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ArevaEPRDCPEm Resource

From: Wunder, GeorgeSent: Friday, January 30, 2015 12:25 PMTo: ArevaEPRDCPEm ResourceSubject: FW: Submittal of US EPR RAI 620 Supplement 1 ResponseAttachments: 002 RAI 620 Supplement 1 Response US EPR DC.pdf; 001 AREVA Transmittal Letter NRC

15 007.pdf

From: RYAN Tom (AREVA) [mailto:Tom.Ryan@areva.com] Sent: Friday, January 30, 2015 12:09 PM To: Wunder, George Cc: GUCWA Len (EXTERNAL AREVA); RANSOM Jim (AREVA); SEALS Jeff (AREVA); ROMINE Judy (AREVA); DELANO Karen (AREVA); Segala, John; MORENO Edgar (AREVA); HOTTLE Nathan (AREVA); BYRAM Morris (AREVA) Subject: Submittal of US EPR RAI 620 Supplement 1 Response George, Please find attached a courtesy copy of the transmittal letter and RAI 620 Supplement 1 Response. It has been submitted to the NRC Document Control Desk via the EIE process. Sincerely, Tom Ryan Manager, US EPR DCD Regulatory Affairs AREVA 7207 IBM Drive - CLT2B Charlotte, NC 28262 Phone: 704-805-2643, Cell : 704-292-5627 Fax: 434-382-6657

Hearing Identifier: AREVA_EPR_DC_RAIs Email Number: 4882 Mail Envelope Properties (DAC719623E968245BD52D036961111000298D98B4216) Subject: FW: Submittal of US EPR RAI 620 Supplement 1 Response Sent Date: 1/30/2015 12:24:38 PM Received Date: 1/30/2015 12:24:41 PM From: Wunder, George Created By: George.Wunder@nrc.gov Recipients: "ArevaEPRDCPEm Resource" <ArevaEPRDCPEm.Resource@nrc.gov> Tracking Status: None Post Office: HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 795 1/30/2015 12:24:41 PM 002 RAI 620 Supplement 1 Response US EPR DC.pdf 148689 001 AREVA Transmittal Letter NRC 15 007.pdf 190622 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

Response to

Request for Additional Information No.620, Supplement 1

02/03/2014 U.S. EPR Standard Design Certification

AREVA Inc. Docket No. 52-020

SRP Section: 09.01.05 - Overhead Heavy Load Handling Systems Application Section: 9.1.5

AREVA Inc. Response to Request for Additional Information No. 620, Supplement 1 U.S. EPR Design Certification Application Page 2 of 3 Question 09.01.05-25:

In accordance with 10 CFR50 Appendix A and GDC 1, OHLHS and equipment in and around the area of the OHLHS should be properly designed, fabricated, and installed to reduce the likelihood of a single failure. A failure that could cause the release of radioactive materials from damaged irradiated fuel, a criticality accident, or damage to essential safe-shutdown equipment could cause unacceptable radiation exposures.

Based on the staff's review of US-EPR FSAR Revision 5, the following questions are needed related to the Heavy Load Handling.

1. Table 9.1.5-1 includes a listing of the primary HLHE which are located in areas containing safety-related equipment that could be potentially impacted by drops of heavy loads. Since these cranes are located in areas containing safety related equipment, the staff needs to verify their classification. However, details of some cranes are not found. Please address the following:

a. Table 3.2.2-1 refers to “Auxiliary Crane” and Table 9.1.5-1 referring to “Fuel Building Auxiliary Crane”. Confirm these are referencing the same component and reword for consistently.

b. Table 3.2.2-1 refers to “Outdoor Crane” and Table 9.1.5-1 refers to “Gantry Crane” located outside fuel building. Confirm these are referencing the same component and reword for consistently.

c. Table 9.1.5-1 shows a “Decontamination Area Crane”. Clarify where this crane classification is located in Table 3.2.2-1.

