ML18354B284

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

ML18354B284
Person / Time
Site:	NuScale
Issue date:	12/20/2018
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
References
RAIO-1218-63951
Download: ML18354B284 (27)

Text

RAIO-1218-63951 December 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 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 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-8G9A Samuel Lee, NRC, OWFN-8G9A Cayetano Santos, NRC, OWFN-8G9A : 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-1218-63951 :

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:

It is NuScales position that the as-built verification of the NRC-proposed ITAAC would require the same as-built data or a subset of the as-built data already compiled and required by the existing ITAAC which is compiled below in Table 2, Verification of NuScale As-built Safety-Related Valve Attributes. Therefore, NuScale concludes that the additional, proposed ITAAC is redundant and unnecessary as discussed below.

Background

In RAI 9135, question 14.03.03-5, Supplement 1, the NRC proposed the following Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) for the NuScale Power Module (NPM) and chemical and volume control system (CVCS) safety-related valves.

Design Commitment Inspection, Test, and Analysis Acceptance Criteria The installed configuration of An inspection of the installed The installed configuration of the NPM valves and their NPM valves and their electric the NPM valves and their electric and supply lines is and supply lines will be electric and supply lines is consistent with their performed following consistent with their installation specifications such installation of the NPM into its installation specifications for that each valves safety operating position in the geometric configuration, functions can be achieved reactor pool to verify their orientation, accessibility, and appropriate installation line routing (including twisting, configuration. bend radii, crimping, and support) such that each valves safety functions can be achieved.

The installed configuration of An inspection of the installed The installed configuration of the CVCS valves and their CVCS valves and their electric the CVCS valves and their electric and supply lines is and supply lines will be electric and supply lines is consistent with their performed following consistent with their NuScale Nonproprietary

installation specifications such installation of the NPM into its installation specifications for that each valves safety operating position in the geometric configuration, functions can be achieved reactor pool to verify their orientation, accessibility, and appropriate installation line routing (including twisting, configuration. bend radii, crimping, and support) such that each valves safety functions can be achieved.

Valves and associated piping that provide a safety-function are contained in the containment system (CNTS), decay heat removal system (DHRS), emergency core cooling system (ECCS) or CVCS. Containment system, DHRS and ECCS valves and associated piping that provide a safety-function are located on the NPM as shown in Tier 2 Figure 6.6-1: ASME Class Boundaries for NuScale Power Module Piping Systems. Valve design attributes of the safety-related valves are listed in Table 1.

The acceptance criteria for the ITAAC proposed for safety-related valves requires verification of the following design attributes.

• valve geometric configuration

• valve orientation

• accessibility

• line routing (including twisting, bend radii, crimping, and support)

• electrical supply to valves Discussion of NRC-proposed ITAAC acceptance criteria

• Although equipment accessibility is addressed in the design of safety-related valves, standardized ITAAC does not consider valve accessibility to be a top-tier design feature that requires ITAAC to provide a reasonable assurance finding of the valves safety function. The NuScale Design Reliability Assurance Program (D-RAP) process identifies multiple equipment access functions but the functions are all classified as nonsafety-related.

NuScale Nonproprietary

• The line routing acceptance criteria are interpreted to mean attributes of the tubing connecting valve sub-components of CNTS, DHR and ECCS safety-related valves. The requirement to verify twisting and crimping of line routing is a partial verification that the tubing is not damaged. The verification of all ITAAC inherently requires verification that the installed equipment is not damaged and thus twisting and crimping or verification of any damage is not explicitly stated in standardized ITAAC or NuScale ITAAC.

With consideration of the above discussion, Tier 1 already contains ITAAC that satisfy the acceptance criteria of the proposed ITAAC. The remainder of this response provides justification that any as-built data of safety-related valves required to verify the acceptance criteria of the proposed ITAAC is redundant to as-built data to verify existing NuScale ITAAC.

