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Category:Letter
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Hydrogen/Oxygen Monitoring, PM-0420-69518, Revision 0 ML20094H6742020-04-0303 April 2020 LLC Submittal of Presentation Materials Entitled ACRS Full Committee Presentation NuScale Topic-Probabilistic Risk Assessment with a Focus on Emergency Core Cooling System Analysis PM-0420-69559, Revision 0 ML20092L8992020-04-0101 April 2020 LLC - Submittal of Updates to Standard Plant Design Certification Application, Revision 4 ML20072M6682020-03-30030 March 2020 Response to NuScale Letter Dated February 24, 2020, on Planned SDA Application Content ML20072H3332020-03-0909 March 2020 LLC - Submittal of Presentation Materials Entitled Public Meeting Presentation: Topic - Emergency Core Cooling System (ECCS) Boron Distribution, PM-0320-69218, Revision 0 ML20057D9002020-03-0606 March 2020 Submittal of Errata to Final SE for NuScale Power, LLC TR-1010-859-NP-A, Quality Assurance Program Description for the NuScale Power Plant ML20062F7262020-03-0505 March 2020 Request for Withholding Information from Public Disclosure for Nuscale Power, LLC Letter Public ML20069A1572020-03-0404 March 2020 LLC - Submittal of Presentation Materials Entitled ACRS Full Committee Presentation: NuScale Topical Report-Rod Ejection Accident Methodology, PM-0320-69146, Revision 0 ML20069A1772020-03-0404 March 2020 LLC - Submittal of Presentation Materials Entitled ACRS Full Committee Presentation: NuScale Topical Report-Non-Loss-of-Coolant Accident, PM-0320-69141, Revision 0 ML20069A9632020-03-0404 March 2020 LLC Submittal of Presentation Materials Entitled ACRS Full Committee Presentation: NuScale Topical Report, Loss-of-Coolant Accident Evaluation Model, PM-0320-69138, Revision 0 ML20066G2802020-03-0303 March 2020 LLC, Submittal of Presentation Materials Entitled ACRS Subcommittee Presentation: NuScale Topic - Hydrogen Monitoring, PM-0220-69071, Revision 0 ML20066G2882020-02-28028 February 2020 LLC Submittal of Presentation Materials Titled ACRS Full Committee Presentation: NuScale - Steam Generator Design (Closed Session), PM-0220-69053, Revision 0 2023-06-29
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARRAIO-0420-69855, LLC, Submittal of Corrected Response to NRC Request for Additional Information No. 284 (Erai No. 9225) on the NuScale Design Certification2020-04-30030 April 2020 LLC, Submittal of Corrected Response to NRC Request for Additional Information No. 284 (Erai No. 9225) on the NuScale Design Certification ML19332A1202019-11-27027 November 2019 LLC Supplemental Response to NRC Request for Additional Information No. 484 (Erai No. 8930) on the NuScale Design Certification Application ML19304B4712019-10-31031 October 2019 LLC Supplemental Response to NRC Request for Additional Information No. 466 (Erai No. 9482) on the NuScale Design Certification Application ML19296D8052019-10-23023 October 2019 LLC Response to NRC Request for Additional Information No. 526 (Erai No. 9719) on the NuScale Design Certification Application ML19283E5302019-10-10010 October 2019 LLC Supplemental Response to NRC Request for Additional Information No. 522 (Erai No. 9681) on the NuScale Design Certification Application ML19260G7352019-10-0707 October 2019 Summary of Public Meeting with NuScale to Discuss Response to RAI 9681 ML19266A5872019-09-23023 September 2019 LLC Supplemental Response to NRC Request for Additional Information No. 518 (Erai No. 9659) on the NuScale Design Certification Application ML19262G9742019-09-19019 September 2019 LLC - Submittal of Changes to Final Safety Analysis Report, Tier 1, Section 3.11, Reactor Building and Section 3.13, Control Building, and Tier 2, Section 3.8.4, Design of Category I Structure and Section 14.3, Certified ... ML19262G5762019-09-19019 September 2019 LLC - Submittal of Changes to Final Safety Analysis Report, Section 14.2, Initial Plant Test Program, Table 14.2-2, Pool Cleanup Systems Test #2, and Table 14.2-50, Module Assembly Equipment Test #50 ML19259B8102019-09-16016 September 2019 LLC Supplemental Response to NRC Request for Additional Information No. 205 (Erai No. 9044) on the NuScale Design Certification Application ML19259A0922019-09-16016 September 2019 LLC Response to NRC Request for Additional Information No. 525 (Erai No. 9705) on the NuScale Design Certification Application ML19238A3722019-08-26026 August 2019 LLC Supplemental Response to NRC Request for Additional Information No. 197 (Erai No. 9051) on the NuScale Design Certification Application ML19238A3662019-08-23023 August 2019 LLC - Response to NRC Request for Additional Information No. 523 (Erai No. 9682) on the NuScale Design Certification Application ML19215A0032019-08-0202 August 2019 LLC - Supplemental Response to NRC Request for