RAIO-0618-60565, LLC Response to NRC Request for Additional Information No. 410 (Erai No. 9310) on the NuScale Design Certification Application
| ML18171A409 | |
| Person / Time | |
|---|---|
| Site: | NuScale |
| Issue date: | 06/20/2018 |
| From: | Rad Z NuScale |
| To: | Document Control Desk, Office of New Reactors |
| Shared Package | |
| ML18171A408 | List: |
| References | |
| AF-0618-60566, RAIO-0618-60565 | |
| Download: ML18171A409 (14) | |
Text
RAIO-0618-60565 June 20, 2018 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 Response to NRC Request for Additional Information No.
410 (eRAI No. 9310) on the NuScale Design Certification Application
REFERENCE:
U.S. Nuclear Regulatory Commission, "Request for Additional Information No. 410 (eRAI No. 9310)," dated April 09, 2018 The purpose of this letter is to provide the NuScale Power, LLC (NuScale) response to the
referenced NRC Request for Additional Information (RAI).
The Enclosures to this letter contain NuScale's response to the following RAI Question from
NRC eRAI No. 9310:
03.09.02-65 The schedule for questions 03.09.02-62, 03.09.02-64, 03.09.02-69, 03.09.02-70 and
03.09.02-71 was provided in emails to NRC (Greg Cranston) dated May 09, 2018 and June 1,
2018. is the proprietary version of the NuScale Response to NRC RAI No. 410 (eRAI No.
9310). NuScale requests that the proprietary version be withheld from public disclosure in
accordance with the requirements of 10 CFR § 2.390. The proprietary enclosures have been
deemed to contain Export Controlled Information. This information must be protected from
disclosure per the requirements of 10 CFR § 810. The enclosed affidavit (Enclosure 3) supports
this request. Enclosure 2 is the nonproprietary version of the NuScale response.
This letter and the enclosed responses make no new regulatory commitments and no revisions
to any existing regulatory commitments.
If you have any questions on this response, please contact Marty Bryan at 541-452-7172 or at
mbryan@nuscalepower.com.
Sincerely, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com Zackary W. Rad Di t
R l t Aff i
RAIO-0618-60565 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com Distribution:
Gregory Cranston, NRC, OWFN-8G9A Samuel Lee, NRC, OWFN-8G9A Marieliz Vera, NRC, OWFN-8G9A : NuScale Response to NRC Request for Additional Information eRAI No. 9310, proprietary : NuScale Response to NRC Request for Additional Information eRAI No. 9310, nonproprietary : Affidavit of Zackary W. Rad, AF-0618-60566
RAIO-0618-60565 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com :
NuScale Response to NRC Request for Additional Information eRAI No. 9310, proprietary
RAIO-0618-60565 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com :
NuScale Response to NRC Request for Additional Information eRAI No. 9310, nonproprietary
NuScale Nonproprietary Response to Request for Additional Information Docket No.52-048 eRAI No.: 9310 Date of RAI Issue: 04/09/2018 NRC Question No.: 03.09.02-65 In Subquestion 1 of RAI 8911, Question 03.09.02-32, the applicant was asked why there is no simplified steam generator (SG) model within the 3D NuScale power module (NPM) seismic model. In the RAI response, the applicant stated that radial coupling between SG tube support bar assemblies, upper riser, and reactor pressure vessel (RPV) shell is provided for load transfer and the stiffness of the SG assembly in the other directions is inherently flexible and therefore, stiffness of SG is not considered in the 3D NPM seismic model. The staff noticed in Table 4-1 of EC-A014-3306 Steam Generator Structural Model Rev. 2 that the major modes of the SG/riser/vessel model are (( 2(a),(c) Hz (riser/SG beam mode), ((
}}
2(a),(c) Hz (SG mode), ((
}}
2(a),(c) Hz (SG twisting mode), ((
}}
2(a),(c) Hz (vessel beam mode), ((
}}
2(a),(c) Hz (riser/SG vertical mode), and ((
}}
2(a),(c) Hz (complex mode of SG supports). EC-A014-3306 also indicates that a single helical SG tube has frequencies of the local beam mode ranging from (( }} 2(a),(c) Hz to ((
}}
2(a),(c) Hz depending on location of the tube. Both cases indicate that the SG assembly is not flexible. The applicant is requested to perform a confirmative analysis to demonstrate that ignoring the SG stiffness has no significant impact on the results presented in TR-0916-51502. Alternatively, consider incorporating a simplified SG model in the 3D NPM model, similar to the simplified fuel assembly beam model incorporated in the 3D NPM model. Include the requested information in the NPM Seismic Report. NuScale Response: Stiffness in the radial direction is accounted for by constraint equations between the upper riser and RPV. The stiffness in the circumferential direction of the SG tube support bar assemblies and the SG tubes does not affect the results of the model. As a confirmatory analysis for this assumption, the stiffness of the SG tube support bar assemblies is compared to the stiffness of the RPV, by treating each as a simply supported beam. The analysis demonstrates that the circumferential stiffness of the tube supports is negligible. After making this comparison, the circumferential stiffness of the tubes is dispositioned as negligible by engineering judgment.
