Text

LLC Response to NRC Request for Additional Information No. 512 (Erai No. 9634) on the NuScale Design Certification Application
	ML19010A409
Person / Time
Site:	NuScale
Issue date:	01/10/2019
From:	Rad Z; NuScale
To:	; Document Control Desk, Office of New Reactors
References
	RAIO-0119-64111
	Download: ML19010A409 (59)
	v • d • e

RAIO-0119-64111 January 10, 2019 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.

512 (eRAI No. 9634) on the NuScale Design Certification Application

REFERENCE:

U.S. Nuclear Regulatory Commission, "Request for Additional Information No.

512 (eRAI No. 9634)," dated November 29, 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 Enclosure to this letter contains NuScale's response to a portion of the RAI Questions from NRC eRAI No. 9634:

16-60-1 16-60-38 16-60-4 16-60-39 16-60-5 16-60-41 16-60-8 16-60-44 16-60-10 16-60-47 16-60-11 16-60-48 16-60-12 16-60-49 16-60-13 16-60-50 16-60-14 16-60-51 16-60-15 16-60-53 16-60-16 16-60-54 16-60-19 16-60-56 16-60-20 16-60-57 16-60-36 16-60-58 16-60-37 16-60-74 The response to the remaining parts of question 16-60 will be provided by separate letters.

This letter and the enclosed response make no new regulatory commitments and no revisions to any existing regulatory commitments.

NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0119-64111 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-8H12 Samuel Lee, NRC, OWFN-8H12 Getachew Tesfaye, NRC, OWFN-8H12 : NuScale Partial Response to NRC Request for Additional Information eRAI No. 9634 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0119-64111 :

NuScale Partial Response to NRC Request for Additional Information eRAI No. 9634 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.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-1 The NRC staff identified issues in Revision 1 of the DCA, mostly in Part 4 which contains the generic TS and Bases, regarding grammar, spelling, typographical errors, and conformance with improved TS writers guide conventions concerning style, format, and content; such items are considered editorial or administrative in nature. Satisfactory disposition of editorial comments will result in high quality generic TS and Bases that are technically accurate, clear, and internally consistent, and therefore easily useable for controlling operation of NuScale units in a safe manner.

Subsequent to the initial draft of the following sub-questions, the staff discussed the draft sub-questions with the applicant in a public meeting conference call on November 6, 2018 (ML183ddAnnn). Also, some draft sub-questions were resolved in Revision 2 of the generic TS and Bases. The results of the meeting and the comparison with Revision 2 are indicated before each affected sub-question.

1. In Revision 2 of DCA part 2, FSAR Section 16.1, on Page 16.1-8: Table 16.1-1:

Surveillance Frequency Control Program Base Frequencies, is missing rows for SR 3.4.10.1 and SR 3.4.10.3.

NuScale Response:

The base frequencies and basis for the frequencies have been added to FSAR Table 16.1-1.

NuScale Nonproprietary

Impact on DCA:

The FSAR has been been revised as described in the response above and as shown in the markup provided in this response.

NuScale Nonproprietary

NuScale Final Safety Analysis Report Technical Specifications Table 16.1-1: Surveillance Frequency Control Program Base Frequencies (Continued)

Surveillance Base Frequency Basis Requirement 3.4.8.1 14 days The 14 day Frequency is adequate to trend changes in the noble gas specific activity level and based on the low probability of an accident occurring during this time period.

3.4.8.2 14 days The 14 day Frequency is adequate to trend changes in the iodine activity level and based on the low probability of an accident occurring during this time period.

3.4.10.1 24 months The 24 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a unit outage and the potential for unplanned plant transients if the Surveillances were performed with the reactor at power. The 24 month Frequency is also acceptable based on consideration of the design reliability of the equipment.

3.4.10 3 24 months The 24 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a unit outage and the potential for unplanned plant transients if the Surveillances were performed with the reactor at power. The 24 month Frequency is also acceptable based on consideration of the design reliability of the equipment.

3.5.1.1 24 months The 24 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a unit outage and the potential for unplanned plant transients if the Surveillances were performed with the reactor at power. The 24 month Frequency is also acceptable based on consideration of the design reliability of the equipment.

3.5.1.3 24 months The 24 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a unit outage and the potential for unplanned plant transients if the Surveillances were performed with the reactor at power. The 24 month Frequency is also acceptable based on consideration of the design reliability of the equipment.

3.5.2.1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on the similarity of the test to a CHANNEL CHECK as performed throughout existing large plant designs. The test verifies the accumulator pressure and thereby assures the OPERABILITY of the valves, as well as the status of the automatically monitored pressure alarms.

3.5.2.2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on the expected low rate of gas accumulation and the availability of control room indication and alarm of decay heat removal system (DHRS) level in the control room.

3.5.2.3 24 months The 24 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a unit outage and the potential for unplanned plant transients if the Surveillances were performed with the reactor at power. The 24 month Frequency is also acceptable based on consideration of the design reliability of the equipment.

3.5.3.1 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Since the ultimate heat sink (UHS) level is normally maintained at a stable level, and is monitored by main control indication and alarm, a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is appropriate. This Frequency also takes into consideration the high ratio of UHS volume change to UHS level change due to the UHS geometry.

3.5.3.2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months The Frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is sufficient to identify a temperature change that would approach either the upper or lower limit of UHS bulk average temperature assumed in the safety analyses. Since the UHS bulk average temperature is normally stable, and is monitored by main control indication and alarm, a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is appropriate. This Frequency also takes into consideration the large heat capacity of the UHS in comparison to the magnitude of possible heat addition or removal mechanisms.

3.5.3.3 31 days Since the UHS volume of borated water is large compared to potential dilution sources, the 31 day Frequency is acceptable. In addition, the relatively frequent Surveillance of the UHS water volume provides assurance that the UHS boron concentration is not changed significantly.

Tier 2 16.1-8 Draft Revision 3

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-4

4. A response is not required because this item is being referred to the NRO technical branch responsible for reviewing FSAR Section 6.4. Markup of Pages 6.4-9 and 6.4-14 of FSAR Section 6.4 in Letter dated June 1, 2018, follow-up to NRC-NuScale public meetings held on 2/26/2018 and 4/3/2018. (Also see response to RAI 5.2.5-7, RAI 6.4-3.) Regarding COL Item 6.4-5 and Table 6.4-4, "CRHS Testing"; in the next to last row, the "Parameter" field says "CRHS supply actuation valves and CRE pressure relief valves operation" and the "Acceptance Criteria" field says "Stroke open on CRHS actuation signal." This information is unchanged in Revision 2 of DCA part 2, FSAR Table 6.4-4. NuScale is requested to provide a more suitable acceptance criterion for the "CRE pressure relief valves operation" parameter.

