ML19291A887

U.S. Nuclear Regulatory Commission Summary Report of Regulatory Close-out Audit of NuScale Power, LLC, Component Design Specification

ML19291A887
Person / Time
Site:	NuScale
Issue date:	10/21/2019
From:	Vera Amadiz M NRC/NRR/DNRL/NRLB
To:	Michael Dudek NRC/NRR/DNRL/NRLB
Vera Amadiz M, 415-5861
References
Download: ML19291A887 (10)

Text

October 21, 2019 MEMORANDUM TO: Michael I. Dudek, Chief New Reactor Licensing Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation FROM: Marieliz Vera, Project Manager /RA/

New Reactor Licensing Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSION

SUMMARY

REPORT OF REGULATORY CLOSE-OUT AUDIT OF NUSCALE POWER, LLC, COMPONENT DESIGN SPECIFICATIONS 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 (ADAMS) Accession No. ML17013A229). The NRC staff started its detailed technical review of NuScales DC application on March 15, 2017.

The NRC staff conducted an audit of design specifications associated with the NuScale DCA, to confirm that the appropriate changes have been completed for the audit items that were assigned the status of confirmatory in the NRC staffs audit report, Summary Follow-Up Audit Report of Design Specifications, dated December 27, 2018 (ADAMS Accession No. ML19018A140). The audit was initiated on July 30, 2019, and ran through September 25, 2019, in accordance with the audit plan in ADAMS (ML19203A249).

The purpose of the audit was to: (1) gain a better understanding of the NuScale design; (2) verify information; (3) identify information that may require docketing to support the basis of the licensing or regulatory decision; and (4) review related documentation and non-docketed information to evaluate conformance with regulatory guidance and compliance with NRC regulations.

CONTACT: Marieliz Vera, NRR/DNRL 301-415-5861

M. Dudek 2 The audit was performed to gain a better understanding of the component design, qualification and classification in support of the NuScale Standard Plant DC application are being performed in accordance with the methodology and criteria described in the NuScale Final Safety Evaluation Report.

The NRC staff conducted the audit via access to NuScales electronic reading room. The audit was conducted in accordance with the NRC Office of New Reactors (NRO) Office Instruction NRO-REG-108, Regulatory Audits.

Docket No.52-048

Enclosures:

Audit Report cc: NuScale DC Listserv

M. Dudek 3

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSION

SUMMARY

REPORT OF REGULATORY CLOSE-OUT AUDIT OF NUSCALE POWER, LLC, COMPONENT DESIGN SPECIFICATIONS DATED: OCTOBER 21, 2019 DISTRIBUTION:

PUBLIC NRLB R/F ABradford, NRR MDudek, NRR MVera, NRR SGreen, NRR TLupold, NRR TScarbrough, NRR RidsNrrOd RidsNrrDnrl RidsNrrDnrlNrlb RidsOpaMail Resource RidsOgcMailCenter RidsAcrsMailCenter NuScale DC Listserv ADAMS Accession No.: ML19291A887 *via email NRR-001 OFFICE DNRL/NRLB:PM DNRL/NRLB:LA DNRL/NRLB:PM NAME MVera SGreen MVera DATE 10/18/2019 10/18/2019 10/21/2019 OFFICIAL RECORD

U.S. NUCLEAR REGULATORY COMMISSION

SUMMARY

REPORT OF REGULATORY CLOSE-OUT AUDIT OF NUSCALE POWER, LLC, COMPONENT DESIGN SPECIFICATIONS DOCKET NO.52-048 I. INTRODUCTION AND BACKGROUND On January 6, 2017, NuScale Power, LLC (NuScale) submitted a design certification application (DCA) with subsequent revisions (Reference 1) for a small modular reactor (SMR) to the U.S.

Nuclear Regulatory Commission (NRC) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19241A315 for DCA Revision 3 submittal letter dated August 22, 2019). On March 23, 2017, the NRC accepted the DCA for docketing to initiate the NRC review of the NuScale SMR design (Reference 2).

The NRC staff conducted an initial regulatory audit of the NuScale design specifications from June 1, 2017, through August 29, 2017, by the review of NuScale design documentation in the NuScale electronic reading room (eRR). The staff documented the results of the initial audit in a report dated January 25, 2018 (Reference 3).

The staff conducted a follow-up audit from May 14, 2018, through October 11, 2018, of the NuScale design specifications in the eRR. The staff documented the results of the follow-up audit in a report dated February 11, 2019 (Reference 4).

In a letter dated June 13, 2019 (Reference 5), NuScale notified the NRC of the completion of the follow-up items from the NuScale design specification audit. On July 24, 2019, the staff issued a plan for a close-out audit of the NuScale design specifications (Reference 6). The NRC staff conducted this audit in accordance with the guidance provided in the Office of New Reactors (NRO)-REG-108, Regulatory Audits (Reference 7).

