ML24087A114
| ML24087A114 | |
| Person / Time | |
|---|---|
| Site: | 99902056 |
| Issue date: | 03/27/2024 |
| From: | NRC |
| To: | NRC/NRR/DNRL |
| References | |
| Download: ML24087A114 (12) | |
Text
From:
Greg Cranston Sent:
Wednesday, March 27, 2024 9:58 AM To:
Schiele, Raymond Joseph; Klein, Spencer Paul; Montague, Kelvin Jevon Cc:
Allen Fetter; Michelle Hayes; Sean Gallagher; ClinchRiver-CPSafDocsPEm Resource; Brian Wittick; Ian Tseng; Thomas Scarbrough; Kaihwa Hsu; Edward Stutzcage; Nicholas Hansing; Yuken Wong; Vijay K Goel; Hanry Wagage; Stewart Bailey; Kevin Hsueh; Wendell Morton
Subject:
Readiness Assessment Observations on draft PSAR Chapter/Sections 8, 10, 3.6, 3.9, 3.10, 3.11, 3.12, 3.13, and 11 - draft Clinch River CP application Attachments:
Initial Observations PSAR 8 Readiness Assessment3-12-24DraftClean.pdf; Initial Observations PSAR 10 Readiness Assessment Phase 2 Draft3 24Clean.pdf; Initial Observations PSAR 3.6 & 3.9-3.13 Readiness Assessment Phase 4 3-12-24.pdf; Initial Observations PSAR 11 Readiness Assessment Phase 4 Draft 3-12-24Clean.pdf Resent to include attachment for Ch 11.
From: Greg Cranston Sent: Wednesday, March 27, 2024 9:49 AM To: 'Schiele, Raymond Joseph' <rjschiele@tva.gov>; 'Klein, Spencer Paul' <spklein@tva.gov>; Montague, Kelvin Jevon <kjmontague@tva.gov>
Cc: Allen Fetter <Allen.Fetter@nrc.gov>; Michelle Hayes <Michelle.Hayes@nrc.gov>; Sean Gallagher
<Sean.Gallagher@nrc.gov>; ClinchRiver-CPSafDocsPEm Resource <ClinchRiver-CPSafDocsPEm.Resource@nrc.gov>; Brian Wittick <Brian.Wittick@nrc.gov>; Ian Tseng
<Ian.Tseng@nrc.gov>; Thomas Scarbrough <Thomas.Scarbrough@nrc.gov>; Kaihwa Hsu
<Kaihwa.Hsu@nrc.gov>; Edward Stutzcage <Edward.Stutzcage@nrc.gov>; Nicholas Hansing
<Nicholas.Hansing@nrc.gov>; Yuken Wong <Yuken.Wong@nrc.gov>; Vijay K Goel <Vijay.Goel@nrc.gov>;
Hanry Wagage <Hanry.Wagage@nrc.gov>; Stewart Bailey <Stewart.Bailey@nrc.gov>; Kevin Hsueh
<Kevin.Hsueh@nrc.gov>; Wendell Morton <Wendell.Morton@nrc.gov>
Subject:
Readiness Assessment Observations on draft PSAR Chapter/Sections 8, 10, 3.6, 3.9, 3.10, 3.11, 3.12, 3.13, and 11 - draft Clinch River CP application Good Afternoon, Attached are initial NRC staff observations on draft PSAR Chapter/Sections 8, Electrical; 10 - Steam and Power Conversion; 3.6 - Protection Against Dynamic Effects Associated with the Postulated Rupture of Piping; 3.9 - Mechanical Systems and Components; 3.10 - Seismic and Dynamic Qualification of Mechanical and Electrical Equipment; 3.11 - Environmental Qualification of Mechanical and Electrical Equipment; 3.12 - ASME BPV Code Class 1, 2, and 3 Piping Systems and Associated Support Design; 3.13
- Threaded FastenersASME BPV Code Class 1, 2, and 3; and 11 - Radioactive Waste Management, that staff viewed in TVAs electronic reading room as part of Phase 2 and Phase 4 of the Readiness Assessment of the draft Clinch River CP application.
