ML19198A325

LLC - Supplemental Response to NRC Request for Additional Information No. 249 (Erai No. 9135) on the NuScale Design Certification Application

ML19198A325
Person / Time
Site:	NuScale
Issue date:	07/17/2019
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
References
RAIO-0719-66341
Download: ML19198A325 (10)

Text

RAIO-0719-66341 July 17, 2019 Docket No.52-048 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738

SUBJECT:

NuScale Power, LLC Supplemental Response to NRC Request for Additional Information No. 249 (eRAI No. 9135) on the NuScale Design Certification Application

REFERENCES:

1. U.S. Nuclear Regulatory Commission, "Request for Additional Information No. 249 (eRAI No. 9135)," dated September 29, 2017

2. NuScale Power, LLC Response to NRC "Request for Additional Information No. 249 (eRAI No.9135)," dated November 21, 2017

3. NuScale Power, LLC Supplemental Response to NRC "Request for Additional Information No. 249 (eRAI No. 9135)," dated June 11, 2018

4. NuScale Power, LLC Supplemental Response to NRC "Request for Additional Information No. 249 (eRAI No. 9135)," dated December 20, 2018 The purpose of this letter is to provide the NuScale Power, LLC (NuScale) supplemental response to the referenced NRC Request for Additional Information (RAI).

The Enclosure to this letter contains NuScale's supplemental response to the following RAI Question from NRC eRAI No. 9135:

• 14.03.03-5 This letter and the enclosed response make no new regulatory commitments and no revisions to any existing regulatory commitments.

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

Sincerely, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution: Gregory Cranston, NRC, OWFN-8H12 Samuel Lee, NRC, OWFN-8H12 Cayetano Santos, NRC, OWFN-8H12 Enclosure 1: NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9135 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0719-66341 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9135 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9135 Date of RAI Issue: 09/29/2017 NRC Question No.: 14.03.03-5 The NRC regulations in 10 CFR 52.47(b)(1) require that a design certification application contain the inspections, tests, analyses, and acceptance criteria (ITAAC) that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a plant that incorporates the design certification is built and will operate in accordance with the design certification, the provisions of the Atomic Energy Act, and the NRC's regulations. The ITAAC proposed in the NuScale FSAR Tier 1, Section 2.1, NuScale Power Module, Section 2.2, Chemical and Volume Control System, and Section 2.4, Turbine Generator System, do not include ITAAC to verify the functional arrangement or installed configuration of the applicable systems and components. See June 21, 2016, transmittal letter providing additional standardized ITAAC, ADAMS Accession No. ML16160A179). Verification of the installed configuration of a system includes verifying that the system and its components are installed in a manner that supports the safety functions for which the system is intended, consistent with procurement, construction, and installation specifications. This verification should include visual inspection (e.g., walkdown) of the system, including its flowpath, and may be performed in conjunction with other preoperational activities.

Examples of the verification performed by the licensee to complete this ITAAC include confirmation of valve orientation, verification of adequate access for inservice inspection (ISI) and inservice testing (IST) activities, and confirmation that interferences are avoided. The Design Commitment of these ITAAC should specify that the installed configuration of the system, including its flowpath, is consistent with procurement, construction, and installation specifications such that the systems safety functions can be achieved. The ITA should specify that inspection of the as-built system will be performed to verify the installed configuration, including the flowpath. The Acceptance Criteria should specify that the systems installed configuration, including the flowpath, of the components listed in the applicable ITAAC table is consistent with procurement, construction, and installation specifications such that the systems NuScale Nonproprietary

safety functions can be achieved. As discussed above, the NRC staff requests that the NuScale design certification applicant include proposed ITAAC to verify the functional arrangement or installed configuration of the applicable systems and components in NuScale FSAR Tier 1, Section 2.1, 2.2, and 2.4.

