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Category:Letter
MONTHYEARML23180A1512023-06-29029 June 2023 LLC, Request for Exemption to the Reporting Requirements of 10 CFR 50.46(a)(3) ML21102A3072021-04-15015 April 2021 OEDO-21-00155 - Lessons-Learned from the Design Certification Review of the NuScale Power, LLC, Small Modular Reactor ML21050A4312021-02-19019 February 2021 LLC - Lessons-Learned from the Design Certification Review of the NuScale Power, LLC Small Modular Reactor ML20247J5642020-09-11011 September 2020 Standard Design Approval for the NuScale Power Plant Based on the NuScale 600 Standard Plant Design Certification Application ML20231A8042020-08-28028 August 2020 Final Safety Evaluation Report for the NuScale Standard Plant Design ML20224A4602020-08-25025 August 2020 OEDO-20-00292-Response to the Advisory Committee on Reactor Safeguards Letter on NuScale Power, LLC, Report on the Safety Aspects of the NuScale Small Modular Reactor ML20231A5982020-08-25025 August 2020 OEDO-20-00285_NuScale Area of Focus - Boron Redistribution ML20210M8902020-07-29029 July 2020 Area of Focus - Boron Redistribution ML20195A5872020-07-13013 July 2020 LLC - Submittal of Draft Operator Licensing and Examination Standard for NuScale Small Modular Reactors ML20195C7662020-07-13013 July 2020 LLC Request for Standard Design Approval Based on the NuScale Standard Plant Design Certification Application ML20192A3262020-07-10010 July 2020 LLC, Submittal of Environmental Report: Revision Status ML20198M3932020-07-0202 July 2020 LLC Submittal of Revised Packing Slip for Submittal of the NuScale Standard Plant Design Certification Application, Revision 4.1, Dated June 19, 2020 ML20174A3472020-07-0101 July 2020 OEDO-20-00220 - Area of Focus - Probabilistic Risk Assessment and Emergency Core Cooling System Valve Performance ML20184A2872020-07-0101 July 2020 LLC Submittal of Presentation Materials Entitled ACRS Full Committee Presentation: NuScale Topic - Boron Redistribution and General Design Criterion 33, PM-0720-70785, Revision 0 ML20181A4322020-06-22022 June 2020 Final SER for NuScale TR-0516-49416 NON-Loss-of-Coolant Analysis Model, Rev 3 (Letter) ML20181A2702020-06-22022 June 2020 Final SER for NuScale TR-0516-49422 Loss-of-Coolant Analysis Model, Rev 2 (Letter) ML20198M3922020-06-19019 June 2020 LLC - 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Response to the ACRS Letter on Combustible Gas Monitoring ML20133K0882020-05-12012 May 2020 LLC, Submittal of Presentation Materials Entitled Public Meeting Presentation: Topic - Emergency Core Cooling System (ECCS) Boron Distribution (Closed Session), PM-0420-69512, Revision 0 ML20133J9142020-05-11011 May 2020 LLC Submittal of Presentation Materials Entitled Public Meeting Presentation: Topic - Emergency Core Cooling System (ECCS) Boron Distribution, PM-0420-69511, Revision 0 ML20112F4552020-05-0101 May 2020 LLC, Design Certification Application Phases 5 and 6 Review Status ML20107F8492020-05-0101 May 2020 OEDO-2000140 - NuScale Area of Focus - Helical Tube Steam Generator Design ML20104A0792020-04-27027 April 2020 OEDO-20-00115 - Safety Evaluation Report for Topical Report TR-0516-49416, Revision 2, Non-Loss-of-Coolant Accident Analysis Methodology ML20099H0802020-04-0808 April 2020 LLC - Submittal of Presentation Materials Entitled NRC Public Meeting: Revisions to Nuscale'S EPZ Sizing Methodology Topical Report, PM-0420-69598, Revision 0 ML20098G2372020-04-0707 April 2020 Nuscale Power, LLC Submittal of Remaining Closure Items for the Emergency Core Cooling System Valve Failure Mode Effects Analysis Audit Items ML20097F1922020-04-0606 April 2020 Nuscale Power, LLC Submittal of Presentation Materials Entitled ACRS Full Committee Presentation: Nuscale Topic - 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)
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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-0218-58727 February 16, 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.
