ML18323A445
| ML18323A445 | |
| Person / Time | |
|---|---|
| Site: | NuScale |
| Issue date: | 11/20/2018 |
| From: | Gregory Cranston NRC/NRO/DLSE/LB1 |
| To: | Samson Lee Office of New Reactors |
| Cranston G V/NRO/0546 | |
| Shared Package | |
| ML18323A444 | List: |
| References | |
| TR-0516-49416 | |
| Download: ML18323A445 (10) | |
Text
November 20, 2018 MEMORANDUM TO: Samuel Lee, Chief Licensing Branch 1 Division of Licensing, Siting, and Environmental Analysis Office of New Reactors FROM:
Gregory Cranston, Senior Project Manager
/RA/
Licensing Branch 1 Division of Licensing, Siting, and Environmental Analysis Office of New Reactors
SUBJECT:
AUDIT PLAN FOR THE REGULATORY AUDIT OF NUSCALE POWER, LLC TOPICAL REPORT TR-0516-49416, NON-LOSS-OF-COOLANT ACCIDENT ANALYSIS METHODOLOGY, REVISION 1 By letter dated January 10, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17010A427), NuScale Power, LLC (NuScale) submitted for U.S.
Nuclear Regulatory Commission (NRC) staff review topical report TR-0516-49416, Revision 0, Non-Loss-of-Coolant Accident Analysis Methodology, in support of the NuScale design certification application. On April 27, 2017, the NRC staff started its detailed technical review of TR-0516-49416-P, Revision 0. NuScale submitted Revision 1 of TR-0516-49416 on August 10, 2017 (ADAMS Accession No. ML17222A827), to incorporate editorial changes with no changes in content. In April and May 2018, the NRC staff issued several requests for additional information (RAIs) resulting from its review of TR-0516-49416. In addition, during the Chapter 6, Engineered Safety Features, Containment audit, the applicant discussed a planned revision to TR-0516-49416 to update NRELAP5 calculations and results.
The purpose of this regulatory audit is to examine underlying calculations, analyses, and evaluations supporting RAI responses as well as the planned updates to TR-0516-49416. In conducting this audit, the NRC staff will gain a better understanding of new or changed calculations or information that supports TR-0516-49416 and will confirm certain statements made in the RAI responses.
CONTACT:
Gregory Cranston, NRO/DLSE (301) 415-6715
S. Lee 2
The audit will take place via the Electronic Reading Room and/or at NuScales offices in Rockville, Maryland. The audit entrance date is November 19, 2018. The contents of the audit plan are provided as an enclosure.
Docket No.52-048
Enclosures:
- 1. Audit Plan - (Non-Proprietary)
- via email NRO-002 OFFICE NRO/DLSE/LB1: PM NRO/DLSE/LB1: LA NRO/DLSE/LB1 NAME GCranston MMoore GCranston (signed)
DATE 11/15/18 11/20/18 11/20/18 Enclosure 1 UNITED STATES NUCLEAR REGULATORY COMMISSION AUDIT PLAN FOR THE REGULATORY AUDIT OF OF NUSCALE TOPICAL REPORT TR-0516-49416, NON-LOSS-OF-COOLANT ACCIDENT ANALYSIS METHODOLOGY Docket No.52-048 AUDIT PLAN APPLICANT:
NuScale Power, LLC (NuScale)
APPLICANT CONTACTS:
Marty Bryan Paul Infanger Steven Mirsky DURATION:
8.5 months Phase 3: November 19, 2018, through January 21, 2019 Phase 4: January 22, 2019, through July 31, 2019 Note: Phase 3 and Phase 4 durations are contingent on the submittal of all responses to requests for additional information (RAIs) by November 19, 2018, and receipt of updated topical report (TR) containing any and all revised NRELAP5 calculations by May 31, 2019. The duration(s) may be extended if RAI responses and/or receipt of updated TR is delayed.
