ML19092A448
| ML19092A448 | |
| Person / Time | |
|---|---|
| Site: | NuScale |
| Issue date: | 04/02/2019 |
| From: | Rad Z NuScale |
| To: | Document Control Desk, Office of New Reactors |
| References | |
| LO-0419-65024 | |
| Download: ML19092A448 (41) | |
Text
LO-0419-65024 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com Docket No.52-048 April 2, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738
SUBJECT:
NuScale Power, LLC Submittal of Changes to Final Safety Analysis Report, Section 6.4 Control Room Habitability and Section 14.2 Initial Plant Test Program
REFERENCES:
Letter from NuScale Power, LLC to Nuclear Regulatory Commission, NuScale Power, LLC Submittal of the NuScale Standard Plant Design Certification Application, Revision 2, dated October 30, 2018 (ML18311A006)
Letter from NuScale Power, LLC to Nuclear Regulatory Commission, NuScale Power, LLC Submittal of Changes to Final Safety Analysis Report, Section 14.2, Initial Plant Test Program and Section 14.3, Certified Design Material and Insoections, Test, Analyses, and Acceptance Criteria, dated February 5, 2019 (ML19036A969)
During several public teleconferences with various NRC Staff, NuScale Power, LLC (NuScale) discussed potential updates to Final Safety Analysis Report (FSAR), Section 6.4 Control Room Habitability and Section 14.2, Initial Plant Test Program. As a result of this discussion, NuScale changed Sections 6.4 and 14.2. The Enclosure to this letter provides a mark-up of the FSAR pages incorporating revisions to Sections 6.4 and 14.2, in redline/strikeout format. NuScale will include this change as part of a future revision to the NuScale Design Certification Application.
Also included in an attachment are NuScales responses to the initial test program questions received by the NRC.
This letter makes no regulatory commitments or revisions to any existing regulatory commitments.
If you have any questions, please feel free to contact Carrie Fosaaen at 541-452-7126 or at cfosaaen@nuscalepower.com.
Sincerely, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution: Samuel Lee, NRC, OWFN-8G9A Gregory Cranston, NRC, OWFN-8G9A Cayetano Santos, NRC, OWFN-8H12
LO-0419-65024 Page 2 of 2 04/02/19 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com
Attachment:
NuScale Responses to ITP Questions
Enclosure:
Changes to NuScale Final Safety Analysis Report Sections, Section 6.4 Control Room Habitability and Section 14.2 Initial Plant Test Program
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 1 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com Pool Surge Control System Test #4 NRC Question 29.0: (a)
Provide a system level test here or under Pool Cleanup System Test #2 to test that the dry dock drain down system can use the pool purification system at the same time that the pool purification system is being used to clean the pool.
NuScale Response:
The normal operation of the Pool Cleanup System (PCUS) is to provide filtering and demineralization to one train of the Spent Fuel Pool Cooling System (SFPCS) or the Reactor Pool Cooling System (RPCS). Periodically, the PCUS will be used to filter and demineralize water as it is pumped from the drydock to the Pool Surge Control System (PSCS) storage tank by the PSCS pumps. These operations (SFPCS or RPCS cleanup and PSCS cleanup) are not required to be performed simultaneously. However, this capability is demonstrated through the overlap of existing tests as follows:
Table 14.2-2, Pool Cleanup System Test #2, System Level Test #2-1 demonstrates the ability of the PCUS to operate with two independent loops of PCUS filters and demineralizers in simultaneous operation.
Table 14.2-4, Pool Surge Control System Test #4, System Level Test #4-1 demonstrates the ability of the PSCS to pump down the drydock.
Table 14.2-2, Pool Cleanup System Test #2, Component Level Test (i) and Table 14.2-4, Pool Surge Control System Test #4, Component Level Test (i) demonstrate the ability to align the PSCS to the PCUS.
No additional testing is needed.
Update: Based on discussion during the 2/5/19 public meeting, Table 14.2-2, Pool Cleanup System Test #2, and Table 14.2-4, Pool Surge Control System Test #4, will be revised to inventory the following two functions to provide additional clarity:
The PSCS supports the PCUS by providing water from the dry dock for UHS inventory control.
This function is verified by component level testing in Table 14.2-2, Pool Cleanup System Test
- 2, and System Level Test #4-1 in Table 14.2-4, Pool Surge Control System Test #4.
The PCUS supports the PSCS, RPCS, and SFPCS by providing a flow path to cross-connect the PSCS, RPCS, and SFPCS.
This function is verified by component level testing.
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 2 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com NRC Question 29.1: (b)
Please add a system level test to demonstrate that the moat/dike surrounding the pool surge control system tank (PSCST) (big tank dike) can drain to the liquid radiation waste system (LRWS).
NuScale Response:
The catch basin for the PSCST is gravity drained to the LRWS via two manually operated valves in the PSCS, and remotely operated valves in the LRWS. Operation of the manual valves is verified during construction testing and system turnover. Operation of the LRWS remotely operated valves is verified by component level testing in Table 14.2-35, Liquid Radioactive Waste System Test #35. Together, these tests verify the ability to drain the PSCST catch basin to the LRWS.
No additional testing is needed.
Update: Based on discussion during the 2/5/19 public meeting, Table 14.2-35, Liquid Radioactive Waste System Test #35, will be revised to include the following function:
The LRWS supports the PSCS by processing any fluid collected in the drain sump of the PSCS dike.
This function is verified by component level testing and System Level Test #35-2 in Table 14.2-35, Liquid Radioactive Waste System Test #35.
NRC Question 29.2: (c)
Please add a system level test to demonstrate the pool surge control system (PSCS) can drain to the LRWS.
NuScale Response:
The pool surge control system only interfaces with the liquid radioactive waste system via the draining of the pool surge control storage tank catch basin. This relationship is explained in NRC Question 29.1.
No additional testing is needed.
NRC Question 29.3: (d)
Add a test here or to Pool Cleanup System Test #2, to verity that water in the dry dock area can be cleaned through the PSCS and returned to the dry dock without sending water to the PSCST.
NuScale Response:
Cleanup of water pumped from the drydock occurs via the Pool Cleanup System (PCUS) rather than the Pool Surge Control System (PSCS), as stated in the question. This capability is demonstrated through overlap of existing tests as follows:
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 3 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com Table 14.2-4, Pool Surge Control System Test #4, System Level Test #4-1 demonstrates the ability of the PSCS to pump down the drydock. This is the method by which water in the drydock is delivered to the PCUS.
Table 14.2-2, Pool Cleanup System Test #2, System Level Test #2-1 demonstrates the ability of the PCUS to filter and demineralize the water it receives.
Table 14.2-2, Pool Cleanup System Test #2, Component Level Test (i) and Table 14.2-4, Pool Surge Control System Test #4, Component Level Test (i) demonstrate the ability to align the PSCS to the PCUS.
Table 14.2-4, Pool Surge Control System Test #4, Component Level Test (i) verifies the operation of the remotely operated valve used to bypass the PSCS storage tank and return the water to the drydock.
Operation of the manual valves necessary for this alignment is verified during construction testing and system turnover.
No additional testing is needed.
Update: Based on discussion during the 2/5/19 public meeting, Table 14.2-2, Pool Cleanup System Test #2, and Table 14.2-4, Pool Surge Control System Test #4, will be revised to inventory the following functions to provide additional clarity:
The PSCS supports the PCUS by providing water from the dry dock for UHS inventory control.
This function is verified by component level testing in Table 14.2-2, Pool Cleanup System Test
- 2, and System Level Test #4-1 in Table 14.2-4, Pool Surge Control System Test #4.
The PCUS supports the PSCS, RPCS, and SFPCS by providing a flow path to cross-connect the PSCS, RPCS, and SFPCS.
This function is verified by component level testing.
NRC Question 29.4: (e)
Add a test to demonstrate that the PSCST overflow line is capable of handling a flow rate equivalent to the maximum addition rate to the tank.
NuScale Response:
The PSCST is provided with both a 10-inch overflow line and a 10-inch vent. Combined, these paths ensure the tank does not overpressurize. Additionally, the primary PSCST overflow protection is provided by PSCS level instrumentation, as described in Section 9.1.3.3.8. If PSCS tank level reaches the high setpoint, the main control room receives an alarm and the inlet line to the PSCST, which is also a 10-inch line, is automatically isolated. The PSCS level instrument is calibrated as a prerequisite in Table 14.2-4, Pool Surge Control System Test #4. The level instrument is then tested by Table 14.2-4, Pool Surge Control System Test #4, Component Level Test (vii).
No additional testing is needed.
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 4 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com NRC Question 29.5: (f)
Add a test to demonstrate that the loop seal in the overflow line can be maintained, with the vent line open, while filling the tank at the maximum addition rate to the tank.
NuScale Response:
The PSCST is provided with both a 10-inch overflow line and a 10-inch vent. Combined, these paths ensure the tank does not overpressurize. Additionally, the primary PSCST overflow protection is provided by PSCS level instrumentation, as described in Section 9.1.3.3.8. If PSCS tank level reaches the high setpoint, the main control room receives an alarm and the inlet line to the PSCST, which is also a 10-inch line, is automatically isolated. The PSCS level instrument is calibrated as a prerequisite in Table 14.2-4, Pool Surge Control System Test #4. The level instrument is then tested by Table 14.2-4, Pool Surge Control System Test #4, Component Level Test (vii).
No additional testing is needed.
NRC Question 29.6: (g)
Add a test to ensure that the PSCST heating system has enough capacity to prevent tank freezing under the assumed lowest ambient temperature for the site, plus some margin.
NuScale Response:
Functionality of the PSCST heaters is demonstrated during generic component testing as described in Section 14.2.3.4, Generic Component Testing. Demonstration of the adequacy of the capacity of the heaters is impractical, as it would require the outside temperature to be at the assumed lowest ambient temperature for the site as an initial condition. Instead, the functionality of the PSCST heaters is demonstrated during generic component testing as described in Section 14.2.3.4, Generic Component Testing. No additional testing is needed.
Update: In the 2/5/19 public meeting, the Staff asked if heater operation would be automatic.
Details of the operation of the PSCST heating system are not yet finalized.
Presumably, operation of the PSCST heating system will be automatic. If true, and in keeping with the typical features of the design, automatic operation will be controlled by the Plant Control System (PCS). Instrumentation will supply the necessary parameter information for the PCS logic to determine when heater operation is required. If needed, PCS will send a signal to energize the heaters. This operation requires the following:
Instrumentation must provide signals to PCS: All PSCS instruments are calibrated as a prerequisite to testing for Table 14.2-4, Pool Surge Control System Test #4. Component Level Test (vii) verifies the instrumentation is communicating correctly with PCS.