NuScale Response:

As noted in the RAI description, a response is not required because this item is being referred to the NRO technical branch responsible for reviewing FSAR Section 6.4. No further action is taken at this time in response to this item.

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-5

5. Revision 2 of DCA part 4, GTS page 1.1-4, definition of MODE: The applicant is requested to clarify the definition of MODE, as indicated by markup:

A MODE shall correspond to any one inclusive combination of Reactivity Condition reactivity condition, Reactor Coolant Temperature reactor coolant temperature, control rod assembly (CRA) withdrawal capability, Chemical and Volume Control System (CVCS) and Containment Flood and Drain System (CFDS) configuration, reactor vent valve electrical isolation, and reactor vessel flange bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

NuScale Response:

The MODE definition in specification 1.1 has been modified to include each attribute described in the footnotes to Table 1.1-1.

Impact on DCA:

The Technical Specifications have been been revised as described in the response above and as shown in the markup provided in this response.

NuScale Nonproprietary

Definitions 1.1 1.1 Definitions LEAKAGE LEAKAGE shall be:

a. Identified LEAKAGE

1. LEAKAGE from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE, or

2. Reactor Coolant System (RCS) LEAKAGE through a steam generator (SG) to the Secondary System (primary to secondary LEAKAGE),

b. Unidentified LEAKAGE All LEAKAGE that is not identified LEAKAGE, and

c. Pressure Boundary LEAKAGE LEAKAGE (except SG LEAKAGE) through a nonisolable fault in a RCS component body, pipe wall, or vessel wall. A fault in an RCS component body, pipe wall, or vessel wall is isolated if LEAKAGE through the isolation device is 0.5 gpm per nominal inch of valve size up to a maximum limit of 5 gpm.

MODE A MODE shall correspond to any one inclusive combination of Rreactivity Ccondition, Rreactor Ccoolant Ttemperature, control rod assembly (CRA) withdrawal capability, Chemical and Volume Control System (CVCS) and Containment Flood and Drain System (CFDS) configuration, reactor vent valve electrical isolation, and reactor vessel flange bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

OPERABLE-OPERABILITY A system, subsystem, separation group, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, electrical power, cooling water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

NuScale 1.1-4 Draft Revision 3.0

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-8

8. No response required because Revision 2 of DCA part 2, on FSAR page 7.1-110, has already corrected the following error, by changing THOT to TCOLD. The staff noted that on Figure 7.1-1n, in FSAR Revision 1, the table describing the active and not-active state of the T-1 interlock mistakenly lists the T-1 ACTIVE status as when "3oo4 THOT INPUTS > T-1 SETPOINT" and the T-1 NOT ACTIVE status as when "2oo4 THOT INPUTS T-1 SETPOINT."

The staff believes that "THOT" should be "WR RCS TCOLD," or just "TCOLD."

NuScale Response:

As noted in the RAI, the T-1 table in FSAR Tier 2 Figure 7.1-1n was corrected in Revision 2 of the FSAR. No additional actions are planned at this time.

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-10

10. A response is not required because in the November 6, 2018, public meeting conference call, the applicant stated the requested changes will be incorporated in Revision 3 of DCA part

4. In Revision 2 of DCA part 4, GTS page 1.2-2, Example 1.2-1; and page 1.2-3, Example 1.2-2:

10.1 Include 0.1 inch left and right margins in Actions table Condition cells, Required Action cells, and Completion Time cells, including in the header row.

10.2 Column titles in Actions table header row should be center aligned.

10.3 In Example Actions tables, the staff recommends that the Condition column be 1.42 inches wide, Required Action column be 1.93 inches wide, and Completion Time column be 1.65 inches wide. Actions table should be 5.00 inches wide.

10.4 In Example Actions tables, the staff recommends that the hanging indentation for Condition statements be 0.2 inches, and Required Action statements be 0.3 inches, which are less than the 0.26 inches and 0.55 inches used in the regular Actions tables. There is one exception. In Example 1.2-2, which shows a second and third level of nesting of logical connectors; the staff recommends using a 0.55 inch hanging indentation for all action statements.

10.5 In Example 1.2-2, Required Action column, the second and third levels of nesting of the logical connectors should be left aligned with second and third periods, respectively, of the preceding Required Action designator.

NuScale Nonproprietary

NuScale Response:

As discussed with the staff during the November 6, 2018 public meeting, the formatting changes identified were incorporated into the technical specifications and bases.

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-11

11. A response is not required because in the November 6, 2018, public meeting conference call, the applicant stated the requested change will be incorporated in Revision 3 of DCA part 4.

GTS page 1.3-2, second paragraph, list item "a" --- Applicant is requested to underline the word "first" to match STS presentation.

NuScale Response:

See response to RAI 16-60-10.

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-12

12. A response is not required because in the November 6, 2018, public meeting conference call, the applicant stated the requested changes will be incorporated in Revision 3 of DCA part

4. In Revision 2 of DCA part 4, GTS page 1.3-3 through page 1.3-10, Applicant is requested to apply comments 10.1, 10.2, 10.3, and 10.4 to Examples 1.3-1, 1.3-2, 1.3-3, 1.3-4, 1.3-5, 1.3-6, and 1.3-7.

NuScale Response:

See response to RAI 16-60-10.

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-13

13. A response is not required because in the November 6, 2018, public meeting conference call, the applicant stated the requested change will be incorporated in Revision 3 of DCA part 4.

In Revision 2 of DCA part 4, GTS page 1.3-9, In the discussion of Example 1.3-6, the second sentence should begin as indicated: "The initial 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months hours interval of Required Action A.1 begins ..."

NuScale Response:

The term 'hours' has been changed to 'hour' in the paragraph after Example 1.3-6 of the proposed technical specifications.

Impact on DCA:

The Technical Specifications have been been revised as described in the response above and as shown in the markup provided in this response.

NuScale Nonproprietary

Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1.3-6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One channel A.1 Perform SR 3.x.x.x. Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable.

OR A.2 Reduce THERMAL 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months POWER to 50%

RTP.

