ML23319A435
| ML23319A435 | |
| Person / Time | |
|---|---|
| Site: | 99902049 |
| Issue date: | 11/29/2023 |
| From: | Holtec, SMR |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML23319A433 | List: |
| References | |
| 160-USNRC-070 | |
| Download: ML23319A435 (1) | |
Text
www.holtec.com www.smrllc.com Holtec SMR Chapter 16 PSAR Content November 29, 2023 Presented by: Rick Rosas SMR, LLC, A Holtec International Company Krishna P. Singh Technology Campus One Holtec Boulevard Camden, NJ 08104, USA
[Not Export Controlled]
holtec.com l smrllc.com l Page 2 Meeting Agenda
Introductions
Purpose & Outcome Summary of October 27, 2022 meeting Review of Regulation and Regulatory Guidance Discussion on Holtec SMR Ch 16 Level of Detail for PSAR Open Forum
holtec.com l smrllc.com l Page 3 Purpose and Outcome
Purpose:
Present the scope, content, and format for Holtecs SMR PSAR Chapter 16 Outcome:
Align with the Staff on the level of detail for Holtecs SMR PSAR Chapter 16
holtec.com l smrllc.com l Page 4 October 27, 2022 TS Meeting Summary In response to the applicants question of the staffs expectations of TS in the preliminary safety analysis report (PSAR) accompanying the CP application, the NRC staff responded that fully developed TS are not expected during the CP application stage.
At the CP application stage, an applicant should identify the items to potentially be the subject of TS requirements for the categories stated in 10 CFR 50.36(c):
safety limits limiting safety system settings limiting conditions for operation surveillance requirements design features administrative controls The selection of structures, systems, and components (SSCs), and process parameters should be based on ensuring the validity of the design and analysis assumptions used in the preliminary safety analysis report (PSAR).
holtec.com l smrllc.com l Page 5 Regulation
[10CFR50.34(a)(5)]
An identification and justification for the selection of those variables, conditions, or other items which are determined as the result of preliminary safety analysis and evaluation to be probable subjects of technical specifications for the facility, with special attention given to those items which may significantly influence the final design.
The CP applicant may also propose TS in Section 16 of the PSAR; such TS should be based on the current STS and any approved STS changes not yet incorporated, or the generic DCD TS (DCD GTS) if referencing a certified plant design.
holtec.com l smrllc.com l Page 6 Regulatory Guidance RG 1.70 Describes submitting a complete set of preliminary TS at PSAR The TS for most of the LWR vendors were already available and fully described for use by a customer/applicant RG 1.206 Does not specifically address content for a CPA.
SRP Ch. 16 Correctly reflects the 10 CFR requirements for a PSAR.
Holtec is proposing documentation in Chapter 16 that identifies the following:
Tech Spec Number Section Name Limited Condition of Operation Justification for its inclusion for Holtec SMR
holtec.com l smrllc.com l Page 7 holtec.com l smrllc.com l Page 7 FSAR TS Level Of Detail
holtec.com l smrllc.com l Page 8 Holtec SMR PSAR Chapter 16 Content SMR PSAR will address:
Modes of Operation Limiting Condition for Operation SMR justification for LCO Commitment to fully developed TS at OLA SMR PSAR will NOT include:
Use and Application Section Specific LCO or Condition parameters LCO Completion Times TS Surveillances Surveillance Frequency Formatting of TS consistent with STS Detailed Tables and Curves Administrative Controls
holtec.com l smrllc.com l Page 9 Holtec SMR PSAR Chapter 16 Level of Detail IReference NUREG-2194 (APl000) 3.,9 3.9.1 Section Name Refueling Operatio,ns Boron Concentration HOLTEC I NTE RNATION A L Specification Tit le & LCO Discussion Boron concentration of the RCSIThe LCO requires that boron concentration be maintained within limit in the RCS and the refueling and the refuel'ing cavity (w hich ca,v*ity which includes the spent fuel pool for the Holtec SMR while in MODE 6. Refuelin,g boron includes the spent f u e I pool) sha II be ma'intained within the limit specified 'in the COLR.
