ML19080A159

LLC - Supplemental Response to NRC Request for Additional Information No. 509 (Erai No. 9608) on the NuScale Design Certification Application

ML19080A159
Person / Time
Site:	NuScale
Issue date:	03/21/2019
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
References
RAIO-0319-64926
Download: ML19080A159 (14)

Text

RAIO-0319-64926 March 21, 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. 509 (eRAI No. 9608) on the NuScale Design Certification Application

REFERENCES:

1. U.S. Nuclear Regulatory Commission, "Request for Additional Information No. 509 (eRAI No. 9608)," dated October 23, 2018

2. NuScale Power, LLC Response to NRC "Request for Additional Information No. 509 (eRAI No.9608)," dated December 20, 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 Enclosure to this letter contains NuScale's supplemental response to the following RAI Question from NRC eRAI No. 9608:

14.03.08-1 This letter and the enclosed response make no new regulatory commitments and no revisions to any existing regulatory commitments.

If you have any questions on this response, please contact Carrie Fosaaen at 541-452-7126 or at cfosaaen@nuscalepower.com.

Sincerely, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution: Gregory Cranston, NRC, OWFN-8H12 Samuel Lee, NRC, OWFN-8H12 Cayetano Santos, NRC, OWFN-8H12 : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9608 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0319-64926 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9608 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.: 9608 Date of RAI Issue: 10/23/2018 NRC Question No.: 14.03.08-1 This is a follow-up to RAI 9303, Question 12.03-52 Regulatory Basis 10 CFR 52.47(b)(1), requires that the application contain the Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC), that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification (DC) has been constructed and will be operated in conformity with the DC, the provisions of the Atomic Energy Act (AEA), and NRC regulations.

Appendix A to 10 CFR Part 50 "General Design Criteria (GDC) for Nuclear Power Plants,"

Criterion 61"Fuel storage and handling and radioactivity control," requires systems which may contain radioactivity to be designed with suitable shielding for radiation protection and with appropriate containment, confinement, and filtering systems.

GDC Criterion 60 "Control of releases of radioactive materials to the environment," requires that the nuclear power unit design include means to control suitably the release of radioactive materials in gaseous and liquid effluents and to handle radioactive solid wastes produced during normal reactor operation, including anticipated operational occurrences.

The Acceptance Criteria of DSRS Section 12.3-12.4, "Radiation Protection Design Features,"

contains a number of criteria related to the radiation protection design, including:

Systems, Structures and Components (SSC) that are described in the application, should be designed to maintain radiation exposures to operating and maintenance personnel ALARA.

NuScale Nonproprietary

Structures housing radioactive waste processing systems or components should be classified using the guidance for potential exposure to site personnel found in RG 1.143.

In addition, DSRS Section 14.3.8 indicates that the reviewer should ensure that Tier 1 identifies and describes, commensurate with their safety significance, those SSCs that provide radiation shielding, confinement or containment of radioactivity, ventilation of airborne contamination, or radiation (or radioactivity concentration) monitoring for normal operations and during accidents.

Background

In a letter issued by the NRC to NuScale, "NuScale Letter on Draft Standard ITAAC," and "Draft Standardized DCA ITAAC Tables - Enclosure to NuScale Letter on Draft Standard ITAAC,"

dated April 8, 2016 (ADAMS Accession Nos. ML16096A132 and ML16097A123), the staff described the ITAAC that are applicable to the staff review of the NuScale application. These standard ITAAC included:

R07 "As-Built Inspection and Reconciliation Analysis," to verify that the structures, systems, and components of the non-Seismic Category I radioactive waste system are designed and constructed to the standards of RG 1.143 to withstand the design loads without loss of structural integrity.

In Tier 2, Sections 11.2, 11.3, and 11.4, the applicant addresses compliance with RG 1.143 and provides the design criteria for which the components of the radwaste systems are to be designed. In the response to RAI 9303, Question 12.03-52, the applicant provided several reasons for not including an ITAAC for verifying that the radwaste systems are designed in accordance with those criteria. These reasons included that the radwaste systems were not safety-related or risk significant, that they did not support safety or risk-significant functions, and because the DCD included several other ITAAC related to the radwaste systems and the radwaste building. These include ITAAC that mitigate the release of radioactivity by initiating the closure of valves upon detection of a high radiation signal. However, these ITAAC do not ensure that the systems are built to the proper criteria. The staff agrees that the radwaste systems are not safety-related, however, they contain some of the most radioactive components in the plant, besides the core and spent fuel. An ITAAC ensuring that the systems are built properly will provide the staff with reasonable assurance that a radwaste system failure will not result in a significant radiological release or worker exposure event. Therefore, the staff does not believe that the response includes adequate justification for excluding the ITAAC.

