ML19116A215

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Plan for Regulatory Audit of NuScale Power, LLC, Component Design
ML19116A215
Person / Time
Site: NuScale
Issue date: 04/29/2019
From: Amadiz Marieliz Vera
NRC/NRO/DLSE/LB1
To: Samson Lee
NRC/NRO/DLSE/LB1
Vera A
References
Download: ML19116A215 (8)


Text

April 29, 2019 MEMORANDUM TO:

Samuel S. Lee, Chief Licensing Branch 1 Division of Licensing, Siting, and Environmental Analysis Office of New Reactors FROM:

Marieliz Vera, 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 THE NUSCALE POWER, LLC, COMPONENT DESIGN On January 6, 2017, NuScale Power, LLC (NuScale) submitted a design certification application (DCA) for a small modular reactor to the U.S. Nuclear Regulatory Commission (NRC)

(Agencywide Documents Access and Management System Accession No. ML17013A229).

The NRC staff initiated its detailed technical review of NuScales DCA on March 15, 2017.

The purpose of the subject audit, to be conducted by the NRC staff, is to review the stress and fatigue reports for components categorized as American Society of Mechanical Engineers, Boiler and Pressure Vessel Code (ASME BPV Code),Section III, Class 1 components, component supports, and core supports, to verify that the component design is in accordance with the methodology and criteria described in the NuScale Final Safety Analysis Report and ASME BPV Code and to confirm a certain level of completeness of the design at the design certification stage.

The audit will review information located at the NuScale Office in Rockville, Maryland and in the NuScale electronic reading room. The audit is currently scheduled to begin on May 1, 2019, and end on September 13, 2019. The audit plan is enclosed.

Docket No.52-048

Enclosure:

As stated cc w/encl.: DC NuScale Power, LLC Listserv CONTACT: Marieliz Vera, NRO/DLSE 301-415-5861

ML19116A215 NRO-002 OFFICE NRO/DLSE/LB1/PM NRO/DLSE/LB1/LA NRO/DLSE/LB1: PM NAME MVera CSmith (MMoore for)

MVera DATE 04/26/2019 04/29/2019 04/29/2019

1 U.S. NUCLEAR REGULATORY COMMISSION REGULATORY AUDIT OF COMPONENT DESIGN NUSCALE STANDARD PLANT DESIGN CERTIFICATION DOCKET NO.52-048 AUDIT PLAN APPLICANT:

NuScale Power, LLC APPLICANT CONTACTS:

Marty Bryan, NuScale Power DURATION:

May 1, 2019 - September 13, 2019 LOCATION:

NuScale (Rockville Office) 11333 Woodglen Drive, Suite 205 Rockville, Maryland 20852 Electronic Reading Room (eRR)

AUDIT TEAM:

Tuan Le, NRO Mechanical Engineer (NRC), Audit Lead Li, Yueh-Li (Renee), Sr. Mechanical Engineer (NRC)

Kaihwa Hsu (Robert), Sr. Mechanical Engineer (NRC)

Alexander Tsirigotis, Mechanical Engineer (NRC)

Jason Huang, Mechanical Engineer (NRC)

Yiu Law, Mechanical Engineer (NRC)

Marieliz Vera Amadiz, Project Manager (NRC)

I.

BACKGROUND On March 23, 2017, the U.S. Nuclear Regulatory Commission (NRC or Commission) accepted the design certification application for docketing for the NuScale Standard Plant Design Certification Application (DCA) for a small module reactor (SMR) design submitted by NuScale Power, LLC (NuScale Power) (Reference 1).

In the NuScale Letter LO-0219-64398 (Reference 2), dated February 4, 2019, NuScale agreed to provide the scope and schedule for the American Society of Mechanical Engineers (ASME),

Boiler and Pressure Vessel Code (BPVC),Section III stress analyses (including fatigue) to be completed for the NuScale Power Module (NPM) during the DCA review of the NuScale plant.

These stress analyses evaluate the loading combinations as required by the ASME design

2 specifications for primary, secondary, and peak stresses, including the calculation of cumulative usage factors (fatigue).

