ML24215A057

LLC, Response to Sdaa Audit Question Number A-3.9.2-19

ML24215A057
Person / Time
Site:	05200050
Issue date:	08/02/2024
From:	NuScale
To:	Office of Nuclear Reactor Regulation
Shared Package
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Download: ML24215A057 (1)

Text

Response to SDAA Audit Question Question Number: A-3.9.2-19 Receipt Date: 08/28/2023 Question:

This request is a follow-on from audit item (1d) of A-3.9.2-10: Audit item A-3.9.2-10 (1d) requested:

"Criteria for how the initial startup testing power ascension plan will be developed, including key Level 1 and Level 2 acceptance criteria (refer to RG 1.20 Rev. 4 Section 2.2.2(c) for details),

limits, and triggered actions in the event the acceptance criteria or limits are challenged or violated."

NuScale continues to defer this request to the COL holder (COL Item 3.9-4). The staff, however, requests the criteria, not the actual power ascension plan. NuScale is requested to provide these criteria and how they relate to critical RVI and the HCSG long-term integrity. No actual limits are requested, only the means by which they will be developed and adhered to during power ascension.

Response

SDA FSAR Section 14.2.3.1 describes the process by which the initial test program procedures are developed. This includes requirements to develop acceptance criteria by which testing is evaluated, remedial actions to take if acceptance criteria are not satisfied, and actions to take if an unexpected or unanalyzed conditions occur. FSAR Section 14.2.5 also describes the administrative procedures that would be in place to ensure review, evaluation, and approval of test results prior to authorizing the next phase of the initial test program.

Test #102 in SDA FSAR Table 14.2-102 lists the NPM vibration test abstract which is part of initial startup testing. The Test Objective and Test Method sections describe the required power levels to be included in the test, required testing durations, and verification steps.

NuScale Nonproprietary NuScale Nonproprietary

Test #102 in SDA FSAR Table 14.2-102 states that the acceptance criteria is:

1. Measured vibration amplitudes in the CNTS steam piping branches confirm there is no acoustic resonance concern.

2. Measured vibration responses in the NuScale Power Module confirm there are no resonant peaks that could indicate a strongly-coupled flow induced vibration mechanism.

These acceptance criteria are used to preclude strongly-coupled flow induced vibration mechanisms which could cause damage, if allowed to occur for an extended duration. The components listed in the acceptance criteria are those where the analysis program showed safety margins less than 100 percent or those that contain novel design changes that warrant validation testing. The test conditions, acceptance criteria, and actions required in response to unanticipated results, will be further developed per Reg. Guide 1.20 Rev. 4. ((2(a),(c) Such test plans will be submitted for review as required by COL Item 3.9-4. The initial test program is governed by the Startup Administration Manual (SAM), which is developed in response to COL Item 14.2-2. As described, the applicant will provide the milestone for completion of the SAM and making it available for NRC inspection. More information on conduct of the test program is available in FSAR Section 14.2.4. In accordance with Regulatory Guide 1.68, FSAR Section 14.2.11 states, Approved test procedures are available for NRC review approximately 60 days before their intended use or at least 60 days before fuel loading for fuel loading and startup test procedures. The NRC is notified of test procedure changes before performance. As required by COL Item 14.2-4, an applicant will provide a schedule for the Initial Test Program (ITP). Section 14.2.5 describes the process for review, evaluation and approval of ITP test results. No changes to the SDAA are necessary. NuScale Nonproprietary NuScale Nonproprietary}}