ML19175A067
| ML19175A067 | |
| Person / Time | |
|---|---|
| Site: | NuScale |
| Issue date: | 07/18/2019 |
| From: | Prosanta Chowdhury NRC/NRO/DLSE/LB1 |
| To: | Samson Lee NRC/NRO/DLSE/LB1 |
| Chowdhury P / 415-1647 | |
| Shared Package | |
| ML19175A069 | List: |
| References | |
| Download: ML19175A067 (5) | |
Text
July 18, 2019 MEMORANDUM TO:
Samuel S. Lee, Chief Licensing Branch 1 Division of Licensing, Siting and Environmental Analysis Office of New Reactors FROM:
Prosanta Chowdhury, Project Manager /RA/
Licensing Branch 1 Division of Licensing, Siting and Environmental Analysis Office of New Reactors
SUBJECT:
AUDIT
SUMMARY
REPORT FOR THE REGULATORY AUDIT OF NUSCALE POWER, LLC, PROPOSED INSPECTIONS, TESTS, ANALYSES, AND ACCEPTANCE CRITERIA AND REVISED DESIGN IMPLEMENTATION IMPLEMENTATION PLAN From April 29, 2019, through May 14, 2019, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a regulatory audit of NuScale Power, LLC (NuScale), revised application materials associated with inspections, tests, analyses, and acceptance criteria (ITAAC) for the design implementation activities related to the human factors design process. The NRC staff conducted the audit in accordance with the Office of New Reactors (NRO) Office Instruction NRO-REG-108, Regulatory Audits. All the audit objectives documented on the audit plan were successfully met.
The staffs audit plan, dated April 26, 2019, can be accessed via the NRCs Agencywide Documents Access and Management System (ADAMS) under accession number ML19108A400.
The first purpose of this regulatory audit was to ensure appropriateness of the following NuScale Design Certification submittals:
- 1.
ITAAC No. 1 in the Final Safety Analysis Report (FSAR) Tier 1, Table 3.15-1, Human Factors Engineering Inspections, Tests, Analyses, and Acceptance Criteria,
- 2.
Associated revision to the FSAR Tier 2, Table 14.3-2, Shared/Common Structures, Systems, and Components and Non-Structures, Systems, and components Based Design Features and Inspections, Tests, Analyses, and Acceptance Criteria Cross Reference, of the NuScale Design Certification Application (DCA)
The second purpose of the audit was to ensure NuScales revised design implementation implementation plan clearly identifies the roles of NuScale and a combined license applicant in accordance with NUREG-0711, Human Factors Engineering Program Review Model.
CONTACT: Prosanta Chowdhury, NRO/DLSE 301-415-1647
- via Email NRO- 002 OFFICE NRO/DLSE/LB1: PM NRO/DLSE/LB1: LA NRR/DIRS/IRAB: BC NRO/DLSE/LB1: PM NAME PChowdhury MMoore*
AAgrawal*
PChowdhury DATE 06/21/2019 07/01/2019 06/21/2019
/ /2019
Enclosure U.S. NUCLEAR REGULATORY COMMISSION AUDIT
SUMMARY
REPORT FOR THE REGULATORY AUDIT OF NUSCALE POWER, LLC PROPOSED INSPECTIONS, TESTS, ANALYSES, AND ACCEPTANCE CRITERIA AND REVISED DESIGN IMPLEMENTATION IMPLEMENTATION PLAN Audit Team Members:
Brian Green (NRR/DIRS/IRAB)
Maurin Scheetz (NRR/DIRS/IOLB)
David Desaulniers (NRR/DIRS)
Greg Galletti (NRR/DIRS/IQVB)
Jim Gaslevic (NRO/DLSE/CIPB)
Chris Welch (NRO/DLSE/CIPB)
Project Manager:
Prosanta Chowdhury (NRO/DLSE/LB1)
=
Background===
By letter dated December 31, 2016, NuScale Power, LLC (NuScale) submitted a DCA for review (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17013A229). The Design Certification Application (DCA) includes Final Safety Analysis Report (FSAR) Tier 2, Chapter 18, Human Factors Engineering, which describes the human factors engineering (HFE) program for the NuScale Power Plant (ADAMS Accession No. ML18310A341).
The U.S. Nuclear Regulatory Commission (NRC) staff is using the review criteria in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, Chapter 18, Human Factors Engineering, and NUREG-0711, Human Factors Engineering Program Review Model, Revision 3, to ensure NuScale design compliance with HFE-related NRC requirements.
The HFE Program Review Model, described in NUREG-0711, Human Factors Engineering Program Review Model, Revision 3, consists of 12 elements (refer to Figure 1-1, Elements of the HFE programs review model, of NUREG-0711 for additional information). FSAR Tier 2, Section 18.0, Human Factors Engineering - Overview, states the NuScale HFE program incorporates accepted HFE standards and guidelines including the applicable guidance provided in NUREG-0711, Revision 3. NuScale submitted two types of technical reports with the DCA to address the 12 elements in NUREG-0711, Implementation Plans, (IPs) and Results Summary Reports (RSRs). NUREG-0711, Section 1.2.2, Review Elements, explains that IPs describe processes and methods for performing HFE activities, and RSRs describe the results of performing those activities.
