ML19072A287

LLC Supplemental Response to NRC Request for Additional Information No. 157 (Erai No. 9033) on the NuScale Design Certification Application

ML19072A287
Person / Time
Site:	NuScale
Issue date:	03/13/2019
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
References
RAIO-0319-64840
Download: ML19072A287 (6)

Text

RAIO-0319-64840 March 13, 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 Supplemental Response to NRC Request for Additional Information No. 157 (eRAI No. 9033) on the NuScale Design Certification Application

REFERENCES:

1. U.S. Nuclear Regulatory Commission, "Request for Additional Information No. 157 (eRAI No. 9033)," dated August 08, 2017

2. NuScale Power, LLC Response to NRC "Request for Additional Information No. 157 (eRAI No.9033)," dated September 14, 2017

3. NuScale Power, LLC Supplemental Response to NRC "Request for Additional Information No. 157 (eRAI No. 9033)," dated March 20, 2018 The purpose of this letter is to provide the NuScale Power, LLC (NuScale) supplemental response to the referenced NRC Request for Additional Information (RAI).

The Enclosure to this letter contains NuScale's supplemental response to the following RAI Question from NRC eRAI No. 9033:

16-12 This letter and the enclosed response make no new regulatory commitments and no revisions to any existing regulatory commitments.

If you have any questions on this response, please contact Carrie Fosaaen at 541-452-7126 or at cfosaaen@nuscalepower.com.

Sincerely, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution: Gregory Cranston, NRC, OWFN-8H12 Samuel Lee, NRC, OWFN-8H12 Getachew Tesfaye, NRC, OWFN-8H12 : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9033 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0319-64840 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9033 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.: 9033 Date of RAI Issue: 08/08/2017 NRC Question No.: 16-12 Paragraph (a)(11) of 10 CFR 52.47 and paragraph (a)(30) of 10 CFR 52.79 state that a design certification (DC) applicant and a combined license (COL) applicant, respectively, are to propose technical specifications (TS) prepared in accordance with 10 CFR 50.36 and 50.36a.

10 CFR 50.36 sets forth requirements for TS to be included as part of the operating license for a nuclear power facility. The model standard technical specifications (STS) in the following documents provide NRC guidance on format and content of TS as acceptable means to meet 10 CFR 50.36 requirements. These documents may be accessed using the Agencywide Documents Access and Management Systems (ADAMS) by their accession numbers.

NUREG-1431, STS Westinghouse Plants, Revision 4 (ADAMS Accession Nos.

ML12100A222 and ML12100A228)

NUREG-1432, STS Combustion Engineering Plants, Revision 4 (ADAMS Accession Nos. ML12102A165 and ML12102A169)

NUREG-2194, STS Westinghouse Advanced Passive 1000 (AP1000) Plants, Revision 0 (ADAMS Accession No. ML16111A132)

The NRC staff needs to evaluate technical differences in the proposed generic TS (GTS) from applicable provisions in these documents, which are referenced by the DC applicant in Design Control Document (DCD) Tier 2, Section 16.1, and the docketed rationale for each difference because conformance to STS provisions is used in the safety review as the initial point of guidance for evaluating the adequacy of the GTS to ensure adequate protection of public health and safety, and the completeness and accuracy of the GTS Bases.

In the Bases for LCO 3.0.5, which are apparently based on the markup of the Bases for LCO 3.0.5 in the Westinghouse STS (NUREG-1431, Revision 4) in TSTF-529, Revision 4, the NuScale Nonproprietary

third and fourth paragraphs are worded differently than the markup of the third and fourth paragraphs of the Bases for LCO 3.0.5 in the Westinghouse STS in TSTF-529, as follows.

In the third paragraph, the generic TS uses RCS pressure boundary leakage while the STS uses RCS Pressure Isolation Valve (PIV) leakage, as follows Third paragraph of generic TS LCO 3.0.5 Bases:

An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) pressure boundary leakage in order to perform testing to demonstrate that RCS pressure boundary leakage is now within limit.

Third paragraph of STS LCO 3.0.5 Bases:

An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.

In the fourth paragraph, the generic TS Bases omit the STS paragraphs first sentence, which states:

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose.

The applicant is requested to provide a justification for each of these differences.

NuScale Response:

At a public meeting on November 6, 2018 the staff provided the following clarification regarding RAI 9033-16-12:

As a part of adopting TSTF-529, the third paragraph of the Bases for LCO 3.0.5, was modified to reflect the NuScale design, which lacks RCS pressure isolation valves (PIVs). In a supplemental response (ML18079B134) to RAI 157-9033, Question 16-12, NuScale Nonproprietary

the applicant stated there are eight CVCS isolation valves, which are specified to be operable by LCO 3.4.6:

o CVC-ISV-0323 Pressurizer Spray Line Outboard Isolation Valve o CVC-ISV-0325 Pressurizer Spray Line Inboard Isolation Valve o CVC-ISV-0329 CVCS Injection Outboard Isolation Valve o CVC-ISV-0331 CVCS Injection Inboard Isolation Valve o CVC-ISV-0334 CVCS Discharge Inboard Isolation Valve o CVC-ISV-0336 CVCS Discharge Outboard Isolation Valve o CVC-ISV-0401 RPV Vent Inboard Isolation Valve o CVC-ISV-0403 RPV Vent Outboard Isolation Valve The containment isolation function of these valves is also required to be operable by LCO 3.6.2. The problem with the LCO 3.0.5 Bases referencing RCPB leakage isolation is that no LCO 3.4.5 Action explicitly requires isolation of leakage by closing a valve.

Although LCO 3.4.6 does not address RCPB leakage, it does address CIV leakage for systems connected to the RCS, such as the four CVCS flowpath lines listed above.

Therefore, the LCO 3.0.5 Bases discussion ought to reference a CVCS isolation valve (CIV) inoperability requiring isolation, possibly because of valve leakage. The staff suggests the following modification of the subject LCO 3.0.5 Bases paragraph:

An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a CVCS flowpath with excessive Reactor Coolant System (RCS) pressure boundary leakage an inoperable CVCS isolation valve in order to perform testing to demonstrate that RCS pressure boundary leakage the isolation valve is now operablewithin limit.

NuScale Supplemental Response The Bases for LCO 3.0.5 have been modified as proposed 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

LCO Applicability B 3.0 BASES LCO 3.0.5 LCO 3.0.5 establishes the allowance of restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance. LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.

An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a chemical and volume control system (CVCS) flowpath with an inoperable CVCS isolation valveexcessive Reactor Coolant System (RCS) pressure boundary eakage in order to perform testing to demonstrate that RCS pressure boundary leakagethe isolation valve is now within limitOPERABLE.

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel. Examples of demonstrating the OPERABILITY of other equipment are taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system, or 2) to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.

NuScale B 3.0-8 Draft Revision 3.0