II. REGULATORY AUDIT BASIS 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 that:

The application must contain a level of design information sufficient to enable the Commission to judge the applicant's 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 [U.S. Nuclear Regulatory Commission] NRC, and procurement specifications and construction and installation specifications by an applicant. The Commission will require, Enclosure

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 conducting the review of the NuScale DCA, the NRC staff requested that the applicant make available the design specifications, as well as design documentation for equipment seismic qualification, environment qualification and component quality group classification (e.g., piping and instrumentation and equipment classification documents) for the staff to confirm the implementation of the provisions in the NuScale DCA Part 2, Tier 2, for the design and qualification of these components.

The information for this close-out audit supported the NRC staffs review of the following standard review plan sections:

• Section 3.9.6, Functional Design, Qualification, and Inservice Testing Programs for Pumps, Valves, and Dynamic Restraints, and

• Section 3.11, Environmental Qualification of Mechanical and Electrical Equipment.

III. NRC AUDIT TEAM Thomas G. Scarbrough, Senior Mechanical Engineer (NRC), Audit Lead Marieliz Vera, Project Manager (NRC)

IV. AUDIT PURPOSE The purpose of this close-out audit was to verify that the open items and confirmatory items identified in the follow-up audit report for the NuScale design specifications have been resolved.

V. AUDIT PREPARATION On July 24, 2019, the NRC staff issued an audit plan describing the performance of this close-out audit for the NuScale design specifications. The audit plan requested that documentation related to the updated NuScale design specifications in response to the follow-up audit report be made available for NRC staff review. NuScale provided specific design specifications in the NuScale eRR.

VI. AUDIT SCOPE The primary scope of this audit was the NRC staff review of the updated NuScale design specifications in response to the follow-up audit report. The staff also reviewed the applicable sections of Revision 3 to the NuScale DCA Part 2, Tier 2, to resolve specific confirmatory items identified in the follow-up audit report.

VII. AUDIT PERFORMANCE During the initial audit, the NRC staff reviewed the design specifications for several types of components to be used in the NuScale Power Plant. During that audit, the staff evaluated whether the design specifications incorporated the provisions specified in the NuScale DCA.

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The initial audit report described the NRC staffs findings from its review of the NuScale component design specifications.

During the follow-up audit, the NRC staff reviewed the NuScale design specifications to determine whether the findings from the initial audit had been addressed. Based on its review of the updated design specifications, the staff found that most of the findings from the initial audit had been resolved. The staff reviewed a total of 112 audit observation items during the follow-up audit. The staff determined that 3 audit items remained open with 32 audit items specified as confirmatory in a table attached to the follow-up audit report.

During this close-out audit from July 30, 2019, to September 25, 2019, the NRC staff reviewed the open and confirmatory items identified in the follow-up audit report.

The results of the close-out audit review of the NuScale design specifications for the open items specified in the follow-up audit report are as follows:

Open Item #4b (Primary stress analysis), Open Item #103 (Reactor internal mechanical loads), and Open Item #104 (Reactor internal stress analysis) are closed for this NRC staff audit of the design specifications for the NuScale DCA review, based on the performance of a separate audit by the NRC staff of the NuScale stress and fatigue analyses.

The results of the close-out audit review of the NuScale design specifications for the confirmatory items specified in the follow-up audit report are as follows:

NuScale prepared Engineering Change Notice ECN-B020-6969, Update Loads and Qualification Requirements for DCA Review, for NuScale Design Specification EQ-B020-2140, ASME Design Specification for Emergency Core Cooling System Valves, Revision 3, dated February 14, 2018, to require an analysis of the valve internal components. Therefore, the staff considers Confirmatory Item #20c (weak link analysis) to be resolved and closed for this NRC audit of the design specifications for the NuScale DCA review.

NuScale updated Design Specification EQ-A010-2235, ASME Design Specification for Primary Systems Containment Isolation Valves, Revision 3, dated June 3, 2019, to require that (a) design activities be performed in accordance with the quality assurance (QA) requirements in 10 CFR Part 50, Appendix B; and (b) a weak link analysis of the valve internal components be performed. Therefore, the staff considers Confirmatory Items #30 (QA requirements) and #31c (weak link analysis) to be resolved and closed for this NRC audit of the design specifications for the NuScale DCA review.

