ML19297D174
| ML19297D174 | |
| Person / Time | |
|---|---|
| Issue date: | 11/26/2019 |
| From: | Matthew Sunseri Advisory Committee on Reactor Safeguards |
| To: | Riccardella P Advisory Committee on Reactor Safeguards |
| Snodderly, M, ACRS | |
| Shared Package | |
| ML19297D008 | List: |
| References | |
| Download: ML19297D174 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, DC 20555 - 0001 November 26, 2019 MEMORANDUM TO: Peter Riccardella, Chairman Advisory Committee on Reactor Safeguards FROM: Matthew Sunseri, Vice Chairman /RA/
NuScale Subcommittee Advisory Committee on Reactor Safeguards
SUBJECT:
PROPOSED RECOMMENDATION FOR ACRS REVIEW OF NUSCALE POWER, LLC, DESIGN CERTIFICATION APPLICATION - SAFETY EVALUATION WITH NO OPEN ITEMS FOR CHAPTER 17, QUALITY ASSURANCE AND RELIABILITY ASSURANCE In response to the Committees request, I have reviewed the NRC staffs safety evaluation with no open items for Chapter 17, Quality Assurance and Reliability Assurance, dated August 8, 2019 (ML19207A371). The following is my recommended course of action concerning further review of this chapter of the design certification application and the staffs associated safety evaluation.
SER Phase 4 Summary This chapter of the safety evaluation report (SER) documents the staffs review of Chapter 17, Quality Assurance and Reliability Assurance, of the NuScale Design Certification Application (DCA), Part 2, Tier 2, Final Safety Analysis Report (FSAR), Revision 2. Chapter 17 of the application discusses quality assurance (QA) during the design phase, QA during the construction and operation phases, the QA program, the reliability assurance program, and the QA program description for the design certification. It also discusses the combined license applicants responsibility for developing a quality assurance program (QAP) for the construction and operations phases and a program for implementing 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants in Section 17.6. The QAP described in Chapter 17 of the DCA Tier 2 applies to QA during the design certification phase for NuScale standard plant design activities. The reliability assurance program described in Section 17.4 of DCA Tier 2 applies to those structures, systems, and components identified as being risk significant or important contributors to plant safety.
Applicable Concerns from ACRS Phase 3 Letter Report
- 1. The staff has requested an exemption from the Commission from requiring an inspection, test, analysis, and acceptance criterion, or ITAAC for the NuScale design reliability assurance program and this remains an open item.
- 2. The applicants Open Design Items for structures, systems, and components covered by Chapter 17 requirements need to be identified for eventual closure.
- a. Additionally, the staff provided a response to this recommendation that we did not find fully responsive to our concern. We had a follow up meeting with staff, including the Director of NRO, that brought us to a clearer understanding of the issue. We revised our concern as follows:
The staff review process prior to design certification should identify those unverified design assumptions that are important to the reasonable assurance finding. This will help ensure that required closure prior to operability of the affected structure, system or component is identified and included as part of the design certification licensing basis. It is important that this process is not limited to items covered by the quality assurance program.
NRC Staff Response to ACRS Letter Report
- 1. The Commission has directed the staff via SRM 18-0093 to not require an ITAAC from NuScale or any applicant for DRAP. The basis for not requiring an ITAAC is described in SECY 18-0093. The SECY identifies that regulatory precedence has been set to not require operational programs to require an ITAAC because other regulatory processes will ensure that operational program implementation is reviewed. Staff makes the case that DRAP is similar and as long as the program is fully described in the DCA then an ITAAC is not necessary to hold a COL applicant accountable to implementation.
- 2. While performing a design certification review, including the NuScale review, the staff identified the key input parameters and specified performance capabilities associated with the applicants demonstration of compliance with the applicable regulatory requirements. The key parameters and performance capabilities that the staff relied upon to make its findings must be appropriately captured or tracked within the final design certification document or supporting controlled documents and calculations. This applies equally to those regulatory requirements that are subject to a quality assurance program and those that are not. With respect to the NuScale review, the staff is confident that the key parameters and performance capabilities to be relied upon in the staff findings are either already captured in the current revision of the DCA or are being tracked using an appropriate regulatory mechanism.
Open Items from Phase 3 Requiring Further ACRS Review None Recommendation The staff has addressed all open items from the ACRS Phase 3 review. Staff also addressed our Phase 3 letter report recommendation. There are no unresolved items related to NuScale DCA Chapter 17 and the associated SER. As lead ACRS reviewer for NuScale Chapter 17, I recommend that no additional Phase 5 review by the Committee is necessary.
November 26, 2019
SUBJECT:
PROPOSED RECOMMENDATION FOR ACRS REVIEW OF NUSCALE POWER, LLC, DESIGN CERTIFICATION APPLICATION - SAFETY EVALUATION WITH NO OPEN ITEMS FOR CHAPTER 17, QUALITY ASSURANCE AND RELIABILITY ASSURANCE Package No.: ML19297D008 Accession No: ML19297D174 Publicly Available Y Sensitive N Viewing Rights: NRC Users or ACRS Only or See Restricted distribution *via email OFFICE ACRS/TSB SUNSI Review ACRS/TSB ACRS NAME MSnodderly MSnodderly LBurkhart MSunseri (KHoward for)
DATE 10/24/2019 10/24/2019 11/12/2019 11/26/2019 OFFICIAL RECORD COPY