ML24215A124
| ML24215A124 | |
| 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: ML24215A124 (1) | |
Text
Response to SDAA Audit Question Question Number: A-5.4.1.4-2 Receipt Date: 09/15/2023 Question:
Please explain the reason for using Revision 7 rather than Revision 8 of the Electric Power Research Institutes (EPRI) Steam Generator Management Program: Pressurized Water Reactor Steam Generator Examination Guidelines in References 5.2-7 and 5.4-2 of the SDAA.
The staff recognizes that proposed Combined License (COL) Item 5.4-1 in the SDAA specifies the latest revision of the EPRI guidelines at the time of the application. However, also including a reference to the current guideline revision would provide the most up-to-date information available for understanding the design. The staff noted during the Carbon Free Power Project readiness assessment that the draft COL application includes departures in Sections 5.4.1.4 and 5.4.6 to reference the latest revision of the EPRI examination guidelines.
Please discuss why the EPRI Primary Water Chemistry Guidelines and the EPRI Secondary Water Chemistry Guidelines are not included in SDAA Section 5.4.6. SDAA Section 5.4.1.6 refers to the EPRI primary and secondary plant chemistry control guidelines (no revision numbers noted), however, these guidelines are not included as references in 5.4.6.
Please discuss why other applicable EPRI SG guidelines, such as the In-Situ Pressure Test Guidelines and Primary-to-Secondary Leak Guidelines, are not referred to or referenced in Section 5.4.1 of the SDAA.
Response
The Standard Design Approval Application (SDAA) uses Revision 7 of Electric Power Research Institute (EPRI) #1013706, Steam Generator Management Program: Pressurized Water NuScale Nonproprietary NuScale Nonproprietary
Reactor Steam Generator Examination Guidelines. Because NuScale used Revision 7 for the US460 standard design, it is the appropriate SDAA reference.
The SDAA references Revision 7 of the EPRI #3002000505, Pressurized Water Reactor Primary Water Chemistry Guidelines, as Reference 5.2-3 in SDAA Section 5.2.3.2.1, Reactor Coolant Chemistry. The SDAA references EPRI #1016555, Pressurized Water Reactor Secondary Water Chemistry Guidelines, as Reference 10.3-2 in SDAA Section 10.3.5, Water Chemistry. SDAA Reference 10.3-2 should include Revision 7; this change is made in the attached markup. Section 5.4.1.6, Steam Generator Program only refers to the primary and secondary water chemistry control guidelines as one mitigation technique to prevent corrosion mechanisms; the discussion is not detailed enough to warrant referencing the EPRI primary water chemistry guidelines in Section 5.4.6.
The SDAA does not reference other EPRI steam generator (SG) guidelines because the text of Section 5.4.1 addresses the purpose of a SG management program. A full, detailed description of a SG management program for the NPM-20 is outside the scope of SDAA. The licensee will be the administrator of a SG management program and will define the details of the SG management program. The EPRI In-Situ Pressure Test Guidelines and the Primary-to-Secondary Leak Guidelines address leak detection and how to deal with leaks and are the licensees responsibility (COL Item 5.4-1).
Markups of the affected changes, as described in the response, are provided below:
NuScale Nonproprietary NuScale Nonproprietary
NuScale Final Safety Analysis Report Main Steam System NuScale US460 SDAA 10.3-10 Draft Revision 2 10.3.8 References 10.3-1 Electric Power Research Institute, "Recommendation for Effective Flow-Accelerated Corrosion Program (NSAC-202L-R4),"
EPRI #3002000563. Technical Report, EPRI, Palo Alto, CA, 2013.
Audit Question A-5.4.1.4-2 10.3-2 Electric Power Research Institute, "Pressurized Water Reactor Secondary Water Chemistry Guidelines, EPRI #1016555, Revision 7, EPRI, Palo Alto, CA, 2009.
10.3-3 Nuclear Energy Institute, "Steam Generator Program Guidelines,"
NEI 97-06, Revision 3, Washington, DC, January 2011.