After all six phases of the Readiness Assessment are completed, NRC will transmit, via letter, a compilation of all final Readiness Observations on the Clinch River CP PSAR chapters and sections. The nomenclature initial is being used to account for potential TVA updates to the PSAR before the end of the Readiness Assessment.
If TVA makes any future updates to the draft PSAR chapters and sections for follow up observations by NRC staff, please contact me, Allen Fetter or Sean Gallagher.
Thank you, Greg
Hearing Identifier:
ClinchRiver_CPSafDocs_Public Email Number:
17 Mail Envelope Properties (DM6PR09MB5271D8AF819F2D0563017C2490342)
Subject:
Readiness Assessment Observations on draft PSAR ChapterSections 8, 10, 3.6, 3.9, 3.10, 3.11, 3.12, 3.13, and 11 - draft Clinch River CP application Sent Date:
3/27/2024 9:57:41 AM Received Date:
3/27/2024 9:57:45 AM From:
Greg Cranston Created By:
Gregory.Cranston@nrc.gov Recipients:
"Allen Fetter" <Allen.Fetter@nrc.gov>
Tracking Status: None "Michelle Hayes" <Michelle.Hayes@nrc.gov>
Tracking Status: None "Sean Gallagher" <Sean.Gallagher@nrc.gov>
Tracking Status: None "ClinchRiver-CPSafDocsPEm Resource" <ClinchRiver-CPSafDocsPEm.Resource@nrc.gov>
Tracking Status: None "Brian Wittick" <Brian.Wittick@nrc.gov>
Tracking Status: None "Ian Tseng" <Ian.Tseng@nrc.gov>
Tracking Status: None "Thomas Scarbrough" <Thomas.Scarbrough@nrc.gov>
Tracking Status: None "Kaihwa Hsu" <Kaihwa.Hsu@nrc.gov>
Tracking Status: None "Edward Stutzcage" <Edward.Stutzcage@nrc.gov>
Tracking Status: None "Nicholas Hansing" <Nicholas.Hansing@nrc.gov>
Tracking Status: None "Yuken Wong" <Yuken.Wong@nrc.gov>
Tracking Status: None "Vijay K Goel" <Vijay.Goel@nrc.gov>
Tracking Status: None "Hanry Wagage" <Hanry.Wagage@nrc.gov>
Tracking Status: None "Stewart Bailey" <Stewart.Bailey@nrc.gov>
Tracking Status: None "Kevin Hsueh" <Kevin.Hsueh@nrc.gov>
Tracking Status: None "Wendell Morton" <Wendell.Morton@nrc.gov>
Tracking Status: None "Schiele, Raymond Joseph" <rjschiele@tva.gov>
Tracking Status: None "Klein, Spencer Paul" <spklein@tva.gov>
Tracking Status: None "Montague, Kelvin Jevon" <kjmontague@tva.gov>
Tracking Status: None Post Office:
DM6PR09MB5271.namprd09.prod.outlook.com
Files Size Date & Time MESSAGE 2393 3/27/2024 9:57:45 AM Initial Observations PSAR 8 Readiness Assessment3-12-24DraftClean.pdf 120683 Initial Observations PSAR 10 Readiness Assessment Phase 2 Draft3-12-24Clean.pdf 141851 Initial Observations PSAR 3.6 & 3.9-3.13 Readiness Assessment Phase 4 3-12-24.pdf 187123 Initial Observations PSAR 11 Readiness Assessment Phase 4 Draft 3-12-24Clean.pdf 141578 Options Priority:
Normal Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Chapter 8, Electric Poweri Clinch River CP application Revision 3/12/24 Chapter/Section 8 - Electric Power Chapter/
Section Basis for Observation/Comment Readiness Assessment Observations/Comments Chapter 8 10 CFR Part 50 Appendix A, GDC 1, 2, 3, 4, 5, 17, 18 1. Chapter 8 shows that there are three Safety Categories of Functions/Systems/Equipment - SC1, SC2, and SC3. Provide a list of electrical equipment by safety category - function/system - and the associated specific qualifications for each category with justification. Also, specify which NRC regulations will apply (or not apply) to each of the category. The terminology and SC1, SC2 and SC3 categories are discussed in GEH LTR NEDC-33934P/NEDO-33934, Revision 0, BWRX-300 Safety Strategy Licensing Topical Report.