Additional Information No. 202 (Erai No. 8911) on the NuScale Design Certification Application ML19215A0062019-08-0202 August 2019 LLC - 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Supplemental Response to NRC Request for Additional Information No. 325 (Erai No. 9268) on the NuScale Design Certification Application ML19164A1452019-06-13013 June 2019 LLC - Submittal of Containment Response Analysis Methodology Technical Report, TR-0516 -49 08 4, Revision 1 ML19157A3262019-06-0606 June 2019 LLC - Supplemental Response to NRC Request for Additional Information No. 232 (Erai No. 9113) on the NuScale Design Certification Application ML19154A6222019-06-0303 June 2019 LLC Supplemental Response to NRC Request for Additional Information No. 202 (Erai No. 8911) on the NuScale Design Certification Application ML19154A6052019-06-0303 June 2019 LLC Response to NRC Request for Additional Information No. 514 (Erai No. 9645) on the NuScale Design Certification Application ML19151A8372019-05-31031 May 2019 LLC - Supplemental Response to NRC Request for Additional Information No. 377 (Erai No. 9380) on the NuScale Design Certification Application ML19140A4592019-05-20020 May 2019 LLC Supplemental Response to NRC Request for Additional Information No. 401 (Erai No. 9447) on the NuScale Design Certification Application ML19137A2902019-05-17017 May 2019 LLC Supplemental Response to NRC Request for Additional Information No. 156 (Erai No. 9031) on the NuScale Design Certification Application ML19137A2872019-05-15015 May 2019 LLC Response to NRC Request for Additional Information No. 519 (Erai No. 9656) on the NuScale Design Certification Application ML19126A2942019-05-0606 May 2019 LLC Supplemental Response to NRC Request for Additional Information No. 26 (Erai No. 8840) on the NuScale Design Certification Application ML19122A5092019-05-0202 May 2019 LLC - Supplemental Response to NRC Request for Additional Information No. 494 (Erai No. 9548)on the Design Certification Application ML19121A6002019-05-0101 May 2019 LLC - Supplemental Response to NRC Request for Additional Information No. 202 (Erai No. 8911) on Design Certification Application 2020-04-30
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Text
RAIO-1018-62173 October 17, 2018 Docket No.52-048 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738
SUBJECT:
NuScale Power, LLC Response to NRC Request for Additional Information No.
498 (eRAI No. 9572) on the NuScale Design Certification Application
REFERENCE:
U.S. Nuclear Regulatory Commission, "Request for Additional Information No.
498 (eRAI No. 9572)," dated August 21, 2018 The purpose of this letter is to provide the NuScale Power, LLC (NuScale) response to the referenced NRC Request for Additional Information (RAI).
The Enclosure to this letter contains NuScale's response to the following RAI Question from NRC eRAI No. 9572:
05.04.02.02-1 This letter and the enclosed response make no new regulatory commitments and no revisions to any existing regulatory commitments.
If you have any questions on this response, please contact Carrie Fosaaen at 541-452-7126 or at cfosaaen@nuscalepower.com.
Sincerely, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution: Gregory Cranston, NRC, OWFN-8G9A Samuel Lee, NRC, OWFN-8G9A Bruce Bavol, NRC, OWFN-8G9A : NuScale Response to NRC Request for Additional Information eRAI No. 9572 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com
RAIO-1018-62173 :
NuScale Response to NRC Request for Additional Information eRAI No. 9572 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com
Response to Request for Additional Information Docket No.52-048 eRAI No.: 9572 Date of RAI Issue: 08/21/2018 NRC Question No.: 05.04.02.02-1 NuScale steam generator (SG) design includes a 40 percent through-wall plugging criterion for meeting the structural integrity performance criterion with a safety factor of 3 for the normal operating pressure differential (NOPD) of 1350 psi. The plugging criterion and performance criteria are included as requirements in Technical Specification (TS) 5.5.4, "Steam Generator (SG) Program." The plugging criterion is used to determine if tube integrity was maintained, in accordance with the TSs, over the most recent operating cycle (condition monitoring), and whether tubes need to be plugged in order to maintain integrity over the next operating cycle (operational assessment). As stated in the response to Question 05.04.02.01-1.e in Request for Additional Information (RAI) 9273 (ADAMS Accession No. ML18093B542), the 40 percent plugging criterion is intended to be bounding, but it is currently enclosed within brackets in the TSs. Enclosing a value in brackets in the TSs means a combined license applicant must provide a plant-specific value (confirm 40 percent or justify an alternative).