To assist in the discussion, Table 1, NuScale Safety-Related Valve Design Attributes, identifies the population and specific design attributes of NuScale safety-related valves. Each CNTS, DHRS, ECCS and CVCS safety-related main valve is listed as well as distinct valve subcomponents of CNTS, DHRS, and ECCS valves. As noted in Table 1, the valve position indication of each safety-related valve is classified as nonsafety-related. Thus, the NRC-proposed ITAAC does not require verification of the NPM and CVCS valves position indication for they do not provide a safety function. For completeness, the PAM classification of each safety-related valve position is provided in Table 1 because Table 2, Verification of NuScale As-built Safety-Related Valve Attributes, identifies existing ITAAC to verify the position indication of PAM B or C variables. The CIV valve positon indication is PAM B and PAM C as listed in Tier 2 Table 7.1-7 and Tier 1 Table 2.5-5. Table 2 provides the ITAAC for the CIV position indication.

Table 1 lists the safety-related valves that receive Class 1E power wiring. This feature is important because the ITAAC related to verification of Class 1E power wiring is contained in Table 2.

Table 2 contains a listing of the major subcomponents of each NuScale safety-related valve. For each subcomponent, the table provides the following:

• The existing as-built ITAAC required to verify design attributes of each safety-related valve subcomponent.

• The existing testing ITAAC required to verify the overall operation of each safety-related valve. These ITAAC tests provide additional assurance that the integrated operation of each safety-related valve satisfies the valves safety-related functions.

NuScale Nonproprietary

Table 1: NuScale Safety-Related Valve Design Attributes Valve Names SSC Valve Safety-related Valve Position Class 1E Classification Functions Indication Power Classification Wiring to Valve?

CNTS safety-related valves Containment safety-related,

• Provides a barrier to nonsafety NA isolation valves risk-significant contain mass, energy, related, (CIVs) (main and fission product PAM B, C and valves) release by closure of the D indication CIVs upon a Containment Isolation signal.

CIV isolation safety-related,

• Provides a barrier to nonsafety Yes solenoid valves risk-significant contain mass, energy, related, and fission product no PAM release by deenergizing indication the solenoid valve upon a Containment Isolation signal to allow the CIV main valve to close.

CIV solenoid safety-related,

• Provides a barrier to nonsafety Yes dump valves risk-significant contain mass, energy, related, and fission product no PAM release by deenergizing indication the solenoid valve upon a Containment Isolation signal to allow the CIV main valve to close.

Feedwater line safety-related,

• Provides the required NA NA check valves nonrisk- pressure boundary for (integral to significant DHR operation.

feedwater isolation valve)

DHR safety-related valves Actuation valves safety-related,

• Supports the RCS by nonsafety NA (main valve) nonrisk- opening the DHRS related, significant actuation valves on a PAM D DHRS actuation signal. indication Actuation valve safety-related,

• Supports the RCS by nonsafety Yes solenoid nonrisk- deenergizing the solenoid related, actuation valves significant valve upon a DHRS no PAM actuation signal to allow indication NuScale Nonproprietary

Valve Names SSC Valve Safety-related Valve Position Class 1E Classification Functions Indication Power Classification Wiring to Valve?

DHRS actuation valves to open.

Actuation valve safety-related,

• Supports the RCS by nonsafety Yes solenoid dump nonrisk- deenergizing the solenoid related, valves significant valve upon a DHRS no PAM actuation signal to allow indication DHRS actuation valves to open.

ECCS safety-related valves Reactor vent safety-related,

• Supports the RCS by nonsafety NA valves (RVVs) risk-significant providing a portion of the related, (main valve) reactor coolant pressure PAM D boundary for maintaining indication the RCPB integrity.

• Supports the RCS by providing recirculated coolant from the containment to the RPV for the removal of core heat.

• Supports RCS by providing low temperature overpressure protection for maintaining the RCPB integrity.

RVV trip valves safety-related,

• Supports the RCS by nonsafety Yes risk-significant providing a portion of the related, reactor coolant pressure PAM D boundary for maintaining indication the RCPB integrity.

• Supports RCS by providing low temperature overpressure protection for maintaining the RCPB integrity.

RVV reset valves safety-related,

• Supports the RCS by nonsafety Yes risk-significant providing a portion of the related, reactor coolant pressure no PAM NuScale Nonproprietary

Valve Names SSC Valve Safety-related Valve Position Class 1E Classification Functions Indication Power Classification Wiring to Valve?

boundary for maintaining indication the RCPB integrity.

