ML19210E146

LLC Supplemental Response to NRC Request for Additional Information No. 197 (Erai No. 9051) on the NuScale Design Certification Application

ML19210E146
Person / Time
Site:	NuScale
Issue date:	07/29/2019
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
References
RAIO-0719-66473
Download: ML19210E146 (26)

Text

RAIO-0719-66473 July 29, 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. 197 (eRAI No. 9051) on the NuScale Design Certification Application

REFERENCES:

1. U.S. Nuclear Regulatory Commission, "Request for Additional Information No. 197 (eRAI No. 9051)," dated August 25, 2017

2. NuScale Power, LLC Response to NRC "Request for Additional Information No. 197 (eRAI No.9051)," dated October 18, 2017

3. NuScale Power, LLC Supplemental Response to "NRC Request for Additional Information No. 197 (eRAI No. 9051)" dated December 27, 2018

4. NuScale Power, LLC Supplemental Response to "NRC Request for Additional Information No. 197 (eRAI No. 9051)" dated July 10, 2019 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. 9051:

16-28 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 Rebecca Norris at 541-602-1260 or at rnorris@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 Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0719-66473 : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9051 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0719-66473 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9051 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.: 9051 Date of RAI Issue: 08/25/2017 NRC Question No.: 16-28 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 (W-STS) (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 NuScale Nonproprietary

and safety, and the completeness and accuracy of the GTS Bases.

The staff reviewed Table C-1, Technical Specification Task Force traveler evaluation, of Technical Specifications Regulatory Conformance and Development report, TR-1116-52011-NP, Revision 0. Regarding the applicants evaluation of unapproved traveler TSTF-541, Add Exceptions to Surveillance Requirements When the Safety Function is Being Performed, Revision 0, which is currently under staff review, the staff noted an apparent deficiency in the applicants evaluation.

In the Discussion field of Table C-1 the applicant states:

The passive NuScale design includes a limited number of valves with potential for the addressed condition to exist. Exceptions consistent with the traveler were incorporated into the surveillance requirements of 3.6.2[, Containment Isolation Valves.]

Revision 0 of GTS SR 3.6.2.3 states (emphasis added):

Verify each automatic containment isolation valve that is not locked, sealed, or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.

This surveillance statement does not include a bracketed Note proposed by the traveler for similar valve actuation SRs; this Note states:

[-------------------------------------NOTE------------------------------------

Not required to be met for automatic valves that are locked, sealed or otherwise secured in the actuated position.

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]

However, the Bases for GTS SR 3.6.2.3 does include a similar statement (emphasis added):

The Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls.

Compared to the travelers proposed Note, the GTS Bases sentence uses the phrases not required for valves instead of not required to be met for automatic valves; and required position instead of actuated position. The Bases sentence also includes under administrative controls. Besides these phrasing differences, the staff also notes that the scope of the traveler does not address automatic containment isolation valves.

The staff also notes that the GTS include the following SRs for verifying [automatic] valve actuation on an actual or simulated [actuation] signal, to the position stated, in accordance NuScale Nonproprietary

with the Surveillance Frequency Control Program:

SR 3.1.9.1 CVCS demineralized water isolation valves isolation position SR 3.4.6.2 CVCS automatic valves isolation position SR 3.5.1.1 ECCS RVVs and RRVs open position SR 3.6.2.3 automatic containment isolation valves isolation position Since TSTF-541, Revision 0, is not yet approved by the staff, and considering the above observations, the staff cannot determine whether the proposed application of the intent of the traveler is needed for the NuScale GTS. As of May 28, 2017, the Technical Specifications Branch staff was to schedule a date for providing the TSTF feedback on a white paper regarding TSTF-541 related issues. The TSTF had submitted this white paper to the NRC on January 12, 2017.

The staff compared the phrasing of SR 3.6.2.3 to that of W-STS SR 3.6.3.8, and found them identical. It does not appear that the applicants consideration of TSTF-541 introduced any deviation in the GTS from Revision 4 of the W-STS. However, the associated GTS Bases do depart from the W-STS Bases as indicated by the following markup of the W-STS Bases for SR 3.6.3.8:

SR 3.6.3.8 Automatic containment isolation valves close on a containment isolation signal to prevent minimize leakage of radioactive material fission products from containment and to maintain required RCS inventory following a DBA. This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation an actual or simulated actuation signal. The is surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. [ The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components NuScale Nonproprietary

usually pass this Surveillance when performed at the [18] month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

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REVIEWERS NOTE-----

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

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]

The above deviations from the W-STS Bases for SR 3.6.3.8 appear unrelated to TSTF-541. The applicant is requested to revise the evaluation of TSTF-541 in Table C-1 to indicate that it is not applicable to automatic valve actuation surveillances in the GTS.