349 (eRAI No. 9284) on the NuScale Design Certification Application
REFERENCE:
U.S. Nuclear Regulatory Commission, "Request for Additional Information No.
349 (eRAI No. 9284)," dated January 29, 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 Questions from NRC eRAI No. 9284:
12.03-29 12.03-30 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 Steven Mirsky at 240-833-3001 or at smirsky@nuscalepower.com.
Sincerely, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution: Gregory Cranston, NRC, OWFN-8G9A Samuel Lee, NRC, OWFN-8G9A Anthony Markley, NRC, OWFN-8G9A : NuScale Response to NRC Request for Additional Information eRAI No. 9284 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com
RAIO-0218-58727 :
NuScale Response to NRC Request for Additional Information eRAI No. 9284 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.: 9284 Date of RAI Issue: 01/29/2018 NRC Question No.: 12.03-29 Regulatory Basis 10 CFR 52.47(a)(5) requires applicants to identify the kinds and quantities of radioactive materials expected to be produced in the operation and the means for controlling and limiting radiation exposures within the limits of 10 CFR Part 20. 10 CFR 20.1101(b) and 10 CFR 20.1003 require the use of engineering controls to maintain exposures to radiation as far below the dose limits in 10 CFR Part 20 as is practical. 10 CFR 20.1701 requires the use of process or engineering controls to minimize the potential for internal exposure to radioactive material.
10 CFR 52.47(a) (22) requires applicants to demonstrate how the operating experience insights have been incorporated into the plant design.
Appendix A to Part 50General Design Criteria (GDC) for Nuclear Power Plants, Criterion 61Fuel storage and handling and radioactivity control, requires systems which may contain radioactivity to be designed with suitable shielding for radiation protection and with appropriate containment, confinement, and filtering systems.
The DSRS Acceptance Criteria section of NuScale DSRS section 12.3-12.4, Radiation Protection Design Features, states that the applications should describe how operating experience insights have been incorporated into the plant design, to reduce maintenance and improve reliability.
Regulatory Guide (RG) 1.206 section C.1.12.3.1, "Facility Design Features," notes that the Applicant should identify features that reduce the potential for exposure by reducing source build up and reducing activation product generation. RG 8.8 Position C2, notes that the applicant should provide design features that reduce the potential for exposure by the selection of materials and finishing of the material surfaces for the purpose of minimizing facilitating decontamination and reducing deposition.
Background
DCD Tier 2 Revision 0 Section 12.3.1, Facility Design Features, describes facility design features that implement as low as reasonably achievable (ALARA) principles to minimize occupation radiation exposure (ORE.) DCD section 12.3.1.1, Equipment Design, provides NuScale Nonproprietary
specific design features for component types that aid in maintaining occupational exposures ALARA. However, there is no description of the design features of the dry dock provided to minimize ORE.
DCD Tier 2 Revision 0 Subsection 9.1.2.1, Design Bases, of Section 9.1.2, New and Spent Fuel Storage, states that smooth and nonporous surfaces prevent the buildup of radioactive material. DCD Subsection 9.1.2.3.7, Radiation, Shielding, and Maintaining Doses as Low as Reasonably Achievable, states that the surface finishes of the components for the fuel storage racks and spent fuel pool (SFP) liner are smooth to minimize accumulation of radioactive materials and to facilitate surface decontamination.
Electric Power Research Institute (EPRI) technical report (TR) 016780, "Advanced Light Water Reactor Utility Requirements Document" (URD), subsection 2.3.1.3.1.2 states "The refueling pool wall liner shall be surface finished to reduce the adherence of contamination and increase the efficiency of refueling pool decontamination activities after draining. The liner plate shall have a No. 4 surface finish or better and the liner plate welds shall be ground smooth." The reason given in the URD for this specification is that past LWR refueling experience has shown that a smooth surface finish on the wall liners reduces the amount and depth of crevices which can accumulate contamination. NUREG-1242, NRC Review of Electric Power Research Institutes Advanced Light Water Reactor Utility Requirements Document, Volume 3, Parts 1 2, documented the NRC staffs safety evaluation of the URD.
