ML20072L727

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Audit Plan for the Regulatory Audit of Gex Nuclear Energy Americas, Llc. TR NEDC-33910, BWRX-300 Reactor Pressure Vessel Isolation and Overpressure Protection Beginning March 12, 2020
ML20072L727
Person / Time
Site: 99900003
Issue date: 03/12/2020
From: Michael Dudek
NRC/NRR/DNRL/NRLB
To: Thomas Scarbrough
NRC/NRR/DEX/EMIB
Franovich R , 415-7443
References
EPID L-2020-TOP-0000, NEDC-33910
Download: ML20072L727 (8)
v • d • e


Text

March 12, 2020 MEMORANDUM TO: Michael I. Dudek, Chief New Reactor Licensing Branch Division of New Reactor Licensing Office of Nuclear Reactor Regulation FROM: Thomas G. Scarbrough, Acting Chief /RA/

Mechanical Engineering and Inservice Testing Branch Division of Engineering and External Hazards Office of Nuclear Reactor Regulation

SUBJECT:

AUDIT PLAN FOR THE REGULATORY AUDIT OF GE-HITACHI NUCLEAR ENERGY AMERICAS, LLC TOPICAL REPORT NEDC-33910, BWRX-300 REACTOR PRESSURE VESSEL ISOLATION AND OVERPRESSURE PROTECTION BEGINNING MARCH 12, 2020 By letter dated December 30, 2019, GE-Hitachi Nuclear Energy Americas, LLC (GEH) submitted Licensing Topical Report (TR) NEDC-33910P, Revision 0, BWRX-300 Reactor Pressure Vessel Isolation and Overpressure Protection (Agencywide Documents Access and Management System Accession No. ML19364A209), to the U. S. Nuclear Regulatory Commission (NRC) staff for its review and approval. Upon its acceptance of the topical report on February 27, 2020, the NRC staff started its technical review.

The purpose of the NRCs regulatory audit of the reactor systems is to: (1) gain a better understanding or confirm the NRC staffs understanding of the detailed calculations, analyses, and bases underlying the GEH LTR; (2) verify information in the LTR and evaluate its conformance with the SRP or technical guidance; and (3) identify any information needed on the docket to support the basis of a reasonable assurance finding.

The audit will take place at GEHs offices in Washington, DC, and/or online via GEHs electronic reading room. The audit is currently scheduled to start on March 12, 2020, and last for the duration of the NRC staffs review of the LTR. The audit plan is provided as an enclosure.

Docket No. 99900003 EPID: L-2020-TOP-0000

Enclosure:

As stated cc w/encl.: Listserv CONTACT: Thomas Scarbrough, NRR/DEX

M. Dudek 301-415-2794

ML20072L727 *via email NRR-106 OFFICE NRR/DNRL/NRLB: LA NRR/DEX/EMIB: TBC NAME CSmith* TScarbrough (signed)

DATE 3/12/2020* 3/12/2020 UNITED STATES NUCLEAR REGULATORY COMMISSION AUDIT PLAN FOR THE REGULATORY AUDIT OF GE-HITACHI NUCLEAR ENERGY TOPICAL REPORT NEDC-33910, BWRX-300 REACTOR PRESSURE VESSEL ISOLATION AND OVERPRESSURE PROTECTION Docket No. 99900003 APPLICANT: GE Hitachi Nuclear Energy (GEH)

APPLICANT CONTACTS: George Wadkins Christer Dahlgren David Hinds Martin Owens DURATION: March 12, 2020, through the completion of the NRC review, currently scheduled to be completed by June 26, 2020 LOCATION: U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 GE Hitachi Nuclear Energy Electronic reading room (eRR)

GE Hitachi Offices 1299 Pennsylvania Avenue Washington, DC 20004 Ge Hitachi Offices 3901 Castle Hayne Rd Wilmington, NC 28401 AUDIT TEAM: Thomas Scarbrough, Audit Lead, NRR/DEX/EMIB Jason Huang, NRR/DEX/EMIB Renee Li, NRR/DEX/EMIB Ryan Nolan, NRR/DSS/SNRB Andrew Proffitt, NRR/DSS/SNRB I. BACKGROUND AND OBJECTIVES By letter dated December 30, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19364A210), GE-Hitachi Nuclear Energy Americas, LLC, submitted for NRC staff review Licensing Topical Report NEDC-33910, Revision 0, BWRX-300 Reactor Pressure Vessel Isolation and Overpressure Protection (ADAMS Accession No. ML19364A211). The NRC staff has initiated its detailed technical review of NEDC-33910-P and determined that based on GEHs requested final safety evaluation issuance date of June 26, 2020, efficiencies can be gained through a regulatory audit of technical information supporting the topical report.