NuScale Response:

Supplemental NRC Clarifying Questions Discussed During Public Meeting on July 24, 2019 The staff identified concerns with exceptions to meeting the safety-function-demonstration SRs for certain automatic valves, when the valve is in its actuated position.

NuScale Nonproprietary

Supplemental Response Discussions of the NuScale design and reasons for the exemptions proposed were conducted.

Staff clarification narrowed the concern to allowances permitting placement of the components in the non-safety position in accordance with 'administrative controls.' The allowances of concern were in Surveillance Requirements or Notes applicable to Surveillance Requirements.

The exemptions for operating the equipment in accordance with administrative controls were removed from the Surveillance Requirements and associated Notes.

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

MPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.4 -------------------------------NOTE-----------------------------

Neutron detectors are excluded from the CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION in accordance In accordance with with the Setpoint Programon each required channel the Surveillance listed in Table 3.3.1 1. Frequency Control Program SR 3.3.1.5 Perform CHANNEL CALIBRATION on each In accordance with required Class 1E isolation device.Verify associated the Surveillance Class 1E isolation devices are OPERABLE. Frequency Control Program.

NuScale 3.3.1-7 Draft Revision 3.0

Reactor Trip System Logic and Actuation 3.3.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.2.1 NOTE Not required to be met for reactor trip breakers that are open.

Perform ACTUATION LOGIC TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.2 NOTE Not required to be met for reactor trip breakers that are open.

Verify requiredACTUATION RESPONSE TIME In accordance with response time is within limits. The ACTUATION the Surveillance RESPONSE TIME is combined with the allocated Frequency Control MPS digital time response and the CHANNEL Program RESPONSE TIME to determine and verify the TOTAL RESPONSE TIME.

SR 3.3.2.3 NOTE Not required to be met for Class 1E isolation devices that have isolated 1E circuits from non 1E power.

Perform CHANNEL CALIBRATION on each In accordance with Class 1E isolation device.Verify associated Class 1E the Surveillance isolation devices are OPERABLE. Frequency Control Program SR 3.3.2.4 NOTE Not required to be met for reactor trip breakers that are open.

Verify each RTB actuates to the open position on an In accordance with actual or simulated actuation signal. the Surveillance Frequency Control Program NuScale 3.3.2-2 Draft Revision 3.0

ESFAS Logic and Actuation 3.3.3 ACTIONS (continued)

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

Action B.1 and Heater(s) may be referenced in energizedPressurizer heater Table 3.3.3-1. breakers may be closed intermittently under manual OR administrative controls.

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6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Both divisions of Pressurizer Heater trip Open pressurizer heater actuationde energization breakers.De energize fFunction inoperable. Pressurizer Heaters.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform ACTUATION LOGIC TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.3.2 NOTE Not required to be met for pressurizer heater breakers that are open or closed under manual control.

Verify required pressurizer heater breaker response In accordance with timeACTUATION RESPONSE TIME is within limits. the Surveillance The ACTUATION RESPONSE TIME is combined Frequency Control with the allocated MPS digital time response and the Program CHANNEL RESPONSE TIME to determine and verify the TOTAL RESPONSE TIME.

NuScale 3.3.3-4 Draft Revision 3.0

ESFAS Logic and Actuation 3.3.3 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.3.3 NOTE Not required to be met for Class 1E isolation devices that have isolated 1E circuits from non 1E power.

Perform CHANNEL CALIBRATION on each In accordance with Class 1E isolation deviceVerify associated Class 1E the Surveillance isolation devices are OPERABLE. Frequency Control Program SR 3.3.3.4 NOTE Not required to be met for pressurizer heater trip breakers that are open or breakers closed under administrative controls.

Verify each pressurizer heater trip breaker (PHTB) In accordance with actuates to the open position on an actual or the Surveillance simulated actuation signal. Frequency Control Program NuScale 3.3.3-5 Draft Revision 3.0

Chemical and Volume Control System Isolation Valves 3.4.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify [required] valves accumulator pressures are In accordance with within limits. the Surveillance Frequency Control Program.