PCS logic must interpret instrumentation information to determine when to send a signal to energize the PSCST heaters: As described in Section 14.2.1.1, Construction Organization Testing, testing and installation of the digital I&C systems includes factory acceptance testing and site acceptance testing which is completed as part of construction and installation tests performed prior to, and as a prerequisite of, preoperational tests. As described in Section 14.2.3.2, Graded Approach to Testing,
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 5 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com credit is taken for the logic testing performed for the nonsafety-related module control system (MCS) and the nonsafety-related plant control system (PCS).
The PSCST heaters must energize when required - As described in Section 14.2.3.4, Generic Component Testing, the operation of components such as heaters and heat tracing is verified by generic component testing.
Control Room Habitability System Test #18 NRC Question 30.0: (h)
There should either be a system level test of the air compressor system used to charge the air bottles, to demonstrate that it can provide air that meets CGA G-7.1, Level D air, or a pointer to the other test in the compressed gas system (9.3.1) that does that test.
NuScale Response:
COL Item 6.4-5 states, A COL applicant that references the NuScale Power Plant design certification will specify testing and inspection requirements for the control room habitability system (CRHS) and control room envelope integrity testing as specified in Table 6.4-4. The fifth line item parameter in Table 6.4-4, CRHS Testing, is CRHS stored air quality (oxygen, carbon dioxide, carbon monoxide, oil, dew point), and the acceptance criterion is CGA G7.1 Level D.
The COL will determine if the test will be conducted as preoperational testing, factory acceptance testing, or site acceptance testing.
Update: In the 2/5/19 public meeting, the Staff expressed concern regarding the wording of COL Item 6.4-5 and Table 6.4-4. Specifically the wording does not explicitly state that the source of the stored air in the CRHS air bottled required to meet the acceptance criteria must be the air compressor. Table 6.4-4 will be revised to clarify that the stored air provided by the air compressor to the CRHS air bottles must meet the requirements of CGA G7.1 Level D.
NRC Question 30.1: (i)
There be a discussion about a test to ensure that the minimum flow rate needed to prevent CO2 buildup is capable of being provided for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
NuScale Response:
The capability of the Control Room Habitability System (CRHS) to provide flow at or above the minimum required flow rate to maintain CO2 within acceptable values for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is demonstrated in Table 14.2-18, Control Room Habitability System Test #18, System Level Test
- 18-2. This is accomplished by first isolating 25 percent of the air bottles in the CRHS, and then isolating 5/6 of the remaining inventory of air bottles. The remaining 1/6 of the air bottles are then placed in service for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (i.e., 1/6 of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />), and the CRHS flow rate is verified to be maintained between the minimum and maximum flow allowable flow rates specified in Table 6.4-1.
No additional testing is needed.
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 6 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com NRC Question 30.2: (j)
There be a discussion about a test to ensure that the minimum flow rate needed to maintain main control room (MCR) temperature below the maximum allowable temperature, is capable of being provided for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
NuScale Response:
The Control Room Habitability System (CRHS) is designed to perform the following functions:
Provide the Control Building and Main Control Room (MCR) clean breathing air.
Maintain a positive pressure in the MCR during high radiation or loss of offsite power conditions.
Provide instrument information signals to the plant protection system.
The CRHS does not have a functional requirement to provide air to the MCR for the purpose of cooling. As this is not a system function, no additional testing is needed.
Normal Control Room HVAC System Test #19 NRC Question 31.0: (k)
Testing of heating/cooling units upstream of adsorption units, sufficient to demonstrate the capability of maintaining the humidity at the inlet of the adsorbent material at or below 70%
relative humidity (RH). (Regulatory Guide (RG) 1.140 Criteria 4.7).
NuScale Response:
DCA Section 9.4.1.2.1 describes the CRVS air filtration units, which include a heater, pre-filters, high-efficiency particulate air (HEPA) filters, an activated charcoal adsorber, test sections, and a variable speed supply fan. Additionally, the same section states that the Components of the AFU are designed, constructed, and tested in accordance with Section C.4 of RG 1.140. RG 1.140 C.4.g states, If the relative humidity of the atmosphere entering the air cleanup system can be expected to exceed 70 percent during normal operation, the design should include heaters or cooling coils, or both, to maintain relative humidity at or below 70 percent to ensure adsorption unit efficiency. Heaters should be designed, constructed, and tested in accordance with Section CA of ASME AG-1b-2009.
Table 14.2-19, Normal Control Room HVAC System Test #19, prerequisite (iii) states:
Verify CRVS high-efficiency particulate air (HEPA) and charcoal adsorbers have been installed and tested and the test records have been approved. This statement was intended to address heater operation testing required by RG 1.140, but can be enhanced. Therefore, a prerequisite will be added to Table 14.2-19, Normal Control Room HVAC System Test #19, which states, Verify CRVS air filtration unit heater testing specified in RG 1.140 C.4.g has been completed and the test records have been approved.
No additional testing is needed.
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 7 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com NRC Question 31.1: (l)
Describe how they address ASME AG-1-1997 SA-4500 Pressure Boundary Leakage, (RG 1.140 Criteria 3.6).
NuScale Response:
Section 9.4.1.4, Inspection and Testing, states, Initial in-place testing of the air filtration unit and fan is in accordance with Section C.6 of RG 1.140, which endorses Section TA of ASME Standard AG-1. Duct and housing leak tests are performed after equipment installation. Testing is in accordance with Section TA of ASME AG-1, with a maximum total leakage rate as defined in Article SA-4500. This testing is conducted by the construction organization prior to system turnover, and not as a preoperational test.
No additional testing is needed.
Reactor Building Evacuation System Test #20 NRC Question 32.0: (m)
Testing of heating/cooling units upstream of adsorption units, sufficient to demonstrate the capability of maintaining the humidity at the inlet of the adsorbent material at or below 70% RH.
(RG 1.140 Criteria 4.7), at the maximum allowable spent fuel pool (SFP) temperature.
NuScale Response:
DCA Section 9.4.2.2.1 describes the Spent Fuel Pool Exhaust Charcoal and HEPA Filter Units.
This section states, Each SFP exhaust charcoal and HEPA filter unit includes, in order of the flow stream: low efficiency filter, heater bank, test section, HEPA filter bank, test section, charcoal adsorbers, test section, bypass section, low efficiency filter, and a HEPA filter bank.
Table 14.2-20, Reactor Building HVAC System Test #20, prerequisite (iii) states:
RBVS high-efficiency particulate air and charcoal adsorbers have been installed and tested.
[This prerequisite is not required for component-level tests.] This statement was intended to address heater operation testing required by RG 1.140, but can be enhanced. Therefore, a prerequisite will be added to Table 14.2-20, Reactor Building HVAC System Test #20, which states, Verify SFP exhaust charcoal and HEPA filter unit heater bank testing specified in RG 1.140 C.4.g has been completed and the test records have been approved.
Additionally, the requested testing initial condition of maximum allowable spent fuel pool (SFP) temperature is not practical. Instead, this testing will be factory testing to permit the appropriate initial humidity conditions to be established, and will not be performed as a preoperational test.
No additional testing is needed.
NRC Question 32.1: (n)
Test that the standby SFP Exhaust Subsystem starts on a failure of the Lead SFP Exhaust Subsystem.
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 8 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com NuScale Response:
There is no design requirement for an auto start of the standby Spent Fuel Pool Exhaust subsystem.
No additional testing is needed.
NRC Question 32.2: (o)
Prerequisite ii. Has Verify an RBVS [reactor building ventilation system] air balance has been performed and the RBV system air balance records have been approved. [This prerequisite is not required for component-level tests.], however, there does not appear to be any criteria associated with demonstrating that the flow balance results in ventilation flow is from lower contaminated areas to higher contaminated areas as stated in DCD Tier 2 Section 12.3.6.1.3.
NuScale Response:
From RAI 9277, Question 12.03-49:
The Reactor Building HVAC system (RBVS) design flow requirements and design differential pressure requirements are established by design documents to satisfy the associated design requirements. Air flow requirements will ensure that exhaust air from areas that have a higher potential for contamination will be designed to create room air movement from areas of lower potential contamination to higher potential for contamination to aid in contamination containment.
The RBVS design air flow requirements and differential pressure requirements are verified by the conduct of an RBVS air flow balance to verify design flow rates and design differential pressures are established in the reactor building during normal and off-normal operation when the RBVS and the Radwaste Building HVAC system (RWBVS) are placed in automatic operation.
Tier 2 Section 9.4.2 Reactor Building and Spent Fuel Pool Area Ventilation System, contains subsection Section 9.4.2.4 Inspection and Testing which states the following:
A system air balance test and adjustment to design conditions is conducted in the course of the plant preoperational test program (Section 14.2). Airflow rates are measured and balanced in accordance with the guidelines of Sheet Metal and Air Conditioning Contractors National Association (SMACNA) HVAC Systems Testing, Adjusting and Balancing (Reference 9.4.2-13).
In system level test #20-1, the RWBVS and the RBVS are placed in automatic control to establish the design flows and design differential pressures established in the RBVS air balance test during normal operation. Reactor Building (RXB) temperature, humidity and differential pressure data is then taken to confirm that these variables satisfy the following Test #20-1 test acceptance criteria.
- i. The temperature and humidity of rooms and areas monitored by the MCR satisfy the design temperature and humidity requirements contained in Table 9.4.2-2.
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 9 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com ii. MCR display indicates the RBVS maintains a negative pressure in the RXB relative to the outside environment while operating in the normal operating alignment.
Note that the differential pressure acceptance criteria are a re-verification of a portion of the RBVS air balance.
Thus, the conduct of RBVS air balance and the conduct of RBVS system level test #20-1 verify that the RBVS maintains design flow rates, design temperatures, design humidity and design differential pressure while operating in automatic control during normal operation.
In system level test #20-3, the RWBVS and RBVS are placed in automatic control to establish the design flows and design differential pressures established in the RBVS air balance test during normal operation. A Hi-Hi radiation signal in the spent fuel pool exhaust upstream of the spent fuel pool charcoal filter units is simulated. The realignment of the RBVS is verified and negative pressure in the RXB and RWB relative to the outside environment while the RBVS is operating in the off-normal alignment is verified.