LOCATION:
U.S. Nuclear Regulatory Commission (NRC) Headquarters (via NuScales electronic reading room (eRR))
Two White Flint North 11545 Rockville Pike Rockville, Maryland 20852-2738 NuScale 11333 Woodglen Drive, Suite 205 Rockville, Maryland 20852 AUDIT TEAM:
Alexandra Siwy, Office of New Reactors (NRO),
Audit Team Lead Ray Skarda, NRO Antonio Barrett, NRO Carl Thurston, NRO Jason Thompson, Office of Nuclear Regulatory Research (RES)
Jeff Schmidt, NRO, Nuclear Performance, and Code Review Branch (SRSB) NuScale Team Lead Rebecca Karas, NRO, SRSB Branch Chief
2 Ronald Harrington, RES Peter Lien, RES Shanlai Lu, NRO Mohsen Khatib-Rahbar, Energy Research Incorporated (ERI)
Alfred Krall, ERI Morgan Libby, ERI Walter Tauche, ERI contractor Zhe Yuan, ERI Michael Zavisca, ERI Rani Franovich, NRO, Project Manager Gregory Cranston, NRO, Project Manager I.
BACKGROUND AND OBJECTIVES By letter dated January 10, 2017 (Reference 1), NuScale submitted for NRC staff review topical report TR-0516-49416, Revision 0, Non-Loss-of-Coolant Accident Analysis Methodology, in support of the NuScale design certification application. On April 27, 2017, the NRC staff started its detailed technical review of TR-0516-49416-P, Revision 0 (Reference 2). NuScale submitted Revision 1 of TR-0516-49416 on August 10, 2017 (Reference 3), to incorporate editorial changes with no changes in content. In April and May 2018, the NRC staff issued several requests for additional information (RAIs) resulting from its review of TR-0516-49416 (References 4-8). Furthermore, during the Chapter 6 Containment audit, the applicant discussed a planned revision to the non-loss-of-coolant-accident (LOCA) TR to update NRELAP5 calculations and results due to a transition from NRELAP5 Version 1.3 to Version 1.4.
Several of the applicants RAI responses refer to new or revised test assessments or calculations that ultimately support the adequacy of the non-LOCA evaluation model (EM). The objective of this audit is for the NRC staff to gain a better understanding of new or changed calculations or information that supports the TR resulting from staffs RAIs as well as the transition to NRELAP5 Version 1.4 and to confirm certain statements made in RAI responses.
The NRC staff needs to fully comprehend the new and changed calculations and information to ensure it supports the applicants docketed conclusions of adequacy of the non-LOCA EM.
To facilitate the NRC staffs understanding of the calculations and rationale underlying RAI responses and the updates to TR-0516-49416-P as a result of implementing a new version of NRELAP5, the staff is planning the following:
An audit entrance meeting is scheduled for November 19, 2018, via conference call.
Audit Phase 3 will focus on certain underlying calculations or information supporting RAI responses, and its duration is two months or 60 days after the submittal of the last RAI response, whichever is later.
Audit Phase 4 will focus on updates to the TR as a result of NRELAP5 Version 1.4, and its duration is six and a half months or 60 days after NRC receipt of the updated TR containing revised NRELAP5 calculations and results, whichever is later.
3 The audit is expected to be performed primarily via the NuScale eRR or, if necessary, at NuScales Rockville office.
- Should any information needs be identified during the audit in addition to those identified in this audit plan, the audit report will capture those items.
II.
REGULATORY AUDIT BASIS Title 10 of the Code of Federal Regulations (CFR), Section 52.47(a)(4) states that a final safety analysis report (FSAR) submitted as part of a standard design certification must include:
[a]n analysis and evaluation of the design and performance of structures, systems, and components with the objective of assessing the risk to public health and safety resulting from operation of the facility and including determination of the margins of safety during normal operations and transient conditions anticipated during the life of the facility, and the adequacy of structures, systems, and components provided for the prevention of accidents and the mitigation of the consequences of accidents.