NuScale prepared ECN-A010-7340, Preclude FWIV Pressure Locking, Revision 0, June 12, 2019, and ECN-A010-7099, Update Specification to Address NRC ASME Design Specification and CIV/RSV Audit Items, Revision 0, May 29, 2019, for NuScale Design Specification EQ-A010-2224, ASME Design Specification for Secondary Side Containment Isolation Valves, Revision 1, dated December 20, 2017, to require that (a) design activities be performed in accordance with the QA requirements in 10 CFR Part 50, Appendix B; and (b) a weak link analysis of the valve internal components be performed. Therefore, the staff considers Confirmatory Items #42 (QA requirements),

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and #43c (weak link analysis) to be resolved and closed for this NRC audit of the design specifications for the NuScale DCA review.

NuScale updated Design Specification EQ-A011-2179, ASME Design Specification for Reactor Safety Valves, Revision 1, dated May 30, 2019, to require that (a) potential thermal binding be addressed by the design; (b) design activities be performed in accordance with the QA requirements in 10 CFR Part 50, Appendix B; and (c) a fatigue analysis of the valve internal components be performed. Therefore, the staff considers Confirmatory Items #52 (thermal binding), #55 (QA requirements), and #57c (weak link analysis) to be resolved and closed for this NRC audit of the design specifications for the NuScale DCA review.

NuScale prepared ECN-B030-7195, Update DHRS Valve Specification to Address NRC Audit Items, for NuScale Design Specification EQ-B030-2258, ASME Design Specification for Decay Heat Removal System Actuation Valves, Revision 1, dated January 29, 2018, to (a) address the remaining open items (except stress analysis for Item #4b discussed above); (b) clarify the provision to apply testing and analysis in accordance with ASME Standard QME-1-2007; (c) require that the design activities be performed in accordance with the QA requirements in 10 CFR Part 50, Appendix B; and (d) require that a weak link analysis of the valve internal components be performed.

Therefore, the staff considers Confirmatory Items #60 (open item resolution), #66 (clarify QME provision reference), #67 (QA requirements), and #68c (weak link analysis) to be resolved and closed for this NRC audit of the design specifications for the NuScale DCA review.

NuScale prepared ECN-B010-7114, CVCS Class 3 Valve Revisions from Design Spec Audit, Revision 0, May 29, 2019, for NuScale Design Specification EQ-B010-3227, ASME Design Specification for CVCS Class 3 Valves, Revision 0, dated June 1, 2017, to (a) address the remaining open items (except stress analysis for Item #4b discussed above); (b) require the application of Appendix QR-B of ASME QME-1-2007 for the environmental qualification of non-metallics in the CVCS Class 3 valves with specification of radiation requirements in the Valve Data Sheets attached to the design specification; (c) require that design activities be performed in accordance with the QA requirements in 10 CFR Part 50, Appendix B; and (d) require an analysis of the valve internal components be performed. Therefore, the staff considers Confirmatory Items

1. 70 (open item resolution), #73 (radiation qualification provisions), #77 (QA requirements), and #78c (valve internal analysis) to be resolved and closed for this NRC audit of the design specifications for the NuScale DCA review.

NuScale prepared ECN-A014-7336, TRV Revisions from NRC Design Spec Audit, Revision 0, June 11, 2019, and ECN-A014-7163, TRV Design Specification Audit Updates, Revision 0, May 29, 2019, for NuScale Design Specification EQ-A014-4255, ASME Design Specification for Thermal Relief Valves, Revision 0, dated August 18, 2016, to (a) include a Valve Data Sheet as an attachment to the design specification; (b) specify the thermal relief valves as ASME Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code) Category AC (self-actuating valves with leakage limitations); (c) update the open items to be addressed as part of the valve capacity requirement qualification; (d) update the radiation qualification provisions; (e) specify that the requirements in the ASME Boiler and Pressure Vessel Code (BPV Code) must be satisfied; (f) require that design activities be performed in accordance with the QA requirements in 10 CFR Part 50, Appendix B; (g) require that an analysis of 4

the valve internal components be performed; and (h) include valve performance requirements in the Valve Data Sheet to be attached to the design specification.

Therefore, the staff considers Confirmatory Items #79 (valve data sheet), #82 (ASME OM Code Category AC), #83 (open item resolution), #85 (radiation qualification provisions), #87 (ASME BPV Code requirement), #88 (QA requirements), #90c (valve internal analysis), and #90i (sizing and setting) to be resolved and closed for this NRC audit of the design specifications for the NuScale DCA review.

In its letter dated October 17, 2018 (Reference 8), NuScale described the planned revisions to the DCA to clarify the environmental qualification requirements for radiation environments for NuScale components to resolve Confirmatory Items #92, 93, 94, 95, 96, 97, 98, and 99. The staff has determined that the planned DCA revisions to address the environmental qualification requirements described in the NuScale letter dated October 17, 2018, have been incorporated into the applicable sections in Revision 3 to the DCA. Therefore, the staff considers Confirmatory Items #92, 93, 94, 95, 96, 97, 98, and 99 to be resolved and closed for this NRC audit of the design specifications for the NuScale DCA review.