Reactor safety-related,

• Supports the RCS by nonsafety NA recirculation valves risk-significant providing a portion of the related, (RRVs) (main reactor coolant pressure PAM D valve) boundary for maintaining indication the RCPB integrity.

• Supports the RCS by providing recirculated coolant from the containment to the RPV for the removal of core heat RRV trip valves safety-related,

• Supports the RCS by nonsafety Yes risk-significant providing a portion of the related, reactor coolant pressure PAM D boundary for maintaining indication the RCPB integrity.

RRV reset valves safety-related,

• Supports the RCS by nonsafety Yes risk-significant providing a portion of the related, reactor coolant pressure no PAM boundary for maintaining indication the RCPB integrity.

DWS safety-related valves DWS Supply safety-related,

• The CVCS supports the nonsafety Yes Isolation Valves nonrisk- RCS by isolating dilution related, significant sources. PAM D indication NuScale Nonproprietary

Table 2 Verification of NuScale As-built Safety-Related Valve Attributes Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions Containment Isolation Valves As-built ITAAC that verify CNTS valve functions ITAAC functional testing that verifies CNTS valve functions CNTS Piping Top of 02.01.01 The ASME Code Section 02.01.07 The leakage rate systems Module III Design Reports for local leak rate containing (NCA-3550) exist and tests (Type B and ASME Code conclude that the NuScale Type C) for Section III Power Module ASME pressure Class 2 and 3 Code Class 1, 2 and 3 as- containing or piping built piping systems listed leakage-limiting in Table 2.1-1 meet the boundaries and requirements of ASME CIVs meets the Code Section III. requirements of 10 CFR Part 50, Appendix J.

All Top of 02.01.02 ASME Code Section III 02.01.08 Each CIV listed in containment Module Data Reports for the Table 2.1-3 isolation NuScale Power Module travels from the valves (main ASME Code Class 1, 2, full open to full valves) and 3 components listed closed position in in Table 2.1-2 and less than or equal interconnecting piping to the time listed exist and conclude that in Table 2.1-3 the requirements of after receipt of a ASME Code Section III containment are met. isolation signal.

02.08.01 The module-specific 02.01.13 Each remotely-Seismic Category I operated CNTS equipment listed in Table containment 2.8-1, including its isolation valve associated supports and listed in Table anchorages, is installed in 2.1-2 strokes fully its design location in a open and fully NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions Seismic Category I closed by remote structure in a operation under configuration bounded preoperational by the equipments temperature, seismic qualification differential record form. pressure, and flow conditions 02.08.02 ii. The module-specific 02.01.18 Each CNTS electrical equipment listed safety-related in Table 2.8-1, including hydraulic-associated connection operated valve assemblies, are installed listed in Table in their design location in 2.1-2 fails to its a configuration safety-related bounded by the EQ position on loss of record form. motive power under preoperational temperature, differential pressure, and flow conditions.

02.01.11 Physical separation 02.05.25 The PAM Type B between MPS Class 1E and Type C instrumentation and displays listed in control current-carrying Table 2.5-5 are circuits and non-Class 1E retrieved and instrumentation and displayed on the control current-carrying SDIS displays in circuits is provided by a the MCR.

minimum separation Note: Tier 1 distance, or by barriers Table 2.5-5 lists (where the minimum CIV positions as separation distances Type B and Type cannot be maintained), or C variables.

NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions by a combination of separation distance and barriers.

All 02.08.01 The module-specific containment Seismic Category I isolation equipment listed in Table valves (main 2.8-1, including its valves) associated supports and position anchorages, is installed in indicators its design location in a Seismic Category I structure in a configuration bounded by the equipments seismic qualification record form.

02.08.02 ii. The module-specific electrical equipment listed in Table 2.8-1, including associated connection assemblies, are installed in their design location in a configuration bounded by the EQ record form.

Valve actuator Within 4 02.01.09 The length of piping for main steam feet of the between each isolation CIVs contain- containment penetration and main ment head and its associated steam bypass outboard CIV is less than CIVs or equal to the length identified in Table 2.1-1.