B. Required B.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated Completion Time not met.

Entry into Condition A offers a choice between Required Action A.1 or A.2. Required Action A.1 has a once per Completion Time, which qualifies for the 25% extension, per SR 3.0.2, to each performance after the initial performance. The initial 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval of Required Action A.1 begins when Condition A is entered and the initial performance of Required Action A.1 must be complete within the first 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval. If Required Action A.1 is followed, and the Required Action is not met within the Completion Time (plus the extension allowed by SR 3.0.2),

Condition B is entered. If Required Action A.2 is followed and the Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is not met, Condition B is entered.

If after entry into Condition B, Required Action A.1 or A.2 is met, Condition B is exited and operation may then continue in Condition A.

NuScale 1.3-9 Draft Revision 3.0

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-14

14. A response is not required because in the November 6, 2018, public meeting conference call, the applicant stated the requested changes will be incorporated in Revision 3 of DCA part

4. In Revision 2 of DCA part 4, GTS page 1.4-2 through page 1.4-7, in Example Surveillance Requirements tables, Include 0.1 inch left and right margins in Surveillance column and Frequency column, including the header row.

NuScale Response:

See response to RAI 16-60-10.

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-15

15. A response is not required because in the November 6, 2018, public meeting conference call, the applicant stated the requested changes will be incorporated in Revision 3 of DCA part

4. In Revision 2 of DCA part 4, GTS page 2.0-1, SL 2.1.1.2: In the expression 4901 - (1.37E-3 x Burnup, MWD/MTU) °F use the math multiplication ascii character symbol "x" in place of the lower case ascii character for the letter "x" and add braces, as shown:

{4901 - (1.37E-3 x Burnup, MWD/MTU)} °F NuScale Response:

The presentation of the equation in specification 2.1.1.2 has been modified.

Impact on DCA:

The Technical Specifications have been been revised as described in the response above and as shown in the markup provided in this response.

NuScale Nonproprietary

SLs 2.0 2.0 SAFETY LIMITS (SLs) 2.1 SLs 2.1.1 Reactor Core SLs 2.1.1.1 In MODE 1 the critical heat flux ratio shall be maintained at or above the following correlation safety limits:

Correlation Safety Limit NSP2 [1.17]

NSP4 [1.21]

Hench-Levy [1.06]

2.1.1.2 In MODE 1 the peak fuel centerline temperature shall be maintained { 4901 - (1.37E-3 xx Burnup, MWD/MTU) } °F.

2.1.2 RCS Pressure SL In MODES 1, 2, and 3 pressurizer pressure shall be maintained 2285 psia.

2.2 Safety Limit Violations 2.2.1 If SL 2.1.1 is violated, restore compliance and be in MODE 2 within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

2.2.2 If SL 2.1.2 is violated:

2.2.2.1 In MODE 1, restore compliance and be in MODE 2 within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

2.2.2.2 In MODE 2 or 3, restore compliance within 5 minutes.

NuScale 2.0-1 Draft Revision 3.0

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-16

16. A response is not required because in the November 6, 2018, public meeting conference call, the applicant stated the requested changes will be incorporated in Revision 3 of DCA part

4. In Revision 2 of DCA part 4, GTS page 3.1.3-2, Note for third Frequency of SR 3.1.3.2 must end with a period; Only required when projected end of cycle MTC is not within limit.

NuScale Response:

See response to RAI 16-60-10.

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-19 The applicant is requested to make the indicated changes or make appropriate equivalent changes:

18.2 A response is not required because this sub-question is withdrawn. Condition B (third condition statement) of Subsection 3.1.9, for clarity, as follows: "Boric Acid Storage Tank boric acid concentration not within limits.

NuScale Response:

This question was withdrawn by the staff when issued. The question was previously addressed as shown in Revision 2 of the DCA. No further action is planned.

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-20

19. In Revision 2 of DCA part 4, GTS pages 3.1.5-1 and 3.1.6-1: The NOTE to LCO 3.1.5 and the NOTE to LCO 3.1.6 modify the Applicability of Subsection 3.1.5 and Subsection 3.1.6, respectively, and not the LCO statement itself. For consistency with a similar NOTE in W-AP1000-STS Subsection 3.1.6, and in W-STS Subsection 3.1.5 and 3.1.6, and the writer's guide, these NOTES should be located below the Applicability statement of LCO 3.1.5 and LCO 3.1.6, and should use the STS phrasing:

"APPLICABILITY: MODE 1[ with keff 1.0].

NOTE--------------------------------------

This LCO is not applicable while performing SR 3.1.4.2.

Staff notes that SR 3.1.4.2 is performed with one shutdown group or one regulating group in manual control. Each of the four CRAs in each group is manually moved " 4 steps in either direction" individually. Also, while performing this Surveillance, the CRA alignment limits of Subsection 3.1.4, LCO 3.1.4 continue to apply ("Individual CRA positions shall be within 6 steps of their group position.") Therefore, the STS NOTE's phrasing is sufficient, and the proposed more detailed phrasing ("Not applicable to shutdown groups inserted while performing SR 3.1.4.2." and "Not applicable to regulating groups inserted while performing SR 3.1.4.2.") is not needed to understand the exception to the Subsection's Applicability. The applicant is requested to revise Subsections 3.1.5 (LCO and Applicability statements), B 3.1.5 (LCO and NuScale Nonproprietary

Applicability sections), 3.1.6 (LCO and Applicability statements), and B 3.1.6 (LCO and Applicability sections) to be consistent with the W-STS.

NuScale Response:

The Notes to the applicability of LCO 3.1.5 and LCO 3.1.6 have been moved to immediately below the Applicability section. They are also re-worded to be consistent with the W-STS as described in the RAI discussion.

Impact on DCA:

The Technical Specifications have been been revised as described in the response above and as shown in the markup provided in this response.

NuScale Nonproprietary

Shutdown Group Insertion Limits 3.1.5 3.1 REACTIVITY CONTROL SYSTEMS 3.1.5 Shutdown Group Insertion Limits LCO 3.1.5 Each shutdown group shall be within insertion limits specified in the COLR.

NOTE---------------------------------------------

Not applicable to shutdown groups inserted while performing SR 3.1.4.2.

APPLICABILITY: MODE 1.

NOTE---------------------------------------------

This LCO not applicable while performing SR 3.1.4.2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Shutdown group not A.1.1 Verify SDM is within the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months within limits. insertion limits specified in the limits not met. COLR.