Chapter 8 10 CFR Part 50 Appendix A, GDC 1, 2, 3, 4, 5, 17, 18
- 2. In Chapter 8, references to certain International Electrotechnical Commission (IEC) standards are made in addition to the IEEE standards. The application of IEC standards should not conflict with the applicable requirements of IEEE standards or the applicable NRC regulatory guides.
i Input provided by NRR/DEX/EEEB
Readiness Assessment - Phase 2 Chapter 10, Instrumentation and Controlsi Clinch River CP application Revision 3/12/24 Chapter/Section 10 - Steam and Power Conversion System Section Basis for Observation/Comment Readiness Assessment Observations/Comments Section 10.2.1 10 CFR Part 50, Appendix A, General Design Criteria 4 Section 10.2.1 states that the safety classifications, quality groups, and seismic categories of the TG SSCs are listed in Appendix 3A. However, this appendix is not provided for review.
Chapter/Section 10 - Steam and Power Conversion System Section Basis for Observation/Comment Readiness Assessment Observations/Comments Section 10.4.4.3 10 CFR Part 50, Appendix A, General Design Criteria 4 The text indicates that the TBS complies with GDC 4, which will be discussed at plant level in section 3.1. However, section 3.1 is not provided for review.
i Input provided by NRR/DSS/SCPB
Readiness Assessment - Phase 4 Chapter 3, Design of Structures, Components and Systemsi Clinch River CP application Revision 3/12/24 Chapter/Section 3.6 - Protection Against Dynamic Effects Associated with the Postulated Rupture of Piping Section Basis for Observation/
Comment Readiness Assessment Observations/Comments Section 3.6.1.1.4 10 CFR 50, Appendix A, GDC4 Clarify what are indirect dynamic effects.
Chapter/Section 3.9 - Mechanical Systems and Components Section Basis for Observation/
Comment Readiness Assessment Observations/Comments Section 3.9 10 CFR 50.55a RG 1.100
- 1. ASME QME-1-2017 is the latest version of ASME QME-1 endorsed in RG 1.100 at this time. Additionally, the 2019 edition is the current version of the ASME BPV Code incorporated by reference in 10 CFR 50.55a.
While there are plans to endorse/incorporate later versions, the applicant should be aware of any potential conditions on the endorsement/
incorporation when finalized. [Note: NRC understands that TVA plans to use the 2021 Edition, per their listed references in 3.9 and that there are processes to allow for alternatives to the Codes and Standards rule (10 CFR 50.55a). The next rulemaking which will incorporate the 2021 Edition is in process.]
- 2. Section 3.9 should include a table identifying the active valves and a table identifying the inservice testing activities for applicable pumps and valves.
- 3. Section 3.9, first sentence should be Safety Class instead of Safety Cass.
Section 3.9.1.4 10 CFR Part 50, Appendix A RG 1.100.
- 1. Section 3.9.1.4 should include references to the functional qualification of valves per ASME QME-1 as accepted in RG 1.100.
- 2. Clarify whether there are any essential safety-related systems and piping that need to be designed to normal stress limits for plant faulted condition.
- 3. Clarify whether the containment penetration sleeve anchors are designed to combined loads from inside containment (CTMT) and outside CTMT loads. Also, applies to 3.12.1.
Section 3.9.2.1 10 CFR 50.55a Section 3.9.2.1, Piping Vibration, Thermal Expansion and Dynamic Effects - Should reference the standards you are using. Typically, applicants reference ASME Operation and
Readiness Assessment - Phase 4 Maintenance Code Part 3, Vibration Testing of Piping Systems and Part 7, Thermal Expansion Testing of Nuclear Power Plant Piping Systems.
Section 3.9.3.6.1 10 CFR Part 50, Appendix A Subsection 3.12.3.13 states "Combination of inertia and seismic anchor motion effects are discussed in Subsection 3.9.3.6.1. However, Subsection 3.9.3.6.1 does not discuss the combination of inertial and seismic anchor motion effects.
Section 3.9.3.7 10 CFR 50.55a FIV loads associated with transients are evaluated as part of alternative service level. Clarify what is this alternative service level.