NuScale Nonproprietary

Key Issue DCD Tier 1, Chapter 1 "Certified Design Descriptions and Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC)," does not contain ITAAC corresponding to R07, with respect to verifying that the as-built SSCs containing radioactive waste meet the design criteria, consistent with the guidance contained within RG 1.143, provided for demonstrating compliance with the provisions of 10 CFR Part 20 related to the protection of the health and safety of members of the public and protection of occupational radiation workers.

Question Please provide the specified ITAAC (R07) to ensure that the as-built components of the radwaste systems meet the appropriate design criteria or describe an equivalent way that will ensure that the radwaste systems will be built as designed.

NuScale Response:

During a January 22, 2019 public meeting the NRC staff agreed to provide NuScale with example ITAAC that could address concerns raised in eRAI 9608. The Staff stated other variations may also be acceptable. For example, instead of listing the Regulatory Guide (RG) in the ITAAC, NuScale may wish to have the ITAAC list the appropriate design criteria from the RG. An alternative could also have the ITAAC reference a separate table with the components and piping segments and the appropriate design criteria. Two examples were provided by the NRC for guidance:

Design Commitment Inspection, Tests, Acceptance Criteria Analysis The liquid radwaste system An inspection and A report exists and concludes non-Seismic Category I reconciliation analysis that the as-built degasifiers and degasifiers, including piping will be performed of the associated piping up to and up to and including the first as-built liquid radwaste including the first isolation valves isolation valves are system non- Seismic meet the design criteria of RG constructed to the standards Category I degasifiers, 1.143, RW-IIa.

of RG 1.143, RW-IIa, and will including piping up to withstand design loads and including the first without loss of structural isolation valves.

integrity.

NuScale Nonproprietary

Design Commitment Inspection, Tests, Acceptance Criteria Analysis The gaseous radwaste An inspection and A report exists and concludes system non-Seismic Category reconciliation analysis that the as-built guard and decay I guard and decay beds, will be performed of the beds, including all piping including all piping between as-built gaseous between the beds up to and the beds up to and including radwaste system non- including the first isolation valves the first isolation valves prior Seismic Category I prior to the guard bed and to the guard bed and following guard and decay beds, following the decay beds meet the decay beds are including all piping the design criteria of RG 1.143, constructed to the standards between the beds up to RW-IIa.

of RG 1.143, RWIIa, and will and including the first withstand design loads isolation valves prior to without loss of structural the guard bed and integrity. following the decay beds.

NuScale evaluated the ITAAC information provided by the NRC Staff and a follow-up public call was held on February 19, 2019. NuScale presented to the NRC the wording of the ITAAC that NuScale intended to provide in the supplemental response to 9608.

This response supplements the previous response to 9608. NuScale has added ITAAC 03.14.03 to Tier 1 Table 3.14-2, and revised Table 3.14-1 to include the RW-IIa components and piping in the liquid and gaseous radioactive waste systems; Design Commitment Inspection, Tests, Acceptance Criteria Analysis The RW-IIa components and An inspection and A report exists and concludes piping used for processing reconciliation analysis that the as-built RW-IIa gaseous radioactive waste will be performed of the components and piping used for are constructed to the as-built RW-IIa processing gaseous radioactive standards of RW-IIa. components and piping waste listed in Table 3.14-1 meet used for processing the RW-IIa design criteria.

gaseous radioactive waste.

Accordingly, Tier 2 Table 14.3-2 was revised to include ITAAC 03.14.03; ITAAC No. System Discussion 03.14.03 EQ The classification of SSC that contain radioactive waste in accordance with RG 1.143 is discussed in Section 3.2.1.4. The scope of the equipment for this design commitment is the nonsafety-related, radioactive waste components and piping which meet both of the following criteria:

NuScale Nonproprietary

• Classified as RW-IIa in accordance with RG 1.143

• Designed for processing gaseous radioactive waste As described in Section 11.2.2.4 for the liquid radioactive waste system (LRWS) and Section 11.3.2.4 for the gaseous radioactive waste system (GRWS), component classification applies to components up to and including the first isolation device. Tier 1 Table 3.14-1 identifies the components and piping for which this ITAAC is applicable.