OR A.1.2 Initiate boration to restore 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months SDM to within limit.

AND A.2 Restore shutdown group 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to within limits.

B. Required Action and B.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

NuScale 3.1.5-1 Draft Revision 3.0

Regulating Group Insertion Limits 3.1.6 3.1 REACTIVITY CONTROL SYSTEMS 3.1.6 Regulating Group Insertion Limits LCO 3.1.6 Each regulating group shall be within the insertion limits specified in the COLR.

NOTE---------------------------------------------

Not applicable to regulating groups inserted while performing SR 3.1.4.2.

APPLICABILITY: MODE 1 with keff 1.0.

NOTE---------------------------------------------

This LCO not applicable while performing SR 3.1.4.2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Regulating group A.1.1 Verify SDM is within the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months insertion limits not met. limits specified in the COLR.

OR A.1.2 Initiate boration to restore 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months SDM to within limits.

AND A.2 Restore regulating group 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to within limits.

B. Required Action and B.1 Be in MODE 1 with 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion keff < 1.0.

Time not met.

NuScale 3.1.6-1 Draft Revision 3.0

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-36

32. See RAI 506-9614, Question 16-53, Part B NuScale Response:

RAI 9614, 16-53 was submitted on December 12, 2018 as an attachment to NuScale letter RAIO-1218-63828 (ML18347A619).

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-37

33. In Revision 2 of DCA part 4, on GTS page 3.1.9-3, the staff suggests revising SR 3.1.9.1 as indicated for clarity:

SR 3.1.9.1 Verify that CVCS makeup pump demineralized water flow path is configured to ensure that it the maximum demineralized water flowrate remains within the limits specified in the COLR.

The applicant is requested to make the above suggested change, or an appropriate equivalent change.

NuScale Response:

SR 3.1.9.1 has been revised to state "Verify that CVCS makeup pump demineralized water flow path is configured to ensure that the maximum demineralized water flowrate remains within the limits specified in the COLR."

Impact on DCA:

The Technical Specifications have been been revised as described in the response above and as shown in the markup provided in this response.

NuScale Nonproprietary

Boron Dilution Control 3.1.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.9.1 Verify that CVCS makeup pump demineralized In accordance water flow path is configured to ensure that itthe with the maximum demineralized water flowrate remains Surveillance within the limits specified in the COLR. Frequency Control Program SR 3.1.9.2 Verify each automatic CVCS demineralized water In accordance isolation valve that is not locked, sealed, or with the otherwise secured in the isolated position, actuates Surveillance to the isolated position on an actual or simulated Frequency signal except for valves that are open under Control Program administrative controls.

SR 3.1.9.3 Verify Boric Acid supply boron concentration is In accordance within the limits specified in the COLR. with the Surveillance Frequency Control Program SR 3.1.9.4 Verify each CVCS makeup pump maximum In accordance flowrate is 25 gpm. with the Surveillance Frequency Control Program NuScale 3.1.9-3 Draft Revision 3.0

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-38

34. A separate response is not required, because in the November 6, 2018, public meeting conference call with the staff, NuScale stated it would respond to this sub-question when it responds to RAI 506-9614, Question 16-52, which also addresses GTS Subsection 3.7.1 Actions. In Revision 2 of DCA part 4, on GTS pages 3.7.1-1 and -2, the applicant is requested to revise GTS Subsection 3.7.1, "MSIVs," Actions A and B, as indicated by mark up:

1. One or more required MSIV valves MSIVs inoperable. l A.1 Isolate the affected main steam line MSIV flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange. l 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND A.2 Verify the affected main steam line MSIV flow path is isolated. l Once per 7 days

2. One or more required MSIV bypass valves inoperable. l B.1 Isolate the affected main steam line bypass flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange. l 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND A.2 Verify the affected main steam line bypass flow path is isolated. l Once per 7 days The staff observes that the word "required" in Conditions A and B appears to be unnecessary. The LCO requires two operable MSIVs and two operable MSIV bypass valves in the common main steam line from each SG. As long as the MSIV and associated MSIV bypass valve in either the inner valve set or outer valve set, are capable of closing with leakage within the specified limits, the main steam line isolation function to support the actuation of the associated DHRS train remains operable, although there is no capability to withstand a single failure of one of these valves.

The applicant is requested to confirm that the intent of the word "required" is to convey that an MSIV and associated bypass valve are not "required" to be operable for automatic closure if (1) the other MSIV and associated bypass valve in the same main steam line are both closed and de-activated with leakage within specified limits, or (2) the associated flow paths containing the other MSIV and associated bypass valve are otherwise isolated by use of at least one NuScale Nonproprietary

closed manual valve, or blind flange with leakage within specified limits. If this is correct, the applicant is requested to revise Subsection B 3.7.1 by adding an explicit discussion explaining the intended meaning of the word 'required.' This explanation should discuss that each main steam line contains four flow paths, (1) an inner pair of parallel flow paths, one with an MSIV and one with an MSIV bypass valve, located just outside the containment vessel downstream of the steam line penetration, and (2) an outer pair of parallel flow paths, one with an MSIV and one with an MSIV bypass valve, located downstream of the main steam line spool piece.

Isolation of a main steam line requires at least the isolation of either the inner pair of flow paths or the outer pair of flow paths.

The applicant is requested to clarify Actions table Note 1, as indicated: "Separate Condition entry is allowed for each MSIV and each MSIV bypass inoperable valve." It is understood that Conditions are entered for inoperable valves, which are required to be operable by the LCO.

As written, Condition A applies when one SG's main steam line has (1) an open MSIV flow path which is incapable of isolation using the MSIV on either an automatic or manual actuation signal, or (2) an open or closed MSIV with leakage outside the specified limit. By specifying that separate Condition entry is allowed for each MSIV, Condition A could be stated as "One or more MSIV flow paths with the MSIV inoperable." Likewise, Condition B could be stated as "One or more MSIV bypass flow paths with the MSIV bypass valve inoperable."

NuScale Response:

The response to RAI 9614, 16-52 addresses the concerns identified in this request. That RAI response was submitted on December 12, 2018 as an attachment to NuScale letter RAIO-1218-63828 (ML18347A619).