Update: In the 2/5/19 public meeting, the Staff requested that Table 14.2-20, Reactor Building HVAC System Test #20, prerequisite (ii) be revised to indicate the air balance was verifying the flow of air from areas of lower potential contamination to higher potential for contamination. The design of the RBVS is to provide air flow from areas of lower potential contamination to higher potential for contamination. This is accomplished by stipulating air flow rates and differential pressures during system operation. It is these values that are verified by the RBVS air balance.
While verifying these values does provide reasonable assurance that air flows from areas of lower potential contamination to higher potential for contamination, there is not a direct verification of that design feature during the air balance. As a result, revising the prerequisite as requested would be inappropriate.
Update: In the 3/13/19 public meeting, NuScale agreed to add a note to Table 14.2-20, Reactor Building HVAC System Test #20, prerequisite (ii) which states:
The RBVS is designed to move air from areas that are not contaminated or are expected to have low levels of contamination to areas that are likely to be more contaminated.
This note is intended to state a design characteristic of the RBVS, and does not modify the acceptance criteria of the flow balance or preoperational test.
NRC Question 32.3: (p)
Prerequisite ii. Has Verify an RBVS air balance has been performed and the RBV system air balance records have been approved. [This prerequisite is not required for component-level tests.], however, there does not appear to be any criteria associated with demonstrating that the air velocity over the UHS pool water surface doesnt exceed 30 ft/min as listed in DCD Tier 2 Section Table 12.2-32: Input Parameters for Determining Facility Airborne Concentrations.
NuScale Response:
UHS surface air velocity of 30 ft/min is not a limit or requirement, but rather is an assumption in the pool evaporation rate equation. RBVS flow balance will determine the actual air speed across the water. However, it is not plausible to measure the air flow rate at every location of the UHS surface. Instead, the Radiation Protection Program will monitor for any unanticipated dose effects and respond accordingly.
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 10 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com Additionally, the 30 ft/min value is expected to be significantly conservative when compared to actual air velocity over the UHS pool surface. As such, an UHS surface air velocity test is unnecessary.
NRC Question 32.4: (q)
Either Test # 96, or this test should state that the ability to maintain the RXB negative should be done with the SFP Exhaust System in operation.
NuScale Response:
The requested clarification exists in Table 14.2-20, Reactor Building HVAC System Test #20, System Level Test #20-1. Per Section 9.4.2.2.2.1, During normal plant operation, the RBVS main supply air handling units (AHUs), the general exhaust, and the SFP exhaust units are active and servicing the RXB general area, the reactor pool area, the fuel handling area, and the equipment galleries. The Test #20-1 Test Method states Place the RBVS supply, general area exhaust and spent fuel pool exhaust in automatic operation, and the Acceptance Criteria require verification that MCR display indicates the RBVS maintains a negative pressure in the RXB relative to the outside environment while operating in the normal operating alignment.
Combined, these statements require the test to be conducted with the SFP exhaust system in operation, and the ability to maintain the RXB negative to be verified.
No changes are needed.
NRC Question 32.5: (r)
Provide a system level test that checks that the reactor building (RXB) supply fan flow rate decreases and still maintains a negative building pressure when the SFP Exhaust Charcoal filter is put into service.
NuScale Response:
From RAI 9277, Question 12.03-51:
The Plant Control System (PCS) controls the Reactor Building HVAC System (RBVS) as shown in FSAR Figure 7.0-20: Plant Control System Internal Functions and External Interfaces. Therefore, the PCS controls the speed of the RBVS variable speed fans in both normal and offnormal operation.
The PCS is described in Section 7.0.4.6. The testing of the PCS system is described in Section 7.2.1.2.8 Software Integration and Testing. The site acceptance testing of the PCS demonstrates that the installed system performs in accordance with the system design basis. The NuScale Digital l&C Software Master Test Plan governs the generation of the Site Acceptance Test Report.
RBVS component level test vii. verifies that the fan speed of each RBVS variable-speed fan can be manually controlled from minimum to maximum speed. RBVS system level tests
- 20-1 verifies that the RBVS maintains design flow rates from the RBVS fans and design differential pressure is maintained while the RBVS is operating in automatic control during normal operation.
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 11 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com In system level test #20-3, the RWBVS and RBVS are placed in automatic control to establish the design flows and design differential pressures established in the RBVS air balance test during normal operation. A Hi-Hi radiation signal in the spent fuel pool exhaust upstream of the spent fuel pool charcoal filter units is simulated. The realignment of the RBVS is verified and negative pressure in the RXB and RWB, relative to the outside environment while the RBVS is operating in the off-normal alignment, is verified.
No additional testing is needed.
NRC Question 32.6: (s)
Provide a test that demonstrates that the SFP exhaust filter units and associated fans can be powered by the auxiliary AC power source.
NuScale Response:
This ability is demonstrated via overlap of existing tests as follows:
Table 14.2-20, Reactor Building HVAC System Test #20, System Level Test #20-3 demonstrates the ability to power the RBVS spent fuel pool exhaust filter units and associated fans from the low voltage AC electrical distribution system (ELVS).
Table 14.2-56, Low Voltage AC Electrical Distribution System Test #56, Component Level Test (iv) demonstrates the ability to power the ELVS buses from the medium voltage AC electrical distribution system (EMVS).
Table 14.2-55, Medium Voltage AC Electrical Distribution System Test #55, Component Level Test (iv) demonstrates the ability to power the EMVS buses from the 13.8kV and switchyard system (EHVS).
Table 14.2-54, 13.8kV and Switchyard System Test #54, Component Level Test (ii) demonstrates the ability to remotely operate the auxiliary AC power source (AAPS) generator circuit breaker, which allows the AAPS to supply power to the EHVS buses.
Table 14.2-59, Backup Power Supply System Test #59, Component Level Test (v) demonstrates the ability to remotely operate the AAPS from the MCR, while System Level Test #59-2 verifies the automatic start of the AAPS and the ability to achieve rated voltage and frequency.
No additional testing is needed.
NRC Question 32.7: (t)
Provide a test for the filter bank high-high temperature sensors on the entrance and exit sides of the charcoal filter section and the smoke detector on the exit side of the filter section.
NuScale Response:
Table 14.2-20, Reactor Building HVAC System Test #20, prerequisite (i) requires an instrument calibration of the RBVS instruments. Component Level Test (xi) in the same table verifies the functionality of each RBVS instrument by verifying indication is available on an MCS or PCS display. Component Level Tests (iv) and (v) verify the automatic operation of RBVS dampers and fans, respectively, upon actuation of associated fire or smoke alarms.
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 12 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com No additional testing is needed.
NRC Question 32.8: (u)
Provide a test for the charcoal filtration units inlet humidity sensors.
NuScale Response:
Table 14.2-20, Reactor Building HVAC System Test #20, prerequisite (i) requires an instrument calibration of the RBVS instruments. Component Level Test (xi) in the same table verifies the functionality of each RBVS instrument by verifying indication is available on an MCS or PCS display.
No additional testing is needed.
NRC Question 32.9: (v)
Either provide here, or in test # 96, a test to check that both the Fan drive status, and the downstream flow detectors, activate the standby exhaust unit when a running unit fails.
NuScale Response:
Table 14.2-20, Reactor Building HVAC System Test #20, prerequisite (i) requires an instrument calibration of the RBVS instruments. Component Level Test (xi) in the same table verifies the functionality of each RBVS instrument by verifying indication is available on an MCS or PCS display.
Plant control system (PCS) logic monitors instrumentation signals to determine when to send signals for the automatic operation of equipment. As described in Section 14.2.1.1:
The testing and installation of digital I&C systems is described in FSAR Section 7.2.1, and includes factory acceptance testing and site acceptance testing which is completed as part of construction and installation tests performed prior to, and as a prerequisite of, preoperational tests. Factory acceptance tests are performed during the digital I&C system testing phase described in FSAR Section 7.2.1.1.3.1. Site installation and checkout activities are performed as part of the integrated site acceptance testing during the system installation phase as described in FSAR Section 7.2.1.1.3.2. Software integration and testing is governed by the NuScale Digital I&C Software Master Test Plan described in FSAR Section 7.2.1.2.8.
As described in Section 14.2.3.2, credit is taken for the logic testing performed for the plant control system (PCS), and any logic testing during preoperational testing is a duplication of the credited testing. Combined, this provides the overlap in testing necessary to demonstrate the automatic operation of components based on monitored parameters.
No additional testing is needed.
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 13 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com Chemical Volume and Control System Test #38 NRC Question 33.0: (w)
Provide a test for air in leakage to the vacuum portions of the degasifier, and the operation of the degasifier vacuum pumps and the associated controls.
NuScale Response:
Table 14.2-35, Liquid Radioactive Waste System Test #35, System Level Test #35-1 verifies the LRWS can process a gaseous waste stream. The test method directs the following:
Align LRWS to receive pressurizer gaseous waste from the pressurizer during hot functional testing.
Process the pressurizer gaseous waste through the LRW degasifier.
Conduct of this test requires the operation of the degasifier, vacuum pumps, and the associated controls. Additionally, successful performance of this test demonstrates the vacuum portions of the degasifier are sealed sufficiently to permit the vacuum pumps to develop and maintain a vacuum adequate for system operation.
No additional testing is needed.
NRC Question 33.1: (x)
The transfer of resin out of the Chemical and Volume Control System (CVCS) Demineralizers is tested under the solid radioactive waste system (SRWS), and not this system, please add the reference to Test # 37-2 to this section.
NuScale Response:
NuScale functions are arranged in a supporting system/supported system format. The function referenced is The SRWS supports the CVCS by receiving spent resin from CVCS ion exchange vessels. Because the function is considered to be performed by the SRWS, it is inventoried and tested in Table 14.2-37, Solid Radioactive Waste System Test #37. Additionally, because CVCS is the supported system, the function is not listed in Table 14.2-38, Chemical and Volume Control System Test #38. A function is only listed in multiple test abstracts when the supporting system function is tested during another systems test.
This methodology is applied consistently throughout the test abstracts, and it would be inappropriate to deviate in this case.
NRC Question 33.2: (y)
There does not appear to be tests related to the CVCS system support of the Plant Sampling System (PSS). This may be a post-accident sampling concern.
NuScale Response:
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 14 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com Function 2 on Table 14.2-53, Process Sampling System Test #53, states The PSS supports the CVCS by providing sampling of reactor coolant at process points in the CVCS. This function is verified by Test #53-1 in the same table.