SR 3.4.6.2 NOTE Not required to be met for valves that are closed or open under administrative controls.

Verify the required isolation timeACTUATION In accordance with RESPONSE TIME of each automatic power operated the INSERVICE CVCS valve is within limits. The ACTUATION TESTING RESPONSE TIME is combined with the allocated PROGRAM MPS digital time response and the CHANNEL RESPONSE TIME to determine and verify the TOTAL RESPONSE TIME.

SR 3.4.6.3 Verify each automatic CVCS valve that is not locked, In accordance with sealed, or otherwise secured in position, actuates to the Surveillance the isolation position on an actual or simulated Frequency Control actuation signal except for valves that are open under Program administrative controls.

NuScale 3.4.6-3 Draft Revision 3.0

Containment Isolation Valves 3.6.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1 Verify [required] valves accumulator pressures are In accordance with within limits. the Surveillance Frequency Control Program SR 3.6.2.2 ---------------------------------NOTE------------------------------

Valves and blind flanges in high radiation areas may be verified by use of administrative means.

Verify each containment isolation manual valve and In accordance with blind flange that is located outside containment and the Surveillance not locked, sealed, or otherwise secured and is Frequency Control required to be closed during accident conditions is Program closed, except for containment isolation valves that are open under administrative controls.

SR 3.6.2.3 Verify the isolation timeACTUATION RESPONSE In accordance with TIME of each automatic containment isolation valve the INSERVICE is within limits except for valves that are open under TESTING administrative controls. The ACTUATION PROGRAM RESPONSE TIME is combined with the allocated MPS digital time response and the CHANNEL RESPONSE TIME to determine and verify the TOTAL RESPONSE TIME.

SR 3.6.2.4 Verify each automatic containment isolation valve In accordance with that is not locked, sealed, or otherwise secured in the Surveillance position, actuates to the isolation position on an Frequency Control actual or simulated actuation signal except for valves Program that are open under administrative controls.

SR 3.6.2.5 Verify the combined leakage rate for all containment In accordance with bypass leakage paths is 0.6 La when pressurized the Containment to 951 psia. Leakage Rate Testing Program NuScale 3.6.2-3 Draft Revision 3.0

Boron Dilution Control B 3.1.9 BASES SURVEILLANCE SR 3.1.9.1 REQUIREMENTS This Surveillance verifies that CVCS makeup pump demineralized water flow path is configured to ensure that the maximum dilution flow rate that can exist during makeup pump operation remains within the limits specified in the COLR. The Surveillance accomplishes this by assuring that when the maximum demineralized water flowrate is restricted to that of a single CVCS makeup pump, at least one closed manual or one closed and de-activated automatic valve is correctly configured, or verifying that the power supply has been removed from one CVCS makeup pump. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.1.9.2 This Surveillance demonstrates that each automatic CVCS demineralized water isolation valve actuates to the isolated position on an actual or simulated actuation signal. This Surveillance is not required for automatic valves that are locked, sealed, or otherwise controlled under administrative controls. This means the Surveillance does not apply if the valve is open under administrative controls that assure they can be promptly closed. This exception is acceptable because of the slowly changing conditions and responses in the design basis events that the automatic isolation protects.

In addition to this Surveillance, the automatic actuation logic is tested as part of Engineered Safety Features Actuation System Actuation and Logic testing, and valve performance is monitored as part of the INSERVICE TESTING PROGRAM.

The Surveillance Frequency for this test is controlled under the Surveillance Frequency Control Program.

SR 3.1.9.3 This Surveillance ensures that the boric acid supply is not a potential source of dilution water.

The Surveillance is applicable to the boric acid storage tank and the boric acid batch tank when the tank is aligned to supply boric acid to the CVCS. The batch tank is routinely isolated from the CVCS during preparation of boric acid solution, and either tank may be used as a source of boric acid or isolated from use during normal operations.

Condition B permits indefinite operation with a source not meeting the COLR concentration limits with the source isolated from the CVCS.

NuScale B 3.1.9-5 Draft Revision 3.0

Module Protection System Instrumentation B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued) must enter the Condition for the particular MPS Functions 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.

Interlocks and permissives are required to support the Function's OPERABILITY and are addressed by this CHANNEL CALIBRATION.