An ITAAC inspection and reconciliation analysis is performed of the as-built LRWS and GRWS RW-IIa components and piping used for processing gaseous radioactive waste to ensure that deviations between the drawings used for construction and the as-built RW-IIa components and piping are reconciled. A report concludes the as-built RW-IIa components and piping meet the design criteria of RG 1.143, RW-IIa.

Impact on DCA:

Tier 1 Section 3.14 and Tier 2 Section 14.3 have been revised as described in the response above and as shown in the markup provided in this response.

NuScale Nonproprietary

NuScale Tier 1 Equipment Qualification - Shared Equipment 3.14 Equipment Qualification - Shared Equipment 3.14.1 Design Description

System Description

The scope of this section is equipment qualification (EQ) of equipment shared by NuScale Power Modules 1 through 12.

RAI 14.03.03-6, RAI 14.03.03-7 This section applies to the RPV support stand (the only common, safety-related equipment) and a limited population of common, nonsafety-related equipment that has augmented Seismic Category I or environmental qualification requirements. The nonsafety-related equipment in this section provides one of the following nonsafety-related functions:

RAI 14.03.03-6, RAI 14.03.03-7

• Provides physical support of irradiated fuel (fuel handling machine, spent fuel storage racks, reactor building crane, and module lifting adapter).

• Provides a path for makeup water to the UHS.

• Provides containment of the UHS water.

• Monitors UHS water level.

RAI 14.03.08-1S1 Additionally, this section applies to the nonsafety-related, RW-IIa components and piping used for processing gaseous radioactive waste.

Design Commitments RAI 14.03.03-6, RAI 14.03.03-7

• The common, Seismic Category I equipment, including its associated supports and anchorages, withstands design basis seismic loads without loss of its function(s) during and after a safe shutdown earthquake. The scope of equipment for this design commitment is the common, safety-related equipment, and the common, nonsafety-related equipment that provides one of the following nonsafety-related functions:

RAI 14.03.03-6, RAI 14.03.03-7 Provides physical support of irradiated fuel (fuel handling machine, spent fuel storage racks, reactor building crane, and module lifting adapter)

RAI 14.03.03-6, RAI 14.03.03-7 Provides a path for makeup water to the UHS RAI 14.03.03-6, RAI 14.03.03-7 Provides containment of UHS water RAI 14.03.03-6, RAI 14.03.03-7 Monitors UHS water level RAI 14.03.03-6, RAI 14.03.03-7

• The common electrical equipment located in a harsh environment, including its connection assemblies, withstands the design basis harsh environmental conditions experienced during normal operations, anticipated operational occurrences, design Tier 1 3.14-1 Draft Revision 3

NuScale Tier 1 Equipment Qualification - Shared Equipment basis accidents, and post-accident conditions, and performs its function for the period of time required to complete the function. The scope of equipment for this design commitment is the nonsafety-related equipment that provides monitoring of the UHS water level and the non-safety -related electrical equipment on the fuel handling machine and reactor building crane used to physically support irradiated fuel.

RAI 14.03.08-1S1

• The RW-IIa components and piping used for processing gaseous radioactive waste are constructed to the standards of RW-IIa.

3.14.2 Inspections, Tests, Analyses, and Acceptance Criteria Table 3.14-2 contains the inspections, tests, and analyses for EQ -- shared equipment.

Tier 1 3.14-2 Draft Revision 3

Tier 1 NuScale Tier 1 RAI 14.03.03-2, RAI 14.03.03-6, RAI 14.03.03-7, RAI 09.01.03-1, RAI 14.03.08-1S1 Table 3.14-1: Mechanical and Electrical/Instrumentation and Controls Shared Equipment Equipment Identifier Description Location EQ EQ Program Seismic Class 1E EQ Environment Category Category(1)

Module Assembly Equipment - Bolting None RPV Support Stand RXB - UHS N/A N/A I N/A N/A Fuel Handling Equipment B140-CRN-001 Fuel handling machine (FHM) RXB 100'-0" Elevation Harsh Electrical I No B Mechanical Spent Fuel Storage System 00-SFS-SRK-0001 Fuel Storage Racks RXB - Spent Fuel Pool N/A N/A I N/A N/A Ultimate Heat Sink LI/LIT-101A Pool level instruments RXB - UHS 24-0 Elevation Harsh Electrical I No A LI/LIT-101B LI/LIT-102A LI/LIT-102B 3.14-3 None Water Makeup Line RXB - UHS N/A N/A I N/A N/A Reactor Building Cranes 00-RBC-CRN-001 Reactor Building crane RXB 100-0 thru 145-6 Harsh Electrical I No B Elevation Mechanical 00-RBC-MHE-0001 Module Lifting Adapter RXB - Various N/A N/A I N/A N/A Reactor Building Components Equipment Qualification - Shared Equipment None UHS Pool Liner and Dry Dock RXB - UHS N/A N/A I N/A N/A Liner None RXB Over-pressurization Vent RXB N/A N/A I N/A A (OPV) (2)

