ML19297C877

Summary of Public Meeting with NuScale to Discuss ECCS Test #47

ML19297C877
Person / Time
Site:	NuScale
Issue date:	10/24/2019
From:	Cayetano Santos NRC/NRR/DNRL/NRLB
To:	Michael Dudek NRC/NRR/DNRL/NRLB
Santos C 415-7270
References
Download: ML19297C877 (6)

Text

October 24, 2019 MEMORANDUM TO: Michael I. Dudek, Chief New Reactor Licensing Branch Division of New and Renewed Licenses Office of Reactor Licensing Regulation FROM: Cayetano Santos Jr., Project Manager /RA/

New Reactor Licensing Branch Division of New and Renewed Licenses Office of Reactor Licensing Regulation

SUMMARY

OF THE SEPTEMBER 24, 2019, PUBLIC TELECONFERENCE REGARDING THE INITIAL TEST PROGRAM IN NUSCALE POWER, LLCS DESIGN CERTIFICATION APPLICATION On September 24, 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 Emergency Core Cooling System Test #47 as described in the initial test program of NuScales design certification application. The meeting notice was posted on the NRC Web site and is also in the NRCs Agencywide Documents Access and Management System under Accession No. ML19217A113. The meeting summary is provided as Enclosure 1 which captures the summary of topics discussed. The meeting agenda and list of attendees are provided as Enclosures 2 and 3, respectively.

Docket No.52-048

Enclosures:

As stated cc w/encl: DC NuScale Power, LLC Listserv CONTACT: Cayetano Santos Jr., NRR/DNRL 301-415-7270

ML19297C877 *via email NRO-002 OFFICE DNRL/NRLB:PM DNRL/NRLB:LA DNRL/NRLB:PM NAME *CSantos *SGreen *CSantos DATE 10/24/2019 10/24/2019 10/24/2019 PUBLIC TELECONFERENCE REGARDING EMERGENCY CORE COOLING SYSTEM TEST #47 IN NUSCALES INITIAL TEST PROGRAM MEETING

SUMMARY

September 24, 2019 On October 3, 2019, the NRC issued Request for Additional Information (RAI) 9719 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19276D281) to NuScale Power, LLC (NuScale) regarding Emergency Core Cooling System (ECCS) Test #47 as proposed in the Initial Test Program.

NuScale noted that the regulatory basis for RAI 9719 includes General Design Criterion (GDC) 37, Testing of Emergency Core Cooling System, and asked if this GDC is applicable to the as-built ECCS system. The staff responded that GDC 37 does apply, and tests similar to that requested in RAI 9719 have been included in other designs such as the AP1000.

NuScale asked how the performance of a preoperational test requested in RAI 9719 is consistent with a finding that the requirements of Title 10 Code of Federal Regulations (10 CFR) 50.43, Additional Standards and Provisions Affecting Class 103 Licenses and Certifications for Commercial Power, have been met at the design certification stage. The staff stated that the RAI is requesting a test to demonstrate the acceptable performance of the as-built ECCS because it is a first-of-a-kind system and can be impacted by factors such as variations in as-built parameters and uncertainties in complex thermal-hydraulic phenomena. The 10 CFR 50.43 finding is focused on testing at the component level whereas GDC 37 is focused on an integrated test of the whole system. NuScale asked what thermal-hydraulic phenomena were of concern to the staff. The staff responded that there were no specific phenomena of concern but just identified this as an example of a factor that could impact the as-built performance of the system. NuScale stated that they did not agree that the test of the ECCS is a first-of-a-kind system test.

NuScale stated that the proposed hot functional test is not under design basis conditions so only limited circulation flows could be established. The staff asked if NuScales analytical tools could be used to predict these flows to establish test acceptance criteria. NuScale responded that establishing acceptance criteria for this test is not straightforward because of conservative assumptions and other biases in the analyses. NuScale also stated that these tests could be performed but does not agree with the staff that the tests are needed.

The staff asked what value is added by the three acceptance criteria listed for ECCS Test #47:

1. Reactor pressure vessel (RPV) riser level remains above the top of the core

2. Containment vessel (CNV) pressure remains below design pressure

3. CNV temperature remains below design temperature Enclosure 1

NuScale responded that no value is added in acceptance criteria #2 and #3, and it plans to delete these two criteria. NuScale added that criterion #1 is the only meaningful acceptance criterion because it is a fundamental feature of the NuScale design. The staff stated that it was unclear how acceptance criteria #1 is appropriate given that no fuel would be in the vessel when the test is performed.

NuScale commented that the test requested by the NRC staff would essentially validate the codes used in the safety analyses. The staff responded that the purpose of the test is not to validate these codes but to confirm that the as-built plant has been constructed as designed.

The staff noted that for the AP1000, tests similar to what is requested in RAI 9719 were included as preoperational tests and the acceptance criteria were based on test conditions and not design basis conditions.

NuScale asked if the functional acceptance criteria could be that heat is removed from the system. The staff responded that it is looking for a test to demonstrate that the system performs as expected. NuScale asked if the test requested in RAI 9719 had to be done in-situ. The staff responded that it is looking for an integrated functional test.

NuScale agreed to consider the staffs comments and will need to have further internal discussions before responding to RAI 9719. The staff stated that additional discussions with appropriate management involvement could be arranged, if needed.

There was an opportunity for public comments:

• Sarah Fields commented that RAI 9719, its response, and todays meeting summary should be placed in ADAMS. Ms. Fields also stated that as the regulators the NRC should ask necessary questions and ensure that appropriate tests are performed.

• Marvin Lewis commented that an appropriate amount of testing, regardless of cost, should be done before a plant begins operation to ensure accidents do not occur.

2

MEETING AGENDA September 24, 2019 1:30 p.m. - 3:30 p.m.

The purpose of this teleconference was for the U.S. Nuclear Regulatory Commission (NRC) staff to discuss Emergency Core Cooling System Test #47 as described in the initial test program.

Time Topic Speaker 1:30 p.m. - 1:35 p.m. Introductions All Discussion of RAI 9719 and ECCS 1:35 p.m. - 3:15 p.m. NRC/NuScale Test #47 in the ITP 3:15 p.m. - 3:30 p.m. Public Comments Public 3:30 p.m. Adjourn All Enclosure 2

LIST OF ATTENDEES September 24, 2019 1:30 p.m. - 3:30 p.m.

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

Kerri Kavanagh NRC Kevin Coyne NRC Taylor Lamb NRC Ryan Nolan NRC Rebecca Karas NRC Timothy Drzewiecki NRC Jeffrey Schmidt NRC Nadja Joergensen NuScale Power, LLC (NuScale)

Chris Maxwell NuScale Gary Becker NuScale Meghan McCloskey NuScale Jim Osborn NuScale Dustin Greenwood NuScale Mike Melton NuScale Chris Nighbert NuScale Sarah Fields Member of the Public Marvin Lewis Member of the Public Enclosure 3