NuScale Nonproprietary First, Equation 1 and Equation 2 (Reference 10.1.12 in TR-0916-51502 Revision 1) are used to find the deflections at the same elevation in each component, given a uniform distributed load w, with dimensions and properties listed in Table 1: Table 1. Dimensions and elastic properties used to compare SG tube support stiffness to the stiffness of the RPV SG Tube Supports lsg ((
}}2(a),(c),ECI Length of the tube supports b
((
}}2(a),(c),ECI Width of a tube support h
((
}}2(a),(c),ECI Height of a tube support, idealized as a rectangle, rather than being slightly curved Ix,SG
((
}}2(a),(c),ECI Moment of inertia about the bending axis of a single tube support, calculated as bh3/12 ESG 25.05 x 106 psi Elastic modulus of SA-240 Type 304 Stainless Steel at 650 °F Upper RPV Shell lrpv
((
}}2(a),(c),ECI Length of RPV between its simple supports a
((
}}2(a),(c),ECI Length of RPV overhanging the simple support x
((
}}2(a),(c),ECI Location on the RPV to compare to the center of the tube supports do
((
}}2(a),(c),ECI Outer diameter of the RPV, used to idealize the RPV as a cylinder di
((
}}2(a),(c),ECI Inner diameter of the RPV, used to idealize the RPV as a cylinder Ix,RPV
(( }}2(a),(c),ECI Moment of inertia about the bending axis, calculated as (do 4-di 4)/64 ERPV 24.85 x 106 psi Elastic modulus of SA-508 Grade 3 Class 2 at 650 °F Figure 1 shows the components analyzed. The deflection of the RPV under a uniform distributed load at position x is x, which is aligned with the center of the SG tube supports, which have a deflection of center.
NuScale Nonproprietary (( }}2(a),(c),ECI Figure 1. Dimensions used to compare the stiffness of the RPV to the stiffness of the SG tube supports in the circumferential direction Next, by assuming w as a unit force per length, multiplying by the total length of the component, and dividing by the deflection, the stiffness of the RPV and (( }}2(a),(c),ECI tube supports are given as follows for comparison:
NuScale Nonproprietary The above calculation shows that the stiffness of the tube supports in the circumferential direction is four orders of magnitude lower than the RPV. Therefore, the modeling choice to neglect the stiffness of the tube supports in the circumferential direction is justified. The SG tubes rest on the tube support bar assemblies, which provide radial and vertical support. The tubes are only completely constrained at the feed and steam plenum tubesheets. In this configuration the tubes act only to transfer force between the tubesheets and the tube supports, and from one tube support to the next. During bending of the RPV with the SG, the tubes move in unison (irrespective of any anticipated sliding on the supports). Therefore, the stiffness of the SG tubes has been modeled appropriately. Including the steam generator beyond its mass contribution and the radial coupling of the upper riser to the RPV would not have a significant effect on the results calculated in TR-0916-51502. A summary of this discussion has been included with the NPM Seismic Analysis technical report as requested. Impact on DCA: TR-0916-51502 Section 4.1.4.2 has been revised as described in the response above and as shown in the markup provided with this response.
NuScale Power Module Seismic Analysis TR-0916-51502-NP Draft Rev. 10 © Copyright 20187 by NuScale Power, LLC 59 Table 4-11 Mass adjustment summary for the upper RVI Upper RVI Section Mass (lbm) Mesh Mass (lbm) Mass Adjustment (lbm) Upper riser (total) ((
}}2(a),(c)
TOTAL Upper RVI MASS (lbm): ((
}}2(a),(c) 4.1.4.2 Upper Reactor Vessel Internals Boundary Conditions The physical connection between the upper RVI and the lower RVI is shown in Figure C-18 and described in Table C-1, Interfacing component, Upper riser with lower riser. The cone of the upper RVI is coupled to the cone of the lower RVI submodel in the horizontal directions only, as shown in Figure 4-15.