NuScale Response:

The Nuclear Regulatory Commission (NRC) issued request for additional information (RAI) 9135 requesting functional arrangement (installed configuration) Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) on September 29, 2017. In the initial response to the RAI, and two subsequent supplemental responses, NuScale maintained that the proposed ITAAC was redundant and ambiguous, and therefore not required.

On May 7, 2019 the NRC provided NuScale with a proposed example ITAAC to move forward to resolve RAI 9135.

Design Committment:

The as-installed emergency core cooling system (ECCS) valves, containment isolation valves (CIVs), and decay heat removal system (DHRS) actuation valves and their hydraulic lines are consistent with their as-built specifications for geometric configuration, orientation, accessibility, and line routing (including twisting, bend radii, crimping, support, line separation, and removal of safe shipment features), such that each valve can perform its safety functions.

Inspections, Tests, Analyses:

An inspection of the ECCS valves, CIVs, and DHRS actuation valves listed in Table XXX and their hydraulic lines will be performed following installation of the NuScale Power Module (NPM) into its operating position in the reactor pool, or in its on-site dry dock location.

Acceptance Criteria:

The as-installed ECCS valves, CIVs, and DHRS actuation valves listed in Table XXX and their hydraulic lines are consistent with their as-built specifications for geometric configuration, orientation, accessibility, and line routing (including twisting, bend radii, crimping, support, line separation, and removal of safe shipment features), such that each valve can perform its safety functions.

NuScale Nonproprietary

During the meeting NuScale stated that the ITAAC remains ambiguous as written. NuScale provided suggestions as to how the ITAAC could be revised, i.e. quality control hold points as part of the acceptance criteria. NRC responded that they would be open to NuScale proposing language and have further dialogue for final acceptance of the ITAAC and resolution of RAI 9135 which is open item 14.3.3-1 in the Chapter 14 safety evaluation report.

Subsequently, NRC and NuScale have modified the language above as discussed during several public meetings. ITAAC 02.01.26, NPM valve installation verification ITAAC, has been added to both Tier 1 and Tier 2.

Impact on DCA:

Tier 1 Section 2.1, Tier 1 Table 2.1-4, and Tier 2 Table 14.3-1 have been revised as described in the response above and as shown in the markup provided in this response.

NuScale Nonproprietary

NuScale Tier 1 NuScale Power Module RAI 14.03.03-5S3

• The ECCS valves, CIVs, and DHRS actuation valves listed in Table 2.1-2, and their associated hydraulic lines, are installed such that each valve can perform its safety function.

2.1.2 Inspections, Tests, Analyses, and Acceptance Criteria Table 2.1-4 contains the inspections, tests, and analyses for the NPM.

Tier 1 2.1-6 Draft Revision 3

NuScale Tier 1 NuScale Power Module RAI 06.02.06-22, RAI 06.02.06-23, RAI 08.01-1, RAI 08.01-1S1, RAI 08.01-2, RAI 14.03.03-3S1, RAI 14.03.03-4S1, RAI 14.03.03-5S3, RAI 14.03.03-6S1, RAI 14.03.03-7S1, RAI 14.03.03-8, RAI 14.03.03-11S1, RAI 14.03.07-1 Table 2.1-4: NuScale Power Module Inspections, Tests, Analyses, and Acceptance Criteria No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria

1. The NuScale Power Module ASME An inspection will be performed of the The ASME Code Section III Design Code Class 1, 2 and 3 piping systems NuScale Power Module ASME Code Reports (NCA-3550) exist and listed in Table 2.1-1 comply with ASME Class 1, 2 and 3 as-built piping system conclude that the NuScale Power Code Section III requirements. Design Reports required by ASME Module ASME Code Class 1, 2 and 3 as-Code Section III. built piping systems listed in Table 2.1-1 meet the requirements of ASME Code Section III.

2. The NuScale Power Module ASME An inspection will be performed of the ASME Code Section III Data Reports for Code Class 1, 2, and 3 components NuScale Power Module ASME Code the NuScale Power Module ASME conform to the rules of construction of Class 1, 2, and 3 as-built component Code Class 1, 2, and 3 components ASME Code Section III. Data Reports required by ASME Code listed in Table 2.1-2 and Section III. interconnecting piping exist and conclude that the requirements of ASME Code Section III are met.