Liquid Radioactive Waste System None Degasifiers RXB N/A N/A RW-IIa N/A N/A None For each line connected to a RXB N/A N/A RW-IIa N/A N/A degasifier, piping and components up to and including Draft Revision 3 the first isolation valve

Table 3.14-1: Mechanical and Electrical/Instrumentation and Controls Shared Equipment (Continued)

Tier 1 NuScale Tier 1 Equipment Identifier Description Location EQ EQ Program Seismic Class 1E EQ Environment Category Category(1)

Gaseous Radioactive Waste System None Charcoal Guard Bed RWB N/A N/A RW-IIa N/A N/A None For each line connected to the RWB N/A N/A RW-IIa N/A N/A charcoal guard bed, piping and components up to and including the first isolation valve None Charcoal Decay Beds RWB N/A N/A RW-IIa N/A N/A None For each line connected to a RWB N/A N/A RW-IIa N/A N/A charcoal decay bed, piping and components up to and including the first isolation valve Notes:

1. EQ Categories:

• A - Equipment that will experience the environmental conditions of design basis accidents for which it must function to mitigate said accidents, and that will be qualified to demonstrate operability in the accident environment for the time required for accident mitigation with safety margin to failure.

3.14-4

• B - Equipment that will experience the environmental conditions of design basis accidents through which it need not function for mitigation of said accidents, but through which it must not fail in a manner detrimental to plant safety or accident mitigation, and that will be qualified to demonstrate the capability to withstand the accident environment for the time during which it must not fail with safety margin to failure.

Equipment Qualification - Shared Equipment Draft Revision 3

NuScale Tier 1 Equipment Qualification - Shared Equipment RAI 14.03.03-6, RAI 14.03.03-7, RAI 14.03.08-1S1 Table 3.14-2: Equipment Qualification - Shared Equipment ITAAC No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria

1. The common Seismic Category I i. A type test, analysis, or a i. A seismic qualification record form equipment, including its associated combination of type test and exists and concludes that the supports and anchorages, withstands analysis will be performed of the common Seismic Category I design basis seismic loads without loss common Seismic Category I equipment listed in Table 3.14-1, of its function(s) during and after a equipment, including its including its associated supports safe shutdown earthquake. The scope associated supports and and anchorages, will withstand the of equipment for this design anchorages. design basis seismic loads and commitment is common, safety- perform its function during and related equipment, and common, after a safe shutdown earthquake.

nonsafety-related equipment that ii. An inspection will be performed of ii. The common Seismic Category I provides one of the following the common Seismic Category I as- equipment listed in Table 3.14-1, nonsafety-related functions: built equipment, including its including its associated supports

• Provides physical support of associated supports and and anchorages, is installed in its irradiated fuel (fuel handling anchorages. design location in a Seismic machine, spent fuel storage racks, Category I structure in a reactor building crane, and module configuration bounded by the lifting adaptor) equipments seismic qualification

• Provides a path for makeup water to record form.

the UHS

• Provides containment of UHS water

• Monitors UHS water level

2. The common electrical equipment i. A type test or a combination of i. An equipment qualification record located in a harsh environment, type test and analysis will be form exists and concludes that the including its connection assemblies, performed of the common common electrical equipment withstands the design basis harsh electrical equipment, including its listed in Table 3.14-1, including its environmental conditions connection assemblies. connection assemblies, performs experienced during normal its function under the operations, anticipated operational environmental conditions occurrences, DBA, and post-accident specified in the equipment conditions and performs its function qualification record form for the for the period of time required to period of time required to complete the function. complete the function.

The scope of equipment for this ii. An inspection will be performed of ii. The common electrical equipment design commitment is the common as-built electrical listed in Table 3.14-1, including its nonsafety-related equipment that equipment, including its connection assemblies, is installed provides monitoring of the UHS water connection assemblies. in its design location in a level and the non-safety -related configuration bounded by the EQ electrical equipment on the fuel record form.

handling machine and reactor building crane used to physically support irradiated fuel.

