ML19183A409

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OEDO-19-00314 - Response to ACRS Interim Letter Chapter 3 Section 3.9.2 and Chapters 14, 19, and 21 of the NRC Staff'S SER with Open Items Related to the DCA Review of the NuScale SMR
ML19183A409
Person / Time
Site: NuScale
Issue date: 07/24/2019
From: Frederick Brown
NRC/NRO/DLSE
To: Riccardella P
Advisory Committee on Reactor Safeguards
Santos C 415-7270
Shared Package
ML19179A225 List:
References
OEDO-19-00314
Download: ML19183A409 (3)


Text

July 24, 2019 Dr. Peter Riccardella, Chairman Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

INTERIM LETTER - CHAPTER 3, SECTION 3.9.2, AND CHAPTERS 14, 19, AND 21 OF THE U.S. NUCLEAR REGULATORY COMMISSION STAFFS SAFETY EVALUATION REPORT WITH OPEN ITEMS RELATED TO THE DESIGN CERTIFICATION APPLICATION REVIEW OF THE NUSCALE POWER, LLC, SMALL MODULAR REACTOR

Dear Dr. Riccardella:

In your letter dated June 19, 2019, the Advisory Committee on Reactor Safeguards (ACRS or the Committee) reported on the Committees interim safety review of Chapter 3, Section 3.9.2, Dynamic Testing and Analysis of Systems, Structures and Components; Chapter 14, Initial Test Program and Inspections, Tests, Analyses, and Acceptance Criteria; Chapter 19, Probabilistic Risk Assessment and Severe Accident Evaluation for New Reactors; and Chapter 21, Multi-Module Design Considerations, of the U.S. Nuclear Regulatory Commission (NRC) staffs safety evaluation report (SER) with open items for the NuScale Power, LLC (NuScale), small modular reactor (Agencywide Documents Access and Management System Accession No. ML19170A381). I appreciate the time and effort the ACRS has devoted to these important subjects, as reflected in meetings held with the ACRS Subcommittee for NuScale on May 14-16, 2019, and the ACRS Full Committee on June 5, 2019.

Your letter contained three conclusions and recommendations, as shown below with staff responses:

Conclusion and Recommendation 1:

SIET Test Facility-3 (TF-3) comprehensive vibration tests are required to ensure that the steam generator design is not susceptible to flow-induced vibration. The completion of these tests should be identified as an item for Inspections, Tests, Analyses and Acceptance Criteria (ITAAC).

Staff Response: The NRC staff agrees that completion of the TF-3 tests provides additional demonstration that the steam generator design is not susceptible to flow induced vibration. As these tests will not be finished before the planned completion of the staffs review of the design certification application, the NRC staff will apply appropriate licensing tools (e.g., ITAAC and/or combined license action item).

Conclusion and Recommendation 2:

We have not identified any major issues at this time for Chapter 3, Section 3.9.2, and Chapters 14, 19, and 21.

P. Riccardella 2 Staff Response: The NRC staff agrees with Conclusion and Recommendation 2. The staff plans to close the remaining open items and submit an advanced SER for Committee review by the end of the staffs Phase 4 review.

Conclusion and Recommendation 3:

To help identify risk insights in this unique design, there are technical issues in the probabilistic risk assessment (PRA) that merit further consideration.

Staff Response: The NRC staff acknowledges the technical issues raised by the ACRS in its letter and notes that the scope of the staffs review of a design certification PRA is to ensure the applicant has adequately addressed the Commissions objectives regarding consideration of severe accidents and the use of PRA in the design of the facilities. These objectives are focused on identification and reduction of potential vulnerabilities, identification of risk-informed safety insights, comparison to the Commissions safety goals, and support for other programmatic objectives (e.g.,

regulatory treatment of non-safety systems and the reliability assurance program). The staff performed an extensive review of the NuScale DCA and audits of the supporting notebooks, including an assessment of sensitivity studies and uncertainty quantification, to verify that the PRA will support the intended uses of a design certification PRA once all open items are resolved. The staff utilized the agency commissioned enhanced safety focused review approach (ESFRA) and took into consideration the unique design features to limit its review to the information needed to make reasonable assurance findings that the Commissions objectives were met. The staff notes that a COL holder will be required by 10 CFR 50.71(h) to develop a Level 1 and a Level 2 PRA covering those initiating events and modes for which NRC-endorsed consensus standards on PRA exist one year prior to the scheduled date for initial loading of fuel. The staff will consider revisiting the technical issues raised by ACRS as it prepares its Phase 4 advanced SER with no open items.

The NRC staff appreciates your review of these parts of the SER and looks forward to future interactions with the Committee as part of its NuScale review activities.

Sincerely,

/RA/

Frederick D. Brown, Director Office of New Reactors Docket No.52-048 cc: Chairman Svinicki Commissioner Baran Commissioner Caputo Commissioner Wright SECY

Pkg: ML19179A225; Ltr: ML19183A409 *via e-mail NRO-002 OFFICE NRO/DLSE/LB1: NRO/DLSE/LB1: NRO/DLSE/LB1: NRO/DLSE/LB1: NRO/DLSE/LB1:

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