Section 3.9.3.12 10 CFR Part 50, Appendix A RG 1.100 Section 3.9.3.12 should:
(1) be revised to clarify the second paragraph regarding use of parentheses.
(2) specify that ASME QME-1 will be used as accepted by RG 1.100 for the applicable valves (3) indicate the specific valves that will be qualified using QME-1 per RG 1.100 and the valves that will be qualified by a different method (4) specify the approach for the qualification of passive valves to meet the NRC regulations.
Section 3.9.3.14.2 10 CFR Part 50, Appendix A RG 1.100 Section 3.9.3.14.2 should be updated to specify the use of ASME QME-1 as accepted in RG 1.100 for qualification testing. For example, this section includes outdated qualification language that only refers to time limits and differential pressure in demonstrating the functional capability of valves.
Section 3.9.3.14.3 10 CFR Part 50, Appendix A RG 1.100 Section 3.9.3.14.3 should be updated to specify the use of ASME QME-1 as accepted in RG 1.100 for qualification testing because the language appears out of date.
Section 3.9.4.4 NUREG-0800, SRP 3.9.4.
Section 3.9.4.4 "Control Rod Drive Performance Assurance Program" primarily discusses the integrity function of the reactor coolant pressure boundary (RCPB) components of the control rod drive mechanism (CRDM) but has insufficient discussion of the plans for an operability assurance program, as described in SRP 3.9.4, Control Rod Drive Systems.
Section 3.9.5 10 CFR Part 50.34 Section 3.9.5, Reactor Pressure Vessel Internals or other sections of the PSAR should provide more figures to allow the staff to understand the basic design of the reactor internals.
Section 3.9.6 10 CFR 50.55a Section 3.9.6 should:
(1) specify that the ASME OM Code must be implemented as incorporated by reference in 10 CFR 50.55a (2) indicate the pumps, valves, and snubbers that will undergo inservice testing in accordance with 10 CFR 50.55a.
Readiness Assessment - Phase 4 Chapter/Section 3.10 - Seismic and Dynamic Qualification of Mechanical and Electrical Equipment Section Basis for Observation/
Comment Readiness Assessment Observations/Comments Section 3.10.3.3 IEC/IEEE 60980-344 IEEE 382 Section 3.10.3.3, line-mounted equipment refers to IEC/IEEE 60980-344 and IEEE 382. Line-mounted equipment may also include active mechanical equipment that may also be subject to ASME QME-1 qualification. Consider whether discussion of ASME QME-1 may be appropriate in this section.
Section 3.10.1.1.1 10 CFR Part 50, Appendix A RG 1.100, Rev. 4 Section 3.10.1.1.1, Qualification by Actual Seismic Experience states that IEC/IEEE 60980-344, Annex A provides experience based seismic qualification methodology and is utilized as appropriate. The NRC stated the staff positions in RG 1.100, Rev. 4 regarding the necessary information for the review of the use of earthquake experience for the seismic qualification of electrical equipment apply.
Section 3.10.2.2.1 Section 3.10.2.2.4 10 CFR Part 50, Appendix A Section 3.10.2.2.1, Interface Requirements states that the effects of intervening structures or components that serves as interfaces between the equipment to be qualified and that are supplied by others are not qualified as part of the program. Section 3.10.2.2.4, Mounting of Test Specimen states that the test specimen is mounted to the test table so that inservice mounting, including interfaces, is simulated. It is not clear that these statements are consistent. The NRC staff notes that IEC/IEEE 344-60980-2020, Nuclear Facilities - Equipment Important to Safety - Seismic Qualification, Section 9.1.2, Mounting, states that the effect of electrical connections, conduit, sensing lines, and any other interfaces shall be considered and included in the setup up to the first interface support unless otherwise justified.