3. The RW-IIa components and piping i. An inspection and reconciliation i. A report exists and concludes that used for processing gaseous analysis will be performed of the the as-built RW-IIa components radioactive waste are constructed to as-built RW-IIa components and and piping used for processing the standards of RW-IIa. piping used for processing gaseous radioactive waste listed in gaseous radioactive waste. Table 3.14-1 meet the RW-IIa design criteria.

Tier 1 3.14-5 Draft Revision 3

Tier 2 NuScale Final Safety Analysis Report RAI 09.01.04-1, RAI 09.05.01-6, RAI 14.03.02-1, RAI 14.03.02-2, RAI 14.03.03-1, RAI 14.03.03-6, RAI 14.03.03-7, RAI 14.03.03-8, RAI 14.03.07-1, RAI 14.03.08-1S1, RAI 14.03.09-1, RAI 14.03.09-2, RAI 14.03.09-3, RAI 14.03.12-2, RAI 14.03.12-3 Table 14.3-2: Shared/Common Structures, Systems, and Components and Non-Structures, Systems, and components Based Design Features and Inspections, Tests, Analyses, and Acceptance Criteria Cross Reference(1)

ITAAC No. System Discussion DBA Internal/External Radiological PRA & Severe FP Hazard Accident 03.01.01 CRH Testing is performed on the CRE in accordance with RG 1.197, X Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors, Revision 0, to demonstrate that air exfiltration from the CRE is controlled. RG 1.197 allows two options for CRE testing; either integrated testing (tracer gas testing) or component testing. Section 6.4 Control Room Habitability, describes the testing requirements for the CRE habitability program. Section 6.4 provides the maximum air exfiltration allowed from the CRE.

In accordance with Table 14.2-18, a preoperational test using the tracer gas test method demonstrates that the air exfiltration from the CRE does not exceed the assumed unfiltered leakage rate provided in Table 6.4-1: Control Room Habitability System Design Parameters 14.3-55 for the dose analysis. Tracer gas testing in accordance with ASTM Certified Design Material and Inspections, Tests, Analyses, and E741 will be performed to measure the unfiltered in-leakage into the CRE with the control room habitability system (CRHS) operating.

03.01.02 CRH The CRHS valves are tested by remote operation to demonstrate the X capability to perform their function to transfer open and transfer closed under preoperational temperature, differential pressure, and flow conditions.

In accordance with Table 14.2-18, a preoperational test demonstrates that each CRHS valve listed in Tier 1 Table 3.1-1 strokes fully open and fully closed by remote operation under preoperational test conditions.

Preoperational test conditions are established that approximate Acceptance Criteria design-basis temperature, differential pressure, and flow conditions to the extent practicable, consistent with preoperational test limitations.

Draft Revision 3

Table 14.3-2: Shared/Common Structures, Systems, and Components and Non-Structures, Systems, and components Based Tier 2 NuScale Final Safety Analysis Report Design Features and Inspections, Tests, Analyses, and Acceptance Criteria Cross Reference(1) (Continued)

ITAAC No. System Discussion DBA Internal/External Radiological PRA & Severe FP Hazard Accident 03.14.03 EQ The classification of SSC that contain radioactive waste in accordance X with RG 1.143 is discussed in Section 3.2.1.4.

The scope of the equipment for this design commitment is the nonsafety-related, radioactive waste components and piping which meet both of the following criteria:

• Classified as RW-IIa in accordance with RG 1.143

• Designed for processing gaseous radioactive waste As described in Section 11.2.2.4 for the liquid radioactive waste system (LRWS) and Section 11.3.2.4 for the gaseous radioactive waste system (GRWS), component classification applies to components up to and including the first isolation device. Tier 1 Table 3.14-1 identifies the components and piping for which this ITAAC is applicable.

14.3-89 An ITAAC inspection and reconciliation analysis is performed of the Certified Design Material and Inspections, Tests, Analyses, and as-built LRWS and GRWS RW-IIa components and piping used for processing gaseous radioactive waste to ensure that deviations between the drawings used for construction and the as-built RW-IIa components and piping are reconciled. A report concludes the as-built RW-IIa components and piping meet the design criteria of RG 1.143, RW-IIa.

03.15.01 HFE Section 18.11, Design Implementation, describes the implementation of HFE aspects of the plant design.

An ITAAC inspection is performed to verify that the as-built configuration of main control room HSI is consistent with the as-designed configuration of main control room HSI as modified by the Integrated System Validation Report.

Acceptance Criteria Draft Revision 3