CIV actuator Installed on 02.01.02 ASME Code Section III control block central Data Reports for the containing CIV hydraulic NuScale Power Module actuating power unit ASME Code Class 1, 2, NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions solenoid and 3 components listed valves in Table 2.1-2 and interconnecting piping exist and conclude that the requirements of ASME Code Section III are met.

02.01.11 Physical separation between MPS Class 1E instrumentation and control current-carrying circuits and non-Class 1E instrumentation and control current-carrying circuits is provided by a minimum separation distance, or by barriers (where the minimum separation distances cannot be maintained), or by a combination of separation distance and barriers.

02.08.01 The module-specific Seismic Category I equipment listed in Table 2.8-1, including its associated supports and anchorages, is installed in its design location in a Seismic Category I structure in a configuration bounded by the equipments seismic qualification NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions record form.

02.08.02 ii. The module-specific electrical equipment listed in Table 2.8-1, including associated connection assemblies, are installed in their design location in a configuration bounded by the EQ record form.

Tubing Top of 02.08.01 The module-specific between each module to Seismic Category I CIV and its central equipment listed in Table actuation hydraulic 2.8-1, including its solenoid valve power unit associated supports and (subcompo- anchorages, is installed in nent of CIV) its design location in a Seismic Category I structure in a configuration bounded by the equipments seismic qualification record form.

DHR Actuation Valves As-built ITAAC that verify DHR valve functions ITAAC functional testing that verify DHR valve functions DHR Piping Top of 02.01.01 The ASME Code Section 02.01.15 Each DHRS systems Module III Design Reports (NCA- safety-related containing 3550) exist and conclude valve listed in ASME Code that the NuScale Power Table 2.1-2 Section III Module ASME Code strokes fully open Class 2 piping Class 1, 2 and 3 as-built and fully closed piping systems listed in by remote Table 2.1-1 meet the operation under requirements of ASME preoperational Code Section III. temperature, NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions differential pressure, and flow conditions.

All DHR Top of 02.01.02 ASME Code Section III 02.01.20 Each DHRS actuation Module Data Reports for the safety-related valves (main NuScale Power Module hydraulic-valves) ASME Code Class 1, 2, operated valve and 3 components listed listed in Table in Table 2.1-2 and 2.1-2 fails open interconnecting piping on loss of motive exist and conclude that power under the requirements of preoperational ASME Code Section III temperature, are met. differential pressure, and flow conditions.

02.08.01 The module-specific Seismic Category I equipment listed in Table 2.8-1, including its associated supports and anchorages, is installed in its design location in a Seismic Category I structure in a configuration bounded by the equipments seismic qualification record form.

02.08.02 ii. The module-specific electrical equipment listed in Table 2.8-1, including associated connection assemblies, are installed in their design location in NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions a configuration bounded by the EQ record form.

All DHR 02.08.01 The module-specific actuation Seismic Category I valves (main equipment listed in Table valves) 2.8-1, including its position associated supports and indicators anchorages, is installed in its design location in a Seismic Category I structure in a configuration bounded by the equipments seismic qualification record form.

02.08.02 ii. The module-specific electrical equipment listed in Table 2.8-1, including associated connection assemblies, are installed in their design location in a configuration bounded by the EQ record form.

DHR actuation Installed on 02.01.02 ASME Code Section III valve control central Data Reports for the block hydraulic NuScale Power Module containing CIV power unit ASME Code Class 1, 2, actuating and 3 components listed solenoid in Table 2.1-2 and valves interconnecting piping exist and conclude that the requirements of ASME Code Section III NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions are met.

02.01.11 Physical separation between MPS Class 1E instrumentation and control current-carrying circuits and non-Class 1E instrumentation and control current-carrying circuits is provided by a minimum separation distance, or by barriers (where the minimum separation distances cannot be maintained), or by a combination of separation distance and barriers.

02.08.01 The module-specific Seismic Category I equipment listed in Table 2.8-1, including its associated supports and anchorages, is installed in its design location in a Seismic Category I structure in a configuration bounded by the equipments seismic qualification record form.