3. The NuScale Power Module ASME An inspection will be performed of the ASME Code Section III Data Reports for Code Class CS components conform to NuScale Power Module ASME Code the NuScale Power Module ASME the rules of construction of ASME Class CS as-built component Data Code Class CS components listed in Code Section III. Reports required by ASME Code Table 2.1-2 exist and conclude that the Section III. requirements of ASME Code Section III are met.

4. Safety-related SSC are protected An inspection and analysis will be Protective features are installed in against the dynamic and performed of the as-built high- and accordance with the as-built Pipe environmental effects associated with moderate-energy piping systems and Break Hazard Analysis Report and postulated failures in high- and protective features for the safety-related SSC are protected moderate-energy piping systems. safety-related SSC. against or qualified to withstand the dynamic and environmental effects associated with postulated failures in high- and moderate-energy piping systems.

5. The NuScale Power Module ASME An analysis will be performed of the The as-built LBB analysis for the ASME Code Class 2 piping systems and ASME Code Class 2 as-built piping Code Class 2 piping systems listed in interconnected equipment nozzles are systems and interconnected Table 2.1-1 and interconnected evaluated for LBB. equipment nozzles. equipment nozzles is bounded by the as-designed LBB analysis.

6. The RPV beltline material has a Charpy A vendor test will be performed of the An ASME Code Certified Material Test upper-shelf energy of 75 ft-lb Charpy V-Notch specimen of the RPV Report exists and concludes that the minimum. beltline material. initial RPV beltline material Charpy upper-shelf energy is 75 ft-lb minimum.

7. The CNV serves as an essentially leak- A leakage test will be performed of the The leakage rate for local leak rate tight barrier against the uncontrolled pressure containing or leakage- tests (Type B and Type C) for pressure release of radioactivity to the limiting boundaries, and CIVs. containing or leakage-limiting environment. boundaries and CIVs meets the requirements of 10 CFR Part 50, Appendix J.

8. Containment isolation valve closure A test will be performed of the Each CIV listed in Table 2.1-3 travels times limit potential releases of automatic CIVs. from the full open to full closed radioactivity. position in less than or equal to the time listed in Table 2.1-3 after receipt of a containment isolation signal.

Tier 1 2.1-14 Draft Revision 3

NuScale Tier 1 NuScale Power Module Table 2.1-4: NuScale Power Module Inspections, Tests, Analyses, and Acceptance Criteria (Continued)

No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria

22. i. A CNTS containment electrical i. An analysis will be performed of the i. A circuit interrupting device penetration assembly is rated to CNTS as-built containment electrical coordination analysis exists and withstand fault currents for the time penetration assembly. concludes that the current carrying required to clear the fault from its capability for each CNTS containment power source. electrical penetration assembly listed OR in Table 2.1-3 is greater than the analyzed fault currents for the time required to clear the fault from its power source.

OR ii. A CNTS containment electrical ii. An analysis of the CNTS containment penetration assembly is rated to penetration maximum fault current withstand the maximum fault current exists and concludes the fault current for its circuits without a circuit is less than the current carrying interrupting device. capability of the CNTS containment electrical penetration

23. The CNV serves as an essentially A preservice design pressure leakage No water leakage is observed at CNV leaktight barrier against the test of the CNV will be performed. bolted flange connections.

uncontrolled release of radioactivity to the environment.

24. The NPM lifting fixture supports its A rated load test will be performed of The NPM lifting fixture supports a load rated load. the NPM lifting fixture. of at least 150 percent of the manufacturer's rated capacity.

25. The NPM lifting fixture is constructed An inspection will be performed of the The NPM lifting fixture is single-failure-to provide assurance that a single as-built NPM lifting fixture. proof.

failure does not result in the uncontrolled movement of the lifted load.

