ML19260G735

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Summary of Public Meeting with NuScale to Discuss Response to RAI 9681
ML19260G735
Person / Time
Site: NuScale
Issue date: 10/07/2019
From: Cayetano Santos
NRC/NRO/DLSE/LB1
To: Samson Lee
Office of New Reactors
Santos C, 415-7270
References
Download: ML19260G735 (9)


Text

October 7, 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

SUBJECT:

SUMMARY

OF THE SEPTEMBER 17, 2019, PUBLIC TELECONFERENCE REGARDING RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION NO. 9681 On September 17, 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 meeting was to discuss NuScales response to Request for Additional Information No.

9681. The meeting notice was posted on the NRC website and is also in the NRCs Agencywide Documents Access and Management System under Accession Number ML19217A108. The Meeting Summary is provided as Enclosure 1, which captures the summary of topics discussed. Enclosure 2 contains a list of discussion topics. The Meeting Agenda and List of Attendees are provided as Enclosures 3 and 4, respectively.

CONTACT: Cayetano Santos, Jr., NRO/DLSE 301-415-7270

S. Lee 2 Docket No.52-048

Enclosures:

1. Meeting Summary
2. Meeting Discussion Topics
3. Meeting Agenda
4. List of Attendees cc w/encl: DC NuScale Power, LLC Listserv

ML19260G735 *via email NRO-002 OFFICE DLSE/LB1:PM DLSE/LB1:LA DLSE/LB1:PM NAME CSantos MMoore* CSantos (signed)

DATE 10/07/2019 10/07/2019 10/07/2019 U.S. NUCLEAR REGULATORY COMMISSION PUBLIC TELECONFERENCE REGARDING RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION NO. 9681 MEETING

SUMMARY

September 17, 2019 On May 21, 2019, the U.S. Nuclear Regulatory Commission (NRC) staff issued Request for Additional Information (RAI) No. 9681 (ADAMS Accession No. ML19151A027) to NuScale Power, LLC (NuScale) based on its review of the inspections, tests, analyses, and acceptance criteria (ITAAC) and other Tier 1 information contained in Revision 2 of NuScales design certification application (ADAMS Accession No. ML18310A313). NuScale responded to this RAI on July 19, 2019 (ADAMS Accession No. ML19200A248). The purpose of this meeting was to discuss staffs review of the response to RAI No. 9681. To facilitate discussions, the staff provided NuScale with a list of specific comments and observations (Enclosure 2).

For most of the comments listed in Enclosure 2, NuScale stated that they understood the NRC staffs concern and would make the requested change:

  • Comment No. 1
  • Comment No. 2
  • Comment No. 4
  • Comment No. 5
  • Comment No. 6
  • Comment No. 7
  • Comment No. 8
  • Comment No. 9
  • Comment No. 11
  • Comment No. 12 The remaining comments were briefly discussed.

Regarding Comment No. 3, NuScale noted that the change requested by the NRC staff would clarify the scope and ensure consistent terminology among the design commitment (DC),

inspections, tests, analyses (ITA), and acceptance criteria (AC) for ITAAC No. 2 in Table 2.3-1, Containment Evacuation System ITAAC, but would then be inconsistent with the approach used for ITAAC No. 1 in that same table. Specifically, the AC for ITAAC No. 1 specifies that the Enclosure 1

CES [containment evacuation system] level instrumentation detects a level increase in the CES sample tank, whereas the DC and ITA do not identify the CES sample tank. The staff stated that it had no objection to revising ITAAC No. 1 in Table 2.3-1 to include the CES sample tank in the DC and ITA to ensure a consistent approach in the wording between ITAAC Nos. 1 and 2 in Table 2.3-1.

Regarding Comment No. 10, NuScale stated that another option for ensuring consistency in referencing Table 3.17-1, Radiation Monitoring - Automatic Actions for NuScale Power Modules 1 - 6, would be to remove BPDS (balance-of-plant drain system) from the last row under the column Variable Monitored. The staff responded that its preference would be to incorporate the change as described in Enclosure 2. NuScale agreed to make the change described in Enclosure 2 and stated that a corresponding change would also be made to Table 3.18-1, Radiation Monitoring - Automatic Actions for NuScale Power Modules 7 - 12.

NuScale concluded the meeting by stating that these revisions would be submitted to the NRC as a supplemental response to RAI No. 9681 or a unilateral change letter.

There was an opportunity for members of the public to provide comments and ask questions.

No comments or questions were received.

2

U.S. NUCLEAR REGULATORY COMMISSION STAFF OBSERVATIONS AND COMMENTS ON RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION NO. 9681 (For comments in which staff requests changes, NuScale is asked to make the requested change or show how the ITAAC comply with 10 CFR 52.47(b)(1))

Comment Table ITAAC Observation/Comment No. No. No.

Request for Additional Information (RAI) No. 9681 response added the language requested except for the phrase, "the 1 2.1-4 12 objectives of" in the DC. This phrase was included in the AC. The design commitment in Section 2.1 is also lacking this phrase.