NRC Question 33.3: (z)
Provide a test to demonstrate the ability to inject argon (Primary to secondary leakage detection) into the CVCS system.
NuScale Response:
Injection of argon into the CVCS is performed using manual valves. Verification of manual valve installation and the required fittings for argon addition in accordance with the design will be verified during construction, not as a preoperational test.
No additional testing is needed.
NRC Question 33.4: (aa)
Provide a test that shows the LRWS supports the CVCS system by receiving and processing fluids from the High Point vent. See Figure 9.3.4-1.
NuScale Response:
Table 14.2-35, Liquid Radioactive Waste System Test #35, System Function #7 states LRWS supports the CVCS by receiving and processing the noncondensable gases and vapor from the pressurizer. This function is verified by System Level Test #35-1, which tests the ability of the LRWS to receive gaseous waste from the pressurizer high point vent and separate the liquid and gaseous waste. The liquid waste is sent to the low conductivity waste collection tanks.
System Level Test #35-2 tests the ability to process waste from the low conductivity waste collection tanks. Combined, these test the ability of the LRWS to receive and process fluids from the high point vent.
No additional testing is needed.
Containment Evacuation System Test #41 NRC Question 34.0: (bb)
Provide a test related demonstrating that the LRWS can receive liquid from the system.
NuScale Response:
The LRWS does not receive liquid directly from the containment evacuation system (CES).
Instead, liquid that is collected in the CES by the CES sample tank gravity drains to the radioactive waste drain system (RWDS) through an air-operated CES valve. Operation of the valve is tested in Table 14.2-41, Containment Evacuation System Test #41, Component Level Test (i).
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 15 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com The ability of the LRWS to receive and process water from the RWDS is tested in Table 14.2-23, Radioactive Waste Drain System Test #23, System Level Test #23-1, and Table 14.2-35, Liquid Radioactive Waste System Test #35, System Level Test #35-2.
No additional testing is needed.
Reactor Building Ventilation System Capability Test #96 NRC Question 35.0: (cc)
See the discussion above about the RXB ventilation system tests.
NuScale Response:
Questions 32.0(m) through 32.9(v) have been addressed.
Liquid Radioactive Waste System Test # 35 Questions NRC Question 36.1:
Provide a test to demonstrate that the LRWS receives and processes water from the resin transfer system (there appears to only currently be a test for high integrity container (HIC) dewatering).
NuScale Response:
This capability is demonstrated via overlap of existing testing as follows:
In addition to the test for HIC dewatering (System Level Test #37-7), Table 14.2-37, Solid Radioactive Waste System Test #37, System Level Test #37-1 demonstrates the ability to transfer water from the phase separator tanks in the solid radioactive waste system (SRWS) to the liquid radioactive waste system (LRWS).
Table 14.2-35, Liquid Radioactive Waste System Test #35, System Level Test #35-2 demonstrates the ability of the LRWS to process a liquid waste stream.
Component Level Test (i) in Table 14.2-35 and Table 14.2-37 verifies the ability to operate the necessary valves in the SRWS and LRWS for the LRWS to process liquid from the SRWS.
No additional testing is needed.
NRC Question 36.2:
Provide a test that the chilled water system (CHWS) provides chilled water to the LRWS condensers.
NuScale Response:
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 16 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com Table 14.2-8, Chilled Water System Test #8, includes prerequisite (ii), which states Verify a CHWS flow balance has been performed. Performance of the flow balance will establish the required CHWS flow to the LRWS condensers.
Additionally, Table 14.2-35, Liquid Radioactive Waste System Test #35, System Level Test #35-1 tests the ability of the LRWS to receive gaseous waste from the pressurizer high point vent, and separate the liquid and gaseous waste. This occurs in the LRWS degasifier condenser which is cooled by chilled water. Meeting the acceptance criteria for this test demonstrates that chilled water flow to the degasifier condenser is sufficient to support LRWS operation.
No additional testing is needed.
NRC Question 36.3:
Provide a test to demonstrate that nitrogen can appropriately be supplied to the LRWS degasifiers.
NuScale Response:
This capability is demonstrated through existing testing as follows:
Table 14.2-15, Nitrogen Distribution System Test #15, Component Level Test (i) verifies the necessary valves in the nitrogen distribution system can be operated.
Table 14.2-35, Liquid Radioactive Waste System Test #35, Component Level Test (i) verifies the necessary valves in the LRWS can be operated.
As described in Section 14.2.3.4, Generic Component Testing, the pressure control valves used to supply nitrogen to the LRWS at the appropriate pressure are tested as part of generic component testing.
Update: Table 14.2-35, Liquid Radioactive Waste System Test #35, System Level Test #35-1 was revised to demonstrate the ability to purge the LRWS degasifiers with nitrogen. The following direction was added to the Test Method: Purge the degasifier with nitrogen following operation. A new Acceptance Criterion was added to verify the LRW degasifier is purged with nitrogen. Additionally, a function which states The NDS supports the LRWS by providing nitrogen for purging of the LRWS, and is verified by Test #35-1, was added to the System Function list of Table 14.2-35.
NRC Question 36.4:
Provide a test to demonstrate that the LRWS can receive water from the reactor component cooling water system (RCCWS) for processing and transfer it back to the RCCW.
NuScale Response:
The LRWS does not receive RCCW drains directly, but rather, as shown on Figure 9.3.3-1, Radioactive Waste Drain System Diagram, RCCW drains are collected in the RCCW drain tank, which is in the radioactive waste drain system. As described in Section 9.2.2.2.3, the drains can be sampled and returned to the RCCW expansion tank, or, if necessary, the water can be transferred to the LRWS for processing. In Table 14.2-23, Radioactive Waste Drain System Test #23, the combination of Component Level Tests (i) and (iv), and System Level Test #23-1
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 17 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com demonstrate the ability to transfer the contents of the RCCW drain tank to the LRWS for processing.
No additional testing is needed.
NRC Question 36.5:
Provide a test to demonstrate that the LRWS receives contaminated drainage from the RCCW into the high conductivity waste (HCW) tank.
NuScale Response:
The LRWS does not receive RCCW drains directly, but rather, as shown on Figure 9.3.3-1, Radioactive Waste Drain System Diagram, RCCW drains are collected in the RCCW drain tank, which is in the radioactive waste drain system. Transfer of water from the RCCW drain tank to the LRWS is a procedurally driven evolution requiring manual remote operation of the RCCW drain tank pumps. The ability to start the pumps is tested in Table 14.2-23, Radioactive Waste Drain System Test #23, Component Level Test (iv). The ability to line up to pump the RCCW drain tank to the HCW collection tanks is demonstrated by Component Level Test (i) in Table 14.2-23, Radioactive Waste Drain System Test #23, and Table 14.2-35, Liquid Radioactive Waste System Test #35.
No additional testing is needed.
NRC Question 36.6:
Provide a test to demonstrate that the LRWS receives liquid from equipment drains.
NuScale Response:
Equipment drains are collected in the equipment drain sumps in the radioactive waste drain system as shown on Figure 9.3.3-1. Table 14.2-23, Radioactive Waste Drain System Test #23, System Level Test #23-1 tests the ability to pump from the equipment drain sumps to the designated location in the LRWS.
No additional testing is needed.
NRC Question 36.7:
Provide a test or prerequisite to the LRWS test to ensure that ANSI/ANS-40.37 testing is complete.
NuScale Response:
ANSI/ANS-40.37 is specific to mobile processing equipment. There is currently no mobile equipment in the LRWS design, however connection points and floor space for mobile equipment is provided. To address the potential for the addition of mobile equipment, COL Item 11.2-1 provides the following:
A COL applicant that references the NuScale Power Plant design certification will ensure mobile equipment used and connected to plant systems is in accordance with ANSI/ANS-40.37, Regulatory Guide (RG) 1.143, 10 CFR 20.1406, NRC IE Bulletin 80-10 and 10 CFR 50.34a.
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 18 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com No additional testing or prerequisite is needed.
NRC Question 36.8:
Provide a test or prerequisite to the LRWS test to ensure that ANSI/ANS-55.6 testing is complete.
NuScale Response:
ANSI/ANS-55.6, Liquid Radioactive Waste Processing System for Light Water Reactor Plants, provides general guidance regarding testing in two areas. The first is system integrity testing, which is conducted as part of construction testing. The second area is operability and functional testing, which is provided for in Table 14.2-35, Liquid Radioactive Waste System Test #35. As a portion of the ANSI/ANS-55.6 testing occurs during the performance of the preoperational testing in Table 14.2-35, a prerequisite for the completion of ANSI/ANS-55.6 testing would be inappropriate.
Update: Based on discussion during the 3/13/19 public meeting, Table 14.2-35, Liquid Radioactive Waste System Test #35, was revised to include a prerequisite which states Required ANSI/ANS-55.6 construction testing has been completed.
NRC Question 36.9:
Provide a system level test of the operability of the degasifier under intermittent flow conditions for liquid and pressurizer inputs.
NuScale Response:
The requested testing of the LRWS degasifier under intermittent flow conditions occurs in the existing tests as follows:
While heating the plant to hot functional conditions, Table 14.2-38, Chemical and Volume Control System Test #38, System Level Test #38-1 requires testing of the ability to letdown to the LRWS from the pressurizer. For this to occur, the LRWS must be placed in operation, and then letdown must be started.
Once hot functional conditions are established, Table 14.2-35, Liquid Radioactive Waste System Test #35, System Level Test #35-1 verified the ability of the LRWS to be aligned for and to receive degas flow from the pressurizer.
No additional testing is needed.
NRC Question 36.10:
Provide a test to test the ALARM of the mobile processing skid on high differential pressure.
NuScale Response:
The testing of LRWS alarms occurs via overlap of existing testing. The following three excerpts from the FSAR are provided for background information:
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 19 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com (Section 7.0.4.6.3)
Three networking layers comprise the PCS architecture of the process control systems: the HMI layer, the control network layer, and the input/output network layer. The HMI layer consists of the PCS power operations HMI network, and the PCS radwaste handling HMI network. The separations of function between the PCS power operations and radwaste handling functions prevent input from the waste management control room from adversely affecting power operations.
(Section 7.2.14.4)
The PCS operator workstation displays are located in the MCR, the radwaste building control room, and the RSS.
The HSIs in the locations outside of the MCR are all MCR derivatives, i.e., operated from the same platform and connected to either the MCS or PCS network.
