RAIO-0418-59701, LLC Supplemental Response to NRC Request for Additional Information No. 316 (Erai No. 9222) on the NuScale Design Certification Application
| ML18114A827 | |
| Person / Time | |
|---|---|
| Site: | NuScale |
| Issue date: | 04/24/2018 |
| From: | Rad Z NuScale |
| To: | Document Control Desk, Office of New Reactors |
| References | |
| RAIO-0418-59701 | |
| Download: ML18114A827 (5) | |
Text
RAIO-0418-59701 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com April 24, 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 Supplemental Response to NRC Request for Additional Information No. 316 (eRAI No. 9222) on the NuScale Design Certification Application
REFERENCES:
- 1. U.S. Nuclear Regulatory Commission, "Request for Additional Information No. 316 (eRAI No. 9222)," dated January 02, 2018
- 2. NuScale Power, LLC Response to NRC "Request for Additional Information No. 316 (eRAI No.9222)," dated January 22, 2018 The purpose of this letter is to provide the NuScale Power, LLC (NuScale) supplemental
response to the referenced NRC Request for Additional Information (RAI).
The Enclosure to this letter contains NuScale's supplemental response to the following RAI
Question from NRC eRAI No. 9222:
09.01.01-19 If you have any questions on this response, please contact Steven Mirsky at 240-833-3001 orat smirsky@nuscalepower.com.
Sincerely, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution: Samuel Lee, NRC, OWFN-8G9A Anthony Markley, NRC, OWFN-8G9A Prosanta Chowdhury NRC, OWFN-8G9A : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9222 7KLVOHWWHUDQGWKHHQFORVHGUHVSRQVHPDNHQRQHZUHJXODWRU\\FRPPLWPHQWVDQGQRUHYLVLRQVWRDQ\\
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Zackary W. Rad
RAIO-0418-59701 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com :
NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9222
NuScale Nonproprietary Response to Request for Additional Information Docket No.52-048 eRAI No.: 9222 Date of RAI Issue: 01/02/2018 NRC Question No.: 09.01.01-19 Title 10 of the Code of Federal Regulations (10 CFR), Section 50.68, Criticality accident requirements, provides the regulatory requirements for maintaining subcriticality in the spent fuel pool. General Design Criterion (GDC) 61, Fuel storage and handling and radioactivity control, in Appendix A to 10 CFR Part 50, requires, in part, that the fuel storage and handling systems shall be designed to assure adequate safety under normal and postulated accident conditions, including a capability to permit appropriate periodic inspection and testing of components important to safety. The applicant has chosen to incorporate neutron absorbing material into the design of the spent fuel racks to maintain subcriticality and to assure adequate safety. To meet GDC 61, Standard Review Plan (SRP) Section 9.1.2, New and Spent Fuel Storage, specifies that provisions for inspection and testing are necessary to verify that there is no degradation of any strong fixed neutron absorbers. Furthermore, 10 CFR 50.36, Technical specifications, requires an applicant or licensee to establish administrative controls in the technical specifications (TS) that will assure operation of the facility in a safe manner.
TS 5.5.12, part (a) states that the spent fuel storage rack neutron absorber monitoring program shall include periodic physical examination or neutron attenuation testing; however, the coupon monitoring program description in technical report TR-0816-49833-P, Fuel Storage Rack Analysis, Revision 0, specifies that at least one coupon shall be removed at specified intervals to be measured, visually examined, and to undergo boron-10 (
10B) areal density measurement.
Therefore, TS 5.5.12, part (a) must include periodic physical examination and neutron attenuation testing.
Furthermore, the phrase provide the credited criticality control in parts (a) and (c) of TS 5.5.12 is too vague to constitute an acceptance criterion to ensure the safety function of the neutron absorbing material is maintained, which leaves questions as to how compliance with 10 CFR 50.68 will be ensured. The staff requests more specific acceptance criteria that will ensure the acceptability of the measured 10B areal density, as it is a key assumption in the criticality analysis. The applicants technical report TR-0816-49833-P, Section 3.4.1.3.4 already defines the acceptance criteria for 10B areal density coupon measurements.
Finally, part (b) of TS 5.5.12 calls for establishment of performance-based frequencies for examination or testing based on observed trends or calculated projections of neutron absorber degradation, not to exceed 10 years. However, the applicant has not specified the neutron
NuScale Nonproprietary absorbing material to be used, and as such, there is uncertainty in how the material will behave while in service. In technical report TR- 0816-49833-P, Section 3.4.1.3.4 already defines the sampling schedule for the neutron coupon monitoring program. A 10-year inspection interval is not consistent with the sampling schedule. TS 5.5.12 part (b) should be revised to reflect the licensing basis described in TR-0816-49833-P.
Therefore, please revise TS 5.5.12 as follows:
Update TS 5.5.12 part (a) to include periodic physical examination and neutron a.
attenuation testing.
Provide specific acceptance criteria for the neutron absorber measured 10B areal b.
density.
Update the sampling intervals in accordance with TR-0816-49833-P.
c.
NuScale Response:
This supplemental response is provided in response to information requested during the April 3, 2018 public meeting addressing TSTF traveler 557. The information supplements the response provided in RAI 316-9222, Question 09.01.01-19, as provided in NuScale letter RAIO-0118-58286, dated January 22, 2018, (ML18022A915).
The program description proposed for incorporation into the NuScale TS is modified to conform to the description referenced by the staff in the December 19, 2017 letter from the Technical Specification Task Force to the staff (ML17353A608).
Impact on DCA:
The Technical Specifications have been revised as described in the response above and as shown in the markup provided in this response.
Programs and Manuals 5.5 NuScale 5.5-12 Draft Revision 2.0 5.5 Programs and Manuals 5.5.11 Surveillance Frequency Control Program (continued) b.
Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1. FSAR Table 16.1-1, Surveillance Frequency Control Program Base Frequencies, describes the plant licensing bases for the surveillance test intervals.
c.
The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.
5.5.12 Spent Fuel Storage Rack Neutron Absorber Monitoring Program This Program provides controls for monitoring the condition of the neutron absorber used in the spent fuel pool storage racks to verify the Boron-10 areal density is consistent with the assumptions in the spent fuel pool criticality analysis. The program shall be in accordance with NEI 16-03-A, "Guidance for Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools," Revision 0, May 2017.This Program provides controls for monitoring the condition of the neutron absorber used in the spent fuel pool storage racks to verify the neutron absorber density is consistent with the assumptions in the spent fuel pool criticality analysis. The program shall be in accordance with NEI 16 03 A, "Guidance for Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools," Revision 0, May 2017.