ML24215A170
| ML24215A170 | |
| Person / Time | |
|---|---|
| Site: | 05200050 |
| Issue date: | 08/02/2024 |
| From: | NuScale |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML24215A000 | List:
|
| References | |
| LO-169995 | |
| Download: ML24215A170 (1) | |
Text
Response to SDAA Audit Question Question Number: A-16.4.3.1-1 Receipt Date: 07/17/2023 Question:
If 24-month fuel cycle requires enriched fuel > 5% U235, say 6% or 7%, how can the SDAA assume 24 months vice 18 months? Should all 24-month Surveillance Frequencies in generic TS have brackets? That is, should the initial Frequencies in the Surveillance Frequency Control Program (SFCP), which are stated in SDAA FSAR Table 16.1-1, be bracketed? And should Section 4.2 percent U235 enrichment value also be bracketed? And should a Reviewers Note be provided in Subsection 4.3.1 and in Subsection 5.5.11 for the SFCP Specification?
Response
The surveillance intervals listed in SDAA Table 16.1-1 are initial surveillance frequencies for use in the Surveillance Frequency Control Program (SFCP). The 24 month initial surveillance frequencies provide margin above the 18 month cycle length to account for variations in cycle length. The SFCP establishes the actual surveillance frequencies. NuScale revises SDAA Section 16.1.1 to state: The SFCP ensures surveillance requirements specified in the Technical Specifications are technically justified for a plant specific design and performed at intervals sufficient to assure the associated limiting conditions for operation are met.
There is no need to bracket references to 24 month surveillance intervals in the NuScale GTS or SDAA Table 16.1-1. The NuScale GTS do not include specific references to 24 month surveillance intervals, only references to the SFCP. The SDAA does not utilize brackets as used in the GTS.
There is no need to bracket fuel enrichment in the NuScale GTS. NuScale Generic Technical Specification Section 4.3.1 specifies the 5% enrichment as a maximum enrichment. Use of NuScale Nonproprietary NuScale Nonproprietary
enrichment less than 5% would be allowed by this statement. If a higher enrichment value is desired, then the appropriate process would be followed to request approval from the NRC.
Markups of the affected changes, as described in the response, are provided below:
NuScale Nonproprietary NuScale Nonproprietary
NuScale Final Safety Analysis Report Technical Specifications NuScale US460 SDAA 16.1-3 Draft Revision 2 Completion Times and Surveillance Frequencies When appropriate, the completion times and surveillance frequencies specified in the NuScale GTS are consistent with times and frequencies applied to similar actions and surveillance requirements (SRs) from the NuScale US600 technical specifications, NUREG-1431, and NUREG-1432. The bases for completion times and surveillance frequencies are described in the associated bases or in the Surveillance Frequency Control Program (SFCP) described in technical specification 5.5.11.
Audit Question A-16.4.3.1-1 Table 16.1-1 provides the initial surveillance test frequencies to be incorporated into the Surveillance Frequency Control ProgramSFCP required by NuScale GTS 5.5.11.
The table identifies each GTS surveillance test requirement that references the SFCP, the base testing frequency for evaluation of future changes to the surveillance test frequency, and the basis for that initial base test frequency. Base test frequencies in Table 16.1-1 include consideration of the rules of applicability for surveillance testing including, when applicable, up to 1.25 times the specified interval as permitted by technical specification SR 3.0.2. For example, a base frequency of 24 months implies consideration of up to 30 months between performance of the surveillance test. The SFCP ensures surveillance requirements specified in the Technical Specifications are technically justified for a plant specific design and performed at intervals sufficient to assure the associated limiting conditions for operation are met.
Incorporation of Improved Standard Technical Specification Change Travelers Industry change travelers issued since publication of Revision 5 of the ISTS and available on the NRC Agencywide Documents Access and Management System (ADAMS) system were reviewed in the development of the NuScale GTS. Travelers were incorporated into the NuScale GTS or used as a basis for similar NuScale situations as described in the conformance report (Reference 16.1-4). The travelers considered in development of the NuScale GTS are listed in that report.
The GTS are intended to be used as a guide in the development of the plant-specific technical specifications. Preliminary information was provided in single brackets [ ].
Combined license applicants referencing the NuScale Power Plant US460 standard design are required to provide the final plant-specific information.
COL Item 16.1-1: An applicant that references the NuScale Power Plant US460 standard design will provide the final plant-specific information identified by [ ] in the generic Technical Specifications and generic Technical Specification Bases.
COL Item 16.1-2: An applicant that references the NuScale Power Plant US460 standard design will prepare and maintain an owner-controlled requirements manual that includes owner-controlled limits and requirements described in the Bases of the Technical Specifications or as otherwise specified in the FSAR.
COL Item 16.1-3: An applicant that references the NuScale Power Plant US460 standard design, and uses allocations for sensor response times based on records of tests, vendor test data, or vendor engineering specifications as described in