ML18198A516

LLC Response to NRC Request for Additional Information No. 232 (Erai No. 9113) on the NuScale Design Certification Application

ML18198A516
Person / Time
Site:	NuScale
Issue date:	07/17/2018
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
Shared Package
ML18198A515	List: ML18198A516
References
AF-0718-60927, RAIO-0718-60926
Download: ML18198A516 (16)

Text

RAIO-0718-60926 July 17, 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.

232 (eRAI No. 9113) on the NuScale Design Certification Application

REFERENCES:

1. U.S. Nuclear Regulatory Commission, "Request for Additional Information No. 232 (eRAI No. 9113)," dated September 21, 2017

2. NuScale Power, LLC Response to NRC "Request for Additional Information No. 232 (eRAI No.9113)," dated November 15, 2017 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. 9113:

03.06.03-3 is the proprietary version of the NuScale Response to NRC RAI No. 232 (eRAI No.

9113). NuScale requests that the proprietary version be withheld from public disclosure in

accordance with the requirements of 10 CFR § 2.390. 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, Za Zackary W. Rad Director Director, Regulatory Affairs NuScale Power, LLC Distribution: Gregory Cranston, NRC, OWFN-8G9A Samuel Lee, NRC, OWFN-8G9A

Marieliz Vera, NRC, OWFN-8G9A NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0718-60926 : NuScale Response to NRC Request for Additional Information eRAI No. 9113, proprietary : NuScale Response to NRC Request for Additional Information eRAI No. 9113, nonproprietary : Affidavit of Zackary W. Rad, AF-0718-60927 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0718-60926 :

NuScale Response to NRC Request for Additional Information eRAI No. 9113, proprietary NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0718-60926 :

NuScale Response to NRC Request for Additional Information eRAI No. 9113, nonproprietary 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.: 9113 Date of RAI Issue: 09/21/2017 NRC Question No.: 03.06.03-3 FSAR Section 3.6.3.1.4 specifies that the dynamic load due to water hammer is considered in the main steam (MS) system design by using drain pots, line sloping, drain valves, etc., to minimize their effect. The FSAR stated that the feedwater (FW) system and steam generators also have features to minimize the water hammer dynamic load effects. However, the FSAR did not specify the potential magnitude of the reduced water hammer loads in order for the staff to determine if they are less than the safe shutdown earthquake (SSE) loads used in the LBB evaluation. Please revise the FSAR to show that the greater of the seismic or water hammer loads was indeed used in the LBB evaluation described in FSAR Section 3.6.3.3.

NuScale Response:

In the NuScale piping design, the potential for water hammer in the candidate piping systems is minimized by using drain pots, line sloping, drain valves, etc., as discussed in FSAR Section 3.6.3.1.4. However, assuming a water hammer event does occur, NuScale performed water hammer dynamic loading analysis for the feedwater and steam piping lines in order to quantify the potential water hammer loads. The piping forces and moments were calculated and compared with the SSE loads at each location. For the locations where water hammer forces are higher but moments are lower than SSE loads, the stresses are compared.

The water hammer loads include potential Level B dynamic fluid loads (BDFL) and Level C/D dynamic fluid loads (CDFL). The maximum water hammer loads (axial force, Fa, and resultant moment, Mr) or stresses at each location are verified to be less than the SSE loads, so that it is not a significant contributor to pipe rupture. Table 1 compares the water hammer to the SSE loads for main steam lines, showing that the water hammer loads are below the SSE loads.

Table 2 shows the comparisons for feedwater lines. For some locations, the water hammer axial forces are higher than SSE axial force but the moments are lower. Table 3 compares the stresses from the axial forces and moments for these locations, showing that stresses from water hammer are lower than those from SSE. Therefore, it is concluded that the water hammer loads are bounded by the SSE loads.

NuScale Nonproprietary

The following statement has been inserted to FSAR Section 3.6.3.1.4:

The SSE loading used for the LBB evaluations bounds the water hammer loading for both the feedwater lines and the main steam lines.

Table 1. Comparison of SSE and water hammer loads for steam lines MS Line SSE BDFL CDFL BDFL-SSE CDFL-SSE Fa Mr Fa Mr Fa Mr Fa Mr Fa Mr ratio ratio ratio ratio Location (lbf) (ft-lbf) (lbf) (ft-lbf) (lbf) (ft-lbf)

((2(a),(c) NuScale Nonproprietary

((

                         }}2(a),(c NuScale Nonproprietary

((

                                                                             }}2(a),(c)

Table 2. Comparison of SSE and water hammer loads for feedwater lines FW Line SSE BDFL CDFL BDFL-SSE CDFL-SSE 1 Fa Mr Fa Mr Fa Mr Fa Mr Fa Mr ratio ratio ratio ratio Location (lbf) (ft-lbf) (lbf) (ft- (lbf) (ft-lbf) lbf) ((

                                                                             }}2(a),(c)

NuScale Nonproprietary

((

                         }}2(a),(c)

NuScale Nonproprietary

((

                                                                           }}2(a),(c)

FW Line SSE BDFL CDFL BDFL-SSE CDFL-SSE 2 Fa Mr Fa Mr Fa Mr Fa Mr Fa Mr ratio ratio ratio ratio Location (lbf) (ft-lbf) (lbf) (ft- (lbf) (ft-lbf) lbf) ((