Key Issue 1:
While DCD Chapter 12 and Chapter 9 do indicate that surfaces should be smooth, the information is provided in a manner subject to interpretation. The application does not describe the specification for the surface finish of those portions of the facility (i.e., the dry dock) that, when dry, may increase ORE resulting from direct radiation exposure from surface deposits of radioactive material or from airborne radioactive material, resulting from the suspension of radioactive material remaining on the pool wall surface following dry dock drain down.
Question 1:
To facilitate staff understanding of the application information sufficient to make appropriate regulatory conclusions with respect to ORE, the staff requests that the applicant:
As necessary, revise the DCD Section 12.3-12.4 to include information related to finish specifications for wetted surfaces of the pools, OR Provide the specific alternative approaches used and the associated justification.
NuScale Response:
10 CFR 20.1101(b) and 10 CFR 20.1003 allow the use of both procedures and engineering NuScale Nonproprietary
controls to maintain exposures to radiation as far below the dose limits in 10 CFR Part 20 as is practical. As in the case of operating licensed nuclear power plants and previously NRC-approved design certification applications, the facility's design features work in concert with the radiation protection programs and procedures to comply with this regulation. Operational procedures are frequently relied upon to comply with regulations.
Also, the RAI includes a reference to 10 CFR 52.47(a)(22), which requires applicants to demonstrate how operating experience insights have been incorporated into the plant design, as another part of the regulatory basis. Regulatory Guide 1.206 and NUREG-0800 define operating experience insights specifically as NRC generic letters and bulletins issued after the most recent revision of the applicable standard review plan and six months prior to the docket date of the application. None of the cited references meet the definition of operating experience.
The Electric Power Research Institute (EPRI) Utility Requirements Document (URD) and NUREG-1242 are included in NuScale DSRS Section 12.3-12.4. Many of the URD specific design features have been incorporated into the NuScale design, but there is no regulatory requirement to incorporate any particular URD design feature.
Consistent with GDC 61, FSAR Section 9.2.5.3 states that the water level in the dry dock is adjusted to provide radiation shielding, and FSAR Section 9.1.3.3.8 states that the pool cleanup system is used to clean the water in the dry dock to reduce the radionuclide concentrations.
Consistent with Regulatory Guide 8.8, FSAR Section 12.3.6.1.3 and Table 12.3-42 state that the surfaces of the ultimate heat sink liner (which includes the dry dock liner) will be smooth to minimize contamination and facilitate decontamination. In addition, as stated in FSAR Section 9.4.2 and 12.3.3.3, the Reactor Building HVAC system provides an elevated flow rate in this area to reduce airborne activity.
These radiation protection design features demonstrate compliance with both GDC 61 and Regulatory Guide 8.8.
While the potential for airborne contamination is present in the dry dock, especially during drain down conditions, the COL applicant's operational procedures (as part of the Radiation Protection and ALARA Programs; COL Items 12.5-1 and 12.1-1) will require plant staff to conduct radiation dose surveys, perform decontamination, and institute other radiation protection measures, as necessary, to ensure compliance with 10 CFR 20 exposure limits and the ALARA principle. The aforementioned actions are similar to those that are performed at licensed pressurized water reactor fuel transfer canals during refueling. Therefore, the NuScale design meets the requirements of 10 CFR 20.1101(b).
Impact on DCA:
There are no impacts to the DCA as a result of this response.
NuScale Nonproprietary
Response to Request for Additional Information Docket No.52-048 eRAI No.: 9284 Date of RAI Issue: 01/29/2018 NRC Question No.: 12.03-30 Regulatory Basis and Background in RAI 9284 Question 31035 Key Issue 2:
There is no discussion in DCD Chapters 3, DCD Chapter 5 or DCD Chapter 12 about the surface finish of the exterior containment vessel (CNV). Like the dry dock wall, when dry, ORE results from direct radiation exposure from surface deposits of radioactive material, or from airborne radioactive material, resulting from the suspension of radioactive material remaining on the large wetted surface area of the CNV wall following dry dock drain down.
Question 2:
To facilitate staff understanding of the application information sufficient to make appropriate regulatory conclusions with respect to ORE, the staff requests that the applicant:
As necessary, revise the DCD Section 12.3-12.4 to include information related to finish specifications for wetted surfaces of the CNV, OR Provide the specific alternative approaches used and the associated justification.
NuScale Response:
See the response to RAI 12.03-29.
Impact on DCA:
There are no impacts to the DCA as a result of this response.
NuScale Nonproprietary