The NRC staff reviewed NuScale Standard Plant DC information contained in the NuScale DCA, performed the Design Specification audit (Reference 3), and evaluated NuScales response to the NRC staffs request for additional information (RAI) regarding the level D stresses for containment. The audit is to allow the NRC technical staff to gain an understanding of the supporting design calculations to better focus the staffs inquiries to the applicant and to confirm a certain level of completeness of the design at the design certification stage.

II.

PURPOSE The purpose of the audit is to verify that the component design in support of the NuScale Standard Plant DC application are being performed in accordance with the methodology and criteria described in the NuScale FSAR.

III.

REGULATORY AUDIT BASIS The audit basis is to confirm that the NuScale SMR component designs are being performed consistent with the NuScale DC application and ASME BPV Code and other referenced standards and NRC regulatory guides.

Title 10 of the Code of Federal Regulations (10 CFR), Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants, Section 47, Contents of Applications; Technical Information, states the following:

The application must contain a level of design information sufficient to enable the Commission to judge the applicants proposed means of assuring that construction conforms to the design and to reach a final conclusion on all safety questions associated with the design before the certification is granted. The information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. The Commission will require, before design certification, that information normally contained in certain procurement specifications and construction and installation specifications be completed and available for audit if the information is necessary for the Commission to make its safety determination.

In NRC Standard Review Plan (SRP) Section 3.9.3, ASME Code Class 1, 2, and 3 Components and Component Supports, and Core Support Structures, Section 7 of Appendix A provides guidance that the staff may request the submission of the Code-required design documents (such as design specifications, design reports, load capacity data sheets, or other related material or portion thereof), in order to establish that the design criteria, analytical methods, and functional capability satisfy the guidance provided by SRP Section 3.9.3. This includes verification that the design information, methodologies, stress and fatigue analyses that the components designed to ASME BPV Code,Section III, Class 1, 2, and 3 requirements.

As stated in SECY 90-377 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML0037078920, Reference 4), in order to make a final safety determination with

3 reasonable assurance, the Commission intended that for all structures, systems, and components which can affect safe operation of the plant, the design information contained in the application would reflect a design which was complete, except to the extent that further adjustment to the design within established design envelopes would be necessary. To confirm a certain level of completeness of the design at the design certification stage, the NRC staff will review the stress and fatigue reports for selected components in support of its review of the following SRP sections:

Section 3.6.2, Determination of Rupture Locations and Dynamic Effects Associated with the Postulated Rupture of Piping, Section 3.8.2, Steel Containment, Section 3.9.3, ASME Code Class 1, 2, and 3 Components and Component Supports, and Core Support Structures, and Section 3.9.5, Reactor Pressure Vessel Internals.

The staff will conduct this audit in accordance with the guidance provided in NRO-REG-108, Regulatory Audits (Reference 5).

IV.

REGULATORY AUDIT SCOPE The primary scope of this audit is the review of stress and fatigue reports for components categorized as ASME BPV Code,Section III, Class 1, 2, and 3 components, component supports, and core supports, to verify that the component design is in accordance with the methodology and criteria described in the NuScale FSAR and ASME BPV Code.

V.

DOCUMENTS/INFORMATION NECESSARY FOR THE AUDIT The following documents are to be made available to the NRC staff, in the NuScale eRR:

ASME Stress Analysis Audit Type Evaluation Ready for Audit ASME Design Report for RVV Primary and Secondary, including Fatigue Currently available ASME Design Report for RRV Primary and Secondary, including Fatigue Currently available CRDM Pressure Housing Fatigue Analysis Primary and Secondary, including Fatigue Currently available ASME Component Fatigue Screening N/A May 2019 CNV MS Nozzle Analysis Primary and Secondary, including Fatigue April 2019