                                                                            }}2(a),(c NuScale Nonproprietary

((

                                                                                 }}2(a),(c)

Table 3. Comparison of SSE and water hammer load stresses for feedwater lines FW Line SSE Stress, BDFL CDFL BDFL-SSE CDFL-SSE S Stress, S Stress, S Location psi psi psi ratio ratio ((

                                                                                  }}2(a),(c NuScale Nonproprietary

((

                                                                                      }}2(a),(c)

Impact on DCA: The FSAR Tier 2, Section 3.6.3.1.4 has been revised as described in the response above and as shown in the markup provided with this response. NuScale Nonproprietary

Protection against Dynamic Effects Associated with Postulated Rupture NuScale Final Safety Analysis Report of Piping 3.6.3.1.3 Creep and Creep Fatigue The design temperature for the MSS and FWS lines is 650 degrees F and normal operating temperatures are 585 degrees F and 300 degrees F respectively. Creep and creep fatigue are not a concern for austenitic steel piping below 800 degrees F. Because the design and operating temperatures of the piping systems are below these limits, creep and creep fatigue are not a concern. 3.6.3.1.4 Water Hammer/Steam Hammer The potential for water hammer and relief valve discharge loads are considered and their effects minimized in the design of the main steam system. Utilizing drain pots, proper line sloping, and drain valves minimize this potential. The dynamic loads such as those caused by main steam isolation valve closure or Turbine Stop Valve closure due to water hammer and steam hammer are analyzed and accounted for in the design and analysis of the main steam piping. Therefore, the main steam piping is not susceptible to effects of water hammer. The FWS and SG contain design features and operating procedures that minimize the potential for and effect of water hammer. The SG and FWS features are designed to minimize or eliminate the potential for water hammer in the steam generator FWS. The dynamic loads such as those caused by feedwater isolation valve closure and turbine trip due to water hammer are analyzed and accounted for in the design and analysis of the FWS piping. Therefore, the feedwater system LBB piping is not susceptible to water hammer. RAI 03.06.03-3 The SSE loading used for the LBB evaluations bounds the water hammer loading for both the feedwater lines and the main steam lines. 3.6.3.1.5 Fatigue Low-cycle Fatigue The main steam and feedwater piping inside the CNV is ASME Class 2. Class 2 piping systems incorporate stress range reduction factors in accordance with Subsection NC of Section III of the ASME B&PV Code to account for cyclic loading. The reduction factors mitigate the need for a detailed fatigue evaluation including the calculation of cumulative usage factors. This design requirement ensures the piping is not susceptible to low-cycle fatigue due to operational transients. Confirmation is to be provided in the pre-operational thermal expansion monitoring program. High-cycle Fatigue Main steam and feedwater piping design requirements also ensure the piping is not susceptible to high-cycle fatigue due to vibration. The main steam and feedwater lines are part of the NuScale Power Module and are included within the scope of the NuScale CVAP, see Section 3.9.2. Piping systems that meet the Tier 2 3.6-22 Draft Revision 2

RAIO-0718-60926 : Affidavit of Zackary W. Rad, AF-0718-60927 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

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, Ihave 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 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:

D The information requested to be withheld reveals distinguishing aspects of a process (or component, structure, tool, method, etc.) whose use by NuScale competitors, without a license from NuScale, would constitute a competitive economic disadvantage to NuScale. E The information requested to be withheld consists of supporting data, including test 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. F Use by a competitor of the information requested to be withheld would reduce the 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. G The information requested to be withheld reveals cost or price information, production capabilities, budget levels, or commercial strategies of NuScale. H The information requested to be withheld consists of patentable ideas.

   Public disclosure of the information sought to be withheld is likely to cause substantialharm to NuScale's competitive position and foreclose or reduce the availability of profit-making opportunities. The accompanying Request for Additional Information responsereveals distinguishing aspects about the method and analyses by which NuScale evDluates it power module systems.

NuScale has performed significant research and evaluation to develop a basis for this method and analyses and has invested significant resources, including the expenditure ofa considerable sum of money. The precise financial value of the information is difficult to quantify, but it is a key elementof 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 undertakea similar expenditure of resources. Such disclosure would constitute a misappropriation of NuScale's intellectual property, and would deprive NuScale of the opportunity to exerciseits competitive advantage to seek an adequate return on its investment. AF-0718-60927

4. The information sought to be withheld is in the enclosed response to NRC Request for Additional Information RAI No. 232, eRAI No. 9113. 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.

5. The basis for proposing that the information be withheld is that NuScale treats the 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).

6. Pursuant to the provisions set forth in 10 CFR § 2.390(b)(4), the following is provided for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld:

a. The information sought to be withheld is owned and has been held in confidence by NuScale.

b. The information is of a sort customarily held in confidence by NuScale and, to the best 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.

c. The information is being transmitted to and received by the NRC in confidence.

d. No public disclosure of the information has been made, and it is not available in public 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.

e. Public disclosure of the information is likely to cause substantial harm to the 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 July 17, 2018. Zackary WW. Rad AF-0718-60927}}