NuScale submitted an IP for the design implementation (DI) element of the human factors program. NRC staff reviewed the IP and identified issues relating to the scope of the proposed
2 ITAAC and the clarity of the DI IP regarding the combined license applicants role in the process.
The staff issued Request for Additional Information (RAI) 9415 on April 23, 2018 (ADAMS Accession No. ML18204A190) to address these concerns.
During two public meetings on August 7, 2018, and August 21, 2018, respectively, the NRC staff provided feedback to NuScales response to RAI 9415 (ADAMS ML18172A318). A summary of these two meetings can be found in ADAMS Accession No. ML18235A137. Subsequently, the applicant proposed a supplemental response to RAI 9415, which was discussed in a public meeting on October 17, 2018 (ADAMS Accession No. ML18304A258). In this proposed supplemental RAI response, NuScale described means of documenting the DI activities, which would, if approved, allow an eventual combined license applicant to complete the DI activities without submitting an RSR as described in NUREG-0711, Section 12.3, Applicant Submittals.
On April 8, 2019, NuScale and NRC staff held another public meeting to address the submittal of a revised ITAAC and DI IP. At this meeting, NuScale agreed to put newly revised versions in their electronic reading room so that staff could review it and determine if there were significant remaining issues. The goal of this audit was to ensure that these documents, if submitted on the docket, will not have significant regulatory issues that could cause delays to completion of the Chapter 18 review.
Audit Activities The staff developed the following audit objectives, which are stated in the audit plan (ADAMS Accession No. ML19108A400).
- 1. Confirm that ITAAC Number 1 on Tier 1 Table 3.15-1 and the associated revision to FSAR Tier 2, Table 14.3-2 is appropriate for the NuScale design certification.
- 2. Review the revised DI IP to ensure that it clearly identifies the roles of NuScale and a combined license applicant and is consistent with NUREG-0711.
To meet the objectives described above, the staff reviewed the following documents:
A draft supplemental response to RAI 9415.
A draft revision to Tier 1 ITAAC Table 3.15-1 and FSAR Tier 2 Table 14.3-2.
A red-line strikeout revision of the DI IP (draft Revision 3).
Audit Results Objective 1: Confirm that ITAAC number 1 on Tier 1 Table 3.15-1 and the associated revision to FSAR Tier 2, Table 14.3-2 are appropriate for the NuScale design certification.
The staff reviewed the newest draft of the ITAAC and found that the acceptance criterion sufficiently addressed the issues with the scope identified in RAI 9415. However, the acceptance criterion did not cover the same scope as the associated design criterion. The mismatch between the acceptance criterion and the design criterion was determined to be
3 unacceptable because it was unclear how a combined license applicant could close the ITAAC.
The staff discussed this concern with NuScale staff and as a result, ITAAC No. 1 in FSAR Tier 1, Table 3.15-1 and the supporting information in FSAR Tier 2, Table 14.3-2 to correct the mismatch between the acceptance criterion and the design criterion was revised. Staff reviewed the newly revised version of the ITAAC and the supplemental RAI response and found them satisfactory to resolve the staffs concerns communicated via RAI 9415.
Objective 2: Review the revised design implementation IP to ensure that it clearly identifies the roles of NuScale and a combined license applicant and is consistent with NUREG-0711.
The staff reviewed a redline strikeout version of the DI IP (draft Rev. 3). The staff found that the IP had been modified to address the concerns described in RAI 9415 including changes that clarified the transition of responsibility for tracking human engineering deficiencies (HEDs) from NuScale to the licensee.
The staff also discussed some features of the implementation plan that were not clear, including:
The acceptance criterion of the ITAAC uses the phrase a report exists, however, the DI IP indicates that licensees will not generate an RSR to support the DI activities. The staff questioned this apparent inconsistency. NuScale explained that the licensee would need to generate the appropriate ITAAC closure documentation, however, a separate RSR would not be created. Staff questioned how the content of the ITAAC closure documents would differ from an RSR as described in NUREG-0711. NuScale indicated that the contents would be similar.
Staff discussed specific terminology in the draft ITAAC that was defined in the draft DI IP.
This information clarifies how the relationship between the design validated during ISV and the reconciliation of any deviations identified during DI activities. Staff questioned whether the DI IP was the appropriate place to document this information. NuScale reconsidered putting this information in the DI IP and agreed to move this information to the appropriate table in Tier 2 of the FSAR.
Staff discussed a concern about a statement in the DI IP regarding a licensees quality assurance practices. The DI IP indicated that the NRC approves an applicants Quality Assurance Policy. Staff requested that a correction be made to clarify that the NRC approves an applicants Quality Assurance Program Description (QAPD). NuScale agreed to make the change.
Conclusion The staff conducted an audit exit briefing with NuScale on May 14, 2019. The staff were able to accomplish all the audit objectives and found that the revised materials that were reviewed were appropriate to address the issues identified in RAI 9415. As a result, the staff stated that NuScale should submit the documents on the docket for formal technical review. NuScale agreed to docket the revised ITAAC and Tier 2 table, RAI supplemental response, and DI IP.