4 ASME Stress Analysis Audit Type Evaluation Ready for Audit CNV FW Nozzle Analysis Primary and Secondary, including Fatigue April 2019 RPV Main Steam Plenum Analysis Primary and Secondary, including Fatigue April 2019 RPV Feedwater Plenum Analysis Primary and Secondary, including Fatigue June 2019 RPV Refueling Flange Analysis Primary and Secondary, including Fatigue June 2019 CNV Refueling Flange Analysis Primary and Secondary, including Fatigue June 2019 RVV and RRV ECCS Flange Bolt Analysis Primary and Secondary, including Fatigue July 2019 CNV CVCS Nozzle Analysis Primary and Secondary, including Fatigue July 2019 DHRS Condenser Analysis Primary and Secondary, including Fatigue July 2019 RPV-CNV Upper Support Primary Stress Primary Stress July 2019 RPV Primary Stress Analysis Primary Stress July 2019 CNV Primary Stress Analysis Primary Stress July 2019 RVI Primary Stress Analysis Primary Stress July 2019 SG Primary Stress Analysis Primary Stress July 2019 Core Support Structures Primary and Secondary, including Fatigue TBD VI.

SPECIAL REQUESTS The NRC staff requests that NuScale provide the technical staff with access to the audit documents. NuScale can upload the requested documents into the NuScale ERR for staffs review. During the audit, the staff will have questions and discussion items for the NuScale subject matter experts. When the staffs review of the documents associated with a specific issue is complete the staff will notify NuScale that these documents can be removed from eRR thereby minimizing their residence time in eRR.

VII.

AUDIT ACTIVITIES AND DELIVERABLES The NRC audit team review will cover the technical areas identified in Section V of this audit plan. Depending upon the effort needed in a given area, NRC team members may be reassigned to ensure adequate coverage of important technical elements.

5 The regulatory audit will be scheduled for May 1, 2019 through September 13, 2019, from 7:30 AM to 3:30 PM. At the end of the audit, a technical audit summary will be sent by the technical reviewers to the NRC Project Manager (PM) for prompt issuance to the applicant as well as a public version of the same.

The NRC PM will coordinate with NuScale Power in advance of audit activities to verify specific documents and identify any changes to the audit schedule and requested documents. The audit entrance/exit meetings and weekly audit meeting are to be scheduled as followings:

Entrance Meeting - May 1, 2019; Exit Meeting: TBD; and Weekly NRC Audit Team Meeting, as needed: Wednesdays 11:00 AM - 12:00 PM EDT.

The NRC staff acknowledges the proprietary nature of the information requested. It will be handled 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.

The NRC will hold bi-weekly (once every two weeks) audit calls and/or meetings with NuScale to discuss technical issues identified during the audit. In the bi-weekly meetings, NRC will also identify any new emerging information needs as well as documents that can be removed from eRR.

At the completion of the audit, the audit team will issue an audit summary within 90 days that will be declared and entered as an official agency record in ADAMS records management system.

The audit outcome may be used to identify any additional information to be submitted for making regulatory decisions, and it will assist the NRC staff in the issuance of RAIs (if necessary) for the licensing review of NuScale FSAR Chapter 3, in preparation of the NRCs Safety Evaluation Report.

If necessary, any circumstances related to the conductance of the audit will be communicated to Marieliz Vera Amadiz (NRC) at 301-415-5861or email: Marieliz.VeraAmadiz@nrc.gov VIII.

REFERENCES

1. NRC Letter, NuScale Power, LLC - Acceptance of an Application for Standard Design Certification of a Small Modular Reactor, ADAMS Accession Number ML17074A087, March 23, 2017.
2. NuScale Letter LO-0219-64398, NuScale Power, LLC - Submittal of Scope and Schedule for Component Stress Analysis. ADAMS Accession Number ML19035A682, dated February 4, 2019.
3. U.S. Nuclear Regulatory Commission staffs report of regulatory audit for NuScale Power, LLC; follow-up audit of Component Design Specifications ADAMS Accession Number ML19018A140, dated February 11, 2019.
4. SECY-90-377, SECY-90-377 - Requirements for Design Certification Under 10 CFR Part 52, ADAMS Accession Number ML0037078920, dated February 15, 1991.

6

5. NRO-REG-108, Regulatory Audits, ADAMS Accession Number ML081910260, dated April 2, 2009.
6. NuScale Standard Plant Design Certification Application, Revision 2, October 30, 2018.