ML19024A422

LLC - Supplemental Response to NRC Request for Additional Information No. 154 (Erai No. 8938) on the NuScale Design Certification Application

ML19024A422
Person / Time
Site:	NuScale
Issue date:	01/24/2019
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
Shared Package
ML19024A421	List: ML19024A422
References
RAIO-0119-64288
Download: ML19024A422 (14)

Text

RAIO-0119-64288 January 24, 2019 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 Supplemental Response to NRC Request for Additional Information No. 154 (eRAI No. 8938) on the NuScale Design Certification Application

REFERENCES:

1. U.S. Nuclear Regulatory Commission, "Request for Additional Information No. 154 (eRAI No. 8938)," dated August 07, 2017

2. NuScale Power, LLC Response to NRC "Request for Additional Information No. 154 (eRAI No.8938)," dated December 05, 2018 The purpose of this letter is to provide the NuScale Power, LLC (NuScale) supplemental response to the referenced NRC Request for Additional Information (RAI).

The Enclosures to this letter contain NuScale's supplemental response to the following RAI Question from NRC eRAI No. 8938:

03.12-1 is the proprietary version of the NuScale Supplemental Response to NRC RAI No.

154 (eRAI No. 8938). NuScale requests that the proprietary version be withheld from public disclosure in accordance with the requirements of 10 CFR § 2.390. The enclosed affidavit (Enclosure 3) supports this request. Enclosure 2 is the nonproprietary version of the NuScale response.

This letter and the enclosed responses make no new regulatory commitments and no revisions to any existing regulatory commitments.

If you have any questions on this response, please contact Marty Bryan at 541-452-7172 or at mbryan@nuscalepower.com.

Sincerely, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution: Gregory Cranston, NRC, OWFN-8H12 Samuel Lee, NRC, OWFN-8H12 Marieliz Vera, NRC, OWFN-8H12 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0119-64288 : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 8938, proprietary : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 8938, nonproprietary : Affidavit of Zackary W. Rad, AF-0119-64289 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0119-64288 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 8938, proprietary NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0119-64288 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 8938, nonproprietary 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.: 8938 Date of RAI Issue: 08/07/2017 NRC Question No.: 03.12-1 SECY-90-377 and the NRC white paper on piping level of detail for design certification (ML14065A067) discuss the design information that is required at design certification without the need for design acceptance criteria (DAC) for the NRC staff to be able to make a final safety determination on piping issues at the design certification stage that meets the applicable requirements of 10 CFR 52. Specific to FSAR Tier 2, Section 3.12, provide the following information to support the staffs safety determination.

1. To demonstrate that the piping, which has been structurally evaluated based on the graded approach described in FSAR Tier 2, Section 14.3.2.3, conforms to the requirements of ASME Boiler and Pressure Vessel Code (BPV Code)Section III, mandated by 10 CFR 50.55a, provide the following information in response to this request. The information need not be included in the FSAR unless the applicant chooses to do so.

a) A tabulated, quantitative summary of the calculated maximum stresses and fatigue usage factors (if applicable) with a comparison to ASME BPV Code allowable stress values for each code equation. Include only maximum stresses and data at critical locations, including anchors, flued head anchor penetrations, nozzles, penetrations, flanged connections, valve and relief valve connections, branching pipe connections and pipe supports. List all applicable loads in load combination cases for each service level and code equation.

b) For equipment nozzles, a tabulated quantitative summary of the calculated reaction loads compared to specific nozzle allowable values.

NuScale Nonproprietary

c) For containment penetrations, quantitative maximum calculated results compared to allowable values from the penetration structural qualifications which include loads from both sides of the penetration.

NuScale Response:

The response to RAI 8938 Question 03.12-1, as submitted by NuScale letter RAIO-1218-63709, December 5, 2018, is supplemented by the following stress analysis results for the Main Steam System high-energy piping in the containment penetration area (Break Exclusion Zone).

Main Steam Lines within the Break Exclusion Zone The two high-energy ASME Class 2 main steam lines were analyzed from the containment vessel nozzle connection to the first six-way anchor restraint beyond the reactor bay wall. The stress analysis of these lines is contained in a single representative analysis model (Train 2) shown in Figures 1 and 2. The single analysis is representative as the two lines are mirror images about the CNV z-axis. The two trains of the main steam system do not interact and are not physically connected. The stress results and nozzle loads are shown below.

