ML19067A024

Summary of Public Meeting with NuScale to Discuss an Apparent Inconsistency in the ITP and TS

ML19067A024
Person / Time
Site:	NuScale
Issue date:	03/18/2019
From:	Cayetano Santos NRC/NRO/DLSE/LB1
To:	Samson Lee NRC/NRO/DLSE/LB1
Santos C/nro/415-7270
References
Download: ML19067A024 (6)

Text

March 18, 2019 MEMORANDUM TO: Samuel S. Lee, Chief Licensing Branch 1 Division of Licensing, Siting, and Environmental Analysis Office of New Reactors FROM: Cayetano Santos Jr., Project Manager /RA/

Licensing Branch 1 Division of Licensing, Siting, and Environmental Analysis Office of New Reactors

SUMMARY

OF THE MARCH 6, 2019, PUBLIC TELECONFERENCE REGARDING AN APPARENT INCONSISTENCY BETWEEN THE INITIAL TEST PROGRAM AND TECHNICAL SPECIFICATIONS IN NUSCALE POWER LLCS DESIGN CERTIFICATION APPLICATION On March 6, 2019, a Category 1 public teleconference was held between the U.S. Nuclear Regulatory Commission (NRC) staff and NuScale Power, LLC (NuScale). The purpose of the teleconference was to discuss an apparent inconsistency between the initial test program and technical specifications. The meeting notice was posted on the NRC website and is also in the NRCs Agencywide Documents Access and Management System (ADAMS) under Accession Number ML19064A798. Enclosure 1 captures the summary of topics discussed during this teleconference. The Meeting Agenda and List of Attendees are included in Enclosures 2 and 3, respectively.

Docket No.52-048

Enclosures:

As stated cc w/encl.: DC NuScale Power, LLC Listserv CONTACT: Cayetano Santos Jr., NRO/DLSE 301-415-7270

ML19067A024 *via email NRO-002 OFFICE DLSE/LB1:PM DLSE/LB1:LA DLSE/LB1:PM NAME CSantos CSmith

• CSantos (signed)

DATE 03/18/2019 03/13/2019 03/18/2019 Meeting Summary March 6, 2019 PUBLIC TELECONFERENCE REGARDING AN APPARENT INCONSISTENCY BETWEEN THE INITIAL TEST PROGRAM AND TECHNICAL SPECIFICATIONS IN NUSCALE POWER LLCS DESIGN CERTIFICATION APPLICATION On February 28, 2019, the staff provided NuScale with the following discussion topic regarding various leakage values in the technical specifications (TS), the initial test program (ITP), and inspections, tests, analyses, and acceptance criteria (ITAAC) for the containment evacuation system (CES):

In the initial plant test program Table 14.2-41 for Containment Evacuation System (CES), Test # 41-3 verifies CES RCS leakage detection and Test # 41-4 verifies CES leakage detection system to support leakage-before-break (LBB) leakage detection. The acceptance criterion of leakage rate of one gpm within one hour is specified for both tests. Similarly, in the ITAAC Table 2.3-1 for CES, the acceptance criterion of leakage rate of one gpm within one hour is specified. However, LCO 3.4.5 item (b) specifies a criterion of 0.5 gpm for RCS unidentified leakage, and LCO 3.7.3 specifies a criterion of 1.5 gallons per hour (0.025 gpm) for secondary piping leakage to support LBB application. There seems to be an inconsistency between TS-required leakage limits and the acceptance criterion specified in the ITP and ITAAC. The criterion of one gpm within one hour leakage capability may not ensure the detection of 0.025 gpm. The applicant is requested to revise the ITP and ITAAC to address the inconsistency.

On March 6, 2019, the staff discussed this apparent ITP-TS consistency issue with NuScale.

The applicant stated that there is no discrepancy between the acceptance criteria in the ITP and ITAAC and the TS limiting condition for operation (LCO) leakage limits. The CES leak detection acceptance criterion in the ITP and ITAAC is one gallon per minute (gpm) within one hour, and this value is based on guidance in Regulatory Guide 1.45, Guidance on Monitoring and Responding to Reactor Coolant System Leakage. The 0.5 gpm limit on reactor coolant system (RCS) unidentified leakage of LCO 3.4.5 is verified by performing Surveillance Requirement (SR) 3.4.5.1, which is an RCS water inventory balance, once every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 1.5 gallons per hour (gph) limit on leakage through in-containment secondary system pipe walls of LCO 3.7.3 is also verified by performing SR 3.4.5.1 as described in the proposed Bases for SR 3.7.3.1. The in-containment primary and secondary system leakage is determined by performing an RCS water inventory balance, which includes using data from the CES leakage detection instrumentation channels for CES condensate and CES inlet pressure. NuScale added that there is no requirement to instantaneously measure 1.5 gph; rather, the secondary leakage determination at the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> frequency of SR 3.7.3.1 verifies whether LCO 3.7.3 is met.

NuScale stated that the ITAAC is verified by tests done during the ITP. NuScale noted that Revision 2 of Design Certification Application Part 2, Tier 2, FSAR Section 5.2.5.1 cites the minimum detectable leakage rate of 0.05 gpm for the CES condensate and CES inlet pressure channels. This capability is verified during the Channel Calibrations required by SR 3.4.7.6 and SR 3.4.7.7, respectively, but is not required to be verified by the ITP.

Enclosure 1

The staff stated that the CES condensate and CES inlet pressure channel sensitivity does not support verifying leakage is within the limits of LCO 3.4.5 and LCO 3.7.3. NuScale responded that the objective of CES Test #41-4 is to verify that the CES condensate and CES inlet pressure channels are each functioning as designed by meeting the ITP acceptance criterion of detecting a leak of one gpm within one hour.

There was an opportunity for public comments. No public comments were received.

Meeting Agenda March 6, 2019 3:30 p.m. - 4:00 p.m.

The purpose of this teleconference was for the U.S. Nuclear Regulatory Commission (NRC) staff to discuss an apparent inconsistency between the initial test program and technical specifications.

Time Topic Speaker 3:30 p.m. - 3:35 p.m. Introductions All Discussion of apparent inconsistency 3:35 p.m. - 3:55 p.m. between the initial test program and NRC/NuScale technical specifications 3:55 p.m. - 4:00 p.m. Public Comments Public 4:00 p.m. Adjourn All Enclosure 2

List of Attendees March 6, 2019 3:30 p.m. - 4:00 p.m.

Name Organization Craig Harbuck U.S. Nuclear Regulatory Commission (NRC)

Chang Li NRC Cayetano Santos NRC Spain Abney NuScale Power, LLC (NuScale)

Edan Engstrom NuScale Carrie Fosaaen NuScale Karl Gross NuScale Nadja Joergensen NuScale Chris Maxwell NuScale Mike Melton NuScale Enclosure 3