This is accomplished by ensuring the channels are calibrated properly in accordance with the SP. If the interlock or permissive is not functioning as designed, the condition is entered into the Corrective Action Program and appropriate OPERABILITY evaluations are performed for the affected Function(s). The affected Function's OPERABILITY can be met if the interlock is manually enforced to properly enable the affected Function.

When an interlock or permissive is not supporting the associated Function's OPERABILITY at the existing plant conditions, the affected Function's channels must be declared inoperable and appropriate ACTIONS taken.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.5 SR 3.3.1.5 is the performance of a CHANNEL CALIBRATION of the Class 1E isolation devices, as described in SR 3.3.1.4.

Class 1E isolation devices ensure that electrical power to the associated MPS circuitry and logic will not adversely affect the ability of the system to perform its safety functions. The devices de-energize and isolate the MPS components if such a condition is detected. This surveillance verifies the setpoints and functions of the isolation devices including associated alarms and indications by performing a CHANNEL CALIBRATION of required Class 1E isolation devices. The overcurrent and undervoltage setpoints of the Class 1E isolation devices are established and controlled in accordance with the Setpoint Program.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

NuScale B 3.3.1-61 Draft Revision 3.0

RTS Logic and Actuation B 3.3.2 BASES SURVEILLANCE SR 3.3.2.1 REQUIREMENTS An ACTUATION LOGIC TEST on each RTS Logic division is performed to ensure the division will perform its intended function when needed.

These tests verify that the RTS is capable of performing its intended function, from SFM input signals to the SVM through actuation of the RTBs. A Note is provided indicating that the SR does not need to be met for reactor trip breakers that are open. This allowance permits continued operation when a trip breaker may not be able to satisfy the requirements of the ACTUATION LOGIC TEST but is already open. When a reactor trip breaker is open it has performed its safety function.

MPS testing from the input sensors to the SVMs is addressed by surveillance requirements specified in LCO 3.3.1, Module Protection System (MPS) Instrumentation. The RTS lLogic and aActuation circuitry functional testing is accomplished with continuous system self-testing features on the SVMs and EIMs and the communication between them.

The self-testing features are designed to perform complete functional testing of all circuits on the SVM and EIM, with the exception of the actuation and priority logic (APL) circuitry. The self-testing includes testing of the voting and interlock/permissive logic functions. The built-in self-testing will report a failure to the operator and place the SVM or EIM in a fail-safe state.

The only portion of the RTS lLogic and aActuation circuitry that is not self-tested is the APL. The manual actuation switches, enable nonsafety control switches, and operating bypass switches do not include self-testing features. The manual actuation switches are addressed by surveillance requirements specified in LCO 3.3.4, "Manual Actuation Functions."

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

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

NuScale B 3.3.2-4 Draft Revision 3.0

RTS Logic and Actuation B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.2 This SR measuresensures that the ACTUATION RESPONSE TIMEresponse time of the RTS divisions are verified to be less than or equal to the maximum values assumed in the safety analysis. The ACTUATION RESPONSE TIME is combined with the allocated MPS digital time response and the CHANNEL RESPONSE TIME to determine and verify the TOTAL RESPONSE TIME is less than or equal to the maximum values assumed in the safety analysis. Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the process variable exceeds the trip setpoint value at the sensor to the time at which the RTBs open. Total TOTAL RESPONSE TIMEresponse time may be verified by any series of sequential, overlapping, or total divisionchannel measurements.

Response times of the sensorsCHANNEL RESPONSE TIMES are tested in accordance with LCO 3.3.1. The maximum digital time response is described in the FSAR. This SR encompasses the ACTUATION RESPONSE TIMEresponse time of the RTS division from the output of the equipment interface modules until the RTBs are open.

A note provides an allowance for the SR so that it does not need to be met for reactor trip breakers that are open. This allowance permits continued operation when a trip breaker may not be able to satisfy the requirements of the SR but is already open. When a reactor trip breaker is open it has performed its safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

NuScale B 3.3.2-5 Draft Revision 3.0

RTS Logic and Actuation B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.3 SR 3.3.2.3 is the performance of a CHANNEL CALIBRATION of the Class 1E isolation devices, as described in SR 3.3.1.4.

A note provides an allowance for the SR so that it does not need to be met for class 1E isolation devices that have isolated the 1E circuits from the non 1E power. This allowance permits continued operation when an isolation device that may not be able to satisfy the requirements of the SR but that has already performed its safety function.