GDC 4 requires protection for SSCs important to safety against the effects of internally-generated missiles. GDC 4 applies to SRP Section 9.1.5 because GDC 4 specifies protection against the effects of internally-generated missiles (i.e., dropped loads). A dropped heavy load in a critical area could cause a release of radioactive materials, a criticality accident, or inability to cool fuel within the reactor vessel or spent fuel pool or could prevent safe shutdown of the reactor.

2. The statement found in RAI 9.1.5-24 and RAI 9.1.4-26 response, and FSAR (Rev 5) Section 9.1.5.2.4 appears inaccurate. FSAR Section 9.1.5.2.4 states:

"Design of these devices, in accordance with ASME NOG-1, ensures that the criteria specified in CMAA-70, 2000 and ASME B30.2-2005 is satisfied.”

The staff understands CMAA 70 and ASME NOG-1 are design standards and do overlap. However, ASME B30.2 includes a small amount of design information, but it also includes operational, maintenance, and testing/inspection attributes that are not in the other standards. Therefore, the staff requests Areva to provide additional details to justify how meeting NOG-1 ensures B30.2 is met.

3. The statements found in RAI 9.1.5-24 response and FSAR Revision-5 seems contradictory. It is unclear to the staff whether ANSI N14.6 is applicable to the SFCTF components. FSAR Section 9.1.5.2.4 contains both of the following statements:

AREVA Inc. Response to Request for Additional Information No. 620, Supplement 1 U.S. EPR Design Certification Application Page 3 of 3 “These lifting devices are not conventional cranes, but components of these devices are designed per the guidance of ASME NOG-1 for Type I cranes and ANSI N14.6-2004 (Reference 9).”

“Since these lifting devices do not require the use of special below the hook lifting devices, the criteria of ANSI N14.6 and ASME 30.9, for below the hook lifting devices, do not apply."

Provide additional details regarding application of ANSI N14.6

Response to Question 09.01.05-25:

1. a These are references to the same crane. U.S. EPR FSAR, Tier 2, Table 3.2.2-1 will

be updated to be consistent with the information in U.S. EPR FSAR, Tier 2, Table 9.1.5-1

1. b. These are references to the same crane. U.S. EPR FSAR, Tier 2, Table 3.2.2-1 will

be updated to be consistent with the information in U.S. EPR FSAR, Tier 2, Table 9.1.5-1

1. c The decontamination crane was omitted from U.S. EPR FSAR, Tier 2, Table 3.2.2-1. The FSAR will be updated to include this crane.

2. The intent of the prior response was to address items related specifically to the crane design. It is recognized that ASME B30.2 does include additional requirements

pertaining to the operation, maintenance, testing and inspection of cranes. U.S. EPR FSAR, Tier 2, Section 9.1.5.2.4 will be updated to clarify this.

3. The first paragraph: “These lifting devices are not conventional cranes, but components of these devices are designed per the guidance of ASME NOG-1 for Type I cranes and ANSI N14.6-2004 (Reference 9)”, refers to components in the load train of the hoist. The second paragraph refers only to the “below the hook” lift device, of which there are none. ANSI N14.6 is used specifically for the design of the screw jack and gripper of the biological lid handling device.

FSAR Impact:

U.S. EPR FSAR, Tier 2, Table 3.2.2-1 and Section 9.1.5.2.4 will be revised as described in the response and indicated on the enclosed markup.

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U.S. EPR FINAL SAFETY ANALYSIS REPORT

Tier 2 Revision 8—Interim Page 9.1-116

assembly crane located near an accumulator tank. These cranes provide lifting capabilities during plant outages.

The Fuel Building contains bridge cranes in the equipment lock area. These cranes are used to move equipment and material from the plant grade elevation up to the equipment hatch level. These cranes are located in areas remote from the spent fuel pool such that movement of loads in the vicinity of the spent fuel pool by these cranes is not possible.