Readiness Assessment - Phase 4 Chapter/Section 3.11 - Environmental Qualification of Mechanical and Electrical Equipment Section Basis for Observation/
Comment Readiness Assessment Observations/Comments Section 3.11 10 CFR Part 50, Appendix A, GDC 4 NUREG-0800, SRP 3.11 RG 1.89 Section 3.11 discusses mild and harsh environments. The description of a harsh environment appears to address the definition in 10 CFR 50.49. However, it does not address the potential of equipment degradation due to long term radiation exposure regardless of the change in the environment during accident conditions. GDC 4 specifies that SSCs important to safety shall be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents. The application should address the potential degradation of equipment due to cumulative radiation exposure, even if the accident conditions are not significantly different than normal operating conditions. For example, SRP 3.11 and RG 1.89 provides guidance on the total integrated doses which the staff has previously considered acceptable thresholds for determining if an environment is mild or harsh for the purposes of determining if the equipment may be degraded from long term radiation exposure.
Section 3.11 10 CFR Part 50, Appendix A, GDC 4 It is unclear what assumptions are made for determining the total integrated doses that equipment is expected to receive and what total integrated doses equipment are expected to be exposed to.
Section 3.11.2.5.1 ASME QME-1 The topic of mechanical equipment qualification is discussed in 3.11.2.5.1, but the proposed methodology used is not clear.
Clarify if ASME QME-1 is the intended methodology. Specify if nonmandatory appendices (such as QR-B for non-metallics) will be used.
Readiness Assessment - Phase 4 Chapter/Section 3.12-ASME BPV Code Class 1, 2, and 3 Piping Systems and Associated Support Design Section Basis for Observation/
Comment Readiness Assessment Observations/Comments Section 3.12.2.1 N/A Subsection 3.12.2.1 states "The computer Programs used in the mechanical system and component analyses of the SC1 components are described in Appendix 3J and subsection 3.9.1.2. However, Appendix 3J is not available.
Section 3.12.2.4 10 CFR 50.55a
- 1. Clarify the decoupling criteria used for Piping analysis in terms of diameter ratio, section modulus ratio, or moment of inertia ratio.
- 2. Clarify whether seismic loading from OBE is a part of Service Level B evaluations.
Chapter/Section 3.13 - Threaded FastenersASME BPV Code Class 1, 2, and 3 Section Basis for Observation/
Comment Readiness Assessment Observations/Comments Section 3.13 NUREG-0800, Standard Review Plan, Section 3.13.
It would aid clarity and facilitate the review if the applicant summarized the provided ASME Code citations in a table, organized such as the Table 3.13-1 of NUREG 0800, SRP 3.13. The textual citation of the respective ASME Code requirements is somewhat open to interpretation.
Providing descriptions of novel bolting features, such as permanently affixed tooling fixturing, would be helpful in review of this section as well (these may or may not exist in the design and may or may not already be described elsewhere).
i Input provided by NRR/DEX/EIMB; DRA/ARCB; DNRL/NVIB
Readiness Assessment - Phase 4 Chapter 11, Radioactive Waste Management i Clinch River CP application Revision 3/12/24 Chapter/Section 11 - Radioactive Waste Management Section Basis for Observation/
Comment Readiness Assessment Observations/Comments Section 11 10 CFR 20.1301 10 CFR 50.34a The CP application references the ESP for doses to the public in Section 11.3.3 and in other sections. However, the BWRX-300 was not included in the ESP and some of the radionuclides releases in PSAR Tables 11.2-3 and 11.3-2 are higher than the radionuclide releases in the ESP Tables 11.2-4 and 11.3-3 respectively. This is something that the staff will be looking into as part of the review.
Section 11 RG 1.143 For the components classified in accordance with RG 1.143, the classifications arent entirely clear. PSAR Section 11.2.2.2 states that the RWB is seismic category RW-IIa and that the components within the RG 1.143 boundary are seismic RW-IIa. PSAR Section 11.4.2.2 states that the spent resin tank, sludge tank, pumps, valves, and piping are classified as RW-IIa. However, while Section 11.3 mentions RG 1.143, it doesnt appear to provide the RG 1.143 classification for the gaseous waste management system.
In addition, when section 11.2.2.2 states that the RWB and liquid radwaste components are seismic RW-IIa, it is unclear if that means that they are only meeting the seismic criteria for the RG 1.143, RW-IIa classification or all of the RG 1.143, RW-IIa criteria. In addition, when alternatives to RG 1.143 are used (for example, alternatives are mentioned in Section 11.2.2.2) the alternative code or standard should be specified.
i Input provided by NRR/DRA/ARCB