(Section 14.2.1.1)
The testing and installation of digital I&C systems is described in FSAR Section 7.2.1, and includes factory acceptance testing and site acceptance testing which is completed as part of construction and installation tests performed prior to, and as a prerequisite of, preoperational tests. Factory acceptance tests are performed during the digital I&C system testing phase described in FSAR Section 7.2.1.1.3.1. Site installation and checkout activities are performed as part of the integrated site acceptance testing during the system installation phase as described in FSAR Section 7.2.1.1.3.2. Software integration and testing is governed by the NuScale Digital I&C Software Master Test Plan described in FSAR Section 7.2.1.2.8.
The overlap of existing testing occurs as follows:
Table 14.2-35, Liquid Radioactive Waste System Test #35, prerequisites require all LRWS instruments to be calibrated.
Table 14.2-35, Liquid Radioactive Waste System Test #35, Component Level Test (xii) verifies each LRWS system instrument is available on an MCS or PCS display. This verifies the LRWS instrument is correctly connected to the PCS, and the PCS is communicating with the HSIs.
The PCS logic is fully tested as part of factory and site acceptance testing, which are a prerequisite to preoperational testing, as described in Section 14.2.1.1. As described in Section 14.2.3.2, credit is taken for the logic testing performed for the PCS, and any logic testing during preoperational testing is a duplication of the credited testing.
No additional testing is needed.
NRC Question 36.11:
Provide a test of the MCR control room and waste management control room alarm on loss of nitrogen pressure.
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 20 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com NuScale Response:
The testing of LRWS alarms occurs via overlap of existing testing as detailed in the NuScale response to NRC Question 36.10.
No additional testing is needed.
NRC Question 36.12:
Provide a test for the oil separators to segregate the oily portion of liquid waste inputs before transferring the non-oily portion to the HCW collection tanks.
NuScale Response:
Table 14.2-23, Radioactive Waste Drain System Test #23, System Level Test #23-1 tests the ability to pump from all of the RWDS tanks/sumps to the high-conductivity waste (HCW) and low-conductivity waste collection tanks. The floor drain sumps, chemical drain tank, and RCCWS drain tank must process through the oil separators before being stored in the HCW collection tanks.
The oil separators are designed and procured to provide mechanical oil separation. Intentionally placing oil in sumps or tanks to demonstrate the ability perform that function is impractical and unnecessary. Additionally, the acceptance criteria would likely not be meaningful.
No additional testing is needed.
NRC Question 36.13:
Provide a test for the drum dryer receiver tank input streams, the drum dryer heater, vent condenser, and ventilation system for the drum dryer.
NuScale Response:
The acceptance criteria of Table 14.2-35, Liquid Radioactive Waste System Test #35, System Level Test #35-2 has been revised to include drum dryer skid. As a result, to meet the acceptance criteria the LRWS must demonstrate the ability to successfully process waste treatment streams through the drum dryer skid, which includes the drum dryer receiver tank input streams, the drum dryer heater, vent condenser, and the ventilation system for the drum dryer.
NRC Question 36.14:
Provide a test that the degasifier transfer pump trips and that there is an alarm in the MCR and waste management control room on high level and loss of vacuum in the degasifier.
NuScale Response:
The requested LRWS testing occurs via overlap of existing testing. Refer to the NuScale response to NRC Question 36.10 for the description of how alarms are verified through existing testing.
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 21 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com Regarding the automatic operation of LRWS components, the plant control system (PCS) logic monitors instrumentation signals to determine when to send signals for automatic operation. As described in Section 14.2.1.1:
The testing and installation of digital I&C systems is described in FSAR Section 7.2.1, and includes factory acceptance testing and site acceptance testing which is completed as part of construction and installation tests performed prior to, and as a prerequisite of, preoperational tests. Factory acceptance tests are performed during the digital I&C system testing phase described in FSAR Section 7.2.1.1.3.1. Site installation and checkout activities are performed as part of the integrated site acceptance testing during the system installation phase as described in FSAR Section 7.2.1.1.3.2. Software integration and testing is governed by the NuScale Digital I&C Software Master Test Plan described in FSAR Section 7.2.1.2.8.
As described in Section 14.2.3.2, credit is taken for the logic testing performed for the plant control system (PCS), and any logic testing during preoperational testing is a duplication of the credited testing. Table 14.2-35, Liquid Radioactive Waste System Test #35, Component Level Test (iv) tests the ability to operate the pumps in the LRWS remotely, which demonstrates communication between the PCS logic and the pumps. Combined, this provides the overlap in testing necessary to demonstrate the automatic operation of components based on monitored parameters.
No additional testing is needed.
NRC Question 36.15:
Provide a test to verify the operability of the hydrogen analyzer in the degasifier area.
NuScale Response:
The Table 14.2-35, Liquid Radioactive Waste System Test #35, prerequisites require an instrument calibration of the LRWS instruments. Component Level Test (xii) in the same table verifies the functionality of each LRWS instrument by verifying indication is available on an MCS or PCS display.
No additional testing is needed.
NRC Question 36.16:
Provide testing of indications, controls, and alarms in the waste management control room.
NuScale Response:
The requested testing is provided in existing testing. Refer to the NuScale response to NRC Question 36.10 for the description of how alarms are verified through existing testing, and the relationship between the waste management control room HMI and the plant control system.
Regarding indications and controls, each systems preoperational test abstract includes component level tests requiring each of the systems instruments to be verified to be available on MCS or PCS, and the ability to operate remotely operated equipment (e.g. pumps, valves, and fans). The waste management control room HSI will contain indications and controls from
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 22 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com this inventory of systems. As such, testing of the indications and controls occurs through the existing system tests.
No additional testing is needed.
Gaseous Radioactive Waste System Test #36 NRC Question 37.1:
Provide a system level test to ensure that nitrogen will be supplied.
NuScale Response:
This capability is demonstrated through existing testing as follows:
Table 14.2-15, Nitrogen Distribution System Test #15, Component Level Test (i) verifies the necessary valves in the nitrogen distribution system (NDS) can be operated.
Table 14.2-36, Gaseous Radioactive Waste System Test #36, Component Level Test (i) verifies the necessary valves in the GRWS can be operated.
As described in Section 14.2.3.4, Generic Component Testing, the pressure control valves used to supply nitrogen to the GRWS at the appropriate pressure are tested as part of generic component testing.
Table 14.2-36, Gaseous Radioactive Waste System Test #36, System Level Test #36-1 tests the ability to process a gaseous stream through the charcoal drying heater. This process is performed using nitrogen supplied by the NDS.
Update: In a public meeting, the Staff questioned whether nitrogen was used during the charcoal drying operations. The following discussion is from Section 11.3.2, System
Description:
The guard bed includes a safety relief valve, differential pressure instrumentation, and a means to dry or replace charcoal. Charcoal drying is manually initiated by remotely-operated valves and a normally deenergized charcoal drying heater, which provide a heated nitrogen flow to the guard bed. The heated, moisture-laden nitrogen is recycled back to the inlet of the vapor condenser.
Additionally, Section 11.3.2.1.5, Charcoal Drying Heater, states the following:
The charcoal drying heater is a manually initiated, stainless steel electric heater that heats nitrogen gas from the nitrogen distribution system to flow through the charcoal guard bed to dry the charcoal, if needed. The heated nitrogen can also be routed to the charcoal decay beds. After exiting the guard bed or decay beds, the nitrogen is routed back to the inlet of the waste gas cooler to remove the moisture.
Update: Table 14.2-36, Gaseous Radioactive Waste System Test #36, has been revised as follows:
A function which states The NDS supports the GRWS by providing nitrogen for purging of the GRWS has been added to the System Function list. This function is verified by System Level Test #36-1 and Table 14.2-15, Nitrogen Distribution System Test #15,
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 23 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com Component Level Tests.
System Level Test #36-1 was modified as follows:
o The words and nitrogen stream were added to the Test Objective.
o A second Test Method was added to require the GRWS to process nitrogen supplied by the NDS through the charcoal drying process.
o The Acceptance Criteria requires successful demonstration of the ability to process nitrogen through the charcoal drying heater.
NRC Question 37.2:
Provide a test of the charcoal drying heaters to ensure they properly function to remove moisture from the system.
NuScale Response:
Table 14.2-36, Gaseous Radioactive Waste System Test #36, System Level Test #36-1 tests the ability to process a gaseous stream through the charcoal drying heater.
No additional testing is needed.
Update: System Level Test #36-1 has been revised to specify that a nitrogen stream is processed through the charcoal drying heater, rather than a gaseous stream.
NRC Question 37.3:
Provide a test to verify that the automatic activation of a nitrogen purge upon detection of a fire.
NuScale Response:
The requested GRWS testing occurs via overlap of existing testing. Regarding the automatic operation of GRWS components, the plant control system (PCS) logic monitors instrumentation signals to determine when to send signals for automatic operation. As described in Section 14.2.1.1:
The testing and installation of digital I&C systems is described in FSAR Section 7.2.1, and includes factory acceptance testing and site acceptance testing which is completed as part of construction and installation tests performed prior to, and as a prerequisite of, preoperational tests. Factory acceptance tests are performed during the digital I&C system testing phase described in FSAR Section 7.2.1.1.3.1. Site installation and checkout activities are performed as part of the integrated site acceptance testing during the system installation phase as described in FSAR Section 7.2.1.1.3.2. Software integration and testing is governed by the NuScale Digital I&C Software Master Test Plan described in FSAR Section 7.2.1.2.8.
As described in Section 14.2.3.2, credit is taken for the logic testing performed for the plant control system (PCS), and any logic testing during preoperational testing is a duplication of the credited testing. Table 14.2-36, Gaseous Radioactive Waste System Test #36, prerequisites require all GRWS instruments to be calibrated, and Component Level Test (x) requires each of the systems instruments to be verified to be available on MCS or PCS. Combined, this provides
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 24 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com the overlap in testing necessary to demonstrate the automatic operation of components based on monitored parameters.
No additional testing is needed.
NRC Question 37.4:
Provide a test of the ability of the GWMS to collect gases taken directly from the pressurizer for shutdown degasification.
NuScale Response:
The GRWS does not receive gases directly from the pressurizer. However the path for gases from the pressurizer through the GRWS is tested as follows:
Table 14.2-35, Liquid Radioactive Waste System Test #35, Test #35-1 tests the ability to process gaseous waste from the pressurizer high point vent. The acceptance criteria for this test states, in part, The LRW degasifier removes condensable gases and vents waste to the RBVS or GRWS.