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-39

35. No response required because Revision 2 of DCA part 4, on GTS page 3.7.1-2, has already corrected Subsection 3.7.1, Required Actions D.1 and D.2 by capitalizing "Mode" so these actions read:

D.1 Be in MODE 2. l 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND D.2 Be in MODE 3 and PASSIVELY COOLED. l 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months NuScale Response:

The word MODE in Required Actions D.1 and D.2 of GTS 3.7.1 was capitalized during editorial corrections previously implemented in the TS. The Conditions were previously renumbered in response to eRAI 9614 16-52 as shown on the attached page. The change is now reflected in Required Actions C.1 and C.2.

Impact on DCA:

The Technical Specifications have been been revised as described in the response above and as shown in the markup provided in this response.

NuScale Nonproprietary

MSIVs 3.7.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more required B.1 Isolate the affected main 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months MSIV bypass valves steam line bypass flow path inoperable. by use of at least one closed and de activated automatic valve, closed manual valve, or blind flange.

AND B.2 NOTES

1. Isolation in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected main Once per 7 days steam line bypass flow path is isolated.

CB. Steam line that cannot CB.1 Isolate the affected main 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months be isolated. One flow steam line. flow path by use path with an inner and of at least one closed and outer required valve de activated automatic inoperable. valve, closed manual valve, or blind flange.

DC. Required Action and DC.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND DC.2 Be in MODE 3 and 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months PASSIVELY COOLED.

NuScale 3.7.1-2 Draft Revision 3.0

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-41

37. The staff reviewed Revision 1 of DCA part 4, GTS Chapter 3; the Actions Conditions provided to require a unit shutdown from MODE 1 above 25% RTP whenever a Required Action for another entered Condition of the LCO Subsection is not met within the associated Completion Time. In a few instances, the initially entered Condition specifies an Action to exit the applicability (e.g., LCO 3.1.4 Required Action A.2). The staff compared the default Required Actions and Completion Times to reach different RCS temperatures in Mode 3 based on the affected systems, parameter limits, and instrumentation functions, and their relative importance to safety.

37.1 In Revision 2 of DCA part 4, Required Action F.1 of LCO 3.3.3 says "Isolate CVCS charging and letdown flow paths to the Reactor Coolant System ..."; but Required Action F.1 of LCO 3.3.4 says "Isolate the flow paths from the CVCS to the Reactor Coolant System............... "; the applicant is requested to make the phrasing of these actions more consistent NuScale Response:

The Required Actions of LCO 3.3.3 and LCO 3.3.4 for CVCS isolation and Demineralized Water Supply Isolation have been modified to more consistently and accurately reflect the required actions to align the plant in a way that ensures the isolation function is accomplished consistent with the design and other LCO Required Actions.

NuScale Nonproprietary

Impact on DCA:

The Technical Specifications have been been revised as described in the response above and as shown in the markup provided in this response.

NuScale Nonproprietary

ESFAS Logic and Actuation 3.3.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. As required by Required E.1 ---------------NOTE---------------

Action B.1 and Flow path(s) may be referenced in unisolated intermittently Table 3.3.3-1. under administrative controls.

OR --------------------------------------

Both divisions of Isolate the flow path from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Demineralized Water the demineralized water Supply Isolation storage tank to the reactor actuation function coolant systemIsolate inoperable. dilution source flow paths in the CVCS makeup line by use of at least one closed manual or one closed and de-activated automatic valve.

F. As required by Required F.1 ----------------NOTE--------------

Action B.1 and Flow path(s) may be referenced in unisolated intermittently Table 3.3.3-1. under administrative controls.

OR --------------------------------------

Both divisions of CVCS Isolate theCVCS charging 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Isolation actuation and letdown flow paths from function inoperable. the CVCS to the Reactor Coolant System by use of at least one closed manual or one closed and de-activated automatic valve.

NuScale 3.3.3-3 Draft Revision 3.0

Manual Actuation Functions 3.3.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. As required by Required E.1 ----------------NOTE--------------

Action A.1 or B.1 and Flow path(s) may be referenced in unisolated intermittently Table 3.3.4-1. under administrative controls.

Isolate the flow path from the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months demineralized water storage tank to the Reactor Coolant SystemIsolate dilution source flow paths in the CVCS makeup line by use of at least one closed manual or one closed and de-activated automatic valve.

F. As required by Required F.1 ---------------NOTE--------------

Action A.1 or B.1 and Flow path(s) may be referenced in unisolated intermittently Table 3.3.4-1. under administrative controls.

Isolate the flow paths from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months the CVCS to the Reactor Coolant System by use of at least one closed manual or one closed and de-activated automatic valve.

NuScale 3.3.4-2 Draft Revision 3.0

Manual Actuation Functions B 3.3.4 BASES ACTIONS (continued)

The Completion Times are reasonable because the credited automatic actuation function remains OPERABLE as specified in LCO 3.3.3, and alternative means of manually initiating the safety function remain available, e.g., manually initiating individual MPS division trip logic and component-level actuations.

E.1 If Required Actions A.1 or B.1 direct entry into Condition E as specified in Table 3.3.4-1, then Action E.1 requires the dilution sourceDWSI flow paths to be isolated if the manual actuation function is not restored within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The Action includes a Note that permits the flow path to be opened intermittently under administrative controls. This permits operation of the unit while actions to restore the function are underway.

The Completion Times are reasonable because the credited automatic actuation function remains OPERABLE as specified in LCO 3.3.3, and alternative means of manually initiating the safety function remain available, e.g., manually initiating individual MPS division trip logic and component-level actuations.

F.1 If Required Actions A.1 or B.1 direct entry into Condition F as specified in Table 3.3.4-1, then Action F.1 requires the CVCSI flow paths to be isolated if the manual actuation function is not restored within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The Action includes a Note that permits the flow path to be opened intermittently under administrative controls. This permits operation of the unit while actions to restore the function are underway.

The Completion Times are reasonable because the credited automatic actuation function remains OPERABLE as specified in LCO 3.3.3, and alternative means of manually initiating the safety function remain available, e.g., manually initiating individual MPS division trip logic and component-level actuations.

G.1 If Required Actions A.1 or B.1 direct entry into Condition G as specified in Table 3.3.4-1, then Action G.1 requires the pressurizer heaters to be de-energized if the manual actuation function is not restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The Action includes a Note that permits the heaters to be energized intermittently under administrative controls. This permits operation of the unit while actions to restore the function are underway.