The non-LOCA analysis methodology is incorporated by reference into Chapter 15, Transient and Accident Analysis, of the NuScale FSAR and is used to develop safety conclusions documented therein. The NRC staff must have sufficient information to ensure that acceptable risk and adequate assurance of safety can be documented in the NRC staffs safety evaluation reports for the non-LOCA TR and Chapter 15 of the FSAR. Based on some RAI responses provided to date related to the non-LOCA TR, the NRC staff has identified a need to audit the underlying calculations and test assessments referred to in those responses (see Section III of this audit plan). In addition, the NRC staff has identified a need to audit information related to the planned revision to the non-LOCA TR to update NRELAP5 calculations and results. This will help the staff to understand and confirm new or changed information supporting the non-LOCA EM.
This regulatory audit is based on the following regulations and guidance:
General Design Criteria (GDC) 5, Sharing of structures, systems, and components.
GDC 10, Reactor design.
GDC 13, Instrumentation and control.
GDC 15, Reactor coolant system design.
GDC 17, Electric power systems.
GDC 20, Protection system functions.
GDC 25, Protection system requirements for reactivity control malfunctions.
GDC 26, Reactivity control system redundancy and capability.
GDC 27, Combined reactivity control systems capability.
4 GDC 28, Reactivity limits.
GDC 31, Fracture prevention of reactor coolant pressure boundary.
GDC 34, Residual heat removal.
Regulatory Guide 1.203, Transient and Accident Analysis Methods, December 2005.
NuScale Design-Specific Review Standard (DSRS) 15.0, Introduction - Transient and Accident Analyses, Revision 0, June 2016.
Standard Review Plan (SRP) 15.0.2, Review of Transient and Accident Analysis Method, Revision 0, March 2007.
DSRS 15.1.1-15.1.4, Decrease in Feedwater Temperature, Increase in Feedwater Flow, Increase in Steam Flow, and Inadvertent Opening of the Turbine Bypass System or Inadvertent Operation of the Decay Heat Removal System, Revision 0, June 2016.
DSRS 15.1.5, Steam System Piping Failures Inside and Outside of Containment, Revision 0, June 2016.
DSRS 15.1.6, Loss of Containment Vacuum, Revision 0, June 2016.
DSRS 15.2.1-15.2.5, Loss of External Load; Turbine Trip; Loss of Condenser Vacuum; Closure of Main Steam Isolation Valve; and Steam Pressure Regulator Failure (Closed),
Revision 0, June 2016.
DSRS 15.2.6, Loss of Nonemergency AC Power to the Station Auxiliaries, Revision 0, June 2016.
DSRS 15.2.7, Loss of Normal Feedwater Flow, Revision 0, June 2016.
DSRS 15.2.8, Feedwater System Pipe Break Inside and Outside Containment, Revision 0, June 2016.
SRP 15.4.1, Uncontrolled Control Rod Assembly Withdrawal from a Subcritical or Low Power Startup Condition, Revision 3, March 2007.
SRP 15.4.2 Revision 3, Uncontrolled Control Rod Assembly Withdrawal at Power, Revision 3, March 2007.
SRP 15.4.3, Control Rod Misoperation (System Malfunction or Operator Error), Revision 3, March 2007.
SRP 15.4.6, Inadvertent Decrease in Boron Concentration in the Reactor Coolant System (PWR), Revision 2, March 2007.
SRP 15.4.7, Inadvertent Loading and Operation of a Fuel Assembly in an Improper Position, Revision 2, March 2007.
DSRS 15.5.1 - 15.5.2, Chemical and Volume Control System Malfunction that Increases Reactor Coolant Inventory, Revision 0, June 2016.