As seen on Figure 11.3-1a, the flow of gases from the LRWS degasifiers input into either of the GRWS gas coolers.
Table 14.2-36, Gaseous Radioactive Waste System Test #36, System Level Test #36-1 demonstrates the ability of GRWS to process a gaseous waste stream through the gas coolers, moisture separators, charcoal guard bed, the decay beds and to the RWB exhaust.
No additional testing is needed.
NRC Question 37.5:
Provide leak rate testing of the gaseous radioactive waste system.
NuScale Response:
GRWS leakage testing will be performed as part of construction testing, and not as a preoperational test.
No additional testing is needed.
NRC Question 37.6:
Add the following function: The nitrogen distribution system supports the GRWS by providing nitrogen to the GRWS guard and decay beds.
NuScale Response:
Table 14.2-36, Gaseous Radioactive Waste System Test #36, has been revised to include a function in the System Function list which states The NDS supports the GRWS by providing nitrogen for purging of the GRWS.
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 25 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com Table of Acronyms Acronym or Abbreviation Description AAPS auxiliary AC power source AC alternating current AHU air handling units CES containment evacuation system CHWS chilled water system CRHS control room habitbility system CRVS normal control room HVAC system CVCS chemical and volume control system DCD Design Control Document EHVS 13.8 kV and switchyard system ELVS low voltage AC electrical distribution system EMVS medium voltage AC electrical distribution system FSAR Final Safety Analysis Report GRWS gaseous radioactive waste system HCW high conductivity waste HEPA high-efficiency particulate air HIC high integrity container HMI human machine interface HSI human-system interface HVAC heating ventilation and air conditioning LRWS liquid radioactive waste system MCR main control room NDS nitrogen distribution system PCS plant control system PCUS pool cleanup system PSCS pool surge control system PSCST pool surge control system tank PSS plant sampling system RBVS reactor building ventilation system RCCWS reactor component cooling water system RG Regulatory Guide RH relative humidity RPCS reactor pool cooling system RWB Radioactive Waste Building RWBVS Radioactive Waste Building HVAC system
NuScale Responses to ITP Questions LO-0419-65024 Attachment Page 26 of 26 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com RWDS radioactive waste drain system RXB Reactor Building SFP spent fuel pool SFPCS spent fuel pool cooling system SRWS solid radioactive waste system UHS ultimate heat sink
LO-0419-65024 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com
Enclosure:
Changes to NuScale Final Safety Analysis Report Sections, Section 6.4 Control Room Habitability and Section 14.2 Initial Plant Test Program
NuScale Final Safety Analysis Report Control Room Habitability Tier 2 6.4-14 Draft Revision 3 Table 6.4-4: CRHS Testing Parameter Acceptance Criteria CRE pressure with CRHS in service
> 1/8 inch water gauge CRHS flow rate from storage bottles to control room envelope via actuated flow path
>80 scfm but < 100 scfm CRHS flow rate from storage bottles to control room envelope via manual flow path
>80 scfm but < 100 scfm Control room envelope isolation dampers required for CRHS operation close on CRHS actuation signal CRHS stored air quality (oxygen, carbon dioxide, carbon monoxide, oil, dew point) supplied by the CRHS air compressor CGA G7.1 Level D CRHS available air inventory
> 432,000 SCF CRHS supply actuation valves and CRE pressure relief valves operation Stroke open on CRHS actuation signal CRHS pressure regulating valves operation Within pressure specifications
NuScale Final Safety Analysis Report Initial Plant Test Program Tier 2 14.2-22 Draft Revision 3 Table 14.2-2: Pool Cleanup System Test # 2 Preoperational test is required to be performed once.
The PCUS is described in Section 9.1.3.2.3 and the functions verified by this test are:
System Function System Function Categorization Function Verified by Test #
1.
The SFPCS supports the PCUS by providing spent fuel pool water for purification of the UHS.
nonsafety-related Test #2-1 2.
The reactor pool cooling system (RPCS) supports the PCUS by providing reactor pool water for purification of the UHS.
nonsafety-related Test #2-1 3.
The PSCS supports the PCUS by providing water from the dry dock for UHS inventory control.
nonsafety-related Component level tests PSCS Test #4-1 4.
The PCUS supports the PSCS, RPCS, and SFPCS by providing a flowpath to cross-connect the PSCS, RPCS, and SFPCS.
nonsafety-related Component level tests Prerequisites i.
Verify an instrument calibration has been completed, with approved records and within all calibration due dates, for all instruments required to perform this test.
ii.
Verify a pump curve test has been completed and approved for the RPCS pumps.
iii. Verify a pump curve test has been completed and approved for the SFPCS pumps.
Component Level Tests Test Objective Test Method Acceptance Criteria i.
Verify each PCUS remotely-operated valve can be operated remotely.
Operate each valve from the MCR and local control panel (if design has local valve control).
MCR display and local, visual observation indicate each valve fully opens and fully closes.
ii.
Verify each PCUS air-operated valve fails to its safe position on loss of air.
Place each valve in its non-safe position.
Isolate and vent air to the valve.
MCR display and local, visual observation indicate each valve fails to its safe position.
iii. Verify each PCUS air-operated valve fails to its safe position on loss of electrical power to its solenoid.
Place each valve in its non-safe position.
Isolate electrical power to each air-operated valve.
MCR display and local, visual observation indicate each valve fails to its safe position.
iv. Verify a local grab sample can be obtained from a PCUS grab sample device.
Place the system in service to allow flow through the grab sampling device.
A local grab sample is successfully obtained.
v.
Verify each PCUS instrument is available on an MCS or PCS display.
(Test not required if the instrument calibration verified the MCS or PCS display.)
Initiate a single real or simulated instrument signal from each PCUS transmitter.
The instrument signal is displayed on an MCS or PCS display, or is recorded by the applicable control system historian.
NuScale Final Safety Analysis Report Initial Plant Test Program Tier 2 14.2-25 Draft Revision 3 Table 14.2-4: Pool Surge Control System Test # 4 Preoperational test is required to be performed once.
The pool surge control system (PSCS) is described in Section 9.1.3.2.4 and the function verified by this test is:
System Function System Function Categorization Function Verified by Test #
1.
The PSCS supports the UHS by providing surge control for UHS operations.
nonsafety-related Test #4-1 2.
The PSCS supports the UHS by providing a reactor inspection dry dock makeup and drain capability.
nonsafety-related Test #4-1 3.
The PSCS supports the PCUS by providing water from the dry dock for UHS inventory control.
nonsafety-related Test #4-1 PCUS Test #2 Component level tests 4.
The PCUS supports the PSCS, RPCS, and SFPCS by providing a flowpath to cross-connect the PSCS, RPCS, and SFPCS.
nonsafety-related Component level tests Prerequisites i.
Verify an instrument calibration has been completed, with approved records and within all calibration due dates, for all instruments required to perform this test.
ii.
For system level test #4-1, the drydock gate can be open or closed.
Component Level Tests Test Objective Test Method Acceptance Criteria i.
Verify each PSCS remotely-operated valve can be operated remotely.
Operate each valve from the MCR and local control panel (if design has local valve control).
MCR display and local, visual observation indicate each valve fully opens and fully closes.
ii.
Verify each PSCS air-operated valve fails to its safe position on loss of air.
Place each valve in its non-safe position.
Isolate and vent air to the valve.
MCR display and local, visual observation indicate each valve fails to its safe position.
iii. Verify each PSCS air-operated valve fails to its safe position on loss of electrical power to its solenoid.
Place each valve in its non-safe position.
Isolate electrical power to each air-operated valve.
MCR display and local, visual observation indicate each valve fails to its safe position.
iv. Verify each PSCS pump can be started and stopped remotely.
Stop and start each pump from the MCR. MCR display and local, visual observation indicate each pump starts and stops.
v.
Verify the PSCS automatically responds to mitigate a release of radioactivity.
Initiate a real or simulated high radiation signal in the PSCS tank vent line.
i.
The PSCS tank inlet isolation valve is closed.
ii.
The PSCS tank outlet isolation valve is closed.
[ITAAC 03.09.10]
vi. Verify a local grab sample can be obtained from a PSCS grab sample device indicated on the PSC piping and instrumentation diagram.
Place the system in service to allow flow through the grab sampling device.
A local grab sample is successfully obtained.
vii. Verify each PSCS instrument is available on an MCS or PCS display.
(Test not required if the instrument calibration verified the MCS or PCS display.)
Initiate a single real or simulated instrument signal from each PSCS transmitter.
The instrument signal is displayed on an MCS or PCS display, or is recorded by the applicable control system historian.
NuScale Final Safety Analysis Report Initial Plant Test Program Tier 2 14.2-44 Draft Revision 3 Table 14.2-15: Nitrogen Distribution System Test # 15 Preoperational test is required to be performed once.
The nitrogen distribution system (NDS) is described in Section 9.3.1 and the functions verified by this test are:
System Function System Function Categorization Function Verified by Test #
Has no specific system function, all functionality is supported through supported systems testing.
N/A N/A 1.
The NDS supports the following systems by providing nitrogen:
- RXB nonsafety-related component-level tests 2.
The NDS supports the LRWS by providing nitrogen for purging of the LRWS.
nonsafety-related component-level tests LRWS Test #35-1 3.
The NDS supports the GRWS by providing nitrogen for purging of the GRWS.
nonsafety-related component-level tests GRWS Test #36-1 Prerequisites Verify an instrument calibration has been completed, with approved records and within all calibration due dates, for all instruments required to perform this test.
Component Level Tests Test Objective Test Method Acceptance Criteria i.
Verify each NDS remotely-operated valve can be operated remotely.
Operate each valve from the MCR and local control panel (if design has local valve control)
MCR display and local, visual observation indicate each valve fully opens and fully closes.
ii.
Verify each NDS air-operated valve fails to its safe position on loss of air.
Place each valve in its non-safe position.
Isolate and vent air to the valve.
MCR display and local, visual observation indicate each valve fails to its safe position.
iii. Verify each NDS air-operated valve fails to its safe position on loss of electrical power to its solenoid.
Place each valve in its non-safe position.
Isolate electrical power to each air-operated valve.
MCR display and local, visual observation indicate each valve fails to its safe position.
iv. Verify the NDS high pressure isolation valve closes to protect equipment.
Initiate a simulated signal for the following system conditions.
i.
High flow to high pressure header ii.