NuScale B 3.3.4-4 Draft Revision 3.0

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-44

38. A response is not required because the Surveillance Requirements section of Subsection B 3.3.2, for SR 3.3.2.1, fourth paragraph, regarding the Actuation Logic Test for the RTS, in Revision 1 of the DCA part 4, was revised (in response to RAI 506-9614, Question 16-

50) by Revision 2 of DCA part 4, as indicated, to correct errors:

The ACTUATION LOGIC TEST includes testing of the APL on all RTS and ESFAS EIMs, the enable nonsafety control switches, the main control room isolation switches, the override switches, and the operating bypass switches. The ACTUATION LOGIC TEST includes a review of any alarms or failures reported by the self-checking self-testing features.

NuScale Response:

The response to RAI 9614, 16-50 submitted on December 12, 2018 includes discussion of this item. The RAI response was submitted as an attachment to NuScale letter RAIO-1218-63828 (ML18347A619).

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-47

41. In Revision 2 of DCA part 4, on GTS page B 3.3.1-3, the applicant is requested to replace the second occurrence of "10 CFR 100" with "10 CFR 34" in addition to the first occurrence, which was changed in response to RAI 490-9556, Question 16-48.

NuScale Response:

The reference to 10 CFR 100 in the Background section of the LCO 3.3.1 bases has been changed to refer to 10 CFR 50.34.

Impact on DCA:

The Technical Specifications have been been revised as described in the response above and as shown in the markup provided in this response.

NuScale Nonproprietary

Module Protection System Instrumentation B 3.3.1 BASES BACKGROUND (continued) affected. The channel as-found condition will be entered into the Corrective Action Program for further evaluation and to determine the required maintenance to return the channel to OPERABLE.

During AOOs, which are those events expected to occur one or more times during the plant life, the acceptable limits are:

The critical heat flux ratio (CHFR) shall be maintained above the SL value to prevent critical heat flux (CHF);

Fuel centerline melting shall not occur; and

Pressurizer pressure SL of 2285 psia shall not be exceeded.

Maintaining the variables within the above values ensures that the offsite dose will be within the 10 CFR 50 (Ref. 2) and 10 CFR 50.34 (Ref. 3) criteria during AOOs.

Accidents are events that are analyzed even though they are not expected to occur during the plant life. The acceptable limit during accidents is that the offsite dose shall be maintained within an acceptable fraction of 10 CFR 50.34100 (Ref. 3) limits. Different accident categories allow a different fraction of these limits based on probability of occurrence. Meeting the acceptable dose limit for an accident category is considered having acceptable consequences for that event.

The MPS includes devices and circuitry that generate the following signals when monitored variables reach levels that are indicative of conditions requiring protective action:

1. Reactor Trip System (RTS) actuation;

2. Emergency Core Cooling System (ECCS) actuation;

3. Decay Heat Removal System (DHRS) actuation;

4. Containment Isolation System (CIS) actuation;

5. Chemical and Volume Control System Isolation (CVCSI) actuation;

6. Demineralized Water Supply Isolation (DWSI) actuation;

7. Pressurizer Heater Trip (PHT) actuation; and

8. Low Temperature Overpressure Protection (LTOP) actuation.

NuScale B 3.3.1-3 Draft Revision 3.0

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-48

42. A response is not required because the applicant stated in the November 6, 2018, public meeting conference call that it would make the indicated changes in Revision 2 of TR-1116-52011-NP, Technical Specifications Regulatory Conformance and Development" report (RCDR). In Revision 1 of the RCDR, Appendix C, Industry / NRC STS Traveler Consideration, regarding Table C-1, the applicant clarified the previous version of the third and fourth paragraphs; the staff suggests an additional clarification as indicated by shaded text:

The following table provides details of the extent of applicability, use, and incorporation consideration of features from the listed TSTF STS travelers that correspond directly or indirectly with specifications included in the proposed NuScale GTS.

The TSTF travelers that are were considered are those that were issued as new or revised since the earliest manuscript date of [Revision 4 of] the NUREG STS, October 2011, and by comparison of the TSTF traveler content with the contents of the STS with the changes identified in the TSTF each traveler.

The applicant is requested to make the indicated clarification denoted by shaded text. The staff also requests that the applicant consider adding an explanation in the Discussion field of RCDR Table C-1, regarding TSTF-493, that "the SP language follows the W-AP1000-STS Subsection 5.5.14 phrasing, which is better suited for new reactor generic TS and the 10 CFR Part 52 licensing process."

NuScale Nonproprietary

NuScale Response:

As noted in the RAI, this editorial comment will be considered in development of a future revision of TR-1116-52011-NP, Technical Specifications Regulatory Conformance and Development." No further action is planned at this time.

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-49

43. A response is not required because the applicant stated in the November 6, 2018, public meeting conference call that it would address this sub-question in Revision 2 of the RCDR.

Appendix C, Table C-1, Revision 1 of the RCDR states, regarding TSTF-561-T, Rev. 0 (Grammatical corrections shown in shaded text):

Addition of optional content or reviewer's notes to STS are is not applicable or appropriate for a DCA GTS submittal. Only COL-specific content is presented as bracketed content to be modified by applicants referencing the certified design.

The staff disagrees with the first sentence. GTS may and GTS Bases should include bracketed reviewer's notes when appropriate and can include optional bracketed provisions as COL items. The applicant is asked to see the example of the ESBWR GTS and Bases, including the list of COL items, and revise the above statement accordingly.

NuScale Response:

As noted in the RAI, this editorial comment will be considered in development of a future revision of TR-1116-52011-NP, Technical Specifications Regulatory Conformance and Development." No further action is planned at this time.

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-50

44. The applicant is requested to state where the DCD describes how a COL applicant will meet the three conditions for adoption of TSTF-366-A, Elimination of Requirements for a Post Accident Sampling System. These conditions are provided in a Reviewers Note in W-STS Subsection 5.5.3.

NuScale Response:

Dose analysis for post-accident sampling and Post Accident Sampling System (PASS) is a key issue related to the accident source term topical report.

A PASS program was not included in technical specification 5.5 because such a system would not significantly contribute to plant safety or accident recovery and not based specifically on the allowances of TSTF-366-A which is explicitly based on implementation of a Westinghouse or Combustion Engineering report. Therefore the criteria in the reviewers note in section 5.5.3 of NUREG-1431 (or NUREG-1432) is irrelevant to the NuScale application.

NuScale has addressed this issue in the responses to eRAI listed below:

8837 dated May 18, 2018 (ML18138A383)

9044 dated October 31, 2017 (ML17304B483)

9278 dated May 16, 2018 (ML18136A870)

Additionally, NuScale is pursuing an explicit exemption to address the NuScale design and need for a PASS. That exemption request is schedule for submittal in the first quarter of 2019.