EightThe physical connections between the upper riser and the RPV are shown in Figure 4-16 and Figure 4-17. rectangular contact surfaces on the upper RVI are coupled to the tips of the lower radial cantilever SG supports RPV submodel by coupling the eight pairs of pilot nodes in the radial direction only. Each pair of pilot nodes was created at the same location to avoid an inaccurate constraint. Radial In the entire pool model, radial coupling is provided between the upper riser and the RPV using constraint equations, as shown in Figure 4-18. These represent the radial load transfer that occurs due to the stack-up of SG tube supports between the upper riser and RPV. The load transfer occurs along the height of the SG at the 8 support locations around the circumference. The stiffness in the circumferential direction of the SG tube support bar assemblies and the SG tubes does not affect the results of the model. As a confirmatory analysis for this assumption, the stiffness of the SG tube support bar assemblies on two adjacent planes of supports that are ((
}}2(a),(c) apart (as shown in Figure 4-16) was compared to the stiffness of the RPV by treating each as a simply supported beam. The other two planes of support are oriented mostly in the direction of bending, and these supports will transfer radial loads that are appropriately modeled.
The calculations, performed using beam formulas from Reference 10.1.12, show that the stiffness of the tube supports in the circumferential direction is four orders of magnitude lower than the RPV. The tubes are only completely constrained at the feed and steam plenum tubesheets. In this configuration the tubes act only to transfer force between the tubesheets and the tube supports, and from one tube support to the next. During bending of the RPV with the SG, the tubes move in unison with the supports. Therefore, the modeling choice to neglect the stiffness of the SG tubes in the circumferential direction is justified. Note the Single Bay model, used for the generation of the simplified beam model shown in Section 6.4, does not have radial coupling between the upper riser and the RPV
NuScale Power Module Seismic Analysis TR-0916-51502-NP Draft Rev. 10 © Copyright 20187 by NuScale Power, LLC 60 except at the lower radial cantilever SG supports. Overall, the horizontal harmonic response of the Single Bay models with and without radial coupling along the height of the SG at eight support locations around the circumference between the upper riser and the RPV is not significantly different. The harmonic force amplitudes at key locations from these two models are compared, and the results are comparable. The connections between the upper RVI and the baffle plate are shown in Figures C-14 and Figure C-15, and described in Table C-1, Interfacing component, Upper riser hanger ring with the PZR baffle plate. The upper riser ring hole locations on the upper RVI are coupled to pin locations on the baffle plate of the RPV submodel. This is done by coupling the translational degrees of freedom on the eight pairs of pilot nodes, as shown in Figure 4-19. See Section 5.0 for an additional constraint that applies only to the entire pool models.
NuScale Power Module Seismic Analysis TR-0916-51502-NP Draft Rev. 10 © Copyright 20187 by NuScale Power, LLC 173 10.0 References 10.1 Referenced Documents 10.1.1 ASCE 4-13, Seismic Analysis of Safety-Related Nuclear Structures and Commentary, Working Group on Revision of ASCE Standard 4, July 2013. Not Used. 10.1.2 US NRC, Interim Staff Guidance on Seismic Issues Associated with High Frequency Ground Motion in Design Certification and Combined License Applications, DC/COL-ISG-001. 10.1.3 NUREG-0800, Standard Review Plan for Review of Safety Analysis Reports for Nuclear Power Plants, Section 3.7.3, Seismic Subsystem Analysis Review Responsibilities, Draft Revision 4, September, 2013. 10.1.4 IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations. 10.1.5 ASME Boiler and Pressure Vessel Code, Section III, Rules for Construction of Nuclear Facility Components, 2013 Edition with no addenda. 10.1.6 US NRC Regulatory Guide 1.122,Development of Floor Design Response Spectra for Seismic Design of Floor-Supported Equipment or Components, Revision 1, February 1978. 10.1.7 American Society of Civil Engineers, Seismic Analysis of Safety-Related Nuclear Structures, ASCE 4, 1998. 10.1.8 American Society of Civil Engineers, Seismic Design Criteria for Structures, Systems, and Components in Nuclear Facilities, ASCE/SEI 43, 2005. 10.1.9 R.J. Fritz, The Effect of Liquids on Dynamic Motion of Immersed Solids, Journal of Engineering for Industry, February, 1972. 10.1.10 Meyer, M. et al. Generalized Barycentric Coordinates on Irregular Polygons. Pages 13-22. Journal of Graphic Tools, Volume 7 Issue 1, November 2002. 10.1.11 Matthew D. Snyder, Method for Hydrodynamic Coupling of Concentric Cylindrical Shells and Beams, 2004 International ANSYS Conference, Pittsburgh, PA, May 24-26, 2004. 10.1.12 Manual of Steel Construction: Load and Resistance Factor Design, Volume 1, Second Edition.
