ML24215A107
| ML24215A107 | |
| Person / Time | |
|---|---|
| Site: | 05200050 |
| Issue date: | 08/02/2024 |
| From: | NuScale |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML24215A000 | List:
|
| References | |
| LO-169995 | |
| Download: ML24215A107 (1) | |
Text
Response to SDAA Audit Question Question Number: A-5.2.3.4.2-1 Receipt Date: 02/26/2024 Question:
SDAA Section 5.2.3.4.2 describes how the cleaning, handling, storage, and shipping of RCPB components comply with ASME NQA-1 requirements. However, SDAA Table 1.9-2 does not cite any Chapter 5 sections for conformance with RG 1.28, "Quality Assurance Program Criteria (Design and Construction)." The staff notes that DCA Table 1.9-2 cites Sections 5.2, 5.3, and 5.4. Therefore, please discuss why SDAA Table 1.9-2 does not cite any Chapter 5 sections for conformance with RG 1.28.
Response
During preparation of the standard design approval application, NuScale reviewed the design certification application and removed redundant material.
Section 5.2.3.4.2, Cleaning and Contamination Protection Procedures, describes cleaning requirements for reactor coolant pressure boundary components and the controls used with austenitic stainless steel components to minimize harmful contaminants. Redundant statements were removed from Section 5.3, Reactor Vessel, and Section 5.4, Reactor Coolant System Component and Subsystem Design. When NuScale removed the redundant statements, a reference to Section 5.2.3, Reactor Coolant Pressure Boundary Materials, was maintained.
The attached markup adds a citation for Section 5.2, Integrity of Reactor Coolant Boundary, to Table 1.9-2, Conformance with Regulatory Guides.
Markups of the affected changes, as described in the response, are provided below:
NuScale Nonproprietary NuScale Nonproprietary
NuScale Final Safety Analysis Report Conformance with Regulatory Criteria NuScale US460 SDAA 1.9-3 Draft Revision 2 Audit Question A-3.11.2.3-1, Audit Question A-5.2.3.4.2-1, Audit Question A-6.1.1-8, Audit Question A-8.1-4 Table 1.9-2: Conformance with Regulatory Guides RG Title Rev.
Conformance Status Comments Section 1.6 Safety Guide 6 - Independence Between Redundant Standby (Onsite) Power Sources and Between Their Distribution Sys-tems 0
Not Applicable The onsite electrical AC power systems do not contain Class 1E distribution systems.
Not Applicable 1.7 Control of Combustible Gas Con-centrations in Containment 3
Partially Conforms The design complies with the intent of RG 1.7 regulatory positions that address atmosphere mixing, hydrogen gas production, and containment structural integrity.
However, the design deviates from the positions on hydrogen and oxygen monitors. The design includes a passive autocatalytic recombiner (PAR) that is sized to limit oxygen concentrations to a level that does not sup-port combustion (less than four percent), this results in an inert containment atmosphere. The NuScale design supports an exemption to 10 CFR 50.44(c)(4).
6.2.5 1.8 Qualification and Training of Per-sonnel for Nuclear Power Plants 4
Not Applicable This guidance governs site-specific programmatic and operational activities that are the responsibility of the applicant or licensee.
Not Applicable 1.9 Application and Testing of Safety-Related Diesel Genera-tors in Nuclear Power Plants 4
Not Applicable The NuScale design does not require or include safety-related emergency diesel generators.
Not Applicable 1.11 Instrument Lines Penetrating the Primary Reactor Containment 1
Not Applicable No instrument lines penetrate the NuScale Power Mod-ule (NPM) containment.
Not Applicable 1.12 Nuclear Power Plant Instrumen-tation for Earthquakes 3
Partially Conforms Selection of specific equipment is the responsibility of the applicant or licensee. In addition, seismic instrumen-tation cannot be installed inside the containment, so Section 3.7.4 indicates seismic instrumentation is installed in the Reactor Building (RXB).
3.7.4 12.3
NuScale Final Safety Analysis Report Conformance with Regulatory Criteria NuScale US460 SDAA 1.9-5 Draft Revision 2 1.26 Quality Group Classifications and Standards for Water-, Steam-,
and Radioactive-Waste-Contain-ing Components of Nuclear Power Plants 6
Conforms The quality group classification from RG 1.26 applicable to a specific component is described throughout the FSAR.
3.2 3.12 5.2 5.4 6.2 6.6 9.1 9.2 9.3 10.3 10.4 17.5 1.27 Ultimate Heat Sink for Nuclear Power Plants 3
Not Applicable This guidance does not apply to plants that use a passive cooling system to transfer heat to the UHS. The NuScale design uses a passive cooling system.
Not Applicable 1.28 Quality Assurance Program Cri-teria (Design and Construction) 5 Partially Conforms NuScale conforms with RG 1.28 Rev 4, but follows guid-ance in RG 1.28 Rev 5 in the following instances:
- Compliance with 2011 Nuclear Information and Records Management Association technical guides for electronic records
- Use of NEI 14-05A Rev 1 as a basis for laboratory calibration requirements
- Qualifications for lead auditors based on audit participation Conformance with Rev 4 is maintained to align with SRP 17.5. Site-specific, programmatic, and operational aspects are the responsibility of the applicant or licensee.
5.2 6.1.1 6.3 7.0 7.2 17.5 1.29 Seismic Design Classification for Nuclear Power Plants 6
Conforms The seismic classification from RG 1.29 applicable to a specific component is described throughout the FSAR.
3.2 Table 1.9-2: Conformance with Regulatory Guides (Continued)
RG Title Rev.
Conformance Status Comments Section