The NRC staff has regulatory audit activities underway specifically for the NuScale Emergency Core Cooling System (ECCS) valves, containment isolation valves (CIVs), and reactor safety valves (RSVs). The staff will describe the findings from those activities in the applicable audit reports.

VIII. CONCLUSIONS Based on this close-out audit review, the NRC staff has determined that NuScale has resolved the open items and confirmatory items identified in the NuScale design specification follow-up audit report. As a result, the staff concludes, as required by the NRC regulations in 10 CFR 52.47, that information normally contained in procurement specifications and construction and installation specifications are sufficiently complete for the Commission to make a safety determination regarding the NuScale DCA. The staff also concludes that the NuScale component design specifications are consistent with the provisions in the NuScale DCA for the design of the specific components sampled during the audit. The staff notes that a separate audit of the NuScale stress and fatigue analysis is underway that might identify the need to update certain design specifications. In addition, regulatory audit activities related to the design of the ECCS valves, CIVs, and RSVs might identify the need to update specific design specifications for those valves. During its review of a combined license application for a NuScale Power Plant, the staff might conduct regulatory audit activities to review design specifications for plant-specific components.

IX. DOCUMENTS REVIEWED NuScale ECN-A010-7340, Preclude FWIV Pressure Locking, Revision 0, June 12, 2019, and NuScale ECN-A010-7099, Update Specification to Address NRC ASME Design Specification and CIV/RSV Audit Items, Revision 0, May 29, 2019, for NuScale Design Specification, EQ-A010-2224, ASME Design Specification for Secondary Side Containment Isolation Valves, Revision 1, dated December 20, 2017.

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NuScale Design Specification, EQ-A010-2235, ASME Design Specification for Primary Systems Containment Isolation Valves, Revision 3, dated June 3, 2019.

NuScale Design Specification, EQ-A011-2179, ASME Design Specification for Reactor Safety Valves, Revision 1, dated May 30, 2019.

NuScale ECN-A014-7336, TRV Revisions from NRC Design Spec Audit, Revision 0, June 11, 2019, and NuScale ECN-A014-7163, TRV Design Specification Audit Updates, Revision 0, May 29, 2019, for NuScale Design Specification, EQ-A014-4255, ASME Design Specification for Thermal Relief Valves, Revision 0, dated August 18, 2016.

NuScale ECN-B010-7114, CVCS Class 3 Valve Revisions from Design Spec Audit, Revision 0, May 29, 2019, for NuScale Design Specification, EQ-B010-3227, ASME Design Specification for CVCS Class 3 Valves, Revision 0, dated June 1, 2017.

NuScale ECN-B020-6969, Update Loads and Qualification Requirements for DCA Review, for NuScale Design Specification, EQ-B020-2140, ASME Design Specification for Emergency Core Cooling System Valves, Revision 3, dated February 14, 2018.

NuScale ECN-B030-7195, Update DHRS Valve Specification to Address NRC Audit Items, for NuScale Design Specification, EQ-B030-2258, ASME Design Specification for Decay Heat Removal System Actuation Valves, Revision 1, dated January 29, 2018.

XI. NUSCALE STAFF PARTICIPANTS Gary McGee Wayne Massie Marty Bryan XII. REFERENCES

1. NuScale Standard Plant Design Certification Application, Revision 3, ADAMS Accession No. ML19241A315, August 22, 2019.

2. NRC Letter, NuScale Power, LLC - Acceptance of an Application for Standard Design Certification of a Small Modular Reactor, ADAMS Accession No. ML17074A087, March 23, 2017.

3. NRC Report of Regulatory Audit for NuScale Power, LLC, Component Design Specifications, ADAMS Accession No. ML18018A234, January 25, 2018.

4. NRC Report of Regulatory Audit for NuScale Power, LLC, Follow-Up Audit of Component Design Specifications, ADAMS Accession No. ML19018A140, February 11, 2019.

5. NuScale Letter, NuScale Power, LLC, Notification of Completion of the Confirmatory Items for the Design Specification Audit, ADAMS Accession No. ML19164A193, June 13, 2019.

6. NRC Plan for Regulatory Audit of the NuScale Power, LLC, Component Design Specifications, ADAMS Accession No. ML19203A249, July 24, 2019 6

7. NRO-REG-108, Regulatory Audits, ADAMS Accession No. ML081910260, April 2, 2009.

8. NuScale Letter, NuScale Power, LLC Submittal of Supplemental Response to Design Specification Audit Issue No. 92-99, ADAMS Accession No. ML18290A557, October 17, 2018 7