The Fuel Building also contains lifting devices that are used in conjunction with movement of the spent fuel casks in the spent fuel cask transfer facility (SFCTF). These are designated the cask loading penetration upper cover hoist and the biological lid handling station. The cask loading penetration upper cover hoist is located on the spent fuel pool operating floor. The biological lid handling station is located adjacent to the cask loading pit. The biological lid handling station's functions are to remove the cask lid to allow loading the spent fuel into the cask and then return the lid onto the loaded cask. The cask loading penetration upper cover hoist assists in opening the penetration upper cover to allow loading spent fuel into the cask and closing the penetration upper cover once the cask has been loaded. Additional details regarding the design, function and operation of the SFCTF are given in Section 9.1.4. These lifting devices are not conventional cranes, but components of these devices are designed per the guidance of ASME NOG-1 for Type I cranes and ANSI N14.6 (Reference 9).

These lifting devices also meet the recommended guidance specified in Section 5.0 of NUREG-0612 and SRP 9.1.5 for the handling of heavy loads. Since these lifting devices are stationary units, the safe load path is defined as the area directly below the device. Since these lifting devices do not require the use of special below the hook lifting devices, the criteria of ANSI N14.6 and ASME B30.9, for below the hook lifting devices, do not apply. Design of these devices, in accordance with ASME NOG-1, ensures that the criteria specified in CMAA-70 and ASME B30.2 is satisfied. In addition, these cranes are designed to meet the requirements specified by ASME B30.2 pertaining to crane operation, maintenance, testing and inspection.

The spent fuel cask transfer machine (SFCTM) is used for moving fuel casks into and out of the Fuel Building. A description of the SFCTM and its operation is given in Section 9.1.4.

While not a conventional crane supporting a suspended load, the SFCTM is designed using the same design requirements of ASME NOG-1 for Type I equipment. Since the equipment is designed as single failure proof, the equipment will maintain the supported loads in a safe configuration during design basis events. Provisions are also in place to allow placement of the loads in a safe configuration following a design basis event. The equipment is designed with manual backup capabilities.

All indicated changes are in response to RAI 620, Question 09.01.05-25.

January 30, 2015 NRC:15:007 U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 U.S. EPR Design Certification Application - Response to RAI 620, Question 09.01.05-25 with Associated FSAR Markups Ref. 1: Email, George Wunder (NRC) to Nathan Hottle (AREVA Inc.), “U.S. EPR Final RAI letter 620

RAI 725 – Re-Sent with Correct Attachment, February 3, 2014.” Ref. 2: Letter, Pedro Salas (AREVA Inc.) to Document Control Desk (NRC), “Closure Plan for U.S. EPR

Design Certification Application – FSAR Group B and Group C Chapters,” NRC:14:054, September 30, 2014.

Enclosed with this letter is the AREVA Inc. (AREVA) Supplement 1 response to the request for additional information (RAI) provided by the NRC in Reference 1. AREVA provided a schedule for a response to RAI 620 in Reference 2. The enclosed file “RAI 620 Supplement 1 Response US EPR DC” provides a final response to RAI 620, Question 09.01.05-25. Enclosed as a part of the response are affected pages of the U.S. EPR Final Safety Analysis Report in redline-strikeout format. The following table indicates the respective pages in the response document, “RAI 620 Supplement 1 Response US EPR DC.pdf” that contain AREVA’s response to the subject question.

Question # Start Page End Page RAI 620 – 09.01.05-25 2 3

This concludes AREVA’s response to RAI 620, and there are no questions from this RAI for which AREVA has not provided responses. This response is being provided to the U.S. NRC for review in calendar year 2015.

Document Control Desk NRC:15:007 January 30, 2015 Page 3

Document Components for NRC:15:007 001 AREVA Transmittal Letter NRC 15 007.pdf 107,244 bytes 002 RAI 620 Supplement 1 Response US EPR DC.pdf 148,625 bytes