High pressure on high pressure header MCR display and local, visual observation indicate the nitrogen supply to the high pressure header valve is closed.
v.
Verify a local grab sample can be obtained from a NDS grab sample device indicated on the NDS piping and instrumentation diagram.
Place the system in service to allow flow through the grab sampling device.
A local grab sample is successfully obtained.
vi. Verify each NDS instrument is available on an MCS or PCS display.
(Test not required if the instrument calibration verified the MCS or PCS display.)
Initiate a single real or simulated instrument signal from each NDS transmitter.
The instrument signal is displayed on an MCS or PCS display, or is recorded by the applicable control system historian.
System Level Tests None
NuScale Final Safety Analysis Report Initial Plant Test Program Tier 2 14.2-52 Draft Revision 3 The CRVS supports the PPS by providing instrument information signals relating to isolation of the CRE and activation of the CRHS.
nonsafety-related CRHS Test #18-1 Prerequisites i.
Verify an instrument calibration has been completed, with approved records and within all calibration due dates, for all instruments required to perform this test.
ii.
Verify a CRVS air balance has been performed and the CRVS air balance records have been approved. [This prerequisite is not required for component-level tests.]
iii. Verify CRVS high-efficiency particulate air (HEPA) and charcoal adsorbers have been installed and tested and the test records have been approved. [This prerequisite is not required for component-level tests.]
iv. Verify CRVS control room isolation dampers have been leak tested and the test records have been approved. [This prerequisite is not required for component-level tests.]
v.
Component Level Tests x. and xi. must be performed under preoperational test conditions that approximate design-basis temperature, differential pressure, and flow conditions to the extent practicable, consistent with preoperational test limitations.
vi. Verify CRVS air filtration unit heater testing specified in RG 1.140 C.4.g has been completed and the test records have been approved.
Component Level Tests Test Objective Test Method Acceptance Criteria i.
Verify each CRVS remotely-operated damper can be operated remotely.
Operate each damper from the MCR and local control panel (if design has local damper control).
MCR display and local, visual observation indicate each damper fully opens and fully closes.
ii.
Verify each CRVS air-operated damper fails to its safe position on loss of air.
Place each damper in its non-safe position. Isolate and vent air to the damper.
MCR display and local, visual observation indicate each damper fails to its safe position.
iii. Verify each CRVS air-operated damper fails to its safe position on loss of electrical power to its solenoid.
Place each damper in its non-safe position. Isolate electrical power to its solenoid.
MCR display and local, visual observation indicate each damper fails to its safe position.
iv. Verify CRVS dampers automatically close on associated smoke or fire signals.
Open each damper actuated by a smoke or fire signal. Initiate an alarm signal for each damper.
MCR display and local, visual observation indicate each damper closes.
v.
Verify each required CRVS fan stops on actuation of its associated fire or smoke alarm.
Initiate an alarm signal for each fan.
MCR display and local, visual observation indicate each fan stops.
vi. Verify each CRVS pressurization fan starts automatically on the actuation of its associated fire or smoke alarm.
Initiate an alarm signal for each fan.
MCR display and local, visual observation indicate each pressurization fan starts.
vii. Verify the fan speed of each CRVS variable-speed fan can be manually controlled.
Vary the speed of each fan from the MCR and local control panel (if design has local fan control).
MCR display indicates the speed of each fan varies from minimum to maximum speed.
viii. Verify the standby CRVS main supply air handling unit (AHU) starts automatically on the stop of the operating CRVS main supply AHU.
Place an AHU in service. Place the standby AHU in automatic control. Stop the operating AHU.
MCR display and local, visual observation indicate the standby AHU starts.
ix. Verify each standby CRVS fan coil unit (FCU) starts automatically on the stop of the operating CRVS fan coil unit.
Place an FCU in service. Place the standby FCU in automatic control. Stop the operating FCU.
MCR display and local, visual observation indicate the standby FCU starts.
Table 14.2-19: Normal Control Room HVAC System Test # 19 (Continued)
NuScale Final Safety Analysis Report Initial Plant Test Program Tier 2 14.2-55 Draft Revision 3 Table 14.2-20: Reactor Building HVAC System Test # 20 Preoperational test is required to be performed once.
The RBVS is described in Section 9.4.2 and the functions verified by this test are:
System Function System Function Categorization Function Verified by Test #
1.
The RBVS supports the RXB by providing cooling, heating and humidity control to maintain a suitable environment for the safety and comfort of plant personnel.
nonsafety-related Test #20-1 Test #20-2 Reactor Building Ventilation System Capability Test # 96 2.
The RBVS supports the systems located in the RXB by providing cooling, heating and humidity control to maintain a suitable environment for the operation of system components.
nonsafety-related Test #20-1 Test #20-2 Reactor Building Ventilation System Capability Test # 96 3.
The RBVS supports the RXB by maintaining the RXB at a negative ambient pressure relative to the outside atmosphere to control the movement of potentially airborne radioactivity from the RXB to the environment.
nonsafety-related Test #20-1 Test #20-3 4.
The CRVS supports the CRB by maintaining the CRB at a positive ambient pressure relative to the Reactor Building (RXB) and the outside atmosphere to control the ingress of potentially airborne radioactivity from the RXB or the outside atmosphere to the CRB.
nonsafety-related Test #20-1 (RXB negative pressure)
CRVS Test #19-1 (CRB positive pressure) 5.
The RWBVS supports the RWB by maintaining the RWB at a negative ambient pressure relative to the outside atmosphere to control the movement of potentially airborne radioactivity from the RWB to the environment.
nonsafety-related Test #20-3 (off-normal RBVS exhaust alignment)
RWBVS Test #21-1 (normal RBVS exhaust alignment)
Prerequisites i.
Verify an instrument calibration has been completed, with approved records and within all calibration due dates, for all instruments required to perform this test.
ii.
Verify an RBVS air balance has been performed and the RBV system air balance records have been approved. [This prerequisite is not required for component-level tests.] (Note: The RBVS is designed to move air from areas that are not contaminated or are expected to have low levels of contamination to areas that are likely to be more contaminated.)
iii. RBVS high-efficiency particulate air and charcoal adsorbers have been installed and tested. [This prerequisite is not required for component-level tests.]
iv. Verify SFP exhaust charcoal and HEPA filter unit heater bank testing specified in RG 1.140 C.4.g has been completed and the test records have been approved.
Component Level Tests Test Objective Test Method Acceptance Criteria i.
Verify each RBVS remotely-operated damper can be operated remotely.
Operate each damper from the MCR and local control panel (if design has local damper control).
MCR display and local, visual observation indicate each damper fully opens and fully closes.
ii.
Verify each RBVS air-operated damper fails to its safe position on loss of air.
Place each damper in its non-safe position. Isolate and vent air to the damper.
MCR display and local, visual observation indicate each damper fails to its safe position.
NuScale Final Safety Analysis Report Initial Plant Test Program Tier 2 14.2-85 Draft Revision 3 Table 14.2-35: Liquid Radioactive Waste System Test # 35 Preoperational test is required to be performed once.
The LRWS is described in Section 11.2 and 11.5.2.1.5 and the functions verified by this test are:
System Function System Function Categorization Function Verified by Test #
1.
The LRWS supports the solid radioactive waste system (SRWS) by receiving and processing liquid radioactive waste from the SRWS dewatering skid.
nonsafety-related Test #35-1 Test #35-2 Component-level test xi SRWS Test #37-7 2.
The LRWS supports the SFPCS by receiving contaminated pool water to aid in the removal of titrated water or boron. Treated liquid radwaste has the option to return to the pool as makeup.
nonsafety-related Test #35-1 Test #35-2 Component-level tests 3.
The LRWS supports the CVCS by receiving and processing primary coolant from CVCS letdown.
nonsafety-related Test #35-1 Test #35-2 CVCS Test #38-1 4.
The LRWS supports the RWDS by receiving and processing the effluent from the RWB radioactive waste drain sumps.
nonsafety-related Test #35-1 Test #35-2 RWDS Test #23-1 5.
The LRWS supports the RWDS by receiving and processing the effluent from the RXB radioactive waste drain sumps.
nonsafety-related Test #35-1 Test #35-2 RWDS Test #23-1 6.
The LRWS supports the RWDS by receiving and processing the effluent from the ANB radioactive waste drain sumps.
nonsafety-related Test #35-1 Test #35-2 RWDS Test #23-1 7.
LRWS supports the CVCS by receiving and processing the noncondensable gases and vapor from the pressurizer.
nonsafety-related Test #35-1 8.
LRWS supports the PSCS by processing any fluid collected in the drain sump of the PSCS dike.
nonsafety-related Test #35-2 Component-level tests 9.
The NDS supports the LRWS by providing nitrogen for purging of the LRWS.
nonsafety-related Test #35-1 NDS Test #15 component-level tests The LRWS functions verified by other tests are:
System Function System Function Categorization Function Verified by Test #
The LRWS supports the CVCS by receiving and processing primary coolant from CVCS letdown.
nonsafety-related CVCS Test #38-1 The LRWS supports the RWDS by receiving and processing the effluent from theRWB radioactive waste drain sumps.
nonsafety-related RWDS Test #23-1 The LRWS supports the RWDS by receiving and processing the effluent from theRXB radioactive waste drain sumps.
nonsafety-related RWDS Test #23-1
NuScale Final Safety Analysis Report Initial Plant Test Program Tier 2 14.2-86 Draft Revision 3 The LRWS supports the RWDS by receiving and processing the effluent from the ANB radioactive waste drain sumps.
nonsafety-related RWDS Test #23-1 Prerequisites i.
Required ANSI/ANS-55.6 construction testing has been completed.
ii.
Verify an instrument calibration has been completed, with approved records and within calibration due dates, for instruments required to perform this test.Verify an instrument calibration has been completed, with approved records and within all calibration due dates, for all instruments required to perform this test.
Component Level Tests Test Objective Test Method Acceptance Criteria i.
Verify each LRWS remotely-operated valve can be operated remotely.
Operate each valve from the MCR and local control panel (if design has local valve control)
MCR display and local, visual observation indicate each valve fully opens and fully closes.
ii.
Verify each LRWS air-operated valve fails to its safe position on loss of air.
Place each valve in its non-safe position.
Isolate and vent air to the valve.
MCR display and local, visual observation indicate each valve fails to its safe position.
iii. Verify each LRWS air-operated valve fails to its safe position on loss of electrical power to its solenoid.
Place each valve in its non-safe position.