02.08.02 ii. The module-specific electrical equipment listed in Table 2.8-1, including associated connection assemblies, are installed NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions in their design location in a configuration bounded by the EQ record form.

ECCS Valves As-built ITAAC that verify ECCS valve functions ITAAC functional testing that verify ECCS valve functions Trip/Reset Welded to 02.01.02 ASME Code Section III 02.01.14 Each ECCS Valve (TRV) the exterior Data Reports for the safety-related of the NuScale Power Module valve listed in contain- ASME Code Class 1, 2, Table 2.1-2 ment and 3 components listed strokes fully open vessel in Table 2.1-2 and and fully closed interconnecting piping by remote exist and conclude that operation under the requirements of preoperational ASME Code Section III temperature, are met. differential pressure, and flow conditions.

02.01.11 Physical separation 02.01.19 Each ECCS between MPS Class 1E safety-related instrumentation and RRV and RVV control current-carrying listed in Table circuits and non-Class 1E 2.1-2 fails open instrumentation and on loss of control current-carrying electrical power to circuits is provided by a its minimum separation corresponding trip distance, or by barriers valve under (where the minimum preoperational separation distances temperature, cannot be maintained), or differential by a combination of pressure, and separation distance and flow conditions.

barriers.

NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions 02.08.01 The module-specific Seismic Category I equipment listed in Table 2.8-1, including its associated supports and anchorages, is installed in its design location in a Seismic Category I structure in a configuration bounded by the equipments seismic qualification record form.

02.08.02 ii. The module-specific electrical equipment listed in Table 2.8-1, including associated connection assemblies, are installed in their design location in a configuration bounded by the EQ record form.

Trip/Reset exterior of 02.08.01 The module-specific Valve (TRV) the contain- Seismic Category I Position ment equipment listed in Table Indication vessel 2.8-1, including its associated supports and anchorages, is installed in its design location in a Seismic Category I structure in a configuration bounded by the equipments seismic qualification record form.

NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions 02.08.02 ii. The module-specific electrical equipment listed in Table 2.8-1, including associated connection assemblies, are installed in their design location in a configuration bounded by the EQ record form.

Reactor Vent Flanged to 02.01.02 ASME Code Section III Valve (RVV) the exterior Data Reports for the (main valve) of the NuScale Power Module (Note 2) reactor ASME Code Class 1, 2, pressure and 3 components listed vessel in Table 2.1-2 and interconnecting piping exist and conclude that the requirements of ASME Code Section III are met.

02.01.11 Physical separation between MPS Class 1E instrumentation and control current-carrying circuits and non-Class 1E instrumentation and control current-carrying circuits is provided by a minimum separation distance, or by barriers (where the minimum separation distances cannot be maintained), or by a combination of separation distance and NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions barriers.

02.08.01 The module-specific Seismic Category I equipment listed in Table 2.8-1, including its associated supports and anchorages, is installed in its design location in a Seismic Category I structure in a configuration bounded by the equipments seismic qualification record form.

02.08.02 ii. The module-specific electrical equipment listed in Table 2.8-1, including associated connection assemblies, are installed in their design location in a configuration bounded by the EQ record form.

Reactor Vent exterior of 02.08.01 The module-specific Valve (RVV) the contain- Seismic Category I (main valve) ment equipment listed in Table position vessel 2.8-1, including its indicator associated supports and (Note 2) anchorages, is installed in its design location in a Seismic Category I structure in a configuration bounded by the equipments seismic qualification NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions record form.

02.08.02 ii. The module-specific electrical equipment listed in Table 2.8-1, including associated connection assemblies, are installed in their design location in a configuration bounded by the EQ record form.

Reactor Flanged to 02.01.02 ASME Code Section III Recirculation the exterior Data Reports for the Valve (RRV) of the NuScale Power Module (main valve) reactor ASME Code Class 1, 2, (Note 2) pressure and 3 components listed vessel in Table 2.1-2 and interconnecting piping exist and conclude that the requirements of ASME Code Section III are met.

NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions 02.01.11 Physical separation between MPS Class 1E instrumentation and control current-carrying circuits and non-Class 1E instrumentation and control current-carrying circuits is provided by a minimum separation distance, or by barriers (where the minimum separation distances cannot be maintained), or by a combination of separation distance and barriers.

02.08.01 The module-specific Seismic Category I equipment listed in Table 2.8-1, including its associated supports and anchorages, is installed in its design location in a Seismic Category I structure in a configuration bounded by the equipments seismic qualification record form.

02.08.02 ii. The module-specific electrical equipment listed in Table 2.8-1, including associated connection assemblies, are installed NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions in their design location in a configuration bounded by the EQ record form.

Reactor Flanged to 02.08.01 The module-specific Recirculation the exterior Seismic Category I Valve (RRV) of the equipment listed in Table (main valve) reactor 2.8-1, including its Position pressure associated supports and indicators vessel anchorages, is installed in its design location in a Seismic Category I structure in a configuration bounded by the equipments seismic qualification record form.

02.08.02 ii. The module-specific electrical equipment listed in Table 2.8-1, including associated connection assemblies, are installed in their design location in a configuration bounded by the EQ record form.

Tubing Inside 02.08.01 The module-specific between each contain- Seismic Category I ECCS RRV and ment equipment listed in Table its TRV 2.8-1, including its associated supports and anchorages, is installed in its design location in a Seismic Category I structure in a NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions configuration bounded by the equipments seismic qualification record form.

Tubing Inside 02.08.01 The module-specific between each contain- Seismic Category I ECCS RVV and ment equipment listed in Table its TRV 2.8-1, including its associated supports and anchorages, is installed in its design location in a Seismic Category I structure in a configuration bounded by the equipments seismic qualification record form.

Tubing Inside 02.08.01 The module-specific between RCS contain- Seismic Category I and RRV ment equipment listed in Table 2.8-1, including its associated supports and anchorages, is installed in its design location in a Seismic Category I structure in a configuration bounded by the equipments seismic qualification record form.

CVCS valves As-built ITAAC that verify CVCS valve functions ITAAC functional testing that verify CVCS valve functions CVCS Piping Reactor 02.02.01 The ASME Code Section 02.02.03 Each chemical systems Building III Design Reports (NCA- and volume containing 3550) exist and conclude control system NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions ASME Code that the NuScale Power ASME Code Section III Module ASME Code Class 3 air-Class 2 piping Class 3 as-built piping operated systems meet the demineralized requirements of ASME water system Code Section III. supply isolation valve listed in Table 2.2-2 strokes fully open and fully closed by remote operation under preoperational temperature, differential pressure, and flow conditions.

Reactor 02.02.02 ASME Code Section III 02.02.05 Each chemical Building Data Reports for the and volume NuScale Power Module control system ASME Code Class 3 ASME Code components listed in Class 3 air-Table 2.2-2 and operated interconnecting piping demineralized exist and conclude that water system the requirements of supply isolation ASME Code Section III valve listed in are met. Table 2.2-2 fails closed on loss of motive power under preoperational temperature, differential pressure, and NuScale Nonproprietary

Safety-related Subcom- As-built As-built Inspection Functional Functional Valve Subcom- ponent Inspection ITAAC Acceptance ITAAC # ITAAC ponents Location ITAAC Criteria Acceptance (Note 1) Criteria that verifies safety-related valve functions flow conditions.

Note 1: All CIVs are welded to the containment head with the exception of the main steam isolation valves and the main steam bypass valves. These valves are verified to be within 4 feet of the containment vessel in ITAAC 02.01.09.

Note 2: Inadvertent actuation block (IAB) valves are a subcomponent of each ECCS main valve (RVVs and RRVs).

Summary of response:

It is NuScale's position that the as-built verification of the NRC-proposed ITAAC would require the same as-built "data" or a subset of the as-built "data" already compiled and required by the existing NuScale ITAAC contained in Table 2 above. Therefore, the additional NRC-proposed ITAAC is redundant and unnecessary.

Impact on DCA:

There are no impacts to the DCA as a result of this response.

NuScale Nonproprietary