ML23304A478

LLC Response to NRCs Request for Docketing of Resolved Audit Responses, Chapter 11, Response to Sdaa Question 11.5-4, Re Information Related to Process and Effluent Radiation Monitoring Instrumentation and Sampling System

ML23304A478
Person / Time
Site:	05200050
Issue date:	10/31/2023
From:	NuScale
To:	Office of Nuclear Reactor Regulation
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Download: ML23304A478 (1)

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NuScale Nonproprietary Response to SDAA Audit Question Question Number: A-11.5-4 Receipt Date: 07/31/2023 Question:

Please discuss the interrelationship between the sampling points in FSAR Tables 11.5-2 and 11.5-3 and the sampling points identified in the Section 9.3.2 tables. Some sampling points appear to be repetitive in both Section 11.5 and Section 9.3.2, while other points only appear in one section. For example, the containment evacuation system (CES) sample tank radionuclide sampling point is identified in both Table 9.3.2-4 and Table 11.5-3, but the chilled water return lines radionuclide sample point is identified only in Table 9.3.2-4 and is not identified in Chapter 11.

In addition, there were many more sample points identified and more specificity in the NuScale US600 design than in the US460 design, including sampling points for the purpose of identifying radioactivity. Please discuss the reduction in the sampling points in the US460 design and if the sample points in the US460 design are adequate to address potential leakage paths to the environment and unintentional contamination of normally clean systems? For example, the US600 design specified sample points for each radioactive waste drain system sump tank, the reactor building chemical drain tank, and the reactor component cooling water system drain tank. In the US460 design it just indicates that there is a sample point for the radioactive waste drain system (without any additional specificity where in that system).

Response

Tables in Section 9.3.2, and Tables 11.5-2 and 11.5-3 interrelate in that they show the sample collection method. However, the sampling points in Tables 11.5-2 and 11.5-3 only indicate the radioactivity sampling points, while those in Section 9.3.2 may sample other variables, such as chloride, fluoride, sulfate, lithium, boron, iron, and many others. The chilled water return lines referred to in Table 9.3.2-4 are grab samples however, radioactivity measurements are not included and thus are not included in Table 11.5-3.

NuScale Nonproprietary

NuScale Nonproprietary The reduction in sampling points from the US600 to the US460 are due to the design changes and a smaller plant design. Radiation monitors and their associated sampling points remain in compliance with GDC 64 and 10 CFR 20.1406 for monitoring radioactivity releases and preventing the spread of contamination. Compliance with 10 CFR 20.1406 relies on more design features than just sampling, as described in FSAR Tables 12.3-12 through 12.3-40.

Markups of the affected changes, as described in the response, are provided below:

NuScale Nonproprietary

NuScale Final Safety Analysis Report Process Sampling System Audit Question A-11.5-4 Table 9.3.2-4: Local Sample Points Sample Point System Fluid Type Sampling Analysis(1)

Method BAS batch tank BAS liquid grab boron BAS storage tank BAS liquid grab boron CES sample vessel CES liquid grab radionuclides Chilled water return lines CHWS liquid grab radionuclides GRWS inlet gas GRWS gas continuous, iodine grab PCWS cleanup loop (including SFP) PCWS liquid grab Pool leakage detection system drain Pool liquid grab lines leakage detection system Notes:

1. Specific analyses, limits, and monitoring frequencies are specified in plant chemistry procedures.

NuScale US460 SDAA 9.3-16 Draft Revision 2