A.pplicabHity: MO1DE 6 concentration is the soluble boron concentration in the coolant in each of these volumes ha,v*ing direct access to the reactor core during refueling. The soluble boron concentration offsets the core reactivity and is measured by chemical anal*ysis of a representati*ve sample of the coolant in each of the volumes.
1The boron concentration limit specifi'ed in the COLR ensures that a core keff < 0 1.95 is mainta'ined during I fuel handling operations with control rods and fuel assemb11ies assumed to be in the most adverse configuration (least negati*v*e react'i'v*ity') allowed b*y* procedures. Violation of the LCO could lead to an inadv*ertent criticality during MODE 6.
The reactor is brought to shutdown conditions before beginning operati*ons to open the reactor *vessel for refueling. After the RCS is cooled do*wn and depressurized, the vessel head is unbolt ed and slo*wly remo,v*ed. The refueling cavity and the fuel transfer canal are then flooded *with borated water from Refueling Water Storage Tank (RWST:) b1y the use of the Spent Fuel IPool Cooli'ng System (SFIP}.
During refuel'ing., the water *v*olumes in the RCS, the refueling cavity* and spent fuel pool are contiguous.
However, the soluble boron concentration is not necessarily* the same in each volume. If additions of boron are required during refueling, the Chemical and Volume Control System (CVS:) pro,vides the b1orated makeup.
holtec.com l smrllc.com l Page 10 Open Forum
holtec.com l smrllc.com l Page 11 Backup Slides
holtec.com l smrllc.com l Page 12 Holtec SMR Process Holtec does not have a historical basis of existing TS, nor design-specific operating experience to inform the content of the TS.
No new or unique design features Holtec TS are being developed directly from Design, safety analysis, and planned operations.
TS development is informed by industry operating experience TS content for which similar or parallel functions and features exist in current fleet designs.
These factors are compared with the criteria for inclusion as TS.
holtec.com l smrllc.com l Page 13 Holtec SMR Process Holtec TS are being developed consistent with the Holtec SMR-specific safety analyses and the design-specific probabilistic risk analyses.
The STS are published by the NRC as six NUREGs tailored to various reactor designs and are used as a basis for the content and format of the proposed Holtec SMR STS.
The versions of the STS that are considered during TS development include:
NUREG-1431 Westinghouse NUREG-1432 Combustion Engineering NUREG-2194 Westinghouse AP1000 NUSCALE GTS
holtec.com l smrllc.com l Page 14 Holtec SMR Process Holtec applies the TS inclusion criteria consistent with:
the final NRC policy, considerations detailed in the Split Report, the Writer's Guide for Plant-Specific Improved Technical Specifications, the content of the current versions of the STS, and the refinements to the STS developed by the TSTF as travelers to the extent they are applicable
holtec.com l smrllc.com l Page 15 10CFR50.36 a)(1) Each applicant for a license authorizing operation of a production or utilization facility shall include in his application proposed technical specifications in accordance with the requirements of this section. A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications.
(2) Each applicant for a design certification or manufacturing license under part 52 of this chapter shall include in its application proposed generic technical specifications in accordance with the requirements of this section for the portion of the plant that is within the scope of the design certification or manufacturing license application.
(b) Each license authorizing operation of a production or utilization facility of a type described in § 50.21 or § 50.22 will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to § 50.34. The Commission may include such additional technical specifications as the Commission finds appropriate.
holtec.com l smrllc.com l Page 16 Holtec SMR PSAR Chapter 16 Level of Detail
[RG 1.70] An application for a construction permit should include preliminary Technical Specifications that identify and provide justification for the selection of variables, conditions, or other limitations that are determined to be probable subjects of the final Technical Specifications.
[SRP Ch 16] An applicant for a construction permit (CP) under 10 CFR Part 50 is required by 10 CFR 50.34(a)(5) to include in the preliminary safety analysis report (PSAR)
An identification and justification for the selection of those variables, conditions, or other items which are determined as the result of preliminary safety analysis and evaluation to be probable subjects of TS for the facility, with special attention given to those items which may significantly influence the final design.
The CP applicant may also propose TS in Section 16 of the PSAR; such TS should be based on the current STS and any approved STS changes not yet incorporated.