26. The ECCS valves, CIVs, and DHRS An inspection will be performed of A report exists and concludes each actuation valves listed in Table 2.1-2, each ECCS valve, CIV, and DHRS ECCS valve, CIV, and DHRS actuation and their associated hydraulic lines, actuation valve listed in Table 2.1-2, valve listed in Table 2.1-2, and the are installed such that each valve can and associated hydraulic line. associated hydraulic line, is installed in perform its safety function. accordance with its associated installation specification.

Tier 1 2.1-17 Draft Revision 3

Tier 2 NuScale Final Safety Analysis Report RAI 03.02.02-7, RAI 06.02.06-22, RAI 06.02.06-23, RAI 08.01-1S1, RAI 08.01-2, RAI 10.02-3, RAI 10.02.03-1, RAI 10.02.03-2, RAI 14.03.03-3S1, RAI 14.03.03-4S1, RAI 14.03.03-5S3,RAI 14.03.03-6, RAI 14.03.03-6S1, RAI 14.03.03-7, RAI 14.03.03-7S1, RAI 14.03.03-8, RAI 14.03.03-9, RAI 14.03.03-9S1, RAI 14.03.07-1 Table 14.3-1: Module-Specific Structures, Systems, and Components Based Design Features and Inspections, Tests, Analyses, and Acceptance Criteria Cross Reference(1)

ITAAC No. System Discussion DBA Internal/External Radiological PRA & Severe FP Hazard Accident 02.01.01 NPM As required by ASME Code Section III NCA-1210, each ASME Code X Class 1, 2 and 3 component (including piping systems) of a nuclear power plant requires a Design Report in accordance with NCA-3550. NCA-3551.1 requires that the drawings used for construction be in agreement with the Design Report before it is certified and be identified and described in the Design Report. It is the responsibility of the N Certificate Holder to furnish a Design Report for each component and support, except as provided in NCA-3551.2 and NCA-3551.3. NCA-3551.1 also requires that the Design Report be certified by a registered professional engineer when it is for Class 1 components and supports, Class CS core support structures, Class MC vessels and supports, Class 2 vessels 14.3-14 designed to NC-3200 (NC-3131.1), or Class 2 or Class 3 components designed to Service Loadings greater than Design Loadings. A Class Certified Design Material and Inspections, Tests, Analyses, and 2 Design Report shall be prepared for Class 1 piping NPS 1 or smaller that is designed in accordance with the rules of Subsection NC. NCA-3554 requires that any modification of any document used for construction, from the corresponding document used for design analysis, shall be reconciled with the Design Report.

An ITAAC inspection is performed of the NuScale Power Module ASME Code Class 1, 2 and 3 as-built piping system Design Report to verify that the requirements of ASME Code Section III are met.

Acceptance Criteria Draft Revision 3

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

ITAAC No. System Discussion DBA Internal/External Radiological PRA & Severe FP Hazard Accident 02.01.26 NPM Quality Control inspection hold points are used to ensure the as-built ECCS valves, CIVs, DHRS actuation valves, and their associated hydraulic lines are installed consistent with their associated installation specifications, and therefore capable of performing their safety functions. To demonstrate the acceptance criterion for ITAAC 02.01.26 has been satisfied and the associated design commitment fully met, a report will exist and conclude the following:

1) Quality Control inspection hold points exist and have been completed in accordance with the Quality Assurance Program for each of the following attributes of the ECCS valves, CIVs, and DHRS actuation valves:

a. Geometric configuration

b. Orientation

c. Accessibility 14.3-26 2) Quality Control inspection hold points exist and have been Certified Design Material and Inspections, Tests, Analyses, and completed in accordance with the Quality Assurance Program for each of the following attributes of routing of the hydraulic lines of the ECCS valves, CIVs, and DHRS actuation valves:

a. Twisting

b. Bend radii

c. Crimping

d. Support

e. Line separation

f. Safe shipment feature removal Acceptance Criteria Draft Revision 3