ML20363A025
| ML20363A025 | |
| Person / Time | |
|---|---|
| Site: | 99900003 |
| Issue date: | 12/31/2020 |
| From: | James Shea NRC/NRR/DNRL/NRLB |
| To: | Michael Dudek NRC/NRR/DNRL/NRLB |
| Vera Amadiz M and James Shea - DNRL/NRLB | |
| References | |
| EPID L-2020-TOP-0055, ML20269A469, NEDC-33922 | |
| Download: ML20363A025 (6) | |
Text
December 31, 2020 MEMORANDUM TO:
Michael I. Dudek, Chief New Reactor Licensing Branch Division of New Reactor Licensing Office of Nuclear Reactor Regulation FROM:
James Shea, Project Manager /RA/
New Reactor Licensing Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation
SUBJECT:
AUDIT PLAN FOR THE REGULATORY AUDIT OF GE-HITACHI NUCLEAR ENERGY AMERICAS, LLC TOPICAL REPORT NEDC-33922, BWRX-300 CONTAINMENT EVALUATION METHOD By letter dated September 25, 2020, GE-Hitachi Nuclear Energy Americas, LLC (GEH) submitted Licensing Topical Report (LTR) NEDC-33922P, Revision 0, BWRX-300 Containment Evaluation Method (Agencywide Documents Access and Management System Accession No. ML20269A469), to the U.S. Nuclear Regulatory Commission (NRC) staff for its review and approval. Upon its acceptance of the topical report on November 13, 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) confirm information in the LTR and evaluate its conformance with the Standard Review Plan (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 Wilmington, North Carolina; Washington, District of Columbia, and/or online via GEHs electronic reading room. The audit is currently scheduled to start on January 5, 2021, 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-0055
Enclosure:
As stated cc w/encl.: Listserv CONTACT:
James Shea, NRR/NRLB/PM 301-415-1388
ML20363A025 NRR-106 OFFICE DNRL/NRLB: PM DNRL/NRLB: LA NRR/DSS/SNSB DNRL/NRLB: PM NAME MJohnson CSmith SKrepel JShea DATE 12/23/2020 12/29/2020 12/30/2020 12/30/2020 UNITED STATES NUCLEAR REGULATORY COMMISSION AUDIT PLAN FOR THE REGULATORY AUDIT OF GE-HITACHI NUCLEAR ENERGY TOPICAL REPORT NEDC-33922, BWRX-300 CONTAINMENT EVALUATION METHOD Docket No. 99900003 APPLICANT:
GE Hitachi Nuclear Energy (GEH)
APPLICANT CONTACT:
George Wadkins DURATION:
January 5, 2021, through the completion of the U.S. Nuclear Regulatory Commissions (NRCs) review, currently scheduled to be completed by October 31, 2021 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:
James Shea, NRR/NRLB/PM Syed Haider, Audit Lead, NRR/DSS/SNSB Shanlai Lu, NRR/DSS/SNRB Carl Thurston, NRR/DSS/SNRB Chang Li, NRR/DSS/SCPB Andrew Proffitt, NRR/DSS/SNRB Joseph Staudenmeier, RES/DSA/CRAB Peter Lien, RES/DSA/CRAB Andrew Ireland, RES/DSA/CRAB Shawn Campbell, RES/DSA/FSTCB Kevin Fice, Canadian Nuclear Safety Commission (CNSC)
- Other NRC staff members may be added as the need arises.
I.
BACKGROUND AND OBJECTIVES By letter dated September 25, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20269A469), GE-Hitachi Nuclear Energy Americas, LLC, submitted Licensing Topical Report NEDC-33922, Revision 0, BWRX-300 Containment Evaluation Method (ADAMS Accession No. ML20269A471), for the NRC staffs review. The NRC staff has initiated its detailed technical review of NEDC-33922-P and determined that efficiencies can be gained through a regulatory audit of technical information supporting the topical report.
The objectives of this audit are for the NRC staff to:
gain a better understanding of the detailed calculations, analyses, and bases in the GEH NEDC-33922, BWRX-300 Containment Evaluation Method, and to confirm the NRC staffs understanding; gain a better understanding of the code, scaling, applicability and uncertainty (CSAU) relevant to the Phenomena Identification and Ranking Table (PIRT) in the NEDC-33922, BWRX-300 Containment Evaluation Method, and to confirm the NRC staffs understanding; better understand if the methodology conforms to the NRC regulations and meets the acceptance criteria; and develop requests for additional information (RAIs).
The NRC staff requests that GEH provide the following:
- 1.
Associated calculation notebooks, drawings and documentation of the BWRX-300 in sufficient detail that the NRC staff can develop independent confirmatory calculations with the NRC system thermal-hydraulic codes of the TRACG results (via the electronic reading room (eRR)).
- 2.
List of code changes made to the TRACG code since the application to ESBWR (NEDC-33083PA, Revision 2) (via eRR).
- 3.
GOTHIC documentation of sufficient detail, that the NRC staff can develop independent confirmatory calculations with the NRCs selected codes and evaluate the underlying fine mesh numerical schemes.
- 4.
Isolation condenser LOCA trip logic and flow rate sensor conceptual design documentations if there are any.
- 5.
PCCS and heat transfer calculation spreadsheet and the associated documentation.
As the NRC staff proceeds through its safety review of the topical report, additional material may be requested during the audit and questions may arise that will be discussed with the applicant during audit teleconferences. These discussions will inform the NRC staff of any 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, as indicated by the applicant in the following submittals:
Title 10 of the Code of Federal Regulations (10 CFR) Section 50.34(a)(1),
Contents of Applications; Technical Information.
10 CFR Part 50, Appendix A, General Design Criterion (GDC) 2, Design Bases for Protection Against Natural Phenomena.
GDC 4, Environmental and Dynamic Effects Design Bases.
GDC 16, Containment Design.
GDC 19, Control Room.
GDC 38, Containment Heat Removal.
GDC 41, Containment Atmosphere Cleanup.
GDC 50, Containment Design Basis.
GDC 51, Fracture Prevention of Containment Pressure Boundary.
Through the course of the review, the NRC 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 and containment evaluation methodology, the NRC staff will audit documents, analyses, and calculations that support assertions made by GEH in the topical report. The NRC staff will also audit relevant information regarding the codes, scaling, applicability, and uncertainty (CSAU) relevant to the PIRT in GEH LTR NEDC-33922, BWRX-300 Containment Evaluation Method. The audit will inform the NRC staff of any 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 eRR to facilitate a 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 NRC 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 NRC staffs understanding of any 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 will be held on January 5, 2021. 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 summary report documenting the audit activities, facts and observations, and potential requests for additional information. This report will be made available within 90 days after the completion of the audit and will be placed on the docket and in the NRCs Agencywide Documents Access and Management System separately for making regulatory decisions.
If necessary, any concerns related to the conduct of the audit will be communicated to James Shea (NRC) at 301-415-1388 or James.Shea@nrc.gov.
REFERENCES
- 1.
Letter from GE-Hitachi Nuclear Energy Americas, LLC, Pre-Application Submittal of NEDC-33922P, BWRX-300 Containment Evaluation Method Licensing Topical Report, issued September 25, 2020, ADAMS Accession No. ML20269A469.
- 2.
LIC-111, Regulatory Audits, issued October 31, 2019, ADAMS Accession No. ML19226A274.