RAIO-0618-60565 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com : Affidavit of Zackary W. Rad, AF-0618-60566
AF-0618-60566 NuScale Power, LLC AFFIDAVIT of Zackary W. Rad I, Zackary W. Rad, state as follows: I am the Director, Regulatory Affairs of NuScale Power, LLC (NuScale), and as such, I 1. have been specifically delegated the function of reviewing the information described in this Affidavit that NuScale seeks to have withheld from public disclosure, and am authorized to apply for its withholding on behalf of NuScale. I am knowledgeable of the criteria and procedures used by NuScale in designating 2. information as a trade secret, privileged, or as confidential commercial or financial information. This request to withhold information from public disclosure is driven by one or more of the following: The information requested to be withheld reveals distinguishing aspects of a process a. (or component, structure, tool, method, etc.) whose use by NuScale competitors, without a license from NuScale, would constitute a competitive economic disadvantage to NuScale. The information requested to be withheld consists of supporting data, including test b. data, relative to a process (or component, structure, tool, method, etc.), and the application of the data secures a competitive economic advantage, as described more fully in paragraph 3 of this Affidavit. Use by a competitor of the information requested to be withheld would reduce the c. competitor's expenditure of resources, or improve its competitive position, in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product. The information requested to be withheld reveals cost or price information, production d. capabilities, budget levels, or commercial strategies of NuScale. The information requested to be withheld consists of patentable ideas. e. Public disclosure of the information sought to be withheld is likely to cause substantial 3. harm to NuScale's competitive position and foreclose or reduce the availability of profit-making opportunities. The accompanying Request for Additional Information response reveals distinguishing aspects about the method by which NuScale develops its power module seismic analysis. NuScale has performed significant research and evaluation to develop a basis for this method and has invested significant resources, including the expenditure of a considerable sum of money. The precise financial value of the information is difficult to quantify, but it is a key element of the design basis for a NuScale plant and, therefore, has substantial value to NuScale. If the information were disclosed to the public, NuScale's competitors would have access to the information without purchasing the right to use it or having been required to undertake a similar expenditure of resources. Such disclosure would constitute a misappropriation of NuScale's intellectual property, and would deprive NuScale of the opportunity to exercise its competitive advantage to seek an adequate return on its investment.
AF-0618-60566 The information sought to be withheld is in the enclosed response to NRC Request for 4. Additional Information No. 410, eRAI 9310. The enclosure contains the designation "Proprietary" at the top of each page containing proprietary information. The information considered by NuScale to be proprietary is identified within double braces, "(( }}" in the document. The basis for proposing that the information be withheld is that NuScale treats the 5. information as a trade secret, privileged, or as confidential commercial or financial information. NuScale relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC § 552(b)(4), as well as exemptions applicable to the NRC under 10 CFR §§ 2.390(a)(4) and 9.17(a)(4). Pursuant to the provisions set forth in 10 CFR § 2.390(b)(4), the following is provided for 6. consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld: The information sought to be withheld is owned and has been held in confidence by a. NuScale. The information is of a sort customarily held in confidence by NuScale and, to the best b. of my knowledge and belief, consistently has been held in confidence by NuScale. The procedure for approval of external release of such information typically requires review by the staff manager, project manager, chief technology officer or other equivalent authority, or the manager of the cognizant marketing function (or his delegate), for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside NuScale are limited to regulatory bodies, customers and potential customers and their agents, suppliers, licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or contractual agreements to maintain confidentiality. The information is being transmitted to and received by the NRC in confidence. c. No public disclosure of the information has been made, and it is not available in public d. sources. All disclosures to third parties, including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or contractual agreements that provide for maintenance of the information in confidence. Public disclosure of the information is likely to cause substantial harm to the e. competitive position of NuScale, taking into account the value of the information to NuScale, the amount of effort and money expended by NuScale in developing the information, and the difficulty others would have in acquiring or duplicating the information. The information sought to be withheld is part of NuScale's technology that provides NuScale with a competitive advantage over other firms in the industry. NuScale has invested significant human and financial capital in developing this technology and NuScale believes it would be difficult for others to duplicate the technology without access to the information sought to be withheld. I declare under penalty of perjury that the foregoing is true and correct. Executed on June 20, 2018. Zackary W. Rad j y g g Zackary W Rad}}