The proposed 40 percent through-wall plugging limit is based on degradation from wear, with a length of degradation equivalent to the length of a tube support tab (0.5 inch).
The NRC staff has the following observations based on its independent calculations to evaluate the proposed plugging limit:
For the 0.5 inch long wear flaw, the safety factor against collapse for NOPD is approximately 3.1.
To maintain the safety factor of 3 for NOPD, the maximum allowable length of a 40 percent deep wear flaw would be approximately 0.7 inch.
To maintain the safety factor of 3 for NOPD for a wear flaw of any length, the maximum allowable depth of the flaw would be approximately 24 percent.
NuScale Nonproprietary
The NRC staff's safety factor calculations as a function of flaw depth and length do not include nondestructive examination uncertainty.
To conform to Regulatory Position C.2.b in Regulatory Guide (RG) 1.121, "Bases for Plugging Degraded PWR Steam Generator Tubes," the plugging criteria should include a thickness allowance for degradation. To conform to Regulatory Position C.3.f in RG 1.121, this operational degradation allowance should identify the method and data used to predict degradation and the measurement error in the eddy current tube inspections.
The response to Questions 05.04.02.01-1.b and e in RAI 9273 indicates that industry guidance was used to determine the uncertainty from eddy current testing and flaw sizing uncertainty.
The NRC staff observations listed above indicate that a plugging criterion of 40 percent through-wall may be adequate only if the length is limited, and it may not include a realistic assumption about the degradation rate since there is no operating experience. In addition, the response to Question 05.04.02.01-1.e in RAI 9273 states that when eddy current systems are qualified for NuScale tube inspections, the measurement uncertainties may be different than what was assumed based on the systems used for the current fleet.
In order to ensure that the site-specific SG tube plugging criterion submitted by a combined license (COL) applicant is determined according to RG 1.121, including margin for operational degradation and measurement uncertainty, the NRC staff requests that a COL item be added to Chapter 5 of the Final Safety Analysis Report specifically for resolving the bracketed plugging criterion in the TS. The COL item should state that the SG tube plugging criterion submitted by the COL applicant for review will be determined according to the guidance in RG 1.121 at the time of the application.
NuScale Response:
NuScale FSAR Section 5.4.1.1 states that the SG program is based on NEI 97-06 and Regulatory Guide (RG) 1.121. This includes the SG tube plugging critierion specified by RG 1.121, Regulatory Positions C.2.b and C.3.f.
FSAR Table 1.9-2 also states that the NuScale design conforms with RG 1.121.
RG 1.121 conformance is also described in the Bases for LCO 3.4.9, SG Tube Integrity of DCA Part 4, Technical Specifications. The discussion in the LCO Bases is not enclosed in brackets NuScale Nonproprietary
and therefore not expected to be modified when the generic Technical Specifications (GTS) are adopted by COL applicants.
As noted, Steam Generator (SG) tube plugging criteria is enclosed in brackets in NuScale GTS, section 5.5.4, Steam Generator (SG) Program, indicating that the final value must be finalized and included by a COL Applicant. Note that bracketing of the 40% value was also discussed in an SG Audit question in September 2017.
FSAR Chapter 16, Technical Specifications, Combined License (COL) Item 16.1-1 states: "A COL applicant that references the NuScale Power Plant design certification will provide the final plant-specific information identified by [ ] in the generic Technical Specifications..."
The NuScale Final Safety Analysis Report (FSAR) Table 1.8-2 reiterates this COL Item 16.1-1.
Based on COL item 16.1-1 requiring GTS bracketed items to be assessed and included by the COL applicant, and the description of conformance with RG 1.121 provided in FSAR section 5.4.1.1, FSAR Table 1.9-2, and GTS Bases section 3.4.9, NuScale has determined that no further changes to the Design Certification Application are required to ensure that the site-specific SG tube plugging criterion submitted by a combined license (COL) applicant will be determined according to RG 1.121, including margin for operational degradation and measurement uncertainty.
Impact on DCA:
There are no impacts to the DCA as a result of this response.
NuScale Nonproprietary