Isolate electrical power to each air-operated valve.
MCR display and local, visual observation indicate each valve fails to its safe position.
iv. Verify each LRWS pump can be started and stopped remotely.
Align the LRWS to allow for pump operation.
Stop and start each pump from the MCR.
MCR display and local, visual observation indicate each pump starts and stops.
Audible and visible water hammer are not observed when the pump starts.
v.
Verify the speed of each LRWS variable-speed pump can be manually controlled.
Align the LRWS to provide a flow path to operate a selected pump.
Vary the LRWS pump speed from minimum to maximum from the MCR.
MCR display indicates the speed of each obtains both minimum and maximum pump speeds.
vi. Verify radiation isolation on discharge to the utility water discharge basin high radiation, low dilution flow or underground pipe break.
Initiate the following a real or simulated signals:
i.
LRWS discharge to the utility water discharge basin high radiation signal.
ii.
LRWS discharge to the utility water discharge basin low dilution flow signal.
iii. LRWS discharge to the utility water discharge basin low guard pipe pressure signal.
MCR display and local, visual observation indicate the following:
i.
The LRWS discharge to the utility water discharge basin isolation valves close.
ii.
The LRWS discharge to the utility water discharge basin isolation valves close.
iii. The LRWS discharge to the utility water discharge basin isolation valves close.
[ITAAC 03.09.07]
(items i through iii) vii. Verify tank valves operate to ensure uninterrupted waste receiving.
Simulate an in-service tank high level signal for each of the following tanks:
low-conductivity waste (LCW) collection tank A and B high-conductivity waste (HCW) collection tank A and B LCW sample tank A and B HCW sample tank A and B MCR display and local, visual observation indicate the in-service tank fill valve is closed and the standby tank fill valve is open.
Table 14.2-35: Liquid Radioactive Waste System Test # 35 (Continued)
NuScale Final Safety Analysis Report Initial Plant Test Program Tier 2 14.2-87 Draft Revision 3 viii. Verify degasifier valves operate to ensure uninterrupted waste receiving.
i.
Initiate a simulated high degasifier level signal.
ii.
Initiate a simulated high degasifier pressure signal.
i and ii.
MCR display and local, visual observation indicate the in-service degasifier fill valve is closed and the standby degasifier fill valve is open.
ix. Verify LRW pumps automatically operate to prevent tank overflow.
Align the LRWS to allow each of the following LRW transfer pumps to automatically transfer effluent to one of its design locations.
Degasifier transfer pump A and B LCW collection tank transfer pump A and B
HCW collection tank transfer pump A and B
LCW sample tank transfer pump A and B HCW sample tank transfer pump A and B Detergent waste collection tank transfer pump Demineralized water break tank transfer pump i.
Simulate a HI HI level signal in each of the above tanks.
ii.
Simulate a low level signal in each of the above tanks.
MCR displays and local, visual observation indicate the following:
i.
The transfer pump starts and transfers effluent to its design location.
ii.
The transfer pump stops.
x.
Verify a local grab sample can be obtained from a LRWS grab sample device indicated on the LRW piping and instrumentation diagram.
Place the system in service to allow flow through the grab sampling device.
A local grab sample is successfully obtained.
xi. Verify SRWS dewatering skid effluent can be transferred to LRW high-conductivity waste (HCW) collection tanks.
Align SRWS dewatering skid discharge to one of the LRW high-conductivity waste collection tanks. Fill the SRWS dewatering skid high integrity container (HIC) to above the low level pump stop setpoint. Start the SRWS dewatering skid diaphragm pump.
SRWS dewatering skid effluent is transferred to the LRW high-conductivity waste collection tank. The SRWS dewatering skid diaphragm pump is stopped.
xii. Verify each LRWS instrument is available on an MCS or PCS display.
(Test not required if the instrument calibration verified the MCS or PCS display.)
Initiate a single real or simulated instrument signal from each LRWS transmitter.
The instrument signal is displayed on an MCS or PCS display, or is recorded by the applicable control system historian.
System Level Test #35-1 This test should be performed after the completion of Test 33-1 when the RCS is at normal operating pressure and the RCS has achieved the maximum temperature achievable by warming the RCS using MHS heating.
Test Objective Test Method Acceptance Criteria i.
Verify LRWS can process a gaseous waste stream.
Align LRWS to receive pressurizer gaseous waste from the pressurizer during hot functional testing.
Process the pressurizer gaseous waste through the LRW degasifier.
Purge the degasifier with nitrogen following operation.
i.
The LRW degasifier removes condensable gases and vents waste to the RBVS or GRWS.
ii.
The LRW degasifier liquid transfer pumps transfer the liquid condensate waste to the low conductivity waste collection tanks.
iii. LRW degasifier is purged with nitrogen.
Table 14.2-35: Liquid Radioactive Waste System Test # 35 (Continued)
NuScale Final Safety Analysis Report Initial Plant Test Program Tier 2 14.2-88 Draft Revision 3 System Level Test #35-2 Test Objective Test Method Acceptance Criteria i.
Verify LRWS can process a liquid waste stream.
Align LRWS to receive liquid waste from a liquid waste stream.
i.
Process the liquid waste stream through the low-conductivity waste (LCW) waste process.
ii.
Process the liquid waste stream through the HCW process.
The waste treatment streams are successfully processed through the following processes:
- filtration
- tubular filtration skid
- LCW processing skid
- HCW processing skid
- drum dryer skid
- demineralization
- transfer to LCW or HCW sample tanks
- transfer from LCW or HCW sample tanks to the UWS discharge basin.
Table 14.2-35: Liquid Radioactive Waste System Test # 35 (Continued)
NuScale Final Safety Analysis Report Initial Plant Test Program Tier 2 14.2-89 Draft Revision 3 Table 14.2-36: Gaseous Radioactive Waste System Test # 36 Preoperational test is required to be performed once.
The GRWS is described in Section 11.3 and 11.5.2.2.6 and the functions verified by this test or another preoperational test are:
System Function System Function Categorization Function Verified by Test #
1.
The GRWS supports the LRWS by receiving and / or collecting potentially radioactive and hydrogen-bearing waste gases which require processing prior to release to the environment.
nonsafety-related Test #36-1 2.
The GRWS supports the CES by receiving and / or collecting potentially radioactive and hydrogen-bearing waste gases which require processing prior to release to the environment.
nonsafety-related Test #36-1 CES Test #41-2 3.
The NDS supports the GRWS by providing nitrogen for purging of the GRWS.
nonsafety-related Test #36-1 NDS Test #15 component-level tests Prerequisites Verify an instrument calibration has been completed, with approved records and within all calibration due dates, for all instruments required to perform this test.
Component Level Tests Test Objective Test Method Acceptance Criteria i.
Verify each GRWS remotely-operated valve can be operated remotely.
Operate each valve from the (main control room) MCR and local control panel (if design has local valve control).
MCR display and local, visual observation indicate each valve fully opens and fully closes.
ii.
Verify each GRWS air-operated valve fails to its safe position on loss of air.
Place each valve in its non-safe position.
Isolate and vent air to the valve.
MCR display and local, visual observation indicate each valve fails to its safe position.
iii. Verify each GRWS air-operated valve fails to its safe position on loss of electrical power to its solenoid.
Place each valve in its non-safe position.
Isolate electrical power to each air-operated valve.
MCR display and local, visual observation indicate each valve fails to its safe position.
iv. Verify GRWS valves automatically operate to maintain vessel volume.
i.
Initiate a real or simulated high GRWS moisture separator level.
ii.
Initiate a real or simulated low GRWS moisture separator level.
MCR display and local, visual observation indicate the following:
i.
The moisture separator drain valve is open.
ii.
The moisture separator drain valve is closed.
v.
Verify GRWS inlet isolation valves automatically close and nitrogen purge valve opens on high inlet stream oxygen concentration.
Simulate a GRWS inlet stream oxygen concentration high signal.
MCR display and local, visual observation indicate the following:
i.
The inlet stream isolation valves are closed.
ii.
The nitrogen purge valve is open.
vi. Verify GRWS isolates upon loss of RWBV exhaust flow.
Simulate a loss of RWBVS exhaust flow.
MCR display and local, visual observation indicate the GRWS isolation valves are closed.
NuScale Final Safety Analysis Report Initial Plant Test Program Tier 2 14.2-90 Draft Revision 3 vii. Verify radiation isolation of GRWS charcoal decay beds upon detection of decay bed discharge flow high radiation level.
i.
Initiate a real or simulated GRWS train A decay bed discharge flow high radiation signal.
ii.
Initiate a real or simulated GRWS train B decay bed discharge flow high radiation signal.
MCR display and local, visual observation indicate the following:
i.
GRWS train A charcoal decay bed discharge isolation valve is closed.
[ITAAC 03.09.04]
ii.
GRWS train B charcoal decay bed discharge isolation valve is closed.
[ITAAC 03.09.05]
viii. Verify radiation isolation of GRWS discharge to the RBVS exhaust upon detection of a high radiation level.
Initiate a real or simulated GRWS discharge to the RBVS exhaust high radiation signal.
MCR display and local, visual observation indicate the GRWS discharge to the RBVS exhaust isolation valves are closed.
[ITAAC 03.09.06]
ix. Verify a local grab sample can be obtained from a GRWS grab sample device indicated on the GRWS piping and instrumentation diagram.
Place the system in service to allow flow through the grab sampling device.
A local grab sample is successfully obtained.
x.
Verify each GRWS instrument is available on an MCS or PCS display.
(Test not required if the instrument calibration verified the MCS or PCS display.)
Initiate a single real or simulated instrument signal from each GRWS transmitter.
The instrument signal is displayed on an MCS or PCS display, or is recorded by the applicable control system historian.
System Level Test #36-1 Test Objective Test Method Acceptance Criteria Verify GRWS can process a gaseous waste stream and nitrogen stream.
i.
Align GRWS to receive gaseous waste from a gaseous waste stream.
Process the gaseous waste stream through the gaseous waste process.
ii.
Align GRWS charcoal drying heater to receive nitrogen from NDS.
Process nitrogen through the charcoal drying process.
i.
The gaseous waste stream is successfully processed through the following processes:
- gas cooler
- moisture separator
- charcoal drying heater
- charcoal guard bed
- charcoal decay beds
- RWB exhaust ii.
Nitrogen is successfully processed through the charcoal drying heater.
Table 14.2-36: Gaseous Radioactive Waste System Test # 36 (Continued)