5 III.
REGULATORY AUDIT SCOPE The scope of this audit includes information, documents, and supporting calculations related to RAI Nos. 9158, 9351, and 9466, and NuScales planned revision to the non-LOCA TR to update NRELAP5 calculations and results, as NuScale described to the NRC staff during the Chapter 6 Containment audit. Based on the RAI responses received to date, the NRC staff has identified a need to audit design documents or calculations supporting the statements made in the responses to RAI No. 9158, Questions 15.00.02-1, 15.00.02-2, 15.00.02-3, and 15.00.02-5; RAI No. 9351, Questions 15.00.02-31 and 15.00.02-33; and RAI No. 9466, Question 15.00.02-11.
The audit will also cover aspects of the TR that will be updated as a result of implementing NRELAP5 Version 1.4. In addition, the NRC staff requests to audit any other updated test assessments relevant to the non-LOCA EM as well as two previously audited documents that provide some of the background relevant to RAI No. 9158, Question 15.00.02-5, and RAI No.
9351, Question 15.00.02-33. See Attachment A of this audit plan for a more detailed list.
Additional audit tasks may be added, subject to the NRC staffs review of RAI responses submitted in the future and the changes to the TR. All documents audited will be added to the audit report prepared by the staff following the conclusion of the audit.
IV.
SPECIAL REQUESTS The NRC staff requests the applicant to make identified documents available to the NRC auditors in NuScales eRR to the extent possible. Use of the eRR allows multiple auditors in different geographic locations to examine the same document at the same time, which improves the efficiency and reduces the cost of the audit. Additional documents may be identified as the review progresses. When the NRC staffs review of the documents associated with a specific issue is complete, the staff will notify either the NRCs Division of Licensing, Siting, and Environmental Analysis (DLSE) or NuScale that these documents can be removed from eRR, thereby minimizing their residence time in eRR.
In addition, the NRC staff may request in-person or telephone audit meetings with NuScale personnel to facilitate the staffs understanding of material to be audited. Such meetings will be scheduled based on mutual availability. The staff requests that document titles identified by NRC staff that are germane to an audit meeting be made available in the eRR prior to any scheduled audit meeting.
V.
AUDIT ACTIVITIES AND DELIVERABLES The NRC audit team is expected to consist of aforementioned individuals reviewing the non-LOCA methodology. The NRC staff will conduct this audit in accordance with the guidance provided in NRO-REG-108, Regulatory Audits (Reference 9). The NRC staff acknowledges the proprietary nature of the information requested and will handle it appropriately throughout the audit. While the NRC staff will take notes, the NRC staff will not remove hard copies or electronic files from the audit site(s).
The audit will initiate on November 19, 2018. Phase 3 of the audit is scheduled for a period of two months but may be extended if RAI responses are submitted after November 19, 2018. In that event, the NRC staff requests the Phase 3 audit extend to 60 days after the submittal of the final RAI response. Phase 4 of the audit is scheduled for six and a half months but may be extended if receipt of an updated non-LOCA TR containing all NRELAP5 revised calculations and results is delayed past May 31, 2019. In that event, the NRC staff requests the Phase 4 audit extend to 60 days after receipt of the revised TR.
6 The NRC staff will hold audit calls and/or meetings with NuScale as necessary to understand audit material. The NRC will inform NuScale of emerging information needs as well as documents that can be removed from eRR.
An audit report will be generated at the completion of the audit. If necessary, any circumstances related to the conductance of the audit will be communicated to Gregory Cranston (NRC) at 301-415-0546 or Gregory.Cranston@nrc.gov.
VI.
REFERENCES
- 1. Letter from NuScale Power, LLC, NuScale Power, LLC Submittal of Non-Loss-of-Coolant Accident Analysis Methodology, TR-0516-49416 (NRC Project No. 0769),
January 10, 2017, ADAMS Accession Number ML17010A427.
- 2. Letter to NuScale Power, LLC, Acceptance Letter for the Review Of NuScale Power, LLC Topical Reports TR-0516-49422, Loss-Of-Coolant Accident Evaluation Model, Revision 0, And TR-0516-49416, Non-Loss-Of-Coolant Accident Analysis," Revision 0 (CAC RN6303, RN6305), April 27, 2017, ADAMS Accession Number ML17116A063.