Class 1E isolation devices ensure that electrical power to the associated MPS circuitry and logic will not adversely affect the ability of the system to perform its safety function. The devices de-energize and isolate the MPS components if such a condition is detected. This surveillance verifies the setpoints and functions of the isolation devices including associated alarms and indications by performing a CHANNEL CALIBRATION of required Class 1E isolation devices.

The overcurrent and undervoltage setpoints of the Class 1E isolation devices are established and controlled in accordance with the Setpoint Program.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

NuScale B 3.3.2-6 Draft Revision 3.0

RTS Logic and Actuation B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.4 SR 3.3.2.4 verifies the reactor trip breaker (RTB) actuates to the open position on an actual or simulated trip signal. This test verifies OPERABILITY by actuation of the end devices.

A Note is provided indicating that the SR does not need to be met for reactor trip breakers that are open. This allowance permits continued operation when a trip breaker may not be able to satisfy the requirements of the SR but is already open. When a reactor trip breaker is open it has performed its safety function.

The RTB test verifies the under voltage trip mechanism opens the breaker. Each RTB in a division is tested separately to minimize the possibility of an inadvertent reactor trip.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. FSAR, Section 7.2.

NuScale B 3.3.2-7 Draft Revision 3.0

ESFAS Logic and Actuation B 3.3.3 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.3.2 This SR measuresensures that the pressurizer heater breaker opening response timesACTUATION RESPONSE TIMES. are verified to be less than or equal to the maximum values assumed in the safety analysis. The ACTUATION RESPONSE TIME is combined with the allocated MPS digital time response and the CHANNEL RESPONSE TIME to determine and verify the TOTAL RESPONSE TIME is less than or equal to the maximum values assumed in the safety analysis. Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the process variable exceeds the trip setpoint value at the sensor to the time at which ESF component actuates. Total response timeTOTAL RESPONSE TIME may be verified by any series of sequential, overlapping, or total divisionchannel measurements.

Response times of the sensorsCHANNEL RESPONSE TIMES are tested in accordance with LCO 3.3.1. The maximum digital time response is described in the FSAR. This SR encompasses the response time of the ESFAS from the output of the equipment interface modules to the loss of voltage at the output of the pressurizer heater breaker.

The response timeACTUATION RESPONSE TIME of valves actuated by the ESFAS are verified in accordance with the IST program, and LCO 3.4.6, "Chemical and Volume Control System Isolation Valves," LCO 3.4.10, "LTOP Valves," LCO 3.5.1, "ECCS," LCO 3.5.2, "DHRS," LCO 3.6.2, "Containment Isolation Valves," LCO 3.7.1, "MSIVs," and LCO 3.7.2, "Feedwater Isolation."

A note provides an allowance for the SR so that it does not need to be met for pressurizer heater breakers that are open in their actuated position. This allowance permits continued operation when a pressurizer heater trip breaker is open because it has performed its safety function.

The note also allows intermittent closure of the breakers under manual control when the SR is not met because the slowly occurring nature of the phenomena the automatic heater trip breakers mitigate.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

NuScale B 3.3.3-11 Draft Revision 3.0

ESFAS Logic and Actuation B 3.3.3 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.3.3 SR 3.3.3.3 is the performance of a CHANNEL CALIBRATION of the Class 1E isolation devices, as described in SR 3.3.1.4.

A note provides an allowance for the SR so that it does not need to be met for class 1E isolation devices that have isolated the 1E circuits from the non 1E power. This allowance permits continued operation when an isolation device that may not be able to satisfy the requirements of the SR but that has already performed its safety function.

Class 1E isolation devices ensure that electrical power to the associated MPS circuitry and logic will not adversely affect the ability of the system to perform its safety functions. The devices de-energize and isolate the MPS components if such a condition is detected. This surveillance verifies the setpoints and functions of the isolation devices including associated alarms and indications by performing a CHANNEL CALIBRATION of required Class 1E isolation devices. The overcurrent and undervoltage setpoints of the Class 1E isolation devices are established and controlled in accordance with the Setpoint Program.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.3.4 SR 3.3.3.4 verifies the pressurizer heater trip breaker (PHTB) actuates to the open position on an actual or simulated trip signal on each pressurizer heater breakerPHTB. This test verifies OPERABILITY by actuation of the end devices. The pressurizer heater breakerPHTB test verifies the under voltage trip mechanism opens the breaker. A Note is provided indicating that the SR does not need to be met for pressurizer heater trip breakers that are open or closed under administrative control. This allowance permits continued operation when a trip breaker may not be able to satisfy the requirements of the SR but is already open or can be quickly opened by administrative means. When a pressurizer heater trip breaker is open it has performed its safety function. This is acceptable because of the slowly occurring nature of the phenomena the automatic heater trip breakers mitigate.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