NuScale Nonproprietary

The exemption provides a regulatory basis for concluding that a PASS does not significantly contribute to NuScale plant safety or accident recovery. Therefore no technical specification program is required.

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-51

45. In Revision 2 of DCA part 4, on Bases Pages B 3.3.1-36 and -37 regarding Narrow Range Containment pressure, in particular, High Narrow Range Containment Pressure Decay Heat Removal System Actuation:

Four High Narrow Range Containment Pressure DHRS channels are required to be OPERABLE in MODES 1 and 2, and MODE 3 without PASSIVE COOLING in operation. In MODE 3 with PASSIVE COOLING in operation, sufficient cooling for decay heat loads is met. In MODES 4 and 5 the reactor is subcritical and passively cooled.

The applicant is requested to capitalize "passively cooled" in the last sentence, because this expression is a defined term. It is suggested that a global search of DCA part 4 be done to verify all occurrences of defined terms are in all capital letters.

NuScale Response:

The use of 'passively cooled' in this location is not a defined term; it is a reference to the condition of the plant in these modes. In MODE 5, decay heat is transferred directly to the UHS by contact with the pool water and use of the term would be inappropriately specific. TSTF-GG-05-01, Rev. 1, Writer's Guide for Plant-Specific Improved Technical Specification, section 3.3.2 b addresses this and indicates that the term should not be capitalized. No changes have been made as a result of this RAI.

NuScale Nonproprietary

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-53

46. In Revision 2 of DCA part 4, on Page 3.0-3 regarding the Reviewers Note for LCO 3.0.8, which addresses barriers that are unable to provide their related support for TS LCO required safety functions. (i) Regarding format, the Note as presented in DCA Rev. 1, includes an extra blank line after the Note; the applicant is requested to remove the extra blank line---

there should be only one. (ii) On Bases Page B 3.0-11 regarding the end of the LCO 3.0.8 Note statement, the -A appended to Revision 2 is requested to be moved to the traveler designator, so the reference says: ...bounding generic risk assessment provided in TSTF-427-A, Allowance for Non-Technical Specification Barrier Degradation on Supported System OPERABILITY, Revision 2. (iii) Since the NRC staff must review the risk assessment for the NuScale design (to be provided by the COL applicant) to verify it is consistent with the bounding generic risk assessment provided in TSTF-427-A, the staff requests that the applicant modify the Note so that is says, A COL applicant who wants to adopt LCO 3.0.8 must perform or reference a risk assessment for the NuScale design that has been submitted to and accepted by the the NRC,... Notice that this request also applies to the same Reviewers Note in the Bases for LCO 3.0.8.

NuScale Response:

The format of the Reviewer's Note at LCO 3.0.8 was revised and the words 'and accepted by' were added as requested.

NuScale Nonproprietary

Impact on DCA:

The Technical Specifications have been been revised as described in the response above and as shown in the markup provided in this response.

NuScale Nonproprietary

LCO Applicability B 3.0 BASES LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform special evolutions. Test Exception LCO 3.1.8 allows specified Technical Specification (TS) requirements to be changed to permit performance of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS.

Unless otherwise specified, all the other TS requirements remain unchanged. This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.

The Applicability of a Test Exception LCO represents a condition not necessarily in compliance with the normal requirements of the TS.

Compliance with Test Exception LCOs is optional. A special operation may be performed either under the provisions of the appropriate Test Exception LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Test Exception LCO, the requirements of the Test Exception LCO shall be followed.

[ ------------------------------ REVIEWERS NOTE ------------------------------------

A COL applicant who wants to adopt LCO 3.0.8 must perform or reference a risk assessment for the NuScale design that has been submitted to and accepted by the NRC, and that was prepared consistent with the bounding generic risk assessment provided in TSTF-427-A, Allowance for Non-Technical Specification Barrier Degradation on Supported System OPERABILITY, Revision 2 A.

]

[LCO 3.0.8 LCO 3.0.8 establishes conditions under which systems described in the Technical Specifications are considered to remain OPERABLE when required barriers are not capable of providing their related support function(s).

Barriers are doors, walls, floor plugs, curbs, hatches, installed structures or components, or other devices, not explicitly described in Technical Specifications that support the performance of the safety function of systems described in the Technical Specifications. This LCO states that the supported system is not considered to be inoperable solely due to required barriers not capable of performing their related support function(s) under the described conditions. LCO 3.0.8 allows 30 days before declaring the supported system(s) inoperable and the LCO(s)

NuScale B 3.0-11 Draft Revision 3.0

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-54

47. In Revision 2 of DCA part 4, on Page B 3.0-11 regarding the Reviewers Note for the Bases of LCO 3.0.8, which addresses barriers that are unable to provide their related support for TS LCO required safety functions. Regarding format, the Note includes a blank line before and after the Notes statement (below the top dashed line and above the bottom dashed line);

these blank lines are requested to be removed because they are contrary to the STS convention for the presentation of Notes.

NuScale Response:

The format of the Reviewer's Note at the bases for LCO 3.0.8 was revised as requested.

Impact on DCA:

The Technical Specifications have been been revised as described in the response above and as shown in the markup provided in this response.

NuScale Nonproprietary

LCO Applicability B 3.0 BASES LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform special evolutions. Test Exception LCO 3.1.8 allows specified Technical Specification (TS) requirements to be changed to permit performance of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS.

Unless otherwise specified, all the other TS requirements remain unchanged. This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.

The Applicability of a Test Exception LCO represents a condition not necessarily in compliance with the normal requirements of the TS.

Compliance with Test Exception LCOs is optional. A special operation may be performed either under the provisions of the appropriate Test Exception LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Test Exception LCO, the requirements of the Test Exception LCO shall be followed.

[ ------------------------------ REVIEWERS NOTE ------------------------------------

A COL applicant who wants to adopt LCO 3.0.8 must perform or reference a risk assessment for the NuScale design that has been submitted to and accepted by the NRC, and that was prepared consistent with the bounding generic risk assessment provided in TSTF-427-A, Allowance for Non-Technical Specification Barrier Degradation on Supported System OPERABILITY, Revision 2 A.

]

[LCO 3.0.8 LCO 3.0.8 establishes conditions under which systems described in the Technical Specifications are considered to remain OPERABLE when required barriers are not capable of providing their related support function(s).