ASME Class 2 - Containment System Main Steam Piping and Main Steam System Piping Outside the CNV ASME Combination Joint Component Stress Allowable Ratio Code (psi) Stress Level (psi)

Design ASME Eq. (8) C00 Safe-end weld to custom ((2(a),(c) tee; uses SA-312 TP304 material allowable stress A ASME Eq. (9a) CN03 Branch at DHRSAV tee (( }}2(a),(c) A ASME Eq. (10a) CN04 Straight Pipe Adjacent (( }}2(a),(c) and Upstream of MSIV B ASME Eq. (9a) C00 Safe-end weld to custom (( }}2(a),(c) tee; uses SA-312 TP304 material allowable NuScale Nonproprietary

CN04 Straight Pipe Adjacent (( }}2(a),(c) and Upstream of MSIV B ASME Eq. (10a) CN04 Straight Pipe Adjacent (( }}2(a),(c) and Upstream of MSIV CN03 Branch at DHRSAV tee (( }}2(a),(c) C ASME Eq. (9a) C00 Safe-end weld to custom (( }}2(a),(c) tee; uses SA-312 TP304 material allowable CN04 Straight Pipe Adjacent (( }}2(a),(c) and Upstream of MSIV CN03 Branch at DHRSAV tee (( }}2(a),(c) D ASME Eq. (9a) CN06 Straight Pipe at TSS (( }}2(a),(c) guide support CN05 Straight Pipe Adjacent (( }}2(a),(c) and Upstream of MSIV D ASME CN07 Tee (( }}2(a),(c) NC-3655(b)(4) SAM Bending C00 Safe-end weld to custom (( }}2(a),(c) tee; uses SA-312 TP304 material allowable D ASME C00 Safe-end weld to custom (( }}2(a),(c) NC-3655(b)(4) tee; uses SA-312 TP304 SAM Axial material allowable Note: A portion of the main steam line piping is classified to ASME B31.1. The ASME Service Level D acceptance criteria is expanded to include this portion of ASME B31.1 piping and the results are included in this table. NuScale Nonproprietary

Main Steam Piping Outside the CNV - Global Nozzle Loads Joint C00 (Nozzle Safe-End to Piping Connection) - CNV 3 and CNV4 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Max Gravity(1) (( }}2(a),(c) Max Thermal (( }}2(a),(c) SSE (Inertia) (( }}2(a),(c) SSE (SAM) (( }}2(a),(c) Max Level A DFL(2) (( }}2(a),(c) Max Level B DFL(3) (( }}2(a),(c) Max Level C DFL(4) (( }}2(a),(c) Max Level D DFL(5) (( }}2(a),(c) Notes: (1) Gravity = Max of Operating DHRS vs. Non-Operating DHRS Conditions (2) Time History Case 8 (3) Max of Time History Cases 1, 5, 6, 8, 10, 11, 12, 18, 19, and 20 (4) Max of Time History Cases 7, 9, 10, 11, 12, 15,17, 18, 19, and 20 (5) Max of Time History Cases 2, 7, 10, 11, 12, 15, 18, 19, 20, and 21 NuScale Nonproprietary

((

                                                                                  }}2(a),(c)

Figure 1 - Containment System Main Steam Piping and Main Steam System Piping Outside the CNV - Overall Model NuScale Nonproprietary

((

                                                                                     }}2(a),(c)

Figure 2 - Containment System Main Steam Piping and Main Steam System Piping Outside the CNV - Detailed View Near MSIV Impact on DCA: The FSAR Tier 2, Section 3.12.1 has been revised as described in the response above and as shown in the markup provided with this response. NuScale Nonproprietary

ASME Code Class 1, 2, and 3 Piping Systems, Piping Components and NuScale Final Safety Analysis Report Associated Supports RAI 03.12-1S1, RAI 03.12-5 The two feedwater lines are analyzed from the reactor pressure vessel nozzle connection to anchor supports on the outboard side of the reactor bay wall. Inside containment, these lines are classified as ASME Class 2, while outside containment, the majority of this piping is classified as B31.1 with a limited portion classified as Class 2. The Class 2 main steam lines are similarly analyzed from the reactor pressure vessel nozzle connection to anchor supports on the outboard side of the reactor bay wall. Inside containment, these lines are classified as ASME Class 2, while outside containment, the majority of this piping is classified as B31.1 with a limited portion classified as Class 2. The main steam and feedwater lines isare selected because itthey experiences bounding loads for the Class 2 systems with respect toand are used as inputs for the leak-before-break (LBB) analysis. Detailed stress analyses are evaluated toinclude loads listed in Section 3.12.5.3from deadweight, seismic (dynamic), thermal expansion/contraction, and for Class 1 lines, fatigue (including environmentally assisted fatigue evaluation in conformance to Regulatory Guide (RG) 1.207. The results of these analyses confirm the acceptability of the piping designs. RAI 03.12-5 Piping stress analysis is performed only for the high-energy piping larger than NPS 1 in the NPM in order to support high energy line break evaluations. Therefore, piping evaluations are not performed for the containment flooding and drain line, the containment evacuation line, and the reactor component cooling water lines because they are moderate-energy, and for the emergency core cooling system lines and other small instrument lines because they are smaller than NPS 1. These lines that are excluded from stress evaluation are NPS 2 or smaller, and therefore can be routed using good engineering practice, because the support and nozzle loads for these lines are generally small. 3.12.2 Codes and Standards 10 CFR 50, Appendix A, General Design Criterion (GDC) 1 requires that structures, systems, and components (SSC) must be designed to quality standards commensurate with the importance of the safety functions to be performed. GDC 2 requires that SSC be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, and floods without the loss of their safety function. GDC 4 requires that the nuclear power plant SSC be designed to accommodate the effects of and be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents (LOCAs). GDC 14 requires that reactor coolant pressure boundary of the primary piping systems being designed, fabricated, constructed, and tested to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and gross rupture. GDC 15 requires reactor coolant systems (RCSs) and associated auxiliary, control, and protection systems be designed with sufficient margin to assure that the design condition of normal operation, including anticipated operational occurrences. Codes and standards used in the design of piping systems and piping supports are consistent with 10 CFR 50, Appendix A, GDCs 1, 2, 4, 14, 15, and 10 CFR 50 Appendix S as discussed in the following sections. The design codes for ASME Class 1, 2 and 3 piping systems are described below. Tier 2 3.12-2 Draft Revision 3