NuScale B 3.3.3-12 Draft Revision 3.0

CVCS Isolation Valves B 3.4.6 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.6.2 Verifying that the isolation ACTUATION RESPONSE TIMEtime of each automatic power operated CVCS isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time test ensures that the valve will isolate in a time period less than or equal to that assumed in the safety analysis.The ACTUATION RESPONSE TIME is combined with the allocated MPS digital time response and the CHANNEL RESPONSE TIME to determine and verify the TOTAL RESPONSE TIME is less than or equal to the maximum values assumed in the safety analysis. Isolation time is measured from output of the module protection system equipment interface module until the valves are isolated.

A Note is provided that indicates that the SR is not required to be met when valves are closed or open under administrative controls. This is acceptable because of the slowly occurring nature of the design basis events the CVCS isolation function mitigates. The Surveillance Frequency of this SR is in accordance with the INSERVICE TESTING PROGRAM.

SR 3.4.6.3 This Surveillance demonstrates that each automatic CVCS isolation valve actuates to the isolated position on an actual or simulated actuation signal. This Surveillance is not required for valves that are locked sealed, or otherwise secured in the isolated position under administrative controls. The actuation logic is tested as part of Engineered Safety Features Actuation System Actuation and Logic testing. An exception to the SR is provided for valves that are opened under administrative controls. This is acceptable because of the slowly occurring nature of the design basis events the CVCS isolation function mitigates.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

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

NuScale B 3.4.6-5 Draft Revision 3.0

Containment Isolation Valves B 3.6.2 BASES SURVEILLANCE SR 3.6.2.1 REQUIREMENTS This SR [applies to valves with actuators that incorporate pressurized accumulators as a source of stored energy. The SR] verifies adequate pressure in the accumulators required for containment isolation valve OPERABILITY. The pressure limits required for OPERABILITY, including consideration of temperature effects on those limits, applicable to the valve accumulators are established and maintained in accordance with the INSERVICE TESTING PROGRAM. The Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.2.2 This SR requires verification that each manual containment isolation valve and blind flange located outside containment, and not locked, sealed, or otherwise secured in position, and required to be closed during accident conditions, is closed. The SR helps to ensure that post accident leakage of fission products outside the containment boundary is within design limits. This SR does not require any testing or device manipulation. Rather, it involves verification that those containment isolation devices outside containment and capable of being mispositioned are in the correct position.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time the valves are open. This SR does not apply to devices that are locked, sealed, or otherwise secured in the closed position, since these were verified to be in the correct position upon locking, sealing, or securing.

The Note applies to valves and blind flanges located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted in MODES 1, 2, and 3 with RCS hot temperature 200° F for ALARA reasons.

Therefore, the probability of misalignment of these containment isolation valves, since they have been verified to be in the proper position, is small.

NuScale B 3.6.2-6 Draft Revision 3.0

Containment Isolation Valves B 3.6.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.2.3 Verifying that the isolation timeACTUATION RESPONSE TIME of each automatic containment isolation valve is within the limits is required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analysis. The ACTUATION RESPONSE TIME is combined with the allocated MPS digital time response and the CHANNEL RESPONSE TIME to determine and verify the TOTAL RESPONSE TIME is less than or equal to the maximum values assumed in the safety analysis. Isolation timeACTUATION RESPONSE TIME is measured from output of the module protection system equipment interface module until the valves are isolated.

An exception to the SR is provided for valves that are open under administrative control.

The isolation time and Frequency of this SR are in accordance with the INSERVICE TESTING PROGRAM.

SR 3.6.2.4 Automatic containment isolation valves close on a containment isolation signal to minimize leakage of fission products from containment and to maintain required RCS inventory following a DBA. This SR ensures each automatic containment isolation valve will actuate to its isolation position on an actual or simulated actuation signal. The Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. An exception to the SR is also provided for valves that are open under administrative control.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

NuScale B 3.6.2-7 Draft Revision 3.0