- 3. Letter from Zackary W. Rad (NuScale Power, LLC) to NRC, LO-0817-55242, NuScale Power, LLC Submittal of Topical Report Non-Loss-of-Coolant Accident Analysis Methodology, TR-0516-49416 Revision 1, August 10, 2017 (ADAMS Accession No. ML17222A827).
- 4. Email from Prosanta Chowdhury (NRC) to NuScale, Request for Additional Information Letter No. 9158 (eRAI No. 9158) Topical Report, Non-LOCA Analysis Methodology, 15.00.02, SRSB, June 5, 2018, Issued April 2, 2018 (ADAMS Accession No. ML18156A171).
- 5. Email from Prosanta Chowdhury (NRC) to NuScale, Request for Additional Information Letter No. 9351 (eRAI No. 9351) Transient Analysis Methodology, 15, SRSB, June 5, 2018, Issued May 12, 2018 (ADAMS Accession No. ML18156A177).
- 6. Email from Prosanta Chowdhury (NRC) to NuScale, Request for Additional Information Letter No. 9374 (eRAI No. 9374) Topical Report, Non-LOCA Analysis Methodology, 15.00.02, SRSB, May 9, 2018, Issued May 9, 2018 (ADAMS Accession No. ML18129A407).
- 7. Email from Prosanta Chowdhury (NRC) to NuScale, Request for Additional Information Letter No. 9466 (eRAI No. 9466) Topical Report, Non-LOCA Analysis Methodology, 15.00.02, SRSB, May 8, 2018, Issued May 7, 2018 (ADAMS Accession No. ML18128A341).
- 8. Email from Prosanta Chowdhury (NRC) to NuScale, Request for Additional Information Letter No. 9513 (eRAI No. 9513) Topical Report, Non-LOCA Analysis Methodology, 15.00.02, SRSB, May 8, 2018, Issued May 8, 2018 (ADAMS Accession No. ML18128A389).
- 9. NRO-REG-108, Regulatory Audits, April 2, 2009, ADAMS Accession Number ML081910260.
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION ATTACHMENT A - DOCUMENT LIST AND INFORMATION NEEDED Please provide the most recent version of the following documents as part of Audit Phase 3:
- 1. Analyses, evaluations, or calculations to support the following statements in the response to RAI 9158, Question 15.00.02-1:
- a. (( )).
- 2. The revised NRELAP5 assessment against NIST NLT-2 tests referenced in the response to RAI No. 9158, Question 15.00.02-2.
- 3. The new NRELAP5 assessment against the NIST NLT-15p2 tests referenced in the response to RAI No. 9158, Question 15.00.02-3.
- 4. The revised NRELAP5 assessment against the SIET TF-2 tests referenced in the responses to RAI No. 9158, Question 15.00.02-5, and RAI 9351, Question 15.00.02-33.
- 5. Analyses, evaluations, or calculations documenting the computational fluid dynamics calculation results provided in response to RAI No. 9351, Question 15.00.02-31.
- 6. The revised NRELAP5 assessment against the NIST-1 HP-03 test referenced in the response to RAI No. 9466, Question 15.00.02-11.
- 7. (( )), Evaluation of Helical Geometry Effects for SG Heat Transfer and Pressure Drop, (( ].]
- 8. (( )), Primary and Secondary Steady State Parameters.
- 9. Any other assessments against tests discussed in the non-LOCA TR that may have been updated since the staffs initial review, i.e.:
- a. NRELAP5 assessment against the NIST HP-04 tests ( (( )) ) if newer than Revision 0.
- b. NRELAP5 assessment against the KAIST tests ( (( )) ) if newer than Revision 0.
Please provide the most recent version of the following documents as part of Audit Phase 4:
- 1. For any parts of the TR that will be updated due to NRELAP5 Version 1.4, any supporting calculations, analyses, or evaluations.