Enclosure

The objectives of this audit are for the NRC staff to:

  • gain a better understanding of the detailed calculations, analyses, and bases underlying the GEH NEDC-33910, BWRX-300 Reactor Pressure Vessel Isolation and Overpressure Protection, and confirm the staffs understanding;
  • better understand if the methodology meets NRC regulations and conforms to regulatory guidance; and
  • develop requests for additional information (RAI).

As the staff proceeds through its safety review of the topical report, questions may arise that will be discussed with the applicant during audit calls. These discussions will inform the staffs requests for additional information. Issues of technical merit will be discussed during public meetings, some of which may be closed to the public to allow the exchange of proprietary information.

II. REGULATORY AUDIT BASIS This regulatory audit is being initiated under the guidance contained in Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-500, Revision 8, Topical Report Process, (ADAMS Accession No. ML19123A252) and will be conducted in accordance with NRR Office Instruction LIC-111, Revision 1, Regulatory Audits (Reference 1).

The regulatory audit is based on the following regulations and NRC guidance, as indicated by the applicant in the submittal:

  • GDC 4, Environmental and Dynamic Effects Design Bases
  • GDC 35, Emergency Core Cooling
  • Regulatory Guide 1.26, Quality Group Classifications and Standards for Water-, Steam-and Radioactive-Waste-Containing Components of Nuclear Power Plants
  • Standard Review Plan Section 5.2.2, Overpressure Protection
  • Standard Review Plan Section 5.4.13, Isolation Condenser System (BWR) 2
  • Standard Review Plan Section 15.6.5, Loss-of-Coolant Accidents Resulting from Spectrum of Postulated Piping Breaks Within the Reactor Coolant Pressure Boundary
  • Generic Letter 83-02, NUREG-0737 Technical Specifications Through the course of the review, the staff may identify additional regulations or guidance that need to be incorporated into the audit. The applicant will be promptly notified of any additions.

III. REGULATORY AUDIT SCOPE To further the NRC staffs understanding of the BWRX-300 design, the NRC staff will audit documents, analyses, and calculations that support assertions made by GEH in the topical report. The audit will inform NRC staff requests for information, if such requests are needed.

IV. SPECIAL REQUESTS The NRC staff requests that GEH (1) provide access to its subject matter experts, as needed, during audit discussions and teleconferences, and (2) establish an electronic reading room to facilitate remote NRC audit of requested materials. 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 audit progresses. When the staff completes its review of the documents associated with a specific issue and has completed its audit summary, it will notify either the NRC Project Manager or GEH that these documents can be removed from eRR.

In addition, the NRC staff may request in-person audit meetings with GEH personnel to facilitate the staffs understanding of material being audited. Such meetings will be scheduled based on mutual availability.

V. AUDIT ACTIVITIES AND DELIVERABLES The NRC staff will conduct this audit in accordance with the guidance provided in LIC-111 Regulatory Audits, (Reference 2). The audit entrance was conducted by teleconference March 12, 2020. 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 NRC staff will issue an audit report documenting the audit activities, facts and observations, and potential requests for additional information. This report will be made available in the NRCs ADAMS upon the conclusion of the audit and may be referenced in the staffs safety evaluation of the topical report.

If necessary, any concerns related to the conduct of the audit will be communicated to Rani Franovich (NRC) at 301-415-7334 or Rani.Franovich@nrc.gov.

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VI. REFERENCES

1. Letter from GE-Hitachi Nuclear Energy Americas, LLC, Pre-Application Submittal of NEDC-33910P, BWRX-300 Reactor Pressure Vessel (RPV) Isolation and Overpressure Protection Licensing Topical Report, December 30, 2019, ADAMS Accession No. ML19364A209.
2. LIC-111, Regulatory Audits, October 31, 2019, ADAMS Accession No. ML19226A274.

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ATTACHMENT A - INITIAL LIST OF INFORMATION FOR AUDIT

1. Documents related to the design, qualification, and inservice testing of the Isolation Condenser System (ICS) condensate return valves and their actuators.
2. Documents related to the design, qualification, and inservice testing of the reactor pressure vessel (RPV) isolation valves and their actuators.
3. Documents related to the connections of valves to the RPV.
4. Documents related to the design of the reactor pressure vessel (RPV) including all penetrations, core support features, and internals.
5. Documents related to the design and functionality of the isolation condenser system (ICS).
6. Documents related to the design and functionality of the control rod drive injection system as it relates to mitigation of small pipe breaks.
7. Documents related to the design and functionality of the feedwater injection system as it related to mitigation of small pipe breaks.

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