Barriers are doors, walls, floor plugs, curbs, hatches, installed structures or components, or other devices, not explicitly described in Technical Specifications that support the performance of the safety function of systems described in the Technical Specifications. This LCO states that the supported system is not considered to be inoperable solely due to required barriers not capable of performing their related support function(s) under the described conditions. LCO 3.0.8 allows 30 days before declaring the supported system(s) inoperable and the LCO(s)

NuScale B 3.0-11 Draft Revision 3.0

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-56

49. In Revision 2 of DCA part 4, on Page B 3.0-16, regarding the Bases for SR 3.0.2, the GTS includes the following paragraph after the second paragraph that is not included in the W-STS 3.0.2 Bases:

When a Section 5.5, "Programs and Manuals," Specification states that the provisions of SR 3.0.2 are applicable, a 25% extension of the testing interval, whether stated in the Specification or incorporated by reference, is permitted.

The applicant is requested to explain why this paragraph is needed, including a list of the Section 5.5 subsections it would apply to.

NuScale Response:

Development of the bases for SR 3.0.2 included consideration of the contents of various industry / NRC travelers and initiatives. This included TSTF-545-A, Rev. 3, that removed the inservice testing program from technical specification 5.5. Among the supporting and accompanying changes described in this NRC-approved traveler, is the addition of the subject paragraph to the bases for SR 3.0.2. The programs in section 5.5 that include applicability of SR 3.0.2 are listed in Revision 2 of the specifications, 5.5.2, 5.5.6, and 5.5.11. No changes were made as a result of this RAI.

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-57

50. In Revision 2 of DCA part 4, on Page B 3.0-17, regarding the Bases for SR 3.0.2, fourth paragraph (after the paragraph addressed by Item 49). The applicant is requested to explain why the W-STS paragraph is split into three paragraphs, the second at the beginning of the third sentence ("The exceptions to SR 3.0.2 are ..."), the third at the beginning of the eighth sentence

("As stated in SR 3.0.2, the 25% extension also does not apply...").

Also, the second of the three paragraphs revises the example of exceptions to LCO 3.0.2, as indicated in the following markup:

The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply. These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. An example Examples of where SR 3.0.2 does not apply is are in the Containment Leakage Rate Testing Program required by 10 CFR 50, Appendix J, and the inservice testing of pumps and valves in accordance with applicable American Society of Mechanical Engineers Operation and Maintenance Code, as required by 10 CFR 50.55a. These programs establish testing requirements and Frequencies in accordance with the requirements of regulations. The TS cannot, in and of themselves, extend a test interval specified in the regulations directly or by reference.

The applicant is also requested to explain why the phrase "directly or by reference" added at the end is needed.

NuScale Response:

NuScale Nonproprietary

The paragraph was divided into three parts to more appropriately describe the three topics that were presented in the lengthy paragraph of the W-STS. This was reviewed and determined to improve the readability and understandability of the previous content. These changes were made after consideration of the industry / NRC approved traveler 545-A, Revision 3.

The formatting change to break the paragraph into three parts is not a substantive change to the bases discussion and merely makes the discussion more readable. The inclusion of the examples and clarification to the last sentence of the second paragraph was incorporated previously for consistency with the staff-approved traveler. No changes were made as a result of this RAI.

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-58

51. In Revision 2 of DCA part 4, on Page B 3.0-18, regarding Bases for SR 3.0.3, the following new paragraph, which is not included in the W-STS Bases and is inserted after the first paragraph, states:

When a Section 5.5, "Programs and Manuals," Specification states that the provisions of SR 3.0.3 are applicable, it permits the flexibility to defer declaring the testing requirement not met in accordance with SR 3.0.3 when the testing has not been performed completed within the specified testing interval; this interval includes (including the allowance of SR 3.0.2 if invoked by the Section 5.5 Specification specifies that SR 3.0.2 is applicable).

The applicant is requested to explain why this paragraph is needed. Also consider the suggested edits, indicated by mark up, for improved clarity. The DCA Revision 1 version of this paragraph was changed in DCA Revision 2, as indicated by shaded text. The applicant is requested to explain the reason for this change.

NuScale Response:

The paragraph was included in consideration of the contents of industry / NRC traveler TSTF-545-A, Revision 3. The change from 'completing' to 'performing' was identified by the staff on April 2, 2018 as an editorial issue, and was made consistent with consideration of the content of TSTF-529-A Revision 4. This change was specifically evaluated in section A.6.2 of the Attachment to the staff final safety evaluation of the traveler. No changes were made as a result of this RAI.

NuScale Nonproprietary

Impact on DCA:

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

NuScale Nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9634 Date of RAI Issue: 11/29/2018 NRC Question No.: 16-60-74

68. A response is not required because the applicant stated in an email dated November 12, 2018, to follow up the November 6, 2018, public meeting conference call, that it would address this purely editorial item in Revision 3 of DCA part 4. In Revision 2 of DCA part 4, Subsection B 3.4.1, Surveillance Requirements section, last paragraph. The applicant is requested to improve the clarity of this paragraph as indicated:

The frequency requires this surveillance to be performed once after each refueling. The potential for inadvertent Inadvertent changes that might impact on flow resistance is are most likely to occur during refueling operations. Other credible changes to flow resistance are slow developing phenomena and unlikely to change significantly between performances of the surveillance.

NuScale Response:

The last paragraph of the Surveillance Requirements section of the Bases for LCO 3.4.1 have been revised as requested by the staff.

Impact on DCA:

The Technical Specifications have been been revised as described in the response above and as shown in the markup provided in this response.

NuScale Nonproprietary

RCS Pressure, Temperature, and Flow Resistance CHF Limits B 3.4.1 BASES SURVEILLANCE REQUIREMENTS (continued) before exceeding 75% RTP which provides margin to safety analysis limits that are established at 100% RTP, and due to the low likelihood of a design basis event during the time allowed to perform testing.

The frequency requires this surveillance to be performed once after each refueling. The potential for iInadvertent changes that might impact on flow resistance areis most likely to occur during refueling operations. Other credible changes to flow resistance are slow developing phenomena and unlikely to change significantly between performances of the surveillance.

REFERENCES 1. FSAR Chapter 15, Transient and Accident Analyses.

NuScale B 3.4.1-5 Draft Revision 3.0

ML19010A409

Text

SUBJECT:

REFERENCE:

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