RAIO-0119-64288 : Affidavit of Zackary W. Rad, AF-0119-64289 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

NuScale Power, LLC AFFIDAVIT of Zackary W. Rad I, Zackary W. Rad, state as follows:

1. I am the Director, Regulatory Affairs of NuScale Power, LLC (NuScale), and as such, I have been specifically delegated the function of reviewing the information described in this Affidavit that NuScale seeks to have withheld from public disclosure, and am authorized to apply for its withholding on behalf of NuScale.

2. I am knowledgeable of the criteria and procedures used by NuScale in designating information as a trade secret, privileged, or as confidential commercial or financial information. This request to withhold information from public disclosure is driven by one or more of the following:

a. The information requested to be withheld reveals distinguishing aspects of a process (or component, structure, tool, method, etc.) whose use by NuScale competitors, without a license from NuScale, would constitute a competitive economic disadvantage to NuScale.

b. The information requested to be withheld consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), and the application of the data secures a competitive economic advantage, as described more fully in paragraph 3 of this Affidavit.

c. Use by a competitor of the information requested to be withheld would reduce the competitor's expenditure of resources, or improve its competitive position, in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.

d. The information requested to be withheld reveals cost or price information, production capabilities, budget levels, or commercial strategies of NuScale.

e. The information requested to be withheld consists of patentable ideas.

3. Public disclosure of the information sought to be withheld is likely to cause substantial harm to NuScale's competitive position and foreclose or reduce the availability of profit-making opportunities. The accompanying Request for Additional Information response reveals distinguishing aspects about the method and results by which NuScale develops its piping analyses.

NuScale has performed significant research and evaluation to develop a basis for this method and results and has invested significant resources, including the expenditure of a considerable sum of money. The precise financial value of the information is difficult to quantify, but it is a key element of the design basis for a NuScale plant and, therefore, has substantial value to NuScale. If the information were disclosed to the public, NuScale's competitors would have access to the information without purchasing the right to use it or having been required to undertake a similar expenditure of resources. Such disclosure would constitute a misappropriation of NuScale's intellectual property, and would deprive NuScale of the opportunity to exercise its competitive advantage to seek an adequate return on its investment. AF-0119-64289

4. The information sought to be withheld is in the enclosed response to NRC Request for Additional Information No. 154, eRAI No. 8938. The enclosure contains the designation "Proprietary" at the top of each page containing proprietary information. The information considered by NuScale to be proprietary is identified within double braces, "(( }}" in the document.

5. The basis for proposing that the information be withheld is that NuScale treats the information as a trade secret, privileged, or as confidential commercial or financial information. NuScale relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC § 552(b)(4), as well as exemptions applicable to the NRC under 10 CFR §§ 2.390(a)(4) and 9.17(a)(4).

6. Pursuant to the provisions set forth in 10 CFR § 2.390(b)(4), the following is provided for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld:

a. The information sought to be withheld is owned and has been held in confidence by NuScale.

b. The information is of a sort customarily held in confidence by NuScale and, to the best of my knowledge and belief, consistently has been held in confidence by NuScale.

The procedure for approval of external release of such information typically requires review by the staff manager, project manager, chief technology officer or other equivalent authority, or the manager of the cognizant marketing function (or his delegate), for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside NuScale are limited to regulatory bodies, customers and potential customers and their agents, suppliers, licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or contractual agreements to maintain confidentiality.

c. The information is being transmitted to and received by the NRC in confidence.

d. No public disclosure of the information has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or contractual agreements that provide for maintenance of the information in confidence.

e. Public disclosure of the information is likely to cause substantial harm to the competitive position of NuScale, taking into account the value of the information to NuScale, the amount of effort and money expended by NuScale in developing the information, and the difficulty others would have in acquiring or duplicating the information. The information sought to be withheld is part of NuScale's technology that provides NuScale with a competitive advantage over other firms in the industry.

NuScale has invested significant human and financial capital in developing this technology and NuScale believes it would be difficult for others to duplicate the technology without access to the information sought to be withheld. I declare under penalty of perjury that the foregoing is true and correct. Executed on January 24, 2019. Zackary W. Rad AF-0119-64289}}