-1.

augmented requirements. See Note 2 and Note 3 of These B1 and B2 function, Table 3.2-1.

due to their importance to safety, would not be treated as commercial grade and require augmentation. The staff finds this procedure is not clear. If B1 and B2 function are not be treated as commercial grade and require augmentation, will, DCD Tier 2, Table 3.2-1, reflect that these B1 and B2 components require NuScale augmented quality?

109 Dwg. NP12 Le On Sheet 2 of 3, class break NuScale design basis does Closed The staff requests that B010-M-PD- of SRW and CVC indicates not use class break in the applicant provide the 1021-S02 that the break occurs on the design drawings. ASME class break information pipe line. Provide the Class is identified in piping in this drawing. The classification in each P&ID. information of class

clarification of this class break breaks in ER-A013-4785 location. Rev. 0 - Figure 7.1, is acceptable.

RAI 9619 addresses this item. This item is closed.

110 Dwg. NP12 Le On Sheet 3 of 3, CNT line to NuScale design basis does Closed The staff requests the B010-M-PD- CVC line indicates there is a not use class break in applicant provides the 1021-S02 class break at the isolation design drawings. ASME class break information valve. However, the isolation Class is identified in piping in this drawing. The valve location is not clearly classification in each P&ID. information of class defined. Provide the breaks in ER-A013-4785 clarification that the class Rev. 0 - Figure 7.1, is break location is on the acceptable.

second isolation valve.

RAI 9619 addresses this item. This item is closed.

111 COL Item 3.10- COL Item 3.10-2 states, A Regulatory Guide 1.148 Closed 2 COL applicant that references has been withdrawn as the NuScale Power Plant documented in design certification will ML13066A552. As stated develop the equipment in RG 1.100, Revision 3, qualification database and The NRC is revising this ensure equipment RG (i.e., Revision 3 of RG qualification record files are 1.100) to endorse with created for the structures, exceptions and systems, and components clarifications, IEEE Std.

that require seismic 344-2004 and ASME QME-qualification. However, the 1-2007. (This is the first following requirement stated time the NRC has endorsed in the SRP is omitted: ASME QME-1). This Identification of all design revision of the RG will also (functional) specifications and subsume RG 1.148.

qualification reports and their Specifically, Sections B.1 locations. Functional and C1 of this RG endorse, specifications for active valve with exceptions and assemblies should conform to clarifications, the entire RG 1.148, Functional IEEE Std. 344-2004 and

Specification for Active Valve Section QR General Assemblies in Systems Requirements and Non-Important to Safety in Nuclear mandatory Appendix QR-A Power Plants. Please Seismic Qualification of explain how the design Active Mechanical functional specifications and Equipment, to ASME qualification reports and valve QME-1 2007 for the locations are specified in the seismic qualification of design document. electrical and active mechanical equipment Note: NUREG 0800, Revision 4, still references RG 1.148 even though it has been withdrawn.

Recommend withdrawal of this question as it does not apply.

112 EC-A013-3377 Huang Document EC-A013-3377 on NuScales response stated Closed Closed to NuScale page 64 of 128 states, Due that poor quality is not corrective action to poor quality mesh on the factual and needs to be program, tracking CNV26 cover, results from updated (document not number CR-0918-61768.

CNV27 and CNV30 are currently in eRR to verify).

considered instead. This is acceptable due to similar State that this model is geometry under similar similar to CNV27 and loading. CNV30 and per result tables of Appendix F results Explain the reason for the are inline.

poor quality mesh on CNV26.

Will it be rerun at a later time with a better quality mesh?

Was it due to a software issue, or is it due to assumptions made in the analysis?

U.S. NUCLEAR REGULATORY COMMISSION STAFF REPORT OF REGULATORY AUDIT FOR NUSCALE POWER, LLC; FOLLOW-UP AUDIT OF COMPONENT DESIGN SPECIFICATIONS May 14, 2018 - October 8, 2018 List of Attendees Name Organization Marieliz Vera Amadiz NRC Michael Breach NRC Jason Huang NRC Yiu Law NRC Tuan Le NRC Shanlai Lu NRC Thomas G. Scarbrough NRC James Strnisha NRC Cheng-Ih (John) Wu NRC JJ Arthur NuScale Marty Bryan NuScale Patrick Conley NuScale Scott Harris NuScale Dan Lassiter NuScale Wayne Massie NuScale Gary McGee NuScale Enclosure 2