The phrase "listed in Table 2.2-1" was added to the AC but it 2 2.2-3 1 appears to be in the wrong location. The wrong "system" appears to have been deleted in the AC.

Per RAI response, staff comment in the AC was not incorporated because The acceptance criteria were not revised to add pressure instrumentation. The acceptance criteria already specify 'CES inlet pressure instrumentation (PIT-1001/PIT-1019).' The AC is still unclear. Staff requests revised ITAAC language. DC - "The CES inlet pressure 3 2.3-1 2 instrumentation supports RCS leakage detection." ITA - "A test will be performed of the CES inlet pressure instrumentation." AC - "The CES inlet pressure instrumentation detects a pressure increase which correlates to a detection of an unidentified RCS leakage rate of one gpm within one hour."

There appears to be several cases in which the text for design commitments listed in Section 2.5.1 do not match DC text in 4 2.5-7 1 ITAAC table (see design commitments for 1i, viii, ix). The text for design commitments listed in Section 2.5.1 are listed in a different order than the DC in the ITAAC Table.

Response to RAI No. 9681 incorporates this as item number xiii in ITAAC #1 in Table 2.5-7. The DC uses the term separation channels. The AC uses the term "separation groups." Consistent terms should be used. Staff requests that the DC be revised to "The MPS is capable of performing 5 2.5-7 21 its safety-related functions when any one of its separation groups is out of service."

Enclosure 2

The DC is mathematically inconsistent with the AC because "does not exceed" and "is less than" do not mean the same thing. If the measured value equals the assumed value, then the DC is met, but the AC is not. Staff requests revised 6 3.1-2 1 ITAAC language. DC - "The air exfiltration out of the CRE is less than or equal to the assumptions used to size the CRHS inventory and supply flow rate." AC - "The air exfiltration measured by tracer gas testing is less than or equal to the CRE air infiltration rate assumed in the dose analysis."

There is a slight discrepancy between the DC in the ITAAC Table and the design commitment listed in Section 3.9.1. In the table the DC states "... CHRS automatically respond to the 7 3.9-2 2 high-radiation signals ... " whereas in Section 3.9.1 it states "...

CRHS automatically respond to the CRVS high radiation signals "

In the AC for other ITAAC (e.g., ITAAC #7 and #8 in Table 3.9-2), NuScale replaced "a" real or simulated signal with "the" 8 3.9-2 10 real or simulated signal. However, for this ITAAC this change was not made.

The change to Seismic Qualification Report was suggested by NRC staff in RAI No. 9681. The edit should have been applied throughout the ITAAC (i.e. 02.08.01 and the rest of 9 3.14-2 1 03.14.01) and was suggested to ensure consistency with ASME QME-1 terminology and to be clear in what the AC required.

This ITAAC refers to Table 3.17-1. In Table 3.17-1 "BPDS" 10 3.17-2 2 should be identified in the second row, under the column for "Variable Monitored."

In Table 14.3-2 the entry for ITAAC number 03.14.08 references Section 5.4.2 twice for the decay heat removal system; however, it is DCA Part 2, Tier 2, Section 5.4.3, that 11 14.3-2 covers the DHRS. Per the public meeting on September 4, 2019, staff understands that NuScale plans to move this ITAAC back to Table 2.8-2.

In Tables 2.8-1 and 14.3-3h, both titled Module Specific Mechanical and Electrical/I&C Equipment, under Control Rod 12 14.3-3h Drive System, Rod Position Indication (RPI) Coils it states there are 24 total, but should this be 32 total (16 control rod assemblies x 2 RPI trains/assembly)?

2

U.S. NUCLEAR REGULATORY COMMISSION PUBLIC TELECONFERENCE REGARDING RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION NO. 9681 MEETING AGENDA September 17, 2019 1:00 p.m. - 3:00 p.m.

The purpose of this teleconference was for the U.S. Nuclear Regulatory Commission (NRC) staff to discuss with NuScale Power, LLC (NuScale) the response to Request for Additional Information (RAI) No. 9681.

Time Topic Speaker 1:00 p.m. - 1:05 p.m. Introductions All Discussion of Response to RAI No.

1:05 p.m. - 2:45 p.m. NRC/NuScale 9681 2:45 p.m. - 3:00 p.m. Public Comments Public 3:00 p.m. Adjourn All Enclosure 3

U.S. NUCLEAR REGULATORY COMMISSION PUBLIC TELECONFERENCE REGARDING RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 9681 LIST OF ATTENDEES September 17, 2019 1:00 p.m. - 3:00 p.m.

Name Organization Cayetano Santos U.S. Nuclear Regulatory Commission (NRC)

Nicholas Hansing NRC Chang Li NRC Joseph Ashcraft NRC Dinesh Taneja NRC Ronald Lavera NRC Alexandra Siwy NRC Michael Spencer NRC Ann Paisner NRC Nadja Joergensen NuScale Power, LLC (NuScale)

Chris Maxwell NuScale Edan Engstrom NuScale Spain Abney NuScale Chris Nighbert